1



# Technical Support Document for

Alabama Regional Haze SIP Submittal

January 2012

U.S. EPA

– Region 4 Atlanta, GA2 

### Technical Support Document (TSD) for Alabama Regional Haze SIP Submittal

Table of Contents

I. Background

II. Summary of EPA’s Action

III. Evaluation of State Regional Haze Submittal

A. Identification of Areas

B. Reasonable Progress Goals Development

1. Calculations of Baseline Visibility Conditions

2. Calculations of Natural Visibility Conditions

3. Uniform Rate of Progress (UROP or “Glidepath”)

for Reasonable Progress

C. Long Term Strategy

1. Technical Basis for Strategy

2. Identification of Sources and Factors to be

Considered

3. Source or Source Category Specific Analyses for Reasonable Progress

4. Enforceability of Reasonable Progress Measures

D. Best Available R etrofit Technology (BART) Requirements

1. Identification of all BART Eligible Sources

2. Modeling or other Demonstrations for BART Exempt Sources

3. Identification of Sources Addressed by CAIR Rule

4. Source Specific BART Determinations

5. Enforceability of BART

E. Coordin ation of Regional Haze and RAVI Requirements

F. Monitoring Strategy and Other Implementation Requirements

G. Emission Inventory

IV. Conclusions

__________________________________________________________________ Note : Italicized text in this document that appears under the “State Regional Haze Submittal” headings are excerpts from relevant portions of the Alabama regional haze submittal as cited. Figure and table citations under these headings reflect the actual
references as listed in the State’s SIP submittal. Page numbers refer to the SIP Narrative, unless otherwise specified.3 

### TSD for Alabama Regional Haze SIP Submittal

I. Background

In Section 169A of the 1977 Amendments to the Clean Air Act (CAA), Congress set forth a program for protecting visibility in Federal Class I areas which calls for the “prevention of any future, and the remedying of any existing, impairment of visibility in mandatory Federal Class I areas which impairment results from manmade air pollution.” Congress adopted the visibility provis ions to protect visibility in 156 Federal Class I areas, which include certain national parks, memorial parks, and wilderness areas over a certain size, and all international parks. These areas are defined at 40 CFR 81.400, and listed by s tate at 40 CFR 8 1.401

- 81.437. On December 2, 1980, EPA promulgated regulations to address visibility impairment that is “reasonably attributable” to a single source or small group of sources. 45 FR 80084

. These regulations represented the first phase in addressing visib ility impairment and deferred action on regional haze that emanates from a variety of sources until monitoring, modeling and scientific knowledge about the relationships between pollutants and visibility impairment improved.

In the 1990 Amendments to the CAA, Congress added Section 169B and called on EPA

to issue r egional h aze rules. The Regional Haze rule (RHR) that EPA promulgated on July 1, 1999 (64 FR 35713) revised the existing visibility regulations to integrate provisions addressing regional haze v isibility impairment and establish a comprehensive visibility protection program for Federal Class I areas. States are required to submit state implementation plans (SIPs) to EPA that set out each state’s plan for complying with the RHR, including consult ation and coordination with other states and with Federal Land Managers (FLMs). States must submit a r egional h aze SIP to EPA within three years after the date of designation of areas under the National Ambient Air Quality Standard (NAAQS) for fine partic ulate matter ( PM 2.5 ) . EPA promulgated PM 2.5 designations on December 17, 2004, and thus, regional haze SIPs were to be submitted to EPA by December 17, 2007, which is also specified at 40 CFR 51.308(b).

The RH R addressed the combined visibility effects of various pollution sources over a wide geographic region. Consequently, all 50 states, including those without Class I areas, Washington, D.C., and the Virgin Islands, are required to submit r egional h aze SIPs. 40 CFR 51.300(b)(3). EPA designated five Regional Planning Organizations (RPOs) to assist with the coordination and cooperation needed to address the visibility issue. The RPO that makes up the southeastern portion of the contiguous United States is

kno wn as VISTAS (Visibility Improvement

– State and Tribal Association of the Southeast). VISTAS members include: the Eastern Band of the Cherokee Indians, other Federally Recognized Tribes and Local Air Programs within the geographic area, and the

followin g states: Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, Virginia, and West Virginia. The Alabama Department of Environmental Management (ADEM) chose to participate in VISTAS to develop the technical analyses n eeded to fulfill the requirements of the RH R

.4 Figure 1. Geographical Areas of Regional Planning Organizations

Figure 2 . Class I Areas in the VISTAS Region5

II. Summary of Action

EPA is proposing a limited approval of a revision to the Alabama state implementation plan (SIP) submitted by the State of Alabama through the Alabama Department of Environmental Management (ADEM), on July 15, 2008, that addresses regional haze for the first implementation period. This revi sion addresses the requirements of the Clean Air Act (CAA or Act) and EPA’s rules that require states to prevent any future and remedy any existing anthropogenic impairment of visibility in mandatory Class I areas (national parks and wilderness areas) caus ed by emissions of air pollutants from numerous sources located over a wide geographic area (also referred to as the “regional haze program”). States are required to assure reasonable progress towards the national goal of achieving natural visibility cond itions in Class I areas. EPA is proposing a limited approval of this SIP revision to implement the regional haze requirements for

Alabama on the basis that the revision, as a whole, strengthens the Alabama SIP. Additionally, EPA is proposing to rescind t he federal regulations previously approved into the Alabama SIP on November 24, 1987, and to rely on the provisions in Alabama’s July 15, 2008, SIP submittal to meet the long

- term strategy (LTS) requirements for reasonably attributable visibility impairmen t (RAVI). EPA has previously proposed a limited disapproval of the Alabama regional haze SIP because of deficiencies in the State’s regional haze SIP submittal arising from the remand by the U.S. Court of Appeals

for the District of Columbia Circuit (D.C. Circuit ) to EPA of the Clean Air Interstate Rule (CAIR). Consequently, EPA is not proposing to take action in this rulemaking to address the State’s reliance on CAIR to meet certain regional haze requirements.6

III. Evaluation of State Regional Haze Su bmittal

A. Identification of Areas

The SIP must identify each mandatory Class I Federal area located within the State and in each mandatory Class I Federal area located outside the State that may be affected by

emissions from within the State. Where a mand atory Class I Federal area is in multiple states, a description of how the states have assigned responsibilities for the area needs to

be included.

State Regional Haze Submittal AL SIP Narrative, Page 4:

Alabama has one Class I area within its borders, the Sipsey Wilderness area located within the Bankhead National Forest in Northeastern Alabama (Figure 1.5

- 1). The Alabama Department of Environmental Management (ADEM) is responsible for developing the Regi onal Haze SIP. This SIP establishes Reasonable Progress Goals (RPGs) for visibility improvement at the Sipsey Wilderness, and a Long Term Strategy (LTS) that will achieve those RPGs within the first Regional Haze planning period.

EPA Findings : EPA proposes to find that Alabama has a dequately addressed this provision.7

III. Evaluation of Regional Haze Submittal B. Reasonable Progress Goals Development

B.1. Calculations of B aseline V isibility C onditions : ((40 CFR 51.308(d)(2)(i))

The period for establishing baseline visibility conditions is 2000 to 2004. For each mandatory Class I Federal area located within the State, the State must determine the average degree of visibility impairment (expressed in deciviews) for the most impair ed and least impaired days (i.e. the 20% most impaired days and 20% least impaired days) for each of these years

. Baseline conditions are the average of the se annual values

. For each mandatory Class I Federal area located within the State, the SIP needs to calculate the number of deciviews by which baseline conditions exceed natural visibility conditions for the most impaired and least impaired days.

Where onsite monitoring is not available

, the baseline visibility conditions must be established using t he most representative monitoring available for the 2000

- 2004 period

in consultation with EPA.

State R egional H aze Submittal AL SIP Narrative, Page s 9

- 10:

Baseline visibility conditions at the Sipsey Wilderness area are estimated using sampling data collected at the IMPROVE monitoring site. A five year average (2000 to 2004) was calculated for each of the 20% worst and 20% best visibility days in accordance with 40 CFR 51.308(d)(2) and the 2003 EPA Gu idance

. IMPROVE data records for the Sipsey Wilderness for the period 2000 to 2004 meet EPA requirements for data completeness (75% for the year and 50% for each quarter).

Class 1 area Average for

20 percent Worst Days (deciviews) Average for

20 percent Best Days (deciviews) Bext (Mm

- 1)

Average for 20 percent Worst Days Bext (Mm

- 1)

Average for 20 percent Best Days Sipsey Wilderness 29.0 15.6 187.3 48.3 Figure 3. Baseline Visibility Conditions

– Sipsey Wilderness

EPA Findings : EPA proposes to find that Alabama has adequately addressed this provision

.8

III. Evaluation of Regional Haze Submittal

B . Reasonable Progress Goals Development

B.2. Calculations of N atural V isibility C onditions: ((40 CFR 51.308(d)(2)(iii))

For each mandatory Class I Federal area located within the State, natural visibility conditions must be calculated by estimating the degree of visibility impairment existing under natural conditions for the most impaired and least impaired days, based on

a vailable monitoring information and appropriate data analysis techniques as specified in

EPA

- 454/B

- 03

- 005

, Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Program or an approved alternative technique

.

State R egional H aze Subm ittal AL SIP Narrative, Page s 8

- 10:

Natural background visibility, as defined in the 2003 EPA document Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Rule , is based on annual average concentrations of fine particle components. Natural background visibility for the 20% worst days is estimated by assuming that fine particle concentrations for natural background are normally distributed and the 90th percentile of the annual distribution represents natural background visibility on the 20% worst days. The 20% worst and 20% best days for the Sipsey Wilderness can be found in Section 3.0 of Appendix G.

In the 2003 guidance, EPA also provided that states may use a “refined approach” to estimate the values that characterize the natural visibility conditions of the Class I areas. The purpose of such a refinement would be to provide more accurate estimates with changes to the extinction algorithm that may include the concentration values, factors to calculate extinction from a measured particular species and particle size, the extinction coefficients for certain compounds, geographical variation (by altitude) of a fixed value, and the addition of visibility pollutants. In 2005, the IMPROVE Steering Committee made recommendations for a refined equation that modifies the terms of the original equation to account for the most recent data. The choice between use of the old or the new equation for calculating the visibility metrics for each Class I area is made by the state in which the Class I area is

located.

The new IMPROVE equation accounts for the effect of particle size distribution on light extinction efficiency of sulfate, nitrate, and organic carbon. The mass multi plier for organic carbon (particulate organic matter) is increased from 1.4 to 1.8. New terms are added to the equation to account for light extinction by sea salt and light absorption by gaseous nitrogen

dioxide. Site

- specific values are used for Rayleigh scattering to account for the site

- specific effects of elevation and temperature. Separate relative humidity enhancement factors are used for small and large size distributions of ammonium sulfate and ammonium nitrate and for sea salt. The elemental carbo n (light

- absorbing carbon), fine soil, and coarse mass terms do not change between the original and new IMPROVE equation.

The VISTAS states chose to use the new IMPROVE equation as the basis for the conceptual description because it takes into account th e most recent review of the science and because it is recommended by the IMPROVE Steering Committee. For more detailed discussion of the two IMPROVE equations, see Appendix B.9

Class 1 area Average for

20% Worst Days (deciviews) Average for

20% Best Days (deciviews) Average for

20% Worst Days Bext (Mm

- 1) Average for

20% Best Days Bext (Mm

- 1)

Sipsey

Wilderness 10.9 5.0 30. 1 16.6

Figure 4. Natural Background Conditions

- Sipsey Wilderness

EPA Findings : EPA proposes to find that Alabama has adequately addressed this provision and that he natural background conditions that were used in the reasonable progress assessment were developed in an acceptable manner. EPA Region 4 has approved the use of the VISTAS methodology for use of the n ew IMPROVE equatio n. The S tate used the new IMPROVE equation and developed concentrations for each term of the equation consistent with the recommendations and default data from the

IM PROVE Steering Committee. In a September 27 , 2006

, Question and Answer (Q&A) document (u nder Miscellaneous #1), EPA stated that it would approve a state’s use of the new IMPROVE equation for reasonable progress. That specific Q&A suggested that the new equation should be applied consistently in the development of the state’s regional

haze SI P. The State of Alabama used the new IMPROVE equation in the reasonable

progress assessment to develop baseline and natural background conditions and in the BART modeling. The new IMPROVE equation was used in the reasonable progress assessment in developing the baseline and natural background conditions and in the BART modeling. In the BART evaluations, the new IMPROVE equation was used on a

case

- by

- case basis in a hierarchal approach. The equation was only used in the most

refined of modeling for BART. Of the 35 BART

- eligible sources that modeled their impacts at less than 0.5 d eciview , 33 of the demonstrations relied on the old IMPROVE equation. Only two, BP Amoco Chemicals Chemical Lime Co Montevallo, refined their modeling fur ther and relied on the new IMPROVE equation to demonstrate that their impacts were less than 0.5 deciview

.

The concentration data developed for use in the new IMPROVE equation was consistent

with the recommendations of the Natural Haze Levels II Committe e to the RPO Monitoring/Data Analysis Workgroup. Alabama chose to use apply the new IMPROVE equation in a manner that was consistent with that used by the ten VISTAS RPO states in their regional modeling to evaluate reasonable progress with respect to the glidepath.

References use d in the EPA review:

1. Additional Regional Haze Questions, EPA, September 27, 2006 Revision. Answers to questions that PA received from various States and Regional Planning Organizations (RPOs) related to the submission of regional haze SIPs under the program described by 40 CFR 51.308. This document provides gu idance to the10 State air pollution control agencies and the general public on meeting the regional haze SIP requirements.

2. January 18, 2007, e

- mail from Marc Pitchford, NOAA

- Air Resources Laboratory , to Brenda Johnson, EPA. Subject: “Re: December discus sions.”

3. Powerpoint presentation : Natural Haze Levels II: Application of the New IMPROVE Algorithm to Natural Species Concentration Estimates. Final Report of the Natural Haze Levels II Committee to the RPO Monitoring/Data Analysis Workgroup

.11

III. Eval uation of Regional Haze Submittal

B . Reasonable Progress Goals Development

B

. 3. Uniform Rate of Progress (UROP or “Glidepath”) for Reasonable Progress : (40 CFR 51.308(d)(1) and (40 CFR 51.308(d)(1)(i)(B))

For each mandatory Class I Federal area located within the State, the State must establish goals (expressed in deciviews) that provide for reasonable progress towards achieving natural visibility conditions. For each Class I area within the S tate, the S ta te must analyze and determine the rate of progress needed to attain natural visibility conditions by the year 2064 and determine the uniform rate of visibility improvement (measured in deciviews) that would need to be maintained during each implementation period in order to attain natural visibility conditions by 2064. The State must show that the reasonable progress goal for each mandatory Class I Federal area represents at least as much visibility improvement as is expected to result from implementation o f other requirements of the CAA during the applicable planning period. 40 CFR 51.308(d)(1)(vi)

. The reasonable progress goals must provide for an improvement in visibility for the most impaired days over the period of the implementation plan and

ensure n o degradation in visibility for the least impaired days over the same period. Modeling is not used to determine reasonable progress goals and does not determine whether reasonable progress has been met. Modeling is one part of the reasonable

progress an alysis. The modeling results are used to determine if future year visibility at Class I areas are estimated to be on a (glide) path towards reaching natural background. This is called a uniform rate of progress analysis or “glidepath” analysis.

State Regional Haze Submittal AL SIP Narrative, Pages 14

- 16:

The following glidepaths represent the 20% most impaired days for the Sipsey Wilderness, assuming uniform rate of progress toward Regional Haze goals. The first glidepath (Figure 3.1

- 1) represents wor k prior to January 2008. This work was the basis for the majority of the conclusions presented in this SIP. However, the “Best and Final” run, incorporating all final known inventory changes and BART and RP controls, was completed in late January 2008. Thi s run (Figure 3.1

- 2) resulted in new 2018 predictions, and subsequently, revised glidepaths, which are also presented here. Using 2018 Base G2 emissions, the model projected visibility at the Sipsey Wilderness on the 20% worst days would be 23.69 dv. Using 2018 Best and Final emissions, the model projected visibility at the Sipsey Wilderness on the 20% worst days would be 23.53 dv. For the remainder of this narrative, the most recent “Best and Final” glidepaths will be included. Due to the lateness of the f inal run, it was not possible to revise all of the figures and tables in this SIP, including those in the Appendices. For this reason, ADEM has elected to retain the older figures and tables. The differences may be small had they been updated, but ADEM con tends that the results of the Best and Final Runs show a continued improvement over previous runs that would not change any of the conclusions presented. Natural background visibility at the Sipsey Wilderness is predicted to be slightly less than 11 dv (10 .9)

... Note: Method 1 is the EPA method of averaging all 20% worst days in 2002 without consideration of model performance.1 2

EPA Note : In the Alabama submittal, symbols denoting “Method 1” represent the State’s RPG for that area and for that case depicted in the figure (i.e., “best” or “worst” 20 % days).

AL SIP Narrative, Pages 54

- 55, 96:

In addition to improving visibility on the 20% worst visibility days, states are also required to protect visibility on the 20% best days at Class I areas. As illustrat ed in Figure 7.2.4

- 3, visibility on the 20% best days is projected to improve in 2018 at all VISTAS Class I areas as a result of emissions reductions. Specifically, Figure 7.2.4

- 4 demonstrates that no degradation should occur for the Sipsey Wilderness area , and that, in fact, visibility should improve beyond that level.13

AL SIP, Appendix G

, P ages G

- 6

- 10 :

2018 Model Assessment of the Uniform Rate of Progress The purpose of a modeling assessment of the uniform rate of progress is to determine if a proposed control strategy will result in uniform rate of progress being met when measured concentrations of particulate matter are used to estimate visibility impairm ent at some future date. The modeling is applied in a relative sense.

The first step involves determining the 20% best and worst days. This involves developing model projections to rank visibility (in dv) on each day with observed speciated PM

2.5 data for each of the 5 years comprising the baseline period (2000

- 2004) for each Class I area. Day

- specific observations for mass associated with SO 4 , NO 3 , OC, EC, Soil, and CM, should be used to calculate b ext for each day using climatological

relative humidit

y adjustment factor(s) (

f(rh) ). Total b ext

for all components are then converted to dv for each day to obtain a daily dv value.14

The next step is to use base year and future year modeling results to estimate a relative response factor (RRF) for each compon ent of PM 2.5 on the 20% best and 20% worst monitoring days. Simply put, the RRF is the average modeled future year concentration near the monitor divided by the average modeled base year concentration or: Average

Modeled Base Year Concen tration

RRF = Average Modeled Future Year Concentration

To accomplish this step, concentrations for each component of PM 2.5 and coarse matter (the difference between PM 10 and PM

2.5 ) are extracted from the base year and future year modeling output near IMPROVE monitoring sites for the monitored best and worst days. The component concentrations are then averaged to develop base and future year

average component concentrations. The fu ture year average component concentrations are then divided by their respective base year component concentrations to develop RRFs for each component of PM 2.5 and coarse matter.

As an example, consider Table 3.3

- 1, which has all the pertinent data for the SIPS1 IMPROVE monitor. Looking at the top table, the first column identifies the 20% best days identified in Step 1 (Section 3.1). The next six columns have the 12 km modeled

b ase year (2002) concentration values near the monitor corresponding to the 20% best days. The next six columns have the 12 km modeled future year (2018) component concentrations near the monitor for the same set of days. The final six columns contain

the daily RRF values for each component species, which is simply the future concentration divided by the base year concentration. The bottom row of the table contains the average values for the base year components, the future year components, and the RRFs f

or each of the average component values. The bottom table contains the same data for the 20% worst days15

Table 3.3

- 1: Base year concentrations, future year concentrations, and RRF for SIPS1 on the monitored 20% best days (top) and 20% worst days (bottom ), based on 12 km modeling results.

The next step in using model output to estimate future visibility impairment is to multiply the RRFs (determined in the previous step, Section 3.3) by the measured species concentration data during the baseline period (2000

- 2004) for the measured 20% best and 20% worst days. This results in daily future year species concentrations, where base year concentrations, or the current year design value (DVC) is multiplied by the RRF to determine the future design value (i.e. DVF = RRF * DVC). For regional haze, this calculation is performed for each of the best and worst days for the five

- year baseline period (calculated in Step 2, Section 3.2) using an RRF for each PM component, for both16

the best days and the worst days. T his produces future concentration estimates for SO 4
, NO 3 , OC, EC, Soil and CM, for each of the “worst” and “best” visibility days. Once future year concentrations are calculated (Section 3.4) the future daily extinction coefficients (bext) are then calcul ated for the 20% best and 20% worst visibility days in each of the five base years (2000

- 2004). This is achieved by applying the “new” IMPROVE equation:

bext ≈ 2.2 * f

s (RH) * [Small Sulfate] + 4.8 * f L (RH) * [Large Sulfate] + 2.4 * f

s ( RH) * [Small Nitrate] + 5.1 * f L (RH) * [Large Nitrate] + 2.8 * {Small Organic Mass] + 6.1 * [Large Organic Mass] + 10 * [Elemental Carbon] + 1 * [Fine Soil] + 1.7 * f

ss (RH) * [Sea Salt] + 0.6 * [Coarse Mass] + Rayleigh Scattering (site specific)

+ 0 .33 * [NO 2 (ppb)]

Model estimated daily concentrations are used with the corresponding baseline daily relative humidity adjustment factor(s) ( f(rh) ) identified in Step 1 (Section 3.1).

The final step is to calculate daily dv values from the total daily extinction calculated in the previous step then compute the future average mean dv for the best and worst days for each year. The five years are then averaged together to get the final future mean dv value for the best and worst days. The first step in this process is to convert the total daily b ext for each day (calculated in the previous step, Section 3.5) to deciviews (dv). This future year daily dv value for each of the best and worst days is then averaged to determine the future dv value for the be st and worst visibility days for each year. This leads to five future estimated mean dv values for the worst and five future estimated mean dv values for the best visibility days. The five yearly values for the 20% best and 20% worst days are then average d to produce the final future mean dv value, or dv future . Table

3.6

- 1 displays the yearly mean dv value for each year in the baseline period for both the 20% worst days (center column) and the 20% best days (right column). The last row in the table displa ys the final future mean dv value, or dv future

.

Table 3.6

- 1: Yearly daily deciview values and final future mean deciview values (dv future ) for SIPS1 based on 12km modeling results.17

the baseline mean dv (dv baseline ) values calculated in Step 2 (Section 3.2). If the resulting change in dv is a negative number (future

- base), this represents an improvement in visibility. Table 3.6

- 2 summarizes these calculation for the IMPROVE monitor associated with the Sipsey Wilde rness area. As it can be seen, the Sipsey Wilderness area is showing visibility improvement on both the 20% best and 20% worst days.

Table 3.6

- 2: Comparison of future deciview projections for 2018 compared to 2002 baseline deciview estimates for the Sipse y Wilderness.

EPA Findings : EPA proposes to find that Alabama has adequately addressed this provision. The glidepath for the Sipsey area was developed through a technical analysis that was scientifically and meticulously prepared in an open forum for the RPO and stakeholders review and input. Through the application of the modeled LTS, the S tate has demonstrated that progress toward improved visibility and natural conditions on the 20 percent worst and best days will occur.18

III. Evaluation of Regional Haze Submittal C. Long

- Term Strategy C.1. Technical Basis for Strategy (40 CFR 51.308(d)(3)(iii))

The SIP must document the technical basis, including modeling, monitoring and emissions information, on which the State is relying to analyze reg ional haze. Modeling is not used to determine reasonable progress goals and does not determine whether reasonable progress has been met. Modeling is one part of the reasonable progress analysis. The modeling results are used to determine if future year visibility at Class I areas are estimated to be on a (glide) path towards reaching natural background. This is called a uniform rate of progress analysis or “glidepath” analysis. The State may meet this requirement by relying on technical analyses develo ped by the regional planning organization and approved by all State participants.

Modeling is not used to determine reasonable progress goals and does not determine whether reasonable progress has been met. Modeling is one part of the reasonable

progress analysis. The modeling results are used to compare progress made through emission reductions with future year visibility at Class I areas

. Note that the emission inventory requirements under 40 CFR 51.308(d)(4)(v) are addressed in this section.

State R egional Haze Submittal

The following is taken and/or summarized from Alabama’s July 15, 2008, regional haze

SIP submittal:

EPA Note : The RHR requires states to establish RPGs for visibility improvement at each affected Class I area covering each approxi mately 10

- year period until 2064.

Alabama ’s first set of RPGs will comprise LTS covering the period from the present until 2018. Appendix H of the Alabama SIP submittal provides an overview of this first LTS. Alabama’s LTS contains the following componen ts:

I. Inventory of all controls required or expected under all federal and state regulations by 2009 and 2018. These controls are referred to as “on the books” or “on the way” (OTB/OTW). II. Modeled expected visibility improvement from OTB/OTW (Base G) controls and comparison of Base G results for 2018 to the uniform rate of progress, or “glidepath” for the Sipsey Wilderness area. (See also EPA TSD Section III.B.3) III. Discussion of emissions sensitivity model runs to help determine which pollutants

and source categories are contributing the most to visibility impairment at Class I areas (runs conducted by the Georgia Institute of Technology).

IV. Examination of SO 2 Area of Influence (A O Is) projections for the Sipsey Wilderness area, and also for any surrounding states’ Class I areas whose AoI includes any Alabama sources, to determine which specific sources are most likely to be impairing visibility. V. Application of the four “statutory factors,” listed in 40 CFR 51 .308(d)(1)(i)(A) to those sources identified in the previous step. (See also EPA TSD Section III.C.3)19

VI. Using the results of the four factor analyses, identification of control determinations for specific sources.

VII. Identification of BART

- eligible s ources. (See also EPA TSD Section III.D.1 ) VIII. BART exemption modeling for BART

- eligible sources. (See also EPA TSD

Section III.D.2 ) IX. BART determinations for sources subject to BART. ( See also EPA TSD Section III.D.3) X. Modeling demonstration of visi bility improvement after inclusion of BART and reasonable progress control determinations. XI. Determination of RPGs based on the visibility improvement expected by 2018.

Excerpted from AL SIP Narrative Pages 22

- 30 :

5.1 Analysis Methods

The modeling analysis is a complex technical evaluation that begins by selection of the modeling system. VISTAS decided to use the following modeling systems: Meteorological Model: The Pennsylvania State University/National Center for Atmospheric Research (PSU/NCAR) M esoscale Meteorological Model (MM5) is a nonhydrostatic, prognostic meteorological model routinely used for Urban and Regional scale photochemical, fine particulate matter, and Regional Haze regulatory modeling

studies. Emissions Model: The Sparse Matrix Operator Kernel Emissions (SMOKE) modeling system is an emissions modeling system that generates hourly gridded speciated emission Air Quality Model: EPA‟s Models

- 3/Community Multiscale Air Quality (CMAQ) modeling system is an „One

- Atmosphere‟ photochemi cal grid model capable of addressing ozone, particulate matter (PM), visibility and acid deposition at Regional scales for periods

up to one year.

EPA Modeling Guidance recommends modeling an entire year or, at a minimum, several days in each quarter of a year to adequately represent the range of meteorological conditions that contribute to elevated levels of fine particulate matter. The year 2002 wa s selected by VISTAS as the modeling year for this demonstration. Meteorological inputs were developed for 2002 using MM5. Emission inventories were also developed for 2002 and processed through SMOKE. These inputs were used in the air quality model to pre dict fine particle mass and visibility. The model results for 2002 were compared with observed meteorological and air quality data to evaluate model performance. Several configurations of the meteorological and air quality model were evaluated to select a configuration that gave the best overall performance for the VISTAS region.

Once model performance was deemed acceptable, the current and future year emissions were processed through the emissions model. The air quality modeling results are used to determine a relative reduction in future visibility impairment, which is used to

de termine reasonable progress.

The complete modeling protocol used for this analysis can be found in Appendix C.

..... 5.4.1 Horizontal Modeling Domain20

EPA‟s modeling guidance recommends a 12

- km modeling grid resolution for PM 2.5 modeling

while a 36

- km gr id is considered acceptable for Regional Haze. For the VISTAS modeling, a

coarse 36

- km grid resolution was used for modeling the entire U.S. and a finer 12

- km grid

was used to model the eastern U.S. The CMAQ model was run in one

- way nested grid mode. This allowed the larger outer domains to feed concentration data to the inner nested domain. Two

- way nesting was not considered due to the numerical and computational uncertainty associated with the technique. The horizontal coarse grid modeling domain bounda ries were determined through a national effort to develop a common grid projection and boundary. A smaller 12

- km grid modeling domain was selected in an attempt to balance location of areas of interest, such as ozone and fine particulate matter nonattainme nt areas, as well as Class I areas for Regional Haze. Processing time was also a factor in choosing a smaller 12

- km grid modeling domain.

The coarse 36

- km horizontal grid domain covers the continental U.S. This domain was used as the outer grid domain for MM5 modeling with the CMAQ domain nested within the MM5 domain. Figure 5.4.1

- 1 shows the MM5 horizontal domain as the outer most, blue grid with the CMAQ 36

- km domain nested in the MM5 domain. Figure 5.4.1

- 2 shows the 12

- km grid, modeling domain for the V ISTAS region.

Figure 5.4.1

- 1. The MM5 horizontal domain is the outer most, blue grid, with the CMAQ 36

- km domain nested in the MM5 domain.21

Figure 5.4.1

- 2. A more detailed view of the 12

- km grid over the VISTAS region.

Care was taken in the selection of the modeling system used to develop the long

- term strategy. The VISTAS states tried to ensure that the models selected were scientifically appropriate for the intended application and be freely accessible to all stakehol ders. Scientifically appropriate means that the models address important physical and chemical phenomena in sufficient detail, using peer

- reviewed methods. Freely accessible means that model formulations and coding are freely available for review and tha t the

models are available to stakeholders, and their consultants, for execution and verification at no or low cost. These criteria were used in selecting the modeling system and are documented on pages 22

- 30 of the SIP Narrative.

EPA Modeling Guidance r ecommends modeling an entire year or, at a minimum, several days in each quarter of a year to adequately represent the range of meteorological conditions that contribute to elevated levels of fine particulate matter. The year 2002 was selected by VISTAS as the modeling year for this demonstration. Meteorological inputs were developed for 2002 using MM5. Emission inventories were also developed for 2002 and processed through SMOKE. These inputs were used in the air quality model to predict fine particle mass and visibility. The model results for 2002 were compared with observed meteorological and air quality data to evaluate model performance. Several configurations of the meteorological and air quality model were evaluated to select a configuration that gave the best overall performance for the VISTAS region.

Emissions Controls Modele d ( AL SIP Narrative, Starting at P age 46 )

7.2 Expected Visibility Results in 2018 for the Sipsey Wilderness Area under Existing

and Planned Emissions Controls

There are sign ificant control programs being implemented both nationally as well as across the southeast between the baseline period and 2018. These programs are described in more detail below. The impact of programs such as the Clean Air Interstate Rule (CAIR) and the NOx SIP Call will be realized regionally. The implementation of22

these programs in Alabama will significantly reduce emissions of sources not only within the state that these reductions occur, but these reductions will also improve visibility at surrounding Class I areas outside Alabama. A case in point is Table 7.6

- 1 that clearly illustrates that overwhelmingly Alabama sources impact the Sipsey Wilderness area. These programs will surely benefit visibility and air quality in Alabama.

7.2.1 Federal and Sta te Control Requirements

CAIR

. CAIR will permanently cap emissions of SO2 and NOx from EGUs in the eastern United States by 2015. When fully implemented, CAIR will reduce SO2 emissions from EGUs in these states by more than 70%, and NOx emissions by more than 60%, from

2003 levels.

NOx SIP Call . Phase I of the NOx SIP call applies to certain EGUs and large non

- EGUs, including large industrial boilers and turbines, and cement kilns. Those states affected by

the NOx SIP call in the VISTAS region, including Alabama, have developed rules for the control of NOx emissions that have been approved by EPA. The NOx SIP Call has resulted in a 68% reduction in NOx emissions from large stationary combustion sources in Alabama. For this analysis, emis sions were capped for NOx SIP call

- affected sources at 2007 levels, and carried forward for the 2009 and 2018 future year inventories.

North Carolina CSA . Under the Act, enacted in 2002, coal

- fired power plants in North

Carolina must achieve a 77% cut in NOx emissions by 2009 and a 73% cut in SO2 emissions by 2013. This legislation establishes annual caps on both SO2 and NOx emissions for the two primary utility companies in North Carolina, Duke Energy and Progress Energy. These reductions must be made in North Carolina, and allowances are

not saleable. Consent Agreements (TECO, VEPCO, Gulf Power Crist 7, Santee Cooper, EKPC and APCO Plant Miller). Under a settlement agreement, by 2008, Tampa Electric Company will install permanent emissions

- control equip ment to meet stringent pollution limits; implement a series of interim pollution reduction measures to reduce emissions while the permanent controls are designed and installed; and retire pollution emission allowances that Tampa

Electric or others could us e, or sell to others, to emit additional NOx, SO2, and PM.

• Virginia Electric and Power Co. (VEPCO) agreed to spend $1.2 billion by 2013 to eliminate 237,000 tons of SO2 and NOx emissions each year from eight coal

- fired electricity generating plants in Virginia and West Virginia. VEPCO has installed the following controls/fuel switches already. o Chesterfield Power Station:

Unit #4

- SCR by 01/01/13;

Unit #5

- SCR by 01/01/12; Unit #6 SCR by 01/01/11 & FGD by 01/01/10 o Chesapeake Power Station:

Unit #3

- SCR by 01/01/13;

Unit #4

- SCR by 01/01/13

o Clover Power Station: Unit #1 and Unit #2: Upgrade of the existing FGD to meet 95% removal.23 o Possum Point Power Station Unit #3 and Unit #4: Conversion of these coal fired units to natural gas. Coal fired operations must cease by 5/1/13. • A 2002 voluntary agreement calls for Gulf Power to upgrade its operation to cut NOx emission rates by 61% at its Crist generating plant by 2007, with major reductions beginning in early 2005. The Crist plant is a s ignificant source of NOx emissions in the Pensacola, Florida area. • A 2004 consent agreement calls for Santee Cooper to install and commence operation of continuous emissions control equipment for PM/SO2/NOx emissions; comply with system

- wide annual PM/S O2/NOx emissions limits; agree not to buy, sell or trade PM/SO2/NOx allowances allocated to Santee Cooper System as a result of said agreement; and to comply with emission unit limits of said agreement. Specific plants/units were not identified in the cons ent agreement. • A July 2, 2007 consent agreement between the U.S. EPA and East Kentucky Power Cooperative (EKPC) requires the utility to reduce its emissions by 62,000 tpy (including 54,000 tons of SO2 and 8,000 tons of NOx) by installing/operating selec tive catalytic reduction (SCR) technology; low

- NOx burners, and PM and Mercury Continuous Emissions Monitoring at the utility‟s Spurlock, Dale and Cooper Plants. According to EPA, the plant‟s total emissions will drop from between 50

– 75% from

2005 levels . As with all Federal Consent Decrees, EKPC is precluded from using reductions required under other programs, such as the Clean Air Interstate Rule (CAIR). EKPC is expected to spend over $600 million on pollution controls. o FGD controls for EKPC Spurlock Units 1 and 2 o EKPC Cooper Unit 2 • Alabama Power Company

– Plant Miller (Jefferson County) On April 25, 2006, the U.S. EPA and the Department of Justice announced a settlement with Alabama Power Company (APC) to reduce emissions of sulfur dioxide (SO2 ) and nitrogen oxides (NOx) from Boiler Units 3 and 4 at its Plant Miller in Quinton, Alabama. The plant is required to reduce SO2 by installing flue gas desulfurization (FGD) and is required to reduce NOx by installing selective catalytic reduction (SCR) equipment. The Consent Decree requires APC to commence continuous year

- round operation of SCR equipment for control of NOx emissions by May 1, 2008. APC is also required to begin year

- round operation of the FGD equipment for control of SO2 emissions by Dec ember 31, 2011. The installation and operation of these controls are expected to result in the reduction of 4,953 tons per year of NOx and 22,788 tons per year of SO2. APC is also required to install and operate by December 31, 2008, a mercury continuous e mission monitoring system. APC is precluded from using the emissions reductions required under other programs, such as the Clean Air Interstate Rule (CAIR). In addition, the Consent Decree requires APC to purchase and permanently retire $4.9 million worth of 2007 SO2 emissions allowances. Cargill, Inc. Consent Decree On March 3, 2006, the Federal District Court in Minnesota entered a Consent Decree between Cargill, Incorporated, U.S. EPA, the Iowa Department of Natural Resources and other participating ag encies. Under this agreement, Cargill shall implement a program of enforceable emissions reductions of SO2, CO, NOx, and VOCs from its corn processing and oilseed processing plants of at least 40,000 tons per year. This includes a reduction of SO2 of 15,00 0 tons per year, CO of 16,000 tons per year, NOx of 2,500 tons24

per year, and VOCs of 6,500

- 11,500 tons per year. The Consent Decree requires permit applications to be submitted within three years from entry of the Consent Decree (March 3, 2009) containing annual limits for boilers and facilities in Appendix B of the Consent Decree, which includes Cargill Sweeteners, to less than 15,355 tons per year on a 12

- month rolling sum. This represents a reduction of 15,067 tons of SO2 per year from the

current allowa ble emissions from these sources. Also, Cargill is required submit a permit application within three years from entry of the Consent Decree that will include individual emission limits for boilers at various facilities, including the Cargill

Sweeteners Sto ker Coal

-

fired boiler, (which was evaluated for reasonable progress (RP)) that in aggregate will not exceed a capacity weighted average SO2 emission rate of 1.2 lb/MMBtu. The Cargill Sweetners Decatur Facility is required by 3/3/09 to control and comply wi th SO2 emissions limitations for its coil fired boilers.

One

- hour Ozone SIPs (Atlanta / Birmingham / Northern Kentucky). SIPs have been submitted to EPA to demonstrate attainment of the one

- hour ozone National Ambient Air Quality Standard (NAAQS). These S IPs require NOx reductions from specific coal fired power plants and address transportation plans in these cities. Heavy Duty Diesel (2007) Engine Standard (for onroad trucks and buses). EPA set a PM emissions standard for new heavy

- duty engines of 0.01 g rams per brake

- horsepower

hour (g/bhp

- hr), to take full effect for diesel engines in the 2007 model year. This rule also includes standards for NOx and non

- methane hydrocarbons (NMHC) of 0.20 g/bhp

hr and 0.14 g/bhp

- hr, respectively. These NOx and NMHC sta ndards will be phased in together between 2007 and 2010, for diesel engines. Sulfur in diesel fuel must be lowered to enable modern pollution

- control technology to be effective on these trucks and buses. EPA will require a 97% reduction in the sulfur conte nt of highway diesel fuel from its current level of 500 parts per million (low sulfur diesel, or LSD) to 15 parts per million (ultra

- low sulfur diesel, or ULSD). Tier 2 Tailpipe (Onroad vehicles) . EPA Mobile rules include the Tier 2 fleet averaging

progra m, modeled after the California LEV II standards. Manufacturers can produce vehicles with emissions ranging from relatively dirty to zero, but the mix of vehicles a manufacturer sells each year must have average NOx emissions below a specified value.

Tier 2 standards became effective in the 2005 model year. Large Spark Ignition and Recreational Vehicle Rule . EPA has adopted new standards for emissions of oxides of nitrogen (NOx), hydrocarbons (HC), and carbon monoxide (CO) from several groups of previously unregulated nonroad engines. Included in these are large industrial spark

- ignition engines and recreational vehicles. Nonroad spark

- ignition engines are those powered by gasoline, liquid propane gas, or compressed natural gas rated over 19 kilowatts (kW) (25 horsepower). These engines are used in commercial and industrial applications, including forklifts, electric generators, airport baggage transport vehicles, and a variety of farm and construction applications. Nonroad recreational

vehicles include snow mobiles, off highway motorcycles, and all terrain

- vehicles. These rules were initially effective in 2004 and will be fully phased in by 2012.

Nonroad Diesel Rule . This rule sets standards that will reduce emissions by more than 90% from nonroad diesel equ ipment, and reduce sulfur levels by 99% from current levels in nonroad diesel fuel starting in 2007. This rule will apply to most nonroad diesel fuel in 2010 and to fuel used in locomotives and marine vessels in 2012.25

Combustion Turbine MACT . The projecti on inventories do not include the NOx co

- benefit effects of the MACT regulations for Gas Turbines or stationary Reciprocating Internal Combustion Engines, which EPA estimates to be small compared to the overall inventory.

VOC 2

- , 4

- , 7

- , and 10

- year MACT Standards . Various point source MACTs and associated emission reductions were implemented. Reductions occurring before 2002

were not considered.

Sources and Pollutants relied on for LTS ( AL SIP Narrative, Pages 58

- 61 )

An important step toward identifying further reasonable progress measures is to identify the key pollutants contributing to visibility impairment at the Sipsey Wilderness area. To understand the relative benefit of further reducing emissions from different pollutants, source sectors, and geographic areas, VISTAS engaged the Georgia Institute of Technology to perform emission sensitivity model runs using CMAQ. Emissions sensitivities were initially performed for three episodes representing winter and summer conditions: January 2002, July 2001, and July 2002. These runs used the initial 2018 projection inventory and considered 30% reductions from specific pollutants, source categories, and geographic areas. Emissions sensitivities were repeated using the 2009 Base D projection inventory and two month

- long episodes from 2002:

SO2 from EGU sources in each VISTAS state, other RPOs in the VISTAS 12 km grid, and Boundary Conditions from outside the 12 km domain. SO2 from non

- EGU point sources in each VISTAS state, other RPOs, and Boundary Conditions NOx from ground level sources (on

- road plus off

- road plus area) in each VISTAS state and other RPOs. In the VISTAS states, these reductions were only applied to specific counties that were of concern for 8

- hour ozone no nattainment. NOx from point (EGU plus non

- EGU) sources in each VISTAS state and other

RPOs NH3 from all sources in VISTAS and other RPOs Volatile Organic Compounds from anthropogenic and biogenic sources in the 12 km modeling domain Primary Carbon from all ground level sources in each VISTAS state and other RPOs. In the VISTAS states, these reductions were only applied to specific counties that were of concern for PM2.5 nonattainment. Primary Carbon from all point sources in each VISTAS state and other RPO s Primary Carbon from all fires in each VISTAS state and other RPOs

.....

As Figure 7.4

- 1 shows, the greatest visibility benefits on the 20% worst days for the Sipsey Wilderness area are projected to result from further reducing SO2 from EGUs.

Reductions in SO2 from Alabama‟s EGUs would have the greatest benefit; contributions from other VISTAS states, other RPOs and from the boundary conditions are smaller but not insignificant. Additionally, smaller benefits are projected from additional SO2

emission reduc tions from non

- utility, industrial point sources.26

.... The results indicate that sulfate is the dominant contributor to visibility impairment on the 20% worst days at all sites, and that ammonium nitrate may be important for sites where the 20% worst days occur in the winter. It can be concluded that reducing SO2 emissions from EGU and non

- EGU point sources in the VISTAS states would have the greatest visibility benefits for the Sipsey Wilderness area.

Model Performance Evaluation ( AL SIP Narrative, P ages 30

- 45)

The initial modeling effort focused on evaluating previous regional air quality modeling applications and testing candidate model configurations for the SMOKE emissions and CMAQ model for the VISTAS 36

- km and 12

- km modeling domains. This effort res ulted

in a report recommending the model configuration for the annual emissions and air quality modeling, which is included as part of the VISTAS Emissions and Air Quality Modeling Protocol. The evaluation of the meteorological modeling configuration can be found in Appendix E, with a summary of the final meteorological and air quality modeling configuration in the modeling protocol contained in Appendix E and Appendix C, respectively.

Air quality model performance for the 2002 modeling year was initially tested in 2004 using an early version of the VISTAS emissions inventory. In keeping with the one

atmosphere objective of the CMAQ modeling platform, model performance was evaluated based on measured ozone, fine particles, and acid deposition in the Air Quality

S ystem (AQS), IMPROVE, Speciated Trends Network (STN), Southeastern Aerosol Research and Characterization (SEARCH), National Acid Deposition Program (NADP) and Clean Air Status and Trends Network (CASTNet) monitoring networks

.... The air quality model‟s performance was evaluated with respect to individual components of fine particulate matter (PM 2.5 ), as good model performance of the component species will dictate good model performance of total or reconstituted fine particulate matter. Model performance of the total fine particulate matter and the resulting total light extinction was also provided as a means to discuss the overall model performance for the SIP.

The soccer and bugle plots for the all of the VISTAS IMPROVE monitors are included here for summary purposes. The goal and criteria levels used for regional haze model performance were 30% and 60%, respectively, for mean fractional bias and 50% and 75%, respectively, for mean fractional error. Plots were presented for the average monthly conce ntrations and the performance statistics for all of the most significant light scattering component species (Sulfate, Nitrate, and Organic Carbon) for the 20% best days and 20% worst days. Plots for individual IMPROVE monitors associated with the

Alabama Class I area are included in Appendix N.

The soccer plots of monthly concentrations (Figures. 6.2

- 1 and 6.2

- 2) show that values for nitrate generally fall outside of criteria performance thresholds (red box). Sulfates and organic carbon generally fall wit hin goal thresholds (green box), with a couple of27

months falling just outside the goal thresholds but well within the criteria thresholds. In these figures, each point represents a month. Figure 6.2

- 3 contains separate soccer plots for each season. The seasonal plots emphasize poorer nitrate performance in the summer (does not even appear on the plots provided because performance is off scale with other constituents), when observed nitrate is quite low and predicted nitrate is even

lower. When concentra tion is factored into performance criteria, nitrate performance improves with respect to mean fractional bias and mean fractional error (Figures 6.2

- 4

and 6.2

- 5)

Additionally, performance assessed at the “one atmosphere” level was also deemed acceptable for ozone and particulate matter at various monitoring sites (STN, FRM,

CASTN et , etc.). Overall, VISTAS found the Base G2 modeling results to be representative and acceptable for use in modeling projection for ozone, particulate matter, and regional haze

.

....

Comparing the 20 percent best day chart to the 20 percent worst days chart, illustrates that the various components of particle pollution play a more prominent role in the 20 percent best days than with the 20 percent worst days. Also, the species ma ke

- up on the 20 percent best days varies more widely compared to the 20 percent worst days. This suggests accurately modeling each species is especially important on the 20 percent best days.28

Overall, ADEM found that model performance fell within the accepted limits. As such, ADEM contends that the one atmosphere modeling performed by the VISTAS contractors is representative of conditions in Alabama and across the southeastern states and is

app licable for use as the basis for this SIP. Additional information on model performance across the VISTAS region, including the Sipsey Wilderness can be found in Appendix N.

Model Performance Improvements through Emissions Inventory Improvements ( AL

SIP N arrative, Page 21)

Since the initial model performance evaluation, VISTAS has made several improvements to the emissions inventory, which in turn improves model performance. These inventory improvements are detailed in the VISTAS emissions inventory repor t and in Appendix D,
and are summarized here:

-- For electric generating utilities (EGUs), the Integrated Planning Model (IPM) was used to provide estimates of future year utility production and emissions. Continuous Emissions Monitoring (CEM) data was u sed to define seasonal variability in production and emissions. For Base G2 emissions, states updated IPM model projections from 2005 with control data provided by utility companies in 2006 through early 2007.

-- For on

- road vehicle emissions, agencies provided updated MOBILE model input and VMT data.

-- For ammonia emissions from agricultural sources, the Carnegie Mellon University ammonia model was used to improve annual and monthly estimates.29 -- For fires, the VISTAS states provided fire activity data for 2002 for wildfires, prescribed fire, land clearing and agricultural burning and MACTEC developed a 2002 fire inventory. Where data allowed, Alpine Geophysics modeled fire events as point sources. In 2006, t he U.S. Forest Service and Fish and Wildlife Service provided projections of increased prescribed burning in 2009 and 2018; these data were incorporated in the Base G inventory for all states except Florida.

-- For non

- road engines, the updated EPA NONROA D2005 emissions model was

used in Base G.

-- For commercial marine emissions in shipping lanes in the Gulf of Mexico and Atlantic Oceans, ENVIRON created gridded emissions for the VISTAS modeling domain using inventory data newly developed for EPA by Corb ett at the University of Delaware. These emissions were incorporated in the Base G modeling.

-- Updated inventories from the neighboring RPOs, Mexico, and Canada were incorporated as available.

EPA Note : More detailed discussions of the modeling protoco l, quality assurance report, procedures, models and data used in the regional haze analysis can be found in Appendices C, E, F and G. The archival and acquisition of data and modeling input and output files are discussed in Appendix I.

EPA Findings : In accordance with 40 CFR 51.308(d)(3), the State of Alabama provided the appropriate supporting documentation for all required analyses used to determine the

State’s LTS. EPA believes that t he technical analyses and modeling to assess uniform rate of progr ess and to support the LTS were successfully developed consistent with EPA’s interim and final modeling guidance. EPA proposes to accept the VISTAS technical modeling to support the LTS and determine visibility improvement for uniform rate of progress bec ause the modeling system was chosen and simulated according to EPA modeling guidance

. EPA proposes to agree with the VISTAS model performance procedures and results, and that the CMAQ is an appropriate tool for the regional haze

assessments for the Alabam a LTS and r egional h aze SIP.

CAIR is also an element of Alabama’s LTS. CAIR rule revisions were approved into the

Alabama SIP in 2007

. See 72 FR 55659 (Oct. 1, 2007). Alabama opted to rely on CAIR emission reduction requirements to satisfy the BART r equirements for SO 2 and NO X from EGUs. See 40 CFR 51.308(e)( 4). Therefore, Alabama only required its BART

eligible EGUs to evaluate PM emissions for determining whether they are subject to BART, and if applicable, for performing a BART control assessment. Additionally,

Alabama concluded that no additional control s beyond CAIR are reasonable for reasonable progress for SO 2 for its EGUs for this first implementation period.

Prior to the remand of CAIR, EPA believed the State’s reliance on CAIR for specific BART and reasonable progress provisions affecting its EGU s was adequate. The regional haze provisions specify that a state may not adopt a RPG that represents less visibility improvement than is expected to result from other CAA requirements during the30

planning period (40 CFR 51.308(d)(1)(vi)). As such, Alabam a took into account emissions reductions anticipated from the CAIR in determining its 2018 RPGs.

The RHR allows states to implement an alternative program in lieu of BART so long as the alternative program can be demonstrated to achieve greater reasonab le progress toward the national visibility goal than would BART. Under regulations issued in 2005 revising the regional haze program, EPA made just such a demonstration for CAIR. See 70 FR 39104 (July 6, 2005). EPA’s regulations provide that states part icipating in the CAIR cap

- and trade program under 40 CFR part 96 pursuant to an EPA

- approved CAIR SIP or which remain subject to the CAIR Federal Implementation Plan in 40 CFR part 97

need not require affected BART

- eligible electrical generating (EGUs) to install, operate,

and maintain BART for emissions of SO 2 and NOx. See 40 CFR 51.308(e)(4). Because CAIR did not address direct emissions of PM, states were still required to conduct a BART analysis for PM emissions from EGUs subject to BART for that poll utant. Challenges to CAIR, however, resulted in the remand of the rule to EPA. See North

Carolina v. EPA , 550 F.3d 1175 (D.C. Cir. 2008).

EPA issued a new rule in 2011 to address the interstate transport of NOx and SO 2 in the

eastern United States. S ee 76 FR 48208 (August 8, 2011) (“the Transport Rule,” also

known as the Cross

- State Air Pollution Rule). On December 30, 2011, EPA proposed to find that the trading programs in the Transport Rule would achieve greater reasonable progress towards the national goal than would BART in the states in which the Transport Rule applies. See 76 FR 82219. Based on this proposed finding, EPA also proposed to revise the RHR to allow states to substitute part icipation in the trading programs under the Transport Rule for source

- specific BART. EPA has not yet taken final action on that rule. Also on December 30, 2011, the D.C. Circuit issued an order addressing the status of the Transport Rule and CAIR in resp onse to motions filed by numerous parties seeking a stay of the Transport Rule pending judicial review. In that order, the D.C. Circuit stayed the Transport Rule pending the court’s resolutions of the petitions for review of

that rule in EME Homer Generat ion, L.P. v. EPA (No. 11

- 1302 and consolidated cases). The court also indicated that EPA is expected to continue to administer CAIR in the interim until the court rules on the petitions for review of the Transport Rule.

In a separate action, EPA has proposed a limited disapproval of the Alabama regional haze SIP because of deficiencies in the State’s regional haze SIP submittal arising from the State’s reliance on CAIR to meet certain regional haze requirements. See 76 FR 82219 (December 30, 2011 ). EPA is not proposing to take action in this rulemaking on issues associated with Alabama’s reliance on CAIR in its regional haze SIP.

Also, on July 30, 2007, the D.C. Circuit mandated the vacatur and remand of the Industrial Boiler MACT Rule. Notwithstanding the vacatur of this rule, the VISTAS states, including Alabama , decided to leave these controls in the modeling for their regional haze SIPs since it is believed that by 2018, EPA will have r e

- promulgated an industrial boiler MACT rule or the states will have addressed the issue through state

- level

case

- by

- case MACT reviews in accordance with section 112(j) of the CAA.31

EPA proposes to find this approach acceptable for the following reasons. Effective July 30, 2007, the D.C. Circuit mandated the vacatur and remand of the Industrial Boiler

MACT Rule. 1 This MACT was vacated since it was directly affected by the vacatur and

remand of the Commercial and Industrial Solid Waste Incinerator Defini tion Rule. EPA proposed a new Industrial Boiler MACT rule to address the vacatur on June 4, 2010, (75 FR 32006) and issued a final rule on March 21, 2011 (76 FR 15608). The VISTAS modeling included emissions reductions from the vacated Industrial Boiler MACT rule, and Alabama did not redo its modeling analysis when the rule was re

- issued. Even though the State’s modeling is based on the vacated Industrial Boiler MACT limits,

Alabam a’s modeling conclusions are unlikely to be affected because the expected

reductions due to the vacated rule were relatively small compared to the State’s total SO 2 , PM 2.5 , and coarse particulate matter (PM 10 ) emissions in 2018 ( i.e., 0.2 to 0.5 percent,

d epending on the pollutant, of the projected 2018 SO 2 , PM 2.5 , and PM 10 inventory ). Thus, EPA does not expect that differences between the vacated and final Industrial Boiler MACT emission limits would affect the adequacy of the existing Alabama regional ha ze SIP. If there is a need to address discrepancies between projected

emissions reductions from the vacated Industrial Boiler MACT and the Industrial Boiler MACT issued on March 21, 2011 (76 FR 15608), EPA expects Alabama to do so in the
State’s five

- year progress report.

References used in the EPA review:

1. EPA’s Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone, PM2.5, and Regional Haze. Located at
http://www.epa.gov/scram001/guidance/guide/final

- 03

- pm

- rh

- guidance.pdf ( EPA

- 454/B

07

- 002 ), April 2007.

2. “(Draft) Guidance for Demonstrating Attainment of Air Quality Goals for PM2.5 and Regional Haze”, EPA, 2001. ht tp://www.epa.gov/ttn/scram/guidance_sip.htm.

3. 2002 Base Year Emission Inventory SIP Planning: 8

- hr Ozone , PM2.5 and Regional

Haze

, EPA memorandum from Lydia Wegman to Peter Tsirigotis, November 18,

2002.

4. CAA §§112(j)(2), (3), (5), and (6).

5. CAA §505 specifies procedures for notification to the Administrator and affected

States.

1 See NRDC v. EPA , 489 F.3d 1250 (D.C. Cir. 2007).32

III. Evaluation of Regional Haze Submittal C. Long

- Term Strategy

C.2. Identification of Sources and Factors to be Considered for Reasonable Progress: (40 CFR 51.308(d)(3)( iv

- v))

The State must identify all anthropogenic sources of visibility impairment considered by the State in developing its long

- term strategy. The State should consider major and minor stationary sources, mobile sources, and area sources. The State must consider , at a minimum, the following factors in developing its long

- term strategy: (A) emission reductions due to ongoing air pollution control programs, including measures to address reasonably attributable visibility impairment; (B) m easures to mitigate the imp acts of construction activities; (C) e missions limitations and schedules for compliance to achieve the reasonable progress goal; (D) source retirement and replacement schedules; (E) smoke management techniques for agricultural and forestry management purpo ses including plans as currently exist within the State for these purposes; measures to mitigate the impacts of construction activities; (F) enforceability of emission limitations and control measures; and the (G) anticipated net effect on visibility due t o projected changes in point, area, and mobile source emissions over the period.

State Regional Haze Submittal AL SIP Narrative, Pages 78

- 81:

ADEM’s Process on Reasonable Progress Assessment Step 1: Determine pollutants of concern. VISTAS evaluated the species contribution on the 20% worst visibility days and concluded that sulfate accounted for the greatest contribution of visibility impairing pollution. The VISTAS states concluded that controlling SO2 emissions was the appropriate step in addressing the reasonable progress assessment for 2018. The findings were consistent with the findings of SAMI where it was confirmed that sulfate particles account for the greatest portion of the haze affecting Class I areas in the Southern Appala chian region and that these sulfates were produced in large part from SO2 emissions from coal combustion.

Step 2: Determine which source sectors should be evaluated for reasonable progress

. Since SO2 point source emissions in 2018 are projected to repre sent the majority of the total SO2 emissions inventory, the VISTAS states concluded that the focus should be on electric generating unit (EGU) and non

- EGU point sources of SO2 emissions.

Step 3: Determine if the Clean Air Interstate Rule (CAIR) is suffic ient for reasonable

progress. “In determining the emissions and visibility improvement achieved during each implementation period, states should include all air quality improvements that will be achieved by other programs and activities under the CAA and any state air pollution control requirements” (64 FR 35733). In keeping with this recommendation, Alabama, as part of its long term reasonable progress analysis to consider potential sources33

contributing to visibility impairment, examined other CAA require ments such as CAIR. ADEM evaluated the amount of expected SO2 reduction from EGUs due to CAIR. Since the EGUs will be reducing their SO2 emissions by approximately 70% through these programs, ADEM concluded that additional EGU control during this time peri od (between present and 2018) was not reasonable.

The preceding section (Section 7.6) discusses a general four factor analysis for coal fired units. Additionally, for EGUs subject to CAIR, EPA evaluated a number of factors, including the cost of complian ce and time necessary for compliance. In the CAIR rule, EPA determined "that the earliest reasonable deadline for compliance with the final highly cost effective control levels for reducing emissions was 2015..." (70 FR 25197

- 25198, May 12, 2005) The State believes the cost of compliance and time necessary for compliance are the dominant factors for determining if additional reductions would be reasonable from CAIR subject EGUs. Based on the detailed analyses in the May 12, 2005, CAIR rule, the State conclu des that CAIR controls satisfy reasonable progress for SO2 for the first planning period ending in 2018.

Under the Rule, each “state must identify the uniform rate of progress over the 60 year period that would be needed to attain natural background cond itions by the year 2064” (64 FR 35732). To calculate the rate of progress represented by each reasonable progress goal, Alabama compared baseline visibility conditions to natural visibility conditions at the Sipsey Wilderness area and determined the unifor m rate of visibility (in dv) that would need to be maintained during each implementation period in order to attain natural visibility conditions by 2064. SO2 emissions reductions that are predicted by the IPM to meet the CAIR requirements are not certain d ue to the current rule‟s reliance on trading and the use of banked Title IV allowances. ADEM intends to review the SO2 reductions from CAIR at the time of the periodic report in 2012 to ensure that the reductions are in fact taking place. Based on the cont rols predicted by IPM under CAIR, ADEM has concluded that, at this time, these existing regulatory programs constitute reasonable measures for Alabama‟s EGUs during this first assessment period (baseline to 2018). It is important to note that the IPM model was used extensively by EPA when performing analyses for CAIR.

Step 4: Determine which emission units would be evaluated based on impact. ADEM calculated the fractional contribution from all emission units within the SO2 AoI for a given Class I area an d identified those emission units with a contribution of 1% or more to the visibility impairment at that Class I area. ADEM recognized that there was neither sufficient time nor resources available to evaluate all units within a given AoI. Therefore, a th reshold needed to be established to determine which units would be evaluated. ADEM chose to adopt 1% as the contribution threshold used to consider a source for a four factor analysis of reasonable further controls based on the precedence established in ot her Federal programs that used an equal to or higher threshold for evaluation (For a full explanation of the rationale behind the selection of the 1% threshold, please refer to Appendix H, Section 5.0). These programs are listed below:34 The BART rule specif

ied that a maximum impact of 0.5 dv is an acceptable threshold for establishing source contribution. This threshold is representative of a 5% change in visible perception. The NOx SIP call established a significance level for 126 petitions (the level at

w hich a state‟s contribution to another state‟s ozone was considered significant) at 4 parts per billion. This threshold is representative of approximately 3.2% of the 1 hour ozone standard of 125 parts per billion, which was the standard at the

time. The CAIR rule established a PM contribution threshold of 0.2 μg/m3 as significant. This threshold represents 1.3% of the Annual PM2.5 standard of 15 μg/m3. The NAAQS assign significant impact levels for human health standards based on
a source‟s contribut ion to air quality. These significance levels represent a percentage of the NAAQS. Those facilities able to demonstrate that a new or modified source‟s contribution is less than a particular significance level is relieved of further modeling. ADEM examined all the averaging periods for the criteria pollutants and determined that the 1% threshold contribution chosen for reasonable progress was as stringent as any significant impact level, the most restrictive being NO2 at 1 μg/m3 or 1%. (NO2 NAAQS: 100 μg/m3 )

For the Sipsey Wilderness area, six units were determined to have impacts greater than 1% of the total impact. These included 1 unit at the International Paper

- Courtland Mill, 4 units at the Solutia, Inc. facility and 1 unit at the Cargill, Inc. facil ity.

At both the International Paper

- Courtland Mill and the Solutia, Inc. facilities, all units identified in the Sipsey AoI table were subject to BART and subsequently were evaluated for BART controls. It is ADEM‟s contention that, for these units, BAR T is equivalent to Reasonable Progress (RP).

For the Cargill, Inc, facility, a four factor analysis was performed for the Keeler Stoker Boiler (Unit S

- 407), a summary of which is included in Step 5 below, as well as in Appendix O.

For the Breton Wildli

fe Refuge, a sulfur recovery unit at the Escambia Operating Company

- Big Escambia Creek was determined to have impacts greater than 1% of the total impact. This unit took a permit limit of approximately 7963 tons of actual SO2 emissions (equivalent to a ~ 40% reduction in emissions). This limit precluded the source from BART subjectivity and a permit was issued enforcing this limit in mid 2006. As such, ADEM contends that this unit has, in effect been through the BART process, and that this reduction is suf

ficient for RP. The State of Louisiana used a number of tools including CENRAP source apportionment modeling and the VISTAS AOI analyses in developing their source list for the Breton Wildlife Refuge. Discussions with the State of Louisiana yielded no requ est for a four factor analysis for this source. For these reasons, ADEM contends that no further evaluation is needed for this source.35

For the St. Marks Wilderness area, two units at the Sanders Lead Company were determined to have impacts greater than 1 % of the total impact. The Florida reasonable progress methodology used to identify sources for a four factor analysis for the St. Marks Wilderness Area involved assessing emissions units having sulfur dioxides (SO2) emissions of at least 250 tons per year , and emissions (Q) to distance ratio of greater than or equal to 50 (Q/d>=50), and being within 300 km of the Class I area. Although the States of Alabama and Florida are using different methodologies, ADEM feels it is the responsibility of the state in w hich the Class I area resides to establish procedures for evaluating reasonable progress for that Class I area. In consultation with the Florida Department of Environmental Protection, Florida did not request a four factor analysis of these units. For this reason, ADEM contends that no further evaluation is needed for

these sources.

AL SIP Narrative, Pages 69

- 73:3637

AL SIP Narrative,Pages 91

- 92:

Section 308(d)( 3)(v) of the Rule addresses several factors, including the role of fire at Class I areas and status of state planning for smoke management, the role of dust and fine soil at Class I areas and status of state plans to mitigate emissions from construction

ac tivities and the role of NH3 and potential benefits if emissions from agricultural sources are mitigated.

As discussed in Section 2.4, elemental carbon (sources include agriculture, prescribed wildland fires, and wildfires) is a relatively minor contribu tor to visibility impairment at the Sipsey Wilderness Area in Alabama. Section 51.308(d)(3)(iv)(E) of the Rule requires that each state must consider, at a minimum, the following factors in developing the LTS: Smoke Management techniques for agricultural a nd forestry management purposes38

include plans as they currently exist within the state for these purposes. The Alabama Forestry Commission (“AFC”) has developed The State of Alabama Smoke Management Program, which serves to regulate vegetative debris burni ng for forestry, agriculture, and wildlife purposes in the State of Alabama. ADEM‟s Air Division has developed a state air pollution control regulation (ADEM Admin. Code 335

- 3

- 3

- .01, Open Burning) that lists the specific circumstances in which open burning is permissible. ADEM has an approved smoke management program that addresses the issues laid out in EPA‟s 1998 draft guidance “Interim Air Quality Policy on Wildland and Prescribed Fires” for smoke management plans. The voluntary prescribed fire smoke man agement techniques practiced include Class I areas as a sensitive receptor, and ADEM contends that the current smoke management plan is sufficient to satisfy the directive in Section 308(d)(3)(iv)(E).

In regard to construction activities and fugitive dus t emission sources, ADEM has issued regulations to address the control of fugitive dust from construction activities and to control particulates from fugitive dust emission sources generated within plant

boundaries. ADEM Admin. Code 335

- 3

- 4

- .02, reads as f ollows: (1) No person shall cause, suffer, allow, or permit any materials to be handled, transported, or stored; or a building, its appurtenances, or a road to be used, constructed, altered, repaired, or demolished without taking reasonable precautions to prevent particulate matter from becoming airborne. Such reasonable precautions shall include, but not be limited to, the following: (a) Use, where possible, of water or chemicals for control of dust in the demolition of existing buildings or structures, construction operations, the grading of roads, or the clearing of land; (b) Application of asphalt, oil, water, or suitable chemicals on dirt roads, materials stock piles, and other surfaces which create airborne dust problems; (c) Installation and use of hoods, fans, and fabric filters (or other suitable control devices) to enclose and vent the handling of dusty materials. Adequate containment methods shall be employed during sandblasting or other similar operations. (2) Visibl e Emissions Restrictions Beyond Lot Line. No person shall cause or permit the discharge of visible fugitive dust emissions beyond the lot line of the property on which the emissions originate. (3) When dust, fumes, gases, mist, odorous matter, vapors, or any combination thereof escape from a building or equipment in such a manner and amount as to cause a nuisance or to violate any rule or regulation, the Director may order that the building or equipment in which processing, handling, and storage are done b e tightly closed and ventilated in such a way that all air and gases and air or gas

- borne material leaving the building or equipment are treated by removal or destruction of air contaminants before discharge to the open air.

In regards to agricultural am monia, ADEM currently has no regulations. EPA‟s Safe Harbor Agreement, called the Air Compliance Agreement, is intended to produce air quality monitoring data on Animal Feeding Operations (AFOs) emissions during a two

year study, while at the same time pro tecting participants through a “safe harbor” from liability under certain provisions of federal environmental laws. The purpose of the39

monitoring is to allow development of valid emission factors for equivalent (but unmonitored) farms. At this time, the st udy is ongoing to develop the emissions factors, and as such, there are currently no federal regulations related to the control of ammonia from AFOs. Once EPA has proposed regulations for these sources, ADEM will commit to evaluating potential controls on applicable sources in Alabama. A final CMAQ modeling run was performed in early 2008 to account for the cumulative benefits of the Base G2a emissions controls, BART controls, and additional measures to achieve reasonable progress by 2018. This SIP contains the revised RPGs for the Sipse y Wilderness Area reflecting these final decisions.

EPA Findings: EPA proposes to find that ADEM has adequately identified the 29 non

EGU sources to be evaluated for reasonable progress. The analysis for Cargill is

addressed in EPA’s TSD

- III.C.3.

A DE M has concluded that, at this time, the application of BART constitutes reasonable progress for five units at Solutia and International Paper

- Courtland and thus, is not requiring any additional controls for reasonable progress. As discussed in EPA’s

Reaso nable Progress Guidance document, since the BART analysis is based, in part, on an assessment of many of the same factors that must be addressed in establishing the RPG, EPA believes it is reasonable to conclude that any control requirements imposed in

the BART determination also satisfy the RPG

- related requirements for source review in the first RPG planning period. 2 Thus, EPA proposes to agree with the State’s conclusions that the BART control evaluations satisfy reasonable progress for the first plannin g period for these five units.

For the three units at Sanders Lead and Escambia impacting Class I areas in other states who are using different methodologies, EPA proposes to agree with ADEM that it is the responsibility of the state in which the Class I area resides to establish procedures for evaluating reasonable progress for that Class I area. EPA proposes that t he elimination of Akzo Nobel because of updated data is also appropriate.

Prior to the CAIR remand by the c ourt, EPA believed the State’s demonstration that no additional controls for SO 2 beyond CAIR are reasonable for the 19 affected EGUs for the

first implementation period was acceptable

. A s explained in Section III.C.1

– EPA Findings, the State’s demonstratio n regarding CAIR and reasonable progress for EGUs, and other provisions in this SIP revision, are based on CAIR

.

In a separate action proposing limited disapproval of the regional haze SIPs of a number of states, EPA noted that these states relied on the trading programs of CAIR to satisfy the BART requirement and the requirement for a LTS sufficient to achieve the state

adopted reasonable progress goals. See 76 FR 82219 (December 30, 2011). In that action, EPA proposed a limited disapproval of Alabama’s regional haze SIP submittal insofar as

2 Pages 4.2

- 4.3, July 1, 2007 memorandum from William L. Wehrum, Acting Assistant Administrator for Air and Radiation, to EPA Regional Administrators, EPA Regions 1

- 10, Guidance for Setting Reasonable Progress Goals under the Regional Ha ze Program,40

the SIP relied on CAIR. For that reason, EPA is not taking action on that aspect of Alabama’s regional haze SIP in this action.41

III. Evaluation of Regional Haze Submittal C. Long

- Term Strategy

C.3. Source or Sour ce Category Specific Analyses for Reasonable Progress : (40 CFR 51.308(d)(1)(i)(A)

For the significant sources and source categories located within the State and determined to be significantly impacting a mandatory Class I Federal area, the S tate must document

that it considered the costs of compliance, the time necessary for compliance, the energy

and non

- air quality environmental impacts of compliance, the remaining useful life of any potentially affected sources, and how these factors were taken into consideration in establishing the reasonable progress goal.

State Regional Haze Submittal AL SIP Narrative, Page 81:

The emission unit identified in Step 4 above [ EPA Note : Cargill, Inc, facility, the Keeler Stoker Boiler (Unit S

- 407] 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 environmental impacts of compliance, and 4) the remaining useful life of the emissions

unit. For the limi ted purpose of evaluating the cost for the reasonable progress assessment in this first Regional Haze SIP, ADEM believes it is not equitable to require

non

- EGUs to bear a greater economic burden than EGUs for a given control strategy. ADEM used the capital and operating costs provided in the CAIR rule to establish a $2,000 cost/ton of SO2 removed threshold. This limit acts as an inherent barrier to non

EGUs considering additional controls. The cost of controls is significant

-- not just in terms of capital co st, but also the cost of labor needed to efficiently and effectively maintain the equipment. “The availability of skilled labor

-- specifically, boilermakers

-- is an important constraint for the installation of significant amounts of emission controls.

Boiler makers are skilled steel workers who are specially trained to install both NOX controls, such as SCR, and SO2 controls, such as scrubbers” (69 FR 4617). During the current reasonable progress assessment, no units in Alabama were identified for

additional c ontrol since no measures were found to be below the $2,000 cost threshold. The analysis of Cargill Unit S

- 407 is included in Appendix O and a summary of the Cargill facility is provided below.

Cargill , Inc. Four Factor Analysis

Cargill Unit S

- 407 showed an impact of 1% or greater; therefore, a four factor analysis was necessary. The unit is permitted to burn coal, natural gas, or No. 2 fuel oil. Coal is the primary fuel source. The unit is equipped with a Lear Sigler Continuous O pacity Monitor and Nitrogen Oxide/Oxygen Emissions Monitor. The boiler exhaust is controlled by a Carborundum baghouse. The coal handling system is controlled by a Griffin baghouse. The pneumatic flyash conveying system is controlled by an Ultra Industries Baghouse, while air displaced by the flyash to the ash silo is controlled by a National Conveyor Baghouse. A summary of control options considered is listed below: Cargill evaluated 3 options: lower sulfur content coal, wet scrubbers and dry scrubbers.42

Lower sulfur content coal could not be used because of its availability. Also, lower sulfur content coal would require significant modification to the boiler to burn it and would challenge the combustion integrity due to the higher dust content nature of l ower sulfur coal. Therefore, lower sulfur coal is technically infeasible. As for the add

- on controls (wet and dry scrubbers), Cargill estimated that it would cost $2,946/ton to control SO2 with these technologies. As such, no control was deemed feasible fo r this unit.

EPA Findings : EPA proposes to find that Alabama has adequately addressed this provision. ADEM concluded, based on the State’s evaluation of the four CAA factors, that no further controls were warranted for Cargill unit S

- 407. After reviewin g ADEM’s methodology and analyses, EPA proposes to find Alabama’s conclusions acceptable.

EPA also proposes to find that all currently available control technologies at the time of analysis and applicable to this facility were evaluated fully in terms of the four reasonable progress factors, and the State consistently applied its criteria for reasonable compliance

costs. Although the use of a specific threshold for assessing costs means that Alabama may not have fully considered other available emissions reduction measures above its threshold, EPA believes that the Alabama SIP still ensures reasonable progress. In considering Alabama’s approach, EPA is also proposing to place great weight on the fact

that there is no indication in the SIP submittal that A labama, as a result of using a specific cost effectiveness threshold, rejected potential reasonable progress measures that would have had a meaningful impact on visibility in its Class I area. EPA notes that given the emissions reductions resulting from C AIR, Alabama’s BART determinations, and the measures in nearby states, the visibility improvements projected for the affected Class I area are in excess of that needed to be on the uniform rate of progress.43

III. Evaluation of Regional Haze Submittal

C . Long

- Term Strategy C.4. Enforceability of Reasonable Progress Measures: The SIP needs to provide enforceable emissions limitations and schedules for compliance for each newly adopted measure needed to achieve the reasonable progress goals.

State Regional Haze Submittal

EPA Note : No newly adopted source specific measures were required by the State of

Alabama to achieve the reasonable progress goals for Sipsey Wilderness Area

.

EPA Findings : EPA proposes to find that Alabama has adequately addre ssed this provision.44

III. Evaluation of Regional Haze Submittal D. Best Available Retrofit Technology (BART) Requirements

D.1

. Identification of all BART Eligible Sources: The SIP should include a list of all

BART

- eligible sources within the State

.

State Regional Haze Submittal AL SIP Narrative, Pages 81

- 82 :

Section 169A of the CAA directs states to assess certain emission sources which meet specific criteria for additional controls in order to address visibility impacts. States are

directed to cond uct BART determinations for such sources in specific source categories, whose emissions contribute to visibility impairment in Class I areas. The 1999 Regional Haze rule includes the BART requirement, and directs states to include BART in their Regional Ha ze SIPs. On July 6, 2005, EPA published a revised final rule, including Appendix Y of 40 CFR Part 51, the Guidelines for BART Determinations Under the Regional Haze Rule (hereinafter referred to as the “BART Guidelines”) that provides

direction to states o n determining which sources should be subject to BART, and how to determine BART for these sources.

A BART

- eligible source is one which has the potential to emit 250 tons or more of a visibility

- impairing air pollutant, was put in place between August 7, 1962 and August 7, 1977, and whose operations fall within one or more of 26 specifically listed source categories. Under the CAA, BART is required for any BART

- eligible source that a State determines „„emits any air pollutant which may reasonably be antici pated to cause or contribute to any impairment of visibility in any such area.‟‟ For those sources subject to BART, Section 169A(g)(7) of the CAA requires that States must consider the following factors in making BART determinations: (1) the costs of com pliance, (2) the energy and non

- air quality environmental impacts of compliance, (3) any existing pollution control technology in use at the source, (4) the remaining useful life of the source, and (5) the degree of improvement in visibility which may

reas onably be anticipated to result from the use of such technology.

AL SIP Narrative, Page 83 :

The following is a list of facilities with BART

- eligible sources in Alabama . Please see Attachment H3 to Appendix H for a description of each BART

- eligible emission unit:

Alabama BART Eligible Facility List: 3M Company, Decatur Plant Hunt Refining Co, Tuscaloosa
Alabama Electric Coop Lowman International Paper Co Prattville
Alabama Power Co Barry International Paper Co Riverdale

Alabama Power Co EC Gaston International Paper Co Courtland
Alabama Power Co Gorgas JSC Brewton (Smurfit Stone)

Alabama Power Co Greene Co Lehigh Cement

– JCDH

Alabama Power Co Miller

- JCDH MeadWestvaco Mahrt Mill
American Cast Iron Pipe

- JCDH National Cement Co of Alabama
Boise White Paper Oak Grove Resources

- JCDH45 Bowater Inc.

- Alabama Sanders Lead Co

BP Amoco Chemicals Shell Chemical Co Saraland

Carmeuse Lime & Stone Solutia

- Decatur

CEMEX, Inc. Sloss Industries

- JCDH

Chemical Lime Co Alabaster TVA, Colbert

Chemical Lime Co Montevallo TVA, Widows Creek
Ciba Specialty Chemicals Corp US Pipe & Co

- Bessemer

- JCDH
ConocoPhillips Co Chatom US Steel

- Fairfield

- JCDH
Degussa Corporation Weyerhaeuser
Escambia Operating Co Big Escambia Creek Wise Alloys LLC, Alloys Plant

Ft Jms

- Pennington, Naheola Vintage Petroleum, Inc, Flomaton

These BART

- eligible sources were identified using the following methodology in the

BART Guidelines 3 ;

• One or more emission units at the facility fit within one of the 26 categories listed in the BART Guidelines;

• The emission unit(s) were in existence on August 7, 1977, and began operation at some point on or after August 7, 1962; and

• The potential emissions, considering federally enforceable permit limits, from all emission units identified in the previous two bullets were greater than 250 tons or more per year of any of these v isibility

- impairing pollutants: SO 2 , NO X , and PM

10

.

The BART Guidelines recommend addressing these visibility

- impairing pollutants: SO 2 , NO x , and PM, and suggest that states use their best judgment in determining whether to address VOC or ammonia (NH 3 ) em issions. ADEM addressed SO 2 and NO x , and used PM

10 as an indicator for particulate matter to identify BART

- eligible units, as the BART Guidelines recommend. As discussed in detail in subsequent sections as well as in Appendix H, VISTAS modeling demonstrate d that VOCs and NH 3 from point sources do not contribute to visibility impairment at Class I areas within the VISTAS region. As such, ADEM did not evaluate emissions of VOCs and NH 3 in BART determinations. VISTAS did evaluate a few large
ammonia sources, n one of which were located in Alabama.

3 List of BART Source Categories

. The BART requirement only applies to sources in specific categories listed in the Clean Air Act. These categories are: (1) Fossil

- fuel fired steam electric plants of more than 250

million British thermal units (BTU) per hour heat input, (2) Coal cleaning plants (thermal dryers), (3) Kraft pulp mills, (4) Portland cement plants, (5) Primary zinc smelters, (6) Iron and steel mill plants, (7) Primary aluminum ore reduction plants, (8) Primary copper smelters, (9) M unicipal incinerators capable of charging more than 250 tons of refuse per day, (10) Hydrofluoric, sulfuric, and nitric acid plants, (11) Petroleum refineries, (12) Lime plants, (13) Phosphate rock processing plants, (14) Coke oven batteries, (15) Sulfur

r ecovery plants, (16) Carbon black plants (furnace process), (17) Primary lead smelters, (18) Fuel conversion plants, (19) Sintering plants, (20) Secondary metal production facilities, (21) Chemical process plants, (22) Fossil

- fuel boilers of more than 250 million BTUs per hour heat input, (23) Petroleum storage and transfer facilities with a capacity exceeding 300,000 barrels, (24) Taconite ore processing facilities, (25) Glass fiber processing plants, and (26) Charcoal production facilities.46

EPA Findings : EPA proposes to find that Alabama has adequately addressed this provision.47

III. Evaluation of Regional Haze Submittal D. Best Available Retrofit Technology (BART) Requirements

D

. 2. Modeling or O ther Demonstrations for BART Exempt Sources: For each

BART

- eligible source in the State exempted from BART a demonstration, using an acceptable approach, that the source or group of sources does not violate the established threshold. The established exemp tion threshold for determining if a BART

- eligible source contributes to regional haze cannot exceed 0.5 deciviews.

State Regional Haze Submittal AL SIP Narrative, Pages 83

- 88 :

O f the original 40 sources considered by ADEM as part of its BART source list, 3 sources were given exemption status solely for this reason. [ EPA Note : VOC emissions from BART sources do not cause or contribute to visibility impairment and do not need to be included in BART analyse s

. ] After estimating the potential emissions across all BART eligible sources at these facilities, ADEM determined that the following facilities‟ visibility impairing pollutant (VIP) emissions no longer exceed 250 tons per year (Table

7.8.2

- 1). Therefore , these sources are no longer considered “BART

- eligible” for evaluation of visibility impairment at Federal Class I areas.

The BART Guidelines list specific criteria that must be met in order for sources to be

considered BART

- eligible. One of the criteri a for a source to be considered BART

eligible was the potential emissions from all affected emission units considering all federally enforceable permit limits, were greater than 250 tons or more per year of any of these visibility

- impairing pollutants: SO2 , NOx, and PM10. Alabama had three sources which chose to take emissions limits in order to be exempt from the entire BART process. By taking an emissions limit, Gulf States Paper Corporation, Kerr

- McGee Chemical LLC, and Mobile Energy Services Company no longer have BART

- eligible sources. Additionally, the Escambia Operating Company‟s Big Escambia Creek facility also took an enforceable limit that resulted in an insignificant impact, (i.e. less than 0.5 dv) thereby relieving the source from completing a BA RT determination. These limits have been written into and are enforced through the permits for each applicable source at the facility. Table 7.8.3

- 1 provides information on these sources.48

EPA‟s documents strive to set these thresholds in the context of the human perception of visibility change. As noted above, EPA considers a 1.0 dv change in visibility to be humanly perceptible “in virtually all situations.” Also, the preamble to the BART

Guidance cites an analysis in an Appendix of a NAPAP (National Acid Precipitation Assessment Program) report, which asserts that “changes in light extinction of 5% will evoke just noticeable changes in most landscapes.” (A 5% change is approximately 0.5

dv .) But, as noted above, the preamble also states that perceptibility is not a prerequisite for choosing a contribution threshold. Putting all this together, it appears that “causing” visibility impairment means having a humanly perceptible impact (for whic h EPA considers the practical threshold to be 1.0 dv) while “contributing” to visibility impairment means having a smaller impact (for which EPA considers the threshold to be 0.5 dv or some smaller value) that may or may not be perceptible.

ADEM retained the threshold of 0.5 dv for evaluating significance for several reasons. First, there is a clear spatial variability of sources across the state. Additionally, ADEM is electing to use half of the threshold established by EPA for causing visibility impairm ent. Lastly, the BART rule is a source specific rule and ADEM does not have a technical justification for lowering the threshold based on concerns of multiple plume interaction. As such, ADEM concluded that EPA‟s suggested contribution threshold of

0.5 dv was appropriate for evaluating facility contributions at Class I areas that Alabama sources impact.49

Of Alabama‟s 37 final BART

- eligible sources that submitted exemption modeling demonstrations, 35 of the 37 sources were able to exempt using the 0.5 dv thr eshold. Results of these demonstrations are summarized in Tables 7.8.4

- 1 and 7.8.4

- 2 below. Additional details are available in Appendix H. Facilities found to be subject to BART must complete a BART determination analysis and these analyses can be found i n the Attachments to Appendix H as well.

ADEM requested that its sources follow the VISTAS modeling protocol in development of their site specific protocols and explain any deviations that they proposed to use. In the

site

- specific modeling demonstrations submitted by Alabama‟s BART

- eligible sour ces, the CALPUFF model incorporating three years of pre

- processed MM5 meteorological data was used to evaluate the deciview change compared to natural background conditions at each of the Class I areas within 300 km of the source. Both the 4 km and 12

km M M5 datasets prepared by VISTAS were used. Facilities submitted site

- specific modeling protocols and subsequent modeling demonstrations based upon the VISTAS modeling protocol. The site

- specific protocols are found in Attachment H

- 5 and the

demonstrations are found in Attachment H

- 6. The protocols and demonstrations were reviewed by ADEM‟s Industrial Chemicals and Industrial Minerals Sections as well as the Meteorological Section. The individual facility modeling demonstrations were shared

with both EPA an d FLMs for their review and comment. The resulting comments were in turn shared with the facilities. ADEM worked throughout the process to resolve many of the issues and concerns reflected in their comments. ADEM staff reviewed the

demonstrations to dete rmine whether sources demonstrated impacts of 0.5 deciview (dv) or less on any Class I area within 300 km of the source. Sources demonstrating less than a 0.5 dv impact are considered exempt. Sources contributing 0.5 dv impact or greater

were considered su bject to BART and were required to proceed to an analysis of what control measures, if any, constitute BART for the source.

Table 7.8.4

- 1 lists the facilities that were able to demonstrate exemption from BART based on CALPUFF modeling conducted using the VISTAS modeling protocol and the old IMPROVE equation. [ EPA Note : This t able shows all modeling results. International Paper

– Courtland and Solutia were not “exempted” out of BART

. ]50

Table 7.8.4

- 2 lists the facilities that were able to demonstrate exem ption from BART based on the VISTAS modeling protocol and the new IMPROVE equation.51

In total, 35 of Alabama‟s 37 BART

- eligible sources were able to demonstrate that they did not cause or contribute to visibility impairment in any Class I area within 300 km of the source. Two sources used the new IMPROVE equation in efforts to demonstrate exemption. Eight of Alabama‟s BART

- eligible sources are EGUs. EPA has determined that, as a whole, the CAIR cap

- and

- trade program improves visibility more than implementing BART for individual sources in states affected by CAIR. A state that opts to parti cipate in the CAIR program under part 96 AAA

- EEE need not require affected BART

- eligible EGUs to install, operate, and maintain BART for SO2 or NOx emissions. Given that many of the BART

- eligible units are installing scrubbers and NOx controls, and since

A labama is participating in CAIR and accepts EPA‟s overall finding that CAIR “substitutes” for BART for NOx and SO2, Alabama‟s EGUs were allowed to submit BART exemption modeling demonstrations for PM emissions only. All eight EGUs demonstrated visibility i mpacts below the exemption threshold for all Class I areas.

AL SIP Narrative, Appendix H 12

- 15 : Determination of pollutants to address in BART

7.5 Exemption of Point Source Volatile Organic Compounds (VOCs) for BART Purposes The State of Alabama has de termined through modeling that VOCs from point sources are notanticipated to cause or contribute significantly to the impairment of visibility in any Class I area and should be exempt for BART purposes.

7.5.1 Method It was determined through modeling that VOCs from point sources are not anticipated to cause or contribute significantly to the impairment of visibility in any Class I area.

Modeling was conducted through the Visibility Improvement State and Tribal Association of the Southeast (VISTAS). VISTAS is a collaborative effort of state governments, tribal governments, and various federal agencies established to initiate and coordinate activities associated with the management of regional haze, visibility and other air quality issues in the Southeastern U.S. VISTAS contracted with Georgia Institute of Technology (GA Tech) to perform model sensitivity runs to determine the impact of point source VOCs on visibility in Class I areas.

GA Tech performed emission sensitivities to examine the impact of emission reductions on Regional Haze, annual PM 2.5 , and 8

- hour Ozone concentrations using CMAQv4.4_SOAmods on the VISTAS 12 km modeling domain, using the 2009 OTW (on the way) Base D emissions. One such sensitivity run reduced anthropogenic, point source VOCs by 1 00%. The purpose was to quantify the impact of VOC emissions from VISTAS52

BART sources on Class I areas. Two episodes were examined: June 1

- July 10, 2002 and

November 19

– December 19, 2002. The approach included calculating the extinction coefficient in de civiews (dv), then determining the maximum impact of point source

VOCs.

.... 7.5.2 Conclusions The results show that the maximum impact from eliminating all point source VOC emissions in the VISTAS 12 km domain is less than a 0.5 dv for all Class I areas in the

VISTAS domain.

Given that the fraction of the total point source VOC emissions would be less than the emissions from BART

- eligible sources in Alabama, the expected impact of controlling VOCs from a BART source would be much less than the 0.5 dv thres hold. Therefore, VISTAS and the State of Alabama concluded that VOCs from point sources are not a visibility impairing pollutant for BART purposes and that BART

- eligible sources do not

need to consider VOC emissions.

7.6 Treatment of Ammonia (NH 3 ) Emissio ns for BART Purposes Similar to its treatment of VOCs, EPA guidance allows States the discretion to decide

whether or not NH 3 emissions are to be considered for BART purposes based on evaluations of the contributions of the emissions to haze at Class I are as. One approach a State can use to determine whether applying BART will be needed is to evaluate the haze impacts of all BART

- eligible emissions of NH 3 . If the impact at the Class I area is less than the contribution threshold established by the State, 0. 5 dv for Alabama, then source by source analysis for BART is not needed.

The State of Alabama has determined through modeling that NH 3 emissions from point sources are not anticipated to cause or contribute significantly to any impairment of visibility in Class I areas and should be exempt for BART purposes.

7.6.1 Method It was determined through modeling that NH 3 emissions from point sources are not anticipated to cause or contribute significantly to any impairment of visibility in any Class I area affec ted by Alabama sources.

VISTAS contracted with GA Tech to perform model sensitivity runs to determine the impact of point source NH 3 on visibility in Class I areas.

GA Tech performed emission sensitivities to examine the impact of emission reductions

on Regional Haze using CMAQv4.5 with SOA mods on the VISTAS 12 km modeling domain, using the VISTAS 2009 OTW (on the way) Base F4 emissions. One such sensitivity run reduced BART

- eligible source ammonia by 100%. The purpose was to quantify the impact of NH 3 emissions from VISTAS BART sources on Class I areas. Two episodes were examined:

June 1

- July 10, 2002 and November 19

– December 19, 2002. The approach included53

calculating the extinction coefficient in deciviews (dv), then determining the maximum impact of BART

- eligible source NH 3

.

....

The majority of ammonia emissions in VISTAS region come from four BART

- eligible sources, None of the above sources are significant contributors to the Sipsey Wilderness

area. 7.6.2 Conclusions The BART requirements of the RHR allow states to determine whether or not ammonia is to be considered a visibility impairing pollutant to be addressed for BART purposes. NH 3 emissions from BART sources may impair visibility; however the majority of NH 3 emissions in the VISTAS region a re from a few BART sources. Removal of the large NH 3 emission sources results in minimal impact on visibility at Class I areas in the VISTAS region. At their discretion states may ask those few large sources to evaluate NH 3 impacts and potential controls f

or NH3.

Based on the CMAQ sensitivity analyses of the impact of ammonia emissions, Alabama identified no large sources of ammonia emissions affecting the Sipsey Wilderness or neighboring Class I areas. As a result, Alabama has concluded that NH 3 emissions from point sources are not a visibility impairing pollutant for BART purposes and that BART

eligible sources need not consider NH 3 emissions.

CALPUFF MODELING

AL SIP Appendix H page7 :

Alabama used a multifaceted approach to implement the RHR BART requirements. The approach consists of source identification efforts, use of a permitting process to establish any resulting BART limits for inclusion in the SIP submittal as well as participation in VISTAS BART subgroup to resolve technical issues spannin g states in the VISTAS region, and ongoing consultation with affected sources, and EPA and FLMs throughout the BART process.

....

Alabama‟s BART

- eligible sources were presumed to be subject to BART but were provided the opportunity to submit modeling demons trations showing that they did not contribute to visibility impairment, i.e., had less than 0.5 deciview (dv) impact, on any

Class I area within 300 km.54

AL SIP Narrative , Pages 85

- 86;

Justification of 0.5 dv contribution threshold for CALPUFF BART modeling

Under the BART Guidelines, ADEM may consider exempting some sources from BART if it can be shown that they do not cause or contribute to visibility impairment in a Class I area.

In accordance with the BART Guidelines, ADEM chose to require source

- specific analyses to determine which sources cause or contribute to visibility impairment using the CALPUFF model. The CALPUFF modeling protocol used for determining which facilities are subject to

BART is included in Attachment H4 to Appendix H.

Determining whether a source causes or contributes to visibility impairment is one step in the BART review process. The BART Guidelines state that “A single source that is responsible for a 1.0 deciview (dv) change or mor e should be considered to „cause‟ visibility impairment.” The guideline document also states that “the appropriate threshold for determining whether a source „contributes to visibility impairment‟ may reasonably differ across states,” but, “As a general ma tter, any threshold that you use for determining whether a source „contributes‟ to visibility impairment should not be higher than 0.5 dv.” The55

rationale for these instructions is provided in the preamble to the BART Guidance, in the statement, “If „causin g‟ visibility impairment means causing a humanly perceptible change in visibility in virtually all situations ( i.e. a 1.0 dv change), then „contributing‟ to visibility impairment must mean having some lesser impact on the conditions affecting visibility t hat need not rise to the level of human perception.” The Guidance itself also states that, “States remain free to use a threshold lower than 0.5 dv if they conclude that the location of a large number of BART

- eligible sources within the state and in proxi mity to a Class I area justify this approach.”

EPA‟s documents strive to set these thresholds in the context of the human perception of visibility change. As noted above, EPA considers a 1.0 dv change in visibility to be humanly perceptible “in virtually all situations.” Also, the preamble to the BART Guidance 3 cites an analysis in an Appendix of a NAPAP (National Acid Precipitation Assessment Program) report, which asserts that “changes in ligh t extinction of 5% will evoke just noticeable changes in most landscapes.” 4 (A 5% change is approximately 0.5 dv.) But, as noted above, the preamble also states that perceptibility is not a prerequisite for choosing a contribution threshold. Putting all t his together, it appears that “causing” visibility impairment means having a humanly perceptible impact (for which EPA considers the practical threshold to be 1.0 dv) while “contributing” to visibility impairment means having a smaller impact (for

which EP A considers the threshold to be 0.5 dv or some smaller value) that may or may not be perceptible.

ADEM retained the threshold of 0.5 dv for evaluating significance for several reasons. First, there is a clear spatial variability of sources across the sta te. Additionally, ADEM is electing to use half of the threshold established by EPA for causing visibility impairment. Lastly, the BART rule is a source specific rule and ADEM does not have a technical justification for lowering the threshold based on conce rns of multiple plume interaction. As such, ADEM concluded that EPA‟s suggested contribution threshold of 0.5 dv was appropriate for evaluating facility contributions at Class I areas that Alabama sources impact.

AL SIP Appendix H, Pages 21 to 22 :

Use of the New IMPROVE Algorithm

During the Regional Haze SIP development process, the IMPROVE Steering Committee made recommendations for a new IMPROVE equation. Among other things, the new equation includes components that take into account the effects of sea salt and site specific Rayleigh scattering. Additional discussion of the new IMPROVE equation can be found in Appendix C.

VISTAS contracted Dr. Ivar Tombach to develop a post processor to allow CALPOST outputs to be used with the new IMPROVE equat ion. A discussion of the rationale for use of the new IMPROVE equation follows. The new IMPROVE postprocessor and instructions are included in the request to EPA for approval of its use in Attachment H

11.

Rationale for Need for Use of New IMPROVE Equatio n56

The new IMPROVE equation is a much better representation of the effects of particulate matter on light extinction than the old equation and takes into account the latest scientific understanding of several parameters. 1. The new algorithm overcomes biase s of the old algorithm on the haziest days and the clearest days as demonstrated by comparing the measured light extinction from nephelometers at Class I areas to light extinction calculated using each of the equations. 2. The new algorithm recognizes spat ial and temporal variation in light extinction as size distribution of the aerosol changes by increasing extinction efficiency as sulfate, nitrate and organics concentrations increase. 3. The new algorithm incorporates a term to reflect the contribution of fine sea salt and its hygroscopic growth with increasing relative humidity recognizing research findings showing that fine sea salt can be an important contributor to light extinction in coastal

areas. 4. The new algorithm reflects research finding that t he mass concentration of particulate organic matter in rural areas is greater than represented by the old equation. 5. The new algorithm includes a NO2 term to represent times when light absorption by NO2 is a meaningful contributor to light extinction.

6. The new algorithm incorporates site

- specific Rayleigh scattering values to better represent sites close to sea level or with very hot or cold climates. With this combination of revisions to the IMPROVE equation, the resulting apportionment of extinction t o various components is more accurate on the haziest and clearest days. This is important for development of emission control strategies since the benefits of control of concentrations of each species will be represented more correctly with the new algorit hm.

Two of Alabama‟s BART eligible sources elected to use the new IMPROVE equation The spreadsheet developed by Dr. Tombach to implement the entire new IMPROVE equation for use with CALPUFF contains a modification of CALPOST that calculates the light

ext inction from the CALPUFF output. In their review of the spreadsheet and supporting documentation, EPA Region 4 staff commented that the VISTAS methodology contained in the spreadsheet developed by Dr. Tombach appropriately implements the features of

the ne w IMPROVE equation, with the exception of the nitrogen dioxide term. EPA Region 4 further stated that with the addition of their recommendation for addressing the NO2 term, the VISTAS methodology to incorporate the new IMPROVE equation is acceptable. In ad

dition to its impact for the two non

- EGU sources in Alabama, use of the full new IMPROVE equation was used in Base G modeling.

Data Access

EPA Note : Due to the excessive size of data and modeling files that constitute the BART modeling developed by the s ources, the archival and access of this data is made available to the public upon request and is discussed in Appendix I.

EP A Findings : EPA proposes that t he State has adequately identified the BART

- eligible

sources and those sou rces subject to BART controls and that t he State successfully developed and provided the technical analyses to support the BART assessment provision

for the non

- CAIR sources. However, Alabama opted to have CAIR satisfy BART for

SO 2 and NO

x for affected CAIR EGUs, as allowed u nder the Regional Haze regulations.57

As explained in Section III.C.1

– EPA Findings, the State’s demonstration regarding CAIR and reasonable progress for EGUs, and other provisions in this SIP revision, are based on

CAIR

.

In a separate action proposing lim ited disapproval of the regional haze SIPs of a number of states, EPA noted that these states relied on the trading programs of CAIR to satisfy the BART requirement and the requirement for a LTS sufficient to achieve the state

adopted reasonable progress g oals. See 76 FR 82219 (December 30, 2011). In that action, EPA proposed a limited disapproval of Alabama’s regional haze SIP submittal insofar as the SIP relied on CAIR. For that reason, EPA is not taking action on that aspect of Alabama’s regional haze S IP in this action.

CALPUFF MODELING EPA proposes to find that t he CALPUFF 4 modeling system was appropriately applied by

ADEM in the assessment of visibility impairment in Class I areas for specific sources subject to the BART regulations . The BART regulations indicate that CALPUFF or other appropriate models can be used to determine if an individual source is anticipated to cause or contribute to impairment of visibility in Class I areas. T he current regulatory niche for the CALPUFF modeling system in 40 CFR p art 51, Appendix W: Guideline on Air Quality Models (Appendix W) is for compliance with non

- attainment New Source Review (N NSR ) and Prevention of Significant Deterioration (PSD) permitting requirements for long range transport (i.e., greater th an 50 km ) applications at Class I areas. There is no preferred model for assessing visibility impact under BART.
However, EPA believes that it is appropriate for the State of Alabama to use the CALPUFF modeling system for its BART exemption and control d etermination modeling.

VISTAS developed a “Protocol for the Application of CALPUFF for BART Analyses.” The final VISTAS BART Modeling Protocol (Revision 3.2, dated Aug. 6, 2006) states that VISTAS will use CALPUFF ver. 5.754 and CALMET ver. 5.7 ( i.e. , th e VISTAS version of CALPUFF). No formal approval of the CALPUFF VISTAS version (either ver. 5.754 or 5.756) has been made by EPA Region 4. However, there has been an implied acceptance of the VISTAS CALPUFF version as EPA Region 4 has reviewed

and comment ed on the VISTAS BART Modeling Protocol and the source

- specific modeling protocols and reports that were developed by the Alabama specific sources performing BART modeling. The VISTAS BART modeling protocol underwent an extensive stakeholder development and review process, that involved EPA, FLMs, industrial sources, trade groups, lawyers and other interested parties, before the S tate decided to require CALPUFF modeling to evaluate the BART requirements.

4 Note that E PA’s reference to CALPUFF encompasses the whole CALPUFF modeling system, including CALMET/CALPUFF/CALPOST and other pre and post processors. The different versions of CALPUFF have corresponding versions of CALMET, CALPOST, etc. which may not be compatible with previous versions (e.g., the output from a newer version of CALMET may not be compatible with an older version of CALPUFF). The different versions of the CALPUFF modeling system are available from the model developer on the following website: http://www.src.com/verio/download/download.htm58

The S tate required all BART

- eligible sources to perform BART exemption modeling and to develop source

- specific protocols that complied with the VISTAS protocol. EPA Region 4 provided reviews and comments on the source

- specific protocols and their subsequent exemption modeling reports. The exemption pr otocols and modeling reports

are pre sented in Appendix H of the Alabama regional haze SIP.

New IMPROVE Equation The CALPUFF model was simulated with the default inputs as recommended in the March 16, 2006 EPA memorandum, “Dispersion Coefficients for Regulatory Air Quality Modeling in CALPUFF. ” A new methodology was used by the VISTAS s tates to process the mass concentrations from CALPOST (post

- CALPUFF processor) using the new IMPROVE equation so that the BART analyses could consider both the old and new IMPROVE equations. EPA Headquarters and other EPA r egional o ffices and the Federal Land Managers (FLMs) from the National Park Service and the U.S. Fish and Wildlife Service consulted on the VISTAS approach that was developed to utilize the new

IMPROVE equation in the BART assessment and to determine the change in visibility impacts. W hile these other parties were consulted in preparation of EPA Region 4’s response, the response represented the EPA Region 4 position on the new methodology

.

The new m ethodology uses a spreadsheet developed by VISTAS to post

- process the visibility modeling output from the CALPUFF and CALPOST models. The spreadsheet implements the new IMPROVE equation for calculating visibility impacts that was adopted by the IMPROVE St eering Committee in December 2005. EPA Region 4 has previously provided comments indicating that new methodology is an alternative modeling approach and should meet the requirements in Section 3.2 of Appendix W, Guideline on Air Quality Models contained i n 40 CFR p art 51. Th e State’s demonstration included a rationale for the need to use the new IMPROVE equation, a discussion of the performance of the equation versus measured values, a submittal of the modified post

- processing methodology and documentatio n to support the development of concentrations for the different terms in the equation.

Contribution Threshold With respect to the contribution threshold used in the CALPUFF modeling, the S tate was also required to justify its choice of the 0.5 dv contribution threshold for exempting sources from BART eligibility. EPA proposes to agree with the S tate’s rationale for choosing this threshold value since there are a limited number of in and out of state sources that impact the various Class I areas i n the State. In addition

, there are a limited number of sources in close proximity to each of the Class I areas. Considering results of the visibility impacts modeling conducted (see Appendix H.6), a 0.5 dv threshold was appropriate and a lower threshold was not warranted since the majority of the visibility impac ts were well below 0.5 deciview . Also, even though several sources impacted each

Class I area, the overall impacts were low from the BART sources, and EPA has not made any adverse comments on th e use of the CALPUFF VISTAS versions.

References used in the EPA review:59

1. 40 CFR Part 5 1 , Appendix W: Guideline on Air Quality Model s

2. Appendix Y to 40 CFR Part 51, the Guidelines for BART Determinations Under the Regional Haze Rule

.

3. IWAQM. 1998. Interagency Workgroup on Air Quality Modeling (IWAQM) Phase 2 Summary Report and Recommendations for Modeling Long

- Range Transport and Impacts on Regional Visibility. EPA

- 454/R

- 98

- 019. U.S. Environmental Protection Agency, Office of Air Quality Planning a nd Standards, Research Triangle Park, NC.

4. VISTAS, 2006. Tombach, I., P. Brewer, T. Rogers, and C. Arrington, Protocol for the Application of the CALPUFF Model for Analysis of Best Available Retrofit Technology (BART) Revision 2

– 3/9/06 developed through consultation with EPA, the FLMs, VISTAS state and local Agencies and industry stakeholders VISTAS, 2006. Tombach, I., P. Brewer, T. Rogers, and C. Arrington, Located at http://www.vistas

sesarm.org/documents/BARTModelingProtocol_rev3.2_31Aug06.pdf

.

5. March 16, 2006

, EPA memo randum from Dennis Atkinson to Kay T. Prince on Dispersion Coefficients for Regulatory Air Quality Modeling in CALPUFF

.

6. Additional Regional Haz e Questions, EPA, September 27, 2006 Revision. Answers to questions that PA received from various States and Regional Planning Organizations (RPOs) related to the submission of regional haze SIPs under the program described by 40 CFR 51.308. This documen t provides guidance to the State air pollution control agencies and the general public on meeting the regional haze SIP requirements.

7. " QAPP for VISTAS Emissions and Air Quality Modeling", Revision 0, dated November 17, 2004

, approved 8

- 29

- 05 by EPA Region 4.60

III. Evaluation of Regional Haze Submittal D. Best Available Retrofit Technology (BART) Requirements D.3. Identification of Sources Addressed by CAIR : States which adopt the CAIR cap and trade program for SO 2 and NOx are allowed to apply CAIR controls as a substitute for controls required under BART. The SIP should include a list of all BART

- eligible sources within the State for which the CAIR rule is being applied.

State Regional Haze Submittal

AL SIP Narrative

, Page 88 :

Eight of Alabama‟s BART

- eligible sources are EGUs. EPA has determined that, as a whole, the CAIR cap

- and

- trade program improves visibility more than implementing BART for individual sources in states affected by CAIR. A state that opts to partici pate in the CAIR program under part 96 AAA

- EEE need not require affected BART

- eligible EGUs to install, operate, and maintain BART for SO2 or NOx emissions. Given that many of the BART

- eligible units are installing scrubbers and NOx controls, and since

Ala bama is participating in CAIR and accepts EPA‟s overall finding that CAIR “substitutes” for BART for NOx and SO2, Alabama‟s EGUs were allowed to submit BART exemption modeling demonstrations for PM emissions only. All eight EGUs demonstrated visibility imp acts below the exemption threshold for all Class I areas.

EPA Findings : EPA proposes to find that Alabama has adequately addressed this provision except for its reliance on CAIR . EPA believes that t he State has appropriately

identified the BART

- eligible sources and those sources subject to BART controls. However, Alabama opted to have CAIR satisfy BART for SO 2 and NO

x for affected CAIR EGUs, as allowed under the Regional Haze regulations. A s explained in Section

III.C.1

– EPA Findings, the State’s demons tration regarding CAIR and reasonable progress for EGUs, and other provisions in this SIP revision, are based on CAIR.

In a separate action, EPA has proposed a limited disapproval of the Alabama regional

haze SIP because of deficiencies in the State’s re gional haze SIP submittal arising from the State’s reliance on CAIR to meet certain regional haze requirements. See 76 FR 82219 (December 30, 2011). EPA is not proposing to take action in this rulemaking on issues associated with Alabama’s reliance on CAIR in its regional haze SIP.61

III. Evaluation of Regional Haze Submittal D. Best Available Retrofit Technology (BART) Requirements D.4. Source Specific BART Determinations: For each BART

- eligible source in the State subject to BART, a determination of BART based on an analysis of the best system of continuous emission control technology available and associated emission reductions

achievable (unless the State demonstrates tha t an emissions trading program or other alternative will achieve greater reasonable progress toward natural visibility conditions). To address the requirements for BART, the State must take into consideration of “Five Factors” from 51.308(e)(1)(ii)(A): (1 ) the technology available, (2) the costs of compliance, (3) the energy and non

- air quality environmental impacts of compliance, any pollution control equipment in use at the source, (4) the remaining useful life of the source, and (5) the degree of improv ement in visibility that may reasonably be anticipated to result from the use of such technology.

State Regional Haze Submittal

AL SIP Narrative , Pages 88

- 91:

Two sources, Solutia Inc. in Decatur, Alabama

, and International Paper in Courtland, Alabama, were unable to demonstrate a contribution of less than 0.5 dv at all Class I areas within 300 km from their BART

- eligible sources. These two sources are considered to be “subject to BART” and were required to submit permit applications containing their evaluation of potential BART options and proposed BART determinations. These facilities submitted permit applications including their proposed BART determinations in the spring and summer of 2007. The proposed B ART determinations have been concluded and the requirements have been incorporated into Air Permits. The Air Permits were issued on February 5, 2008. A public comment period was held on the Regional Haze SIP. Summaries of the Solutia and International Pape r Courtland BART determinations

are listed below.

SOLUTIA The Department has concluded that no additional particulate controls would be cost effective for the BART units at Solutia. Each BART unit is currently equipped with an electrostatic precipitator , which range in efficiency from 96% to 99%. The addition of NOx controls would not be cost effective for the Solutia BART units. However, Boiler 7 would be required to install a ROFA (rotating opposed fired

- air) system or comparable technology for NOx sin ce Solutia assume the control system as an existing control for the unit. For the control of SO2, Solutia has proposed to utilize low sulfur coal for Boiler 5 and Boiler 6, and the installation of a flue solvent injection (FSI) system for Boiler 7. It

was concluded that the addition of any controls for the coking units would negate the viability of the coking units; therefore, no additional controls were proposed for these units. The BART limits for each unit are listed below.

NOx

• Solutia has proposed no add on controls for Boiler 5, Boiler 6, and the Cokers for the control of NOx emissions.62

• Boiler 7 would be required to meet an emission limit of 0.36 lb NOx/MMBTU with the installation of a ROFA system or a comparable technology.

SO2

• Solutia has proposed to limit Boilers 5 and 6 to burning coal with a sulfur content resulting in SO2 emissions less than 1.40 lbs/MMBTU.

• Boiler 7 would be required to meet a limitation of 0.47 lb SO2/MMBTU with the installation of the FSI system or a comparable te chnology.

• Solutia has proposed no add on controls for the Cokers.

PM10

• The existing electrostatic precipitators will be utilized to control PM emissions for each BART unit (Boiler 5

- 7, Cokers 1

- 2).

INTERNATIONAL PAPER, COURTLAND MILL The Department has concluded that additional controls for SO2 would not be cost effective at the Courtland Mill and that the control of NOx is only cost effective for the

No. 2 Combination Boiler and that no other add

- on controls would be cost effective f or all other sources. The current add

- on controls which control particles at the Courtland mill have efficiencies of greater than 90% therefore no additional controls would be cost effective. The BART limits for each unit are listed below.

NOx
• Install low NOx Burners or only operate the No. 1 Combination Boiler when one of the following emissions units is either not operating or in periods of start

- up of shutdown: the No. 2 Combination Boiler the No. 2 Recovery Furnace, the No. 3 Combination Boiler,

or the No. 3 Recovery Furnace. • Install low NOx Burners, which will give a 30% baseline reduction in emissions, on the

No. 2 Combination Boiler. • IP has proposed using existing combustion control techniques for the control of NOx on the Package Boiler. • The No. 2 Recovery Furnace will utilize existing combustion control techniques for the control of NOx. • IP proposed the existing Low NOx burners for the No. 1 and No. 2 Lime Kilns for control of NOx emissions for these units.63

SO2 • IP has proposed no add on controls for the No. 1 Combination Boiler, No. 2 Recovery Furnace, No. 2 Smelt Tank, No. 1 Lime Kiln, and No. 2 Lime Kiln for the control of SO2

emissions. • The existing Wet Scrubber will be utilized to control SO2 emissions from the No. 2

Comb ination Boiler. • Since the Package Boiler only fires natural gas, no add

- on controls are warranted. The firing of only natural gas will be a federally enforceable limit

PM10 • IP has proposed utilizing the existing Venturi Scrubber for the control of P M emissions from the No. 1 Combination Boiler. • The No. 2 Combination Boiler will utilize the existing multi tube dust collectors with electrostatic precipitator for the control of PM emissions. • IP had proposed no controls for the Package Boiler due t o the low particulate emissions associated with the firing of natural gas. • The existing electrostatic precipitator will be utilized to control PM emissions for the No. 2 Recovery Furnace. • IP has proposed to utilize the existing wet scrubber which is required by 40, CFR Part 63, Subpart MM, as the BART control device for the control of PM emissions from the

No. 2 Smelt Tank • The existing Venturi Scrubbers will be utilized to control PM emissions from both Lime

Kilns No. 1 and No. 2.

EPA Findings : EPA proposes to find that Alabama has adequately addressed this provision. EPA believes that t he State appropriately documented the technical analysis to assess the need and implementation of BART controls as applicable for those non

- CAIR

EGU emission units of PM, SO 2 and NOx precursor emissions. This involved identification of existing controls on applicable emission units, potential control options for applicable emission precursors, and the successful application of the f ive f actors to64

dete rmine the feasibility of c ontrols that constituted BART. In particular, the limited expected impact of the projected controls was influential for these sources.

EPA proposes to agree with Alabama’s analyses and conclusions for BART for Solutia

and Inter national Paper

- Courtland because the analyses were conducted consistent with
EPA’s BART Guidelines and EPA’s Air Pollution Control Cost Manual , and the conclusions reflect a reasonable application of EPA’s guidance to these sources.65

III. Evaluation of Regional Haze Submittal D. Best Available Retrofit Technology (BART) Requiremen ts D.5. Enforceability of BART: For each BART

- eligible source in the State subject to BART, the SIP should include emission limitations representing BART and schedules for compliance with BART. For each BART

- eligible source in the State subject to BART,

the SIP must include a requirement that each source subject to BART be required to install and operate BART as expeditiously as practicable, but in no event later than five years after approval of the implementation plan revision and a requirement that eac h source subject to BART maintains the control equipment required by this subpart and establishes procedures to ensure such equipment is properly operated and maintained.

State Regional Haze Submittal AL SIP Narrative, Page 88 :

These facilities submitt ed permit applications including their proposed BART determinations in the spring and summer of 2007. The proposed BART determinations have been concluded and the requirements have been incorporated into Air Permits. The Air Permits were issued on February 5, 2008. A public comment period was held on the Regional Haze SIP.

EPA Findings : EPA proposes to find that Alabama has adequately addressed this provision. Alabama directly adopt ed BART emission s limits in its SIP. The proposed

BART determinations h ave been concluded and the requirements have been incorporated

into state air p ermits issued on February 5, 2008. Existing emission s limits are immediately effective , and newly added emission limits will become effective January 1,

2013 . These limits w ill be added to the appropriate t itle V (i.e., Part 70 ) permits.66

III. Evaluation of Regional Haze Submittal

E

. Coordination of Regional Haze and RAVI Requirements The State must revise its plan to provide for review and revision of a coordinated long

term strategy for addressing reasonably attributable and regional haze visibility impairment

.

State Regional Haze Submittal

EPA Note : Alabama did not explicitly address this provision regarding a coordinated RAVI and regional haze long

- term strateg y . However, ADEM has included provisions that updated the elements subject to the RAVI long

- term strategy requirements (including monitoring and new source review (NSR)):

AL SIP Narrative, Page 99 : Monitoring Strategy

Because the current IMPROVE monitor in Alabama represents a unique airshed and a significant component of the contributions are regional, reduction of the IMPROVE network by shutting down these monitoring sites impedes tracking progress or planning improve ments at the affected Class I areas. If this occurs, Alabama, in consultation with EPA and the relevant Federal Land Managers, will develop an alternative approach for meeting the tracking goal, perhaps by seeking contingency funding to carry out limited

m onitoring, or by relying on data from nearby urban monitoring sites to demonstrate trends in speciated PM2.5 mass.

Data produced by the IMPROVE monitoring network will be used nearly continuously for preparing the 5

- year progress reports and the 10

- year SIP revisions, each of which relies on analysis of the preceding five years of data. Consequently, the monitoring data from the IMPROVE sites needs to be readily available and up to date. Presumably, IMPROVE will continue to process information from its ow n measurements at about the same pace and with the same attention to quality as it has shown to date. The Visibility Information Exchange Web System (VIEWS) website has been maintained by VISTAS and the other Regional Planning Organizations (RPOs) to provi de ready access to the IMPROVE data and data analysis tools. Alabama is encouraging VISTAS and the other RPOs to maintain VIEWS or a similar data management system to facilitate analysis of

the IMPROVE data.

AL SIP Narrative, Pages 100

- 101 : Five

- year and Ten

- year reviews

Section 51.308(f) requires ADEM to revise its Regional Haze State Implementation Plan (SIP) and submit a plan revision to EPA by July 31, 2018 and every ten years thereafter. In accordance with the requirements listed in Section 51.308(f) of the Rule, Alabama commits to revising and submitting this Regional Haze SIP by July 31, 2018 and every ten years thereafter.67

In addition, Section 51.308(g) requires periodic reports evaluating progress towards the reasonable progress goals (RPGs) est ablished for each mandatory Class I area. In accordance with the requirements listed in Section 51.308(g) of the Rule, ADEM commits to submitting a report on reasonable progress to EPA every five years following the initial submittal of the SIP. The report will be in the form of a SIP revision. The reasonable progress report will evaluate the progress made towards the RPG for the Sipsey Wilderness Area located within Alabama and in each mandatory Federal Class I area located outside Alabama which may be aff ected by emissions from within Alabama

.

.... All requirements listed in 51.308(g) shall be addressed in the SIP revision for reasonable

progress. ADEM also commits to ongoing consultation with the FLMs throughout the implementation process, including discussions on the implementation process and the most recent IMPROVE monitoring data and VIEWS data.

AL SIP Narrative, Page101

Review of New Sources

Relating to the New Source Review/Prevention of Significant Deterioration Programs, ADEM believes that its New Source Review regulations will address emissions from new sources that may locate near a Class I area, or increased emissions from major modifi cations to existing sources. In addition to the regulations that would govern these sources, consultation with the FLMs is also required for sources that are subject to the Class I provisions of the regulations.

EPA Findings : EPA proposes to find that thi s regional haze submittal adequately supplements and augments Alabama’s RAVI visibility provisions to address regional haze by updating the monitoring and LTS provisions as summarized below in this

section.

EPA’s visibility regulations direct states to coordinate their RAVI LTS and monitoring provisio ns with those for regional haze

. Under EPA’s RAVI regulations, the RAVI portion of a state SIP must address any integral vistas identified by the FLMs pursuant to

40 CFR 51.304. An integral vista is define d in 40 CFR 51.301 as a “view perceived from within the mandatory Class I area of a specific landmark or panorama located outside the boundary of the mandatory Class I area.” Visibility in any mandatory Class I area includes any integral vista associated with that area. The FLMs did not identify any integral vistas in Alabama. In addition, the Class I area in Alabama is neither experiencing RAVI, nor are any of its sources affected by the RAVI provisions. Thus, the Alabama regional haze SIP submittal do es not explicitly address the two requirements regarding coordination of the regional haze with the RAVI LTS and monitoring provisions. However, Alabama previously made a commitment to address RAVI should the FLM certify visibility impairment from an indi vidual source. 5 EPA proposes to find that this regional haze submittal appropriately supplements and augments Alabama’s

5 Alabama submitted its visibility SIP revision s address ing RAVI on November 20, 1985, which EPA approved on February 10, 1986 (51 FR 4908).68

RAVI visibility provisions to address regional haze by updating the monitoring and LTS provisions as summarized below in this section.

In its July 15, 2008, submittal, ADEM updated its visibility monitoring program and developed a LTS to address regional haze. Also in this submittal, ADEM affirmed its commitment to complete items required in the future under EPA’s RHR. Specifically,

A DEM made a commitment to review and revise its regional haze implementation plan and submit a plan revision to EPA by July 31, 2018, and every 10 years thereafter. See 40 CFR 51.308(f). In accordance with the requirements listed in 40 CFR 51.308(g) of

EP A’s regional haze regulations and 40 CFR 51.306(c) of the RAVI LTS regulations, ADEM made a commitment to submit a report to EPA on progress towards the RPGs for each mandatory Class I area located within Alabama and in each mandatory Class I area

located outside Alabama which may be affected by emissions from within Alabama. The progress report is required to be in the form of a SIP revision and is due every five years following the initial submittal of the regional haze SIP. Co nsistent with EPA’s

monito ring regulations for RAVI and regional haze, Alabama will rely on the IMPROVE network for compliance purposes, in addition to any RAVI monitoring that may be

needed in the future. See 40 CFR 51.305, 40 CFR 51.308(d)(4). Also, the Alabama new

source revie w (NSR) rules, previously approved in the State’s SIP, continue to provide a framework for review and coordination with the FLMs on new sources which may have an adverse impact on visibility in either form (i.e., RAVI and/or regional haze) in any

federal C lass I area.

The original Alabama visibility SIP submitted to EPA November 20, 1985, addressing the NSR and monitoring strategy requirements in 40 CFR 51.307 and 40 CFR 51.305, respectively, was supplemented by an EPA regulation (40 CFR 52.61) on Novem ber 24, 1987 (52 FR 45138), which incorporates 40 CFR 52.29 into the Alabama SIP and continues to be in effect. Because the July 15, 2008, submittal appropriately addresses the LTS requirements and supersedes these previous requirements, EPA is proposing to rescind the federal regulations in 40 CFR 52.61 and rely on the provisions in Alabama’s regional haze SIP submittal to meet these requirements.69

III. Evaluation of Regional Haze Submittal

F

. Monitoring Strategy and Other Implementation Requirements

Monitoring Strategy: The SIP must include a monitoring strategy for measuring, characterizing, and reporting of regional haze visibility impairment that is representative of all mandatory Class I Federal areas within the State and/or summarize monitoring strategy of States with affected mandatory Class I Federal areas . Compliance with this requirement may be met through participation in the Interagency Monitoring of Protected Visual Environments (IMPROVE) network.

Other Requirements: The implementation p lan must also provide for the following:

A. The establishment of any additional monitoring sites or equipment needed to assess whether reasonable progress goals to address regional haze for all mandatory Class I Federal areas within the State are being achieved.

B. Procedures by which monitoring data and other information are used in determining the contribution of emissions from within the State to regional haze visibility impairment at mandatory Class I Federal areas both within and outside

the State.

C. The reporting of all visibility monitoring data at least annually for each mandatory Class I Federal area in the State. To the extent possible, the State should report monitoring data for visibility electronically and use of the Visibility Information Exchang e Web System (VIEWS) is encouraged.

D. Other elements, including reporting, recordkeeping, and other measures, necessary to assess and report on visibility.

State Regional Haze Submittal AL SIP Narrative, Pages 96

- 99:

The primary monitoring network for regional haze, both nationwide and in Alabama, is the IMPROVE network. Given that IMPROVE monitoring data from 2000

- 2004 serve as the baseline for the Regional Haze program, the future Regional Haze monitoring

strategy mu st necessarily be based on, or directly comparable to, IMPROVE. The IMPROVE measurements provide the only long

- term record available for tracking visibility improvement or degradation. Therefore, Alabama intends to rely on the IMPROVE network for complying with the Regional Haze monitoring requirement in the

Rule.

There is currently one IMPROVE site in the State, at the Sipsey Wilderness area within the Bankhead National Forest. The State supplements the IMPROVE sampling by operating additional collocated monitoring at the Sipsey, