### Reconciliation of Comments Received on the Proposed Redesignation Request and Maintenan ce Plan for the Birmin gham, AL 2006 24-Hour

PM 2.5 

### 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 transp ort 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 submi tted maintenance plan relies in part on CAIR to reduce transport of pollutants into the State fr om 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 PM 2.5 emissions reductions that will result fr om 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 PM 2.5 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 mainte nance plan as a result of this comment.

EPA Comment #1:

It appears that the Sloss Industries Corpor ation – 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 th ese 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 s ources in the future. After the area is

- 1 -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 mainte nance 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. Pi pe and Foundry Company – North Birmingham

facilities have contributed towa rd attainment of the 24-hour PM 2.5 NAAQS for the 2007 – 2009 attainment years. Many of the reductions at th ese facilities appear to have occurred too late or have yet to occu r during the attainment year s 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 re ductions 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 mainte nance plan as a result of this comment.

EPA Comment #3:

Please elaborate on how the emission reducti ons 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 pr ovide a discussion in the appendix on the development of the emissions inventory on thes e particular emission source categories. For example, the federal locomotive rule re quires compliance at the time of original manufacture and each subsequent re-manuf acture 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 uncle ar 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

- 2 -Birmingham sources and CAIR. Emissions reductions from these measures are shown in tables 2.2-1 and 2.2-2 of th e maintenance plan. While the other measures listed in Section 2-2 were applic able 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 cont rols, 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. Pleas e discuss how reductions of the precursor pollutants for the 24-hour PM 2.5 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 NE SHAPS during the attainment period (40 CFR 63 Subpart CCCCC, for example), no cr edit was specificall y 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. Pleas e provide specific information as to the location of this particular discussion.

ADEM Response: The purpose of an emissions in ventory 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:

- 3 -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 categ ories on page 4-5 of section 4.2.5 and the total emissions are much larger than the da ta in the state implementation plan (SIP)

Narrative Tables 4.3-1 to 4.3- 3. It is assumed the emi ssions totals in Appendix D3c would be even larger if the date in the rema ining 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 refl ected 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 bas is 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 firs t two pages of Appendix D3c represent output

from the nonroad model.

ADEM Response: The tables following the first tw o pages of Appendix D3 are the output tables fr om the nonroad model.

No changes were made as a result of this comment.

EPA Comment #9

- 4 -- 5 - Section 4.2 does not direct the r eader to the location of deta iled and specific information on the various emissions inventory source cate gories and precursor pollutant components

of the 24-hour PM 2.5 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.