BOARD: Paul C. Aughtry, I11 Chairman Edwin H. Cooper, 111 Vice Chairman BOARD: Henry C. Scott

Steven G. Kisner Secretary C. Earl Hunter, Commissioner Promoting andprotecting the health ofthe public and the environment M. David Mitchell, MD
Glenn A. McCall
Coleman F. Buckhouse, MD

November 9,2009 A. StanleyMeiburg, Acting Regional Administrator US EPA Region 4 Atlanta Federal Center 6 1 Forsyth Street, SW Atlanta, GA 30303-8909

Re: South Carolina Regional Haze State ImplementationPlan 

### - Clarification

Dear Mr. Meiburg:

The South Carolina Department of Health & Environmental Control (Department) submitted its regional haze StateImplementation Plan (SIP) package on December 21,2007. Subsequentto this submittal, the Department received a question from the United States Environmental Protection Agency (USEPA) Region 4 staffvia electronic mail on June 1,2009 (Attachment 1).

This question pertains to the Department's reasonable progress analysis as depicted in the methodology applied to Appendix H.2.b and H.2.c ofthe regional haze SIP. Specifically, Region 4 staff question why sixemission units located at three South Carolina facilities (Alumax, Cogen South, and Showa Denka Carbon) whose SO2emissions were identified as contributing to one percent or greater impact on visibility at Cape Romain were not evaluated for controls using the four reasonable progress factors. The Department's response/clarification to the regional haze SIP as submitted in December is outlined in Attachment 2.

Should you have any further questions concerning South Carolina's regional haze SIP, please feel free to contact Maeve S.R Mason of my staff at (803) 898-2230 or masonmr~,dhec.sc.nov.

I Robert W. King, Jr., P.E. Deputy Commissioner Environmental Quality Control

ec: Myra C. Reece, Chief, Bureau of Air Quality, SCDHEC Renee G. Shealy, Assistant Bureau Chief, Bureau of Air Quality, SCDHEC Robert J. Brown, Jr., Director, Division of Air Planning, Development & Outreach, Bureau of Air Quality, SCDHEC John Glass, Manager, Modeling, Division ofEmissions Evaluation and Support, Bureau of Air Quality, SCDHEC Maeve S.R. Mason, Manager, Regulation Development, Division of Air Planning, Development & Outreach, Bureau of Air Quality, SCDHEC

Attachment 1:EPA Region 4 electronic mail transmission (June 1,2009) Attachment 2: The Department's response to questions on its regional haze SIP (December 2 1,2007)

SOUTHCARO1,INA DEPARTMENT OF HEALTH AND ENVIRONMENTAL CONTROL 2600 Bull Street Columbia,SC29201 Phone:(803) 898-3432 www.scdhec.govFrom: <Ward.Nacosta@epamail.epa.gov> To: <hollisao@dhec.sc.gov~, <flynntj@dhec.sc.gov>, <loftonat@dhec.sc.gov~ CC: <masonmr@dhec.sc.gov>, <Farngalo.Zuri@epamail.epa.gov>, <Benjamin.Lynora



### ... Date: 6/1/2009 1 1:05 AM Subject: Training Opportunities 

### - Notes from 5120109 Call

Good Day All, *Please pass this on to Brian*

This is a follow-up to the conference call that we held on 512012009. The main outcome ofthe call was the desire from DHEC for various trainings. In addition to training updates, I have also included the notes on Regional Haze from Michele.

TRAINING Conformity Training Mike Roberts of the FHWA staff has been in contact with Melinda Mathias ofyour staff and plans to do a training in Columbia, SC on June 25, 2009. For more information, contact Mike Roberts 404-562-3928. Source Apportionment Modeling Training No specific training is planned at this time. We are checking with OAQPS to follow-up on any potential planned briefings or trainings to state and local agencies.
STAQS 

### - August (Webinar~Webcast of the Summit?) Right now, webcastinglwebinar is not set up for this conference.

REGIONAL HAZE Update: Staff has begun drafting the Federal Register on SC's Regional Haze SIP. The Region's original timetable for publishing these actions has slowed somewhat due to impacts of the CAIR remand on processing these SIPS. As discussed on previous calls with SC and the other States, the Agency continues to discuss options for acting on Regional Haze SIPSthat rely on CAIR, in light of the CAIR remand and that CAIR will be revamped in the next few years along with changes in the SO2 allowance market. No decisions will be made until the new Administration has been briefed on this issue. EPA Headquarters is currently updating model runs for where CAIR emissions reductions are anticipated to occur in light of changing conditions in the SO2 allowance trading market due tothe CAIR remand. We will continue to keep States informed on this issue.
Question: We can use the State's help to answer a question related to its reasonable progress analysis. Specifically, using the State's reasonable progress area of influence methodology, all SO2 emission units with a 1%or greater impact on visibility at Cape Romain would be evaluated for control using the four reasonable progress factors. The following six emission units located at three SC facilities (Alumax, Showa Denko Carbon, and Cogen South) are listed as having a greater than 1% impact according to the VISTAS spreadsheet in Appendix H.2.b of the

SC Regional Haze SIP - Clarijication Attachment I November 9,2009SC Regional Haze SIP. We could not find these six units discussed anywhere else in the SIP or any reasons for excluding them from 

### further analysis. Could the State please explain its thinking related to these units?

COGEN SOUTH ( OCA ( Electric and Other Services ( .02030 

### I 

## 1 Combined 3 

### ------------------------------+--------+--------------------------------+---------

ALUMAX OF SOUTH CAROLINA 

### 1 002 ( Primary Production of ( 0.017 ( 

### 1 Aluminum 

### 1 ------------------------------+--------+--------------------------------+---------

ALUMAX OF SOUTH CAROLINA 

### 1 003 ( Primary Production of ( 0.0169 ( ( Aluminum 5 ------------------------------+--------+--------------------------------+---------

ALUMAX OF SOUTH CAROLINA 

### 1 005 ( Primary Production of 

### 1 0.0169 

### I I Aluminum 3 ------------------------------+--------+--------------------------------+---------

ALUMAX OF SOUTH CAROLINA 

### 1 004 

### 1 Primary Production of ( 0.01 50 

### 1 ( Aluminum 8 ------------------------------+--------+--------------------------------+---------

SHOWA DENKO CARBON 

### 1 007 

### 1 Carbon and Graphite Products 

### 1 0.0141 

### I I 7

Ifthere are additional points of interest that you were looking for follow-up on, please let me know.

Have a wonderful day! Nacosta C. Ward, Environmental Scientist U. S.Environmental Protection Agency, Region 4 Air, Pesticides & Toxics Management Division Air Planning Brancmegulatory Development Section 6 1Forsyth Street, SW Atlanta, GA 30303-8960 email: ward.nacosta@epa.gov telephone: (404) 562-9 140 facsimile: (404) 562-90 19

SC Regional Haze SIP - Clarijication Attachment I November 9, 2009The South Carolina DepartmentofHealth and Environmental Condrol's Response to questions on it regionalhaze State ImplementationPlan (Decedber 21,2007)



### Below is the South Carolina Department of Health and Environmental Control, Bureaul ofAir Quality's (Department) response to questions on its regional haze State ImplementationPlan (sI*) submittal. The discussion below addresses questions that were received by the United States Environqental Protection Agency's 

### (USEPA)Region 

### 4 staffin an electronicmail correspondenceon June 1,20019, which sought clarification on the Department's rationale regarding its reasonable further progress analysis (four factor analysis). Region 4 

### staff specifically questioned why six emissionunits located at thre$ South Carolina facilities (Alumax, Cogen South,and Showa Denka Carbon) whose SO2emissions conbibuted to 1 percent or greater impact on visibility at Cape Romain (AppendixH.2.b) were not eval ated for controls using the four reasonableprogress factors. The Department's response regarding the s'x units atthe three facilities is outlined below. 

# 7

Background: 

### Using meteorological back trajectories, extinction-weighted residencetime plots, and emissions inventoriesto identify the specificpoint sourcesof SO2that were likely to be major contributorsto visibility impairment at Cape Romain, the Department identified the specific geographic area that most likely influences visibility at Cape Romain (know as the area's SO2area of influence [AOI]).

As stated in section 1.3of the SIP narrative,the Department then identified emission reductionsthat have already occurred or will occur by 20 18 within each sourcecategory or at specificunits (to include other CAA programs, any BART requirements,and by measures in each State's long term strategy).

In conducting the reasonable further progress analysis associated with the regional haze SIP, the Department calculated the fractional contributionfrom all emission units within the SO2 A01for Cape Romain and identified those emissionunits with a contribution of 0.0 1 or above (or greater than or equalto one percent contribution)to the visibility impairment at Cape Romain. The Department chose to adopt one percent as the contributionthreshold used to consider a source for four factor analysis ofreasonable further controlsbased on precedence established in other Federalprograms.
Each emission unit identified as having a contribution greaterthan or equal to one percent was evaluated using the statutory and regulatory factors of: (1) cost of compliance, (2) time necessary for compliance, (3) the energy and non-air quality environmentalimpacts of compliance, and (4) the remaining useful life ofthe emissions unit.

For the purpose of evaluating the cost for the reasonableprogress assessment, the Department believes it was not equitabletorequire non-EGUs to bear a greater economicburden than EGUs for a given control strategy. In determining reasonable costs of controls for the EGU sector, the Department determined that the cost of SO2controls (the primary contributorto visibility impairment in the state) beyond those required by CAIR are not reasonable. These capital and operatingunit-by-unit costs ranged from about $912 to $1,922 dollars per ton of SO2 removed; with an average cost per system ranging from $1,23 1 to $1,375 dollars per ton of SO2 removed (AppendixH.2.a). Therefore, $2,000.00 per ton was selected as the threshold for costs for non-EGU sources.The Department used this cost of compliance threshold as a screening tool to determine the universe of sourcesto perform the full four-factor evaluation.

On behalf of its members, VISTAS employed a contractorto perform additional analysis of "every available SOzcontrol strategyin AirControlNET against the EGU and non-EGU point source inventories to develop a master list of available,incremental control strategies" (Appendix H, page 44). Where

SC Regional Haze SIP - Clarification Attachment 2 November 9,2009appendix H.2.c lists 

### "VISTAS base case," it was determined that no potential controls here suggested for the particular unit(s). 

### As depicted in appendixH.2.c, this is the case for unit 

### 007at Showa Denko Carbon and unit OCA at CogenSouth (no controlssuggested for these units). Units 002, 003, 004,and 005 at Alumax ofSouth Carolina were identified as having one potential control option (Flue-gas desulfurization);however, the costassociated with this control option was estimated ad $35,404per ton of SOZ removed; well above the $2,000cost threshold established.
Only those units identified in the SIP narrative on page 100 and in Table 8.0-2 (represeptingthose sources identified ashaving a potential cost associatedwith fuel switching below the $2,000 tweshold established) were asked to conduct a four factor analysis to evaluate the potential costsassociated with fuel switching (see Appendix H, section 6.2.1 for more information).



### Conclusions: While each of the six units at the three facilitiesasked about in the aforementionedeledtronicmail correspondence (Cogen South, Showa Denka, and Alumax) were found to contribute one percent or greater to the visibility impairmentat Cape ~omain,' they were not asked to conduct a four factor analysis based on the fact that no addition controlswere identified as feasible and/or cost effective. Ths information was depicted in appendixH.2.c ofthe regional haze SIP submittal.

The Department believes that it addressed this concern within the existing regional haze SIP submittal that was submittedon December 2 1, 2007, and that this documentationis provided to clarify the issue.



## 'All sources with a Qld greater than or equal to five and an RTmax greater than or equal to 10 percent were added to the list for further consideration because it has been determined that these
sources may contribute to visibility impairment on the 20 percent worst days. I

SC Regional Haze SIP - Clarrfication Attachnient 2 November 9, 2009