1 CHATTANOOGA-HAMILTON COUNTY 

2 AIR POLLUTION CONTROL BOARD 

3 

4 PUBLIC HEARING 

5 JUNE 30, 2014 

6 6:09 p.m. 

7 

8 Air Pollution Board Members Present: 

9 John Tucker 

Thorn Carmichael 

10 Bob Lynch 

Steve Meyer, Chairman 

11 Robert Howard 

Sabrina Novak 

12 Val DeOlloqui 

Colleen Russell 

13 Air Pollution Control Bureau: 

14 Bob Colby 

Kathy Robertson 

15 

16 Pamela Fisher, Wilson Reporting Agency 

17 

18 

19 

20 

21 

22 

23 

24 

25 

1 
2 

1 (June 30, 2014) (6:09p.m.) 

2 MR.. JY.IEYER: I would like to open up 

3 the public hearing of the Air Pollution Control Board 

4 today, the 30th of June. 

5 Mr. Colby. 

6 MR. COLBY: Thank you, Mr. Chairman, 

7 Members of the Board. This is a permitting action 

8 which does, by law, require a public hearing following 

9 a public comment period. 

10 ALSTOM Power, Inc., which operates a 

11 power system component manufacturing facility at 1119 

12 Riverfront Parkway in Chattanooga has made application 

13 for a Federal Enforceable Certificate of Operation. 

14 These Federal Enforceable Certificates of Operation are 

15 also referred to as Synthetic Minor Permits. And the 

16 purpose of seeking one of these is to avoid more 

17 stringent permitting requirements and control 

18 requirements at your facility because your emissions 

19 are actually down here, and the trigger level for these 

20 more stringent standards is way up here, and you're 

21 never going to get up here to a hundred tons in this 

22 instance. So what ALSTOM wants to do is they have 

23 reduced their coating usage, their VOC and HAP content, I 

I 

24 which would have made them a major source. And since 

25 they have reformulated their coatings, they can become 
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

I, 

13 

14 

15 

16 

17 

18 

·19 

20 

21 

22 

23 

24 

25 

a synthetic minor and avoid these more stringent 

permitting requirements as they have been operating as 

a major source with a Part 70 Operating Permit for a 

number of years now. But they have the ability to shed 

themselves of this Part 70 Permit requiremept, and they 

should be commended in seeking to do that because what 

they have done is they have reduced the emissions from 

the facility. So the air is cleaner as a result of 

their actions in reformulating. 

Public notice said that folks, if they 

wanted to comment, would need to make written comment 

by Thursday, June 26th, at close of business. We have 

not received any public comments on this matter, and it 

would probably be appropriate if you inquired if there 

was anyone in the audience who would like to make a 

public comment before the Board takes action on this. 

But there is a resolution in your 

Board package, Resolution 0614-03, which would 

authorize the Bureau Director to issue this Federal 

Enforceable Certificate of Operation following the 

application of ALSTOM Power, Inc., and a public comment 

period and public hearing. 

MR. MEYER: At this time the Chair 

will entertain any comments from the general public 

regarding the motion for this Part 70 Permit. 

3 
1 Hearing no request for comment or 

2 public hearing, I'll close the part of the open 

3 hearing. The Bureau's recommendation is Resolution No. 

4 614-03 and should be on your desk, copy of that. I'.ll 

5 entertain a motion to approve the Resolution 614-03. 

6 DR. TUCKER: I move approval of 

7 Resolution 614-03. 

8 IV.IR. MEYER: Motion made by Dr. Tucker 

9 for Resolution No. 614-03. 

10 Is there a second? 

11 IV.IR. CARMICHAEL: Second. 

12 IV.IR. MEYER: Second by Mr. Carmichael. 

13 Any further discussion regarding this 

14 particular change in permit? 

15 All in favor say ll aye. ll 

16 (Response of ll aye. ") 

17 IV.IR. MEYER: Opposed? 

18 (No response.) 

19 Motion is carried and approved. 

20 IV.IR. COLBY: Thank you. 

21 The final item for the public hearing 

22 is the PM2 . 5 or Fine Particle Redesignation Request. 

