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 PollutionBoardMembers Present: 9 John Tucker Thorn Carmichael 10 Bob Lynch Steve Meyer, Chairman 11 Robert Howard SabrinaNovak 12 Val DeOlloqui ColleenRussell 13 Air Pollution Control Bureau: 14 Bob Colby Kathy Robertson 15 16 Pamela Fisher, WilsonReportingAgency 17 18 19 20 21 22 23 24 25 12

1 (June 30, 2014) (6:09p.m.) 2 MR.. JY.IEYER: I would like to openup 3 the public hearing of theAir Pollution Control Board 4 today, the 30thof 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 Operationare 15 also referred to as SyntheticMinor Permits. And the 16 purpose of seeking one of these is to avoidmore 17 stringent permittingrequirements and control 18 requirements at your facilitybecause your emissions 19 are actually down here, and the trigger level for these 20 more stringent standards is way up here, andyou're 21 never going to get up here to a hundred tons in this 22 instance. So what ALSTOM wants to do is theyhave 23 reduced their coatingusage, theirVOC and HAP content, 

### I I 24 whichwould have made them a major source. And since 25 they have reformulated their coatings, they canbecome1 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 permittingrequirements as theyhave been operating as

a major source with a Part 70 Operating Permit for a number of years now. But theyhave the ability to shed themselves of this Part 70 Permit requiremept, and they shouldbe commended in seeking to do that because what theyhave done is theyhave 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, wouldneedto make written comment byThursday, June 26th, at close of business. We have not received anypublic comments on this matter, and it wouldprobablybe appropriate if you inquired if there

was anyone in the audience who would like tomake a public comment before the Board takes action on this. But there is a resolution inyour Boardpackage, Resolution 0614-03, which would authorize the BureauDirector to issue this Federal Enforceable Certificate of Operation following the application of ALSTOM Power, Inc., and a public comment period andpublic hearing. MR. MEYER: At this time the Chair will entertain any comments from the general public regarding the motion for this Part 70 Permit. 31 Hearing no request for comment or 2 public hearing, I'll close the part of the open 3 hearing. The Bureau's recommendation is ResolutionNo. 4 614-03 and shouldbe onyour 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: Motionmade byDr. Tucker 9 for ResolutionNo. 614-03. 10 Is there a second? 11 IV.IR. CARMICHAEL: Second. 12 IV.IR. MEYER: SecondbyMr. Carmichael. 13 Any further discussion regarding this 14 particular change inpermit? 15 All in favor say llaye. ll 16 (Response of llaye.") 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 RedesignationRequest. 23 You previouslyreceivedmaterials on that**at~**the 24 opening of thepublic comment period, and we have had 25 one comment which came inbymail today. I got itby 41 e-mail on, I believe it was, last Thursday afternoon 2 from U.S. EPA Region 4, who hadbeen looking at thi's, 3 versions of the draft, for a year now 4 MR.. MEYER: Yeah. 5 MR. COLBY:

-- but theyhad some more 6 comments. So as part of the public hearing, I needto 7 go over the comments that we received from EPA and our 8 response to those comments, whichwill go into the 9 package that we will then forward, withBoard approval, 10 to the TennesseeAir Pollution Control Board, because 11 theyhave to approve it and then they send it to 12 U.S. EPA Region 4 to approve tobecome 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 PlanRevision, 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 afterme to 19 withdrawthat. Of course, that would take Board 20 approval. And because of some jeopardypossibilities, 21 I told them that I wasn't in a position to recommend to 22 the Board that itbe withdrawnuntil they approved our 23 RedesignationRequest because, as I indicated, withthe 24 old standardbeingnonattainment, if you don't ask that 25 that be taken away andbe designated attainment, you'll 51 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 RedesignationRequest to 5 submit to the state and then to EPA, that it also 6 authorize the BureauDirector to request that EPA 7 that we withdraw ourprevious 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 theywant me to 11 withdraw the other. 12 So that being said, the first comment 13 EPA made was operations at CaraustarMill Group, Inc., 14 also known as Chattanooga Paperboard, ceased on 15 July 22nd, 2008, andno emissions are beingused for 16 boilers for years after 2008 in our request. We 17 recommend the text onpage 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 onpage 20 of the 21 document to indicate that the operatingpermit for 22 CaraustarMill Group, Inc., doingbusiness 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 61 surrenderyourpermits if you no longer have a 2 facility. 3 Their second comment was withregard 4 toAppendix F, please include emissions from PM2.5 5 point sources andAppendix 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 andNOx 10 emissions, and itwas there for the purpose of 11 demonstrating to whoever was reading the document that 12 the

## so2 andNOx emissions that we had frompoint 13 sources inHamilton Countywas minuscule compare to 14 what was in area coal-firedutilities. So no change is 15 needed as a result of that comment. 16 Their third comment was: Recommend 17 placement of titles andunits for the datapresented in 18 AppendixHand a written description as to how the data 19 in the tables were used inthe development of emissions 20 inventories. 21 The Bureau response is: As requested, 22 titles, data units, and a calculationmethodologywere 23 added to each of the five spreadsheets inAppendixH 24 used for the calculationof point source emissions. 25 Furthermore, althoughnot requested, titles, data units 71 and a calculationmethodology were also added to each 2 of the five similar spreadsheets inAppendix Kused for 3 the calculationof area sources. 4 Their final comment was with respect 5 toAppendix J: Additional textual narratives are 6 recommended for Appendix J for aircraft. Also, for 7 marine vessels, please explainhow port emissions 8 differ from underway emissions andhow data is 9 updated/projected/developed from 2005 to**~007** as used 10 in the State Implementation PlanNarrative. 11 The Bureau response is as follows: As 12 requested, text was added to the last paragraph onpage 13 18 of the document to explain that emissions data in 14 Appendix J for aircraft, marine, and railroad sources 15 were determinedby the U.S. EPA. Also as requested, 16 text was added to this paragraph to indicate types and 17 sources of data that were usedby the U.S. EPA as the 18 basis for emissions frommarine vessels in order to 19 show the difference between the port andunderway 20 emissions categories. Furthermore, althoughnot 21 requested, text was also added to this paragraphto 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 81 that EPA wantedus to explainhow 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 RedesignationRequest and 5 Maintenance Plan, whichwe would ask the Board to 6 authorize the BureauDirector 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 Region4 9 for action to redesignate us, and also to authorize the 10 BureauDirector 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 allowus 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 saidbe made part of the

-- 20 MR. MEYER: Is there a second of 21 Mr. Carmichael's initialmotion? 22 MR. LYNCH: Second. 23 MR. MEYER: SecondbyMr. Lynch. Is 24 there any discussionregardingwhat Mr. Colbyjust 25 presented to us? 91 Since there is no discussion, all in 2 favor say 11aye. 11 3 (Response of 11aye. 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 verymuch. 15 MR. fv'IEYER: The Chairwill entertaina 16 motion for dismissal or adjournment. 17 18 19 20 MR. LYNCH: So moved. MR.. fv'IEYER: Moved byMr. Lynch. DR. TUCKER: Seconded. MR. fv'IEYER: SecondedbyDr. Tucker. 21 All in favor say aye. 22 (Response of 11aye. 11 ) 23 24 25 MR. fv'IEYER: You-all are dismissed, (Meeting adjourned 6:22p.m.) 101 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 undermy direction; and that the 9 foregoing pages 1 through 11 represent a true, 10 complete, and correct transcript of saidproceedings to 11 the best of my ability. 12 IN WITNESS WHEREOF, I have hereunder set my hand 13 and affixedmy 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