Reconciliation of Comments Received on the Proposed Redesignation 

Request and Maintenance Plan for the Birmingham, AL 2006 24-Hour 

PM2.5 Nonattainment Area 

The U.S. EPA was the only commenter. A summary of their comments follows. 

EPA Comment from cover letter:

In order to approve Alabama’s maintenance plan for the nonattainment area, the U.S. 

Environmental Protection Agency (EPA) would need additional information which 

addresses the impact of transport from other states during the period of the plan. Such a 

maintenance plan must not rely in any way on CAIR to show maintenance for the 10-year 

period after redesignation. Because the submitted maintenance plan relies in part on 

CAIR to reduce transport of pollutants into the State from other states, EPA cannot 

approve the request as submitted. As it now stands, CAIR is projected to remain 

enforceable for only a few years at most, and EPA is unable to predetermine and project 

the PM2.5 emissions reductions that will result from the new Transport Rule, which will 

replace CAIR. The Transport Rule is under development and EPA anticipates finalizing 

it in 2011. 

ADEM Response: The maintenance plan acknowledges that it may need to be 

revised to be consistent with EPA’s final action on the new Transport Rule which 

will replace CAIR. This is unlikely to be necessary because the new Transport 

Rule will likely be at least as stringent as CAIR and possibly more stringent. 

ADEM requests that EPA redesignate the Birmingham nonattainment area to 

attainment status for the 24-hour PM2.5 standard and approve the maintenance 

plan. ADEM commits to work with EPA to make any revisions to the 

maintenance plan necessary to be consistent with the new Transport Rule. 

No revisions were made to the maintenance plan as a result of this comment.

EPA Comment #1: 

It appears that the Sloss Industries Corporation – Mineral Wool and U.S. Pipe and 

Foundry Company – North Birmingham are in the process of shutting down their 

Birmingham facilities and will eventually turn in their permits, but are also banking the 

emissions (see Appendix F). Emissions for these facilities are included in the emissions 

inventory of 2009 but are listed as zeroes in the future years (2012-2024). Please explain 

why the emissions were not carried forward in the future year inventories and how 

banking emissions affect that decision. 

ADEM Response: There is presently no regulatory framework in place to 

facilitate the banking of fine particle emissions reductions. As part of the 

maintenance plan, ADEM and JCDH will monitor the growth of emissions that 

occur as a result of new or modified major sources in the future. After the area is 

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redesignated to attainment, any new or modified major sources of fine particles or 

fine particle precursors will be subject to Prevention of Significant Deterioration 

permitting requirements, including Best Available Control Technology 

requirements. The maintenance plan does anticipate some point source growth in 

the later years of the plan. Also, the maintenance plan will be revised eight years 

after redesignation to attainment and any major deviations of actual emissions 

from the projections in the maintenance plan will be evaluated and addressed at 

that time. 

No revisions were made to the maintenance plan as a result of this comment.

EPA Comment #2: 

Please discuss why controls and shutdowns at the W.J. Bullock, Sloss Industries 

Corporation – Mineral Wool and U.S. Pipe and Foundry Company – North Birmingham 

facilities have contributed toward attainment of the 24-hour PM2.5 NAAQS for the 2007 – 

2009 attainment years. Many of the reductions at these facilities appear to have occurred 

too late or have yet to occur during the attainment years and perhaps would be better 

suited for discussion in the maintenance plan. See the footnote at the bottom of pages 2-

5. 

ADEM Response: The actual emission reductions obtained through the 

shutdown of these facilities prior to 2009 were accounted for in the base year. 

Any reductions occurring after this were captured in projections for the year 

2012. 

No revisions were made to the maintenance plan as a result of this comment. 

EPA Comment #3: 

Please elaborate on how the emission reductions from the federal, state and local 

permanent and enforceable measures (listed in Section 2-2, page 2-3) in the Birmingham 

nonattainment area were determined, and the amount of reductions that have occurred 

during the attainment time period. Please provide a discussion in the appendix on the 

development of the emissions inventory on these particular emission source categories. 

For example, the federal locomotive rule requires compliance at the time of original 

manufacture and each subsequent re-manufacture using a tiered phase-in approach. 

Please elaborate on how the reductions in locomotive engines in the Birmingham 

nonattainment area were determined and the amount of reductions that have occurred 

during the attainment time period. It is unclear how reliance on this rule was determined 

for the nonattainment area.

 

ADEM Response: No credit was specifically taken during the attainment period 

for any federal, state or local measure with the exception of RACT for local 

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Birmingham sources and CAIR. Emissions reductions from these measures are 

shown in tables 2.2-1 and 2.2-2 of the maintenance plan. While the other 

measures listed in Section 2-2 were applicable during the attainment period, it is 

not possible to estimate specific emissions reductions that occurred from each 

measure listed. The only manipulation for the future year inventories, aside from 

taking credit for known point source controls, was to apply growth factors. 

No changes were made as a result of this comment. 

EPA Comment #4: 

The executive summary states that permanent and enforceable reductions leading to 

attainment have come from the Federal National Emission Standards for Hazardous Air 

Pollutants (NESHAP) under Section 112 (42 U.S.C. 7412). These pollutants are 

basically volatile organic compounds. Please discuss how reductions of the precursor 

pollutants for the 24-hour PM2.5 national ambient air quality standards (NAAQS) at 

Birmingham facilities are affected by this rule. 

ADEM Response: Even though it is likely that some fine particle emissions 

reductions occurred as a result of NESHAPS during the attainment period (40 

CFR 63 Subpart CCCCC, for example), no credit was specifically taken for any 

federal, state or local measures with the exception of RACT for local Birmingham 

sources and CAIR. The only manipulation for the future year inventories, aside 

from taking credit for known point source controls, was to apply growth factors. 

No changes were made as a result of this comment. 

EPA Comment #5: 

Upon review of the appendices, EPA could not find discussion on the development of the 

filterable and condensable PM emissions. Please provide specific information as to the 

location of this particular discussion. 

ADEM Response: The purpose of an emissions inventory for a maintenance plan 

is to project future year emissions and to estimate how these emissions will 

change over the period of the maintenance plan. Speciation of particulate matter 

into condensable and filterable is unnecessary for this effort, as growth factors 

are only applied to the total particulate value. 

No changes were made as a result of this comment. 

EPA Comment #6: 

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Please clarify why the total nonroad mobile sources in Appendix D3c do not match the 

data in Tables 4.3-1 thru 4.3-3. For example, the nonroad totals for the first two pages of 

Appendix D3c do not address all of the categories on page 4-5 of section 4.2.5 and the 

total emissions are much larger than the data in the state implementation plan (SIP) 

Narrative Tables 4.3-1 to 4.3-3. It is assumed the emissions totals in Appendix D3c 

would be even larger if the date in the remaining tables were added to the first two pages 

of this Appendix. 

ADEM Response: Appendix D3 reflects both the emissions from the nonroad 

model (in tons per year) and the emissions from those source categories that are 

not contained in the nonroad model (in both tons per year and tons per day). The 

sum of these emissions is reflected in Tables 4.3-1 thru 4.3-3. 

No changes were made as a result of this comment. 

EPA Comment #7: 

Please explain why information in Appendix D2 is included in the redesignation requests 

since the data does not support data in Tables 4.3-1 thru 4.3-3 of the SIP Narrative of 

Appendices D-3b and D3c. 

ADEM Response: Appendix D2 contains the discussion of the development of the 

BAPS inventory, which was used as a basis for Jefferson County’s point source 

inventory for the maintenance plan. This inventory as well as the VISTAS 

inventory served as the starting point for the inventory in the maintenance plan. 

A clarifying footnote was added to Section 4.2.2 of the document.

EPA Comment #8: 

Please clarify if the tables following the first two pages of Appendix D3c represent output 

from the nonroad model. 

ADEM Response: The tables following the first two pages of Appendix D3 are 

the output tables from the nonroad model. 

No changes were made as a result of this comment. 

EPA Comment #9 

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Section 4.2 does not direct the reader to the location of detailed and specific information 

on the various emissions inventory source categories and precursor pollutant components 

of the 24-hour PM2.5 NAAQS. 

ADEM Response: Section 4.2 directs the reader to Appendix D, which addresses 

the development and growth of the emissions inventory. 

No changes were made as a result of this comment.