23 You previously received materials on that at~ the 

24 opening of the public comment period, and we have had 

25 one comment which came in by mail today. I got it by 

4 
1 e-mail on, I believe it was, last Thursday afternoon 

2 from U.S. EPA Region 4, who had been looking at thi's, 

3 versions of the draft, for a year now 

4 MR.. MEYER: Yeah. 

5 MR. COLBY: -- but they had some more 

6 comments. So as part of the public hearing, I need to 

7 go over the comments that we received from EPA and our 

8 response to those comments, which will go into the 

9 package that we will then forward, with Board approval, 

10 to the Tennessee Air Pollution Control Board, because 

11 they have to approve it and then they send it to 

12 U.S. EPA Region 4 to approve to become part of the 

13 State Implementation Plan. 

14 One of the things that we ultimately 

15 want to do, we previously, in 2009, submitted a State 

16 Implementation Plan Revision, a nonattainment plan as 

17 to how we were going to get back into attainment with 

18 the PM2 .

5 standard, and EPA has been after me to 

19 withdraw that. Of course, that would take Board 

20 approval. And because of some jeopardy possibilities, 

21 I told them that I wasn't in a position to recommend to 

22 the Board that it be withdrawn until they approved our 

23 Redesignation Request because, as I indicated, with the 

24 old standard being nonattainment, if you don't ask that 

25 that be taken away and be designated attainment, you'll 

5 
1 be forever nonattainment for PM2 .

5 and, obviously, you 

2 didn't want that. 

3 So one of the outcomes I would ask for 

4 is if the Board approves this Redesignation Request to 

5 submit to the state and then to EPA, that it also 

6 authorize the Bureau Director to request that EPA 

7 that we withdraw our previous SIP submittal from 2009 

8 to EPA for our PM2 .

5 nonattainment because I figured 

9 this might act as an impetus for them to go ahead and 

10 process this request quickly since they want me to 

11 withdraw the other. 

12 So that being said, the first comment 

13 EPA made was operations at Caraustar Mill Group, Inc., 

14 also known as Chattanooga Paperboard, ceased on 

15 July 22nd, 2008, and no emissions are being used for 

16 boilers for years after 2008 in our request. We 

17 recommend the text on page 22 also discuss the status 

18 of permits for this facility. 

19 Our response is: As requested, text 

20 was added to the last paragraph on page 20 of the 

21 document to indicate that the operating permit for 

22 Caraustar Mill Group, Inc., doing business as 

23 Chattanooga Paperboard, was withdrawn after all 

24 operations at the plant ceased. And we explained to 

25 them that that's what the law required, that you 

6 
1 surrender your permits if you no longer have a 

2 facility. 

3 Their second comment was with regard 

4 to Appendix F, please include emissions from PM2 .

5 

5 point sources and Appendix F. 

6 Our response, I'll paraphrase it here 

7 for the Board, was, essentially, that we didn't mean to 

8 include PM2 . 5 emissions in that because the appendix 

9 that they're referring to contained only so2 and NOx 

10 emissions, and it was there for the purpose of 

11 demonstrating to whoever was reading the document that 

12 the so2 and NOx emissions that we had from point 

13 sources in Hamilton County was minuscule compare to 

14 what was in area coal-fired utilities. So no change is 

15 needed as a result of that comment. 

16 Their third comment was: Recommend 

17 placement of titles and units for the data presented in 

18 Appendix H and a written description as to how the data 

19 in the tables were used in the development of emissions 

20 inventories. 

21 The Bureau response is: As requested, 

22 titles, data units, and a calculation methodology were 

23 added to each of the five spreadsheets in Appendix H 

24 used for the calculation of point source emissions. 

25 Furthermore, although not requested, titles, data units 

7 
1 and a calculation methodology were also added to each 

2 of the five similar spreadsheets in Appendix K used for 

3 the calculation of area sources. 

4 Their final comment was with respect 

5 to Appendix J: Additional textual narratives are 

6 recommended for Appendix J for aircraft. Also, for 

7 marine vessels, please explain how port emissions 

8 differ from underway emissions and how data is 

9 updated/projected/developed from 2005 to ~007 as used 

10 in the State Implementation Plan Narrative. 

11 The Bureau response is as follows: As 

12 requested, text was added to the last paragraph on page 

13 18 of the document to explain that emissions data in 

14 Appendix J for aircraft, marine, and railroad sources 

15 were determined by the U.S. EPA. Also as requested, 

16 text was added to this paragraph to indicate types and 

17 sources of data that were used by the U.S. EPA as the 

18 basis for emissions from marine vessels in order to 

19 show the difference between the port and underway 

20 emissions categories. Furthermore, although not 

21 requested, text was also added to this paragraph to 

22 indicate types and sources of data that were used as 

23 the basis for emissions from both aircraft and railroad 

24 sources. 

25 And I take it that everyone caught 

8 
1 that EPA wanted us to explain how EPA determined those. 

2 I won't make any further comment on that. 

3 So we have before the Board in this 

4 public hearing a draft Redesignation Request and 

5 Maintenance Plan, which we would ask the Board to 

6 authorize the Bureau Director to submit that to the 

7 Tennessee Air Pollution Control Board for consideration 

8 and approval and to send that on to U.S. EPA Region 4 

9 for action to redesignate us, and also to authorize the 

10 Bureau Director to withdraw the previous State 

11 Implementation Plan submittal for PM2 . 5 nonattainment 

12 once EPA approves this one. 

13 MR. MEYER: I'll entertain a motion of 

14 what Bob just said to allow us to move forward with 

15 these submittals to EPA and to the state. 

16 Do I hear a motion? 

17 MR. CARMICHAEL: Mr. Chairman, you 

18 very eloquently expressed that, so I recommend that 

19 what you have said be made part of the --

20 MR. MEYER: Is there a second of 

21 Mr. Carmichael's initial motion? 

22 MR. LYNCH: Second. 

23 MR. MEYER: Second by Mr. Lynch. Is 

24 there any discussion regarding what Mr. Colby just 

25 presented to us? 

9 
1 Since there is no discussion, all in 

2 favor say 11 aye. 11 

3 (Response of 11 aye. 11 ) 

4 MR. fv'IEYER: Opposed? 

5 (No response.) 

6 MR. fv'IEYER: Motion is carried. 

7 MR.. COLBY: Thank you. And with that, 

8 if EPA approves the Redesignation Request before they 

9 finalize a revised tighter ozone standard, we will be 

10 in compliance with all. 

11 MR. fv'.IEYER: · Excellent. Excellent. 

12 Until the next time they --

13 MR. COLBY: Yeah, until next time they 

14 change. Thank you very much. 

15 MR. fv'IEYER: The Chair will entertain a 

16 motion for dismissal or adjournment. 

17 

18 

19 

20 

MR. LYNCH: So moved. 

MR.. fv'IEYER: Moved by Mr. Lynch. 

DR. TUCKER: Seconded. 

MR. fv'IEYER: Seconded by Dr. Tucker. 

21 All in favor say aye. 

22 (Response of 11 aye. 11 ) 

23 

24 

25 

MR. fv'IEYER: You-all are dismissed, 

(Meeting adjourned 6:22p.m.) 

10 
1 

2 C E R T I F I C A T E 

3 

4 STATE OF TENNESSEE 

5 

6 I hereby certify that the foregoing proceedings 

7 were taken down, as stated in the caption, and reduced 

8 to typewriting under my direction; and that the 

9 foregoing pages 1 through 11 represent a true, 

10 complete, and correct transcript of said proceedings to 

11 the best of my ability. 

12 IN WITNESS WHEREOF, I have hereunder set my hand 

13 and affixed my notarial seal this 23rd day of July 

14 2014. 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

PAMELA A. FISHER, TN-319 

Expiration Date: 06/30/16. 

Notary Public Commission Expires: 04/09/16. 

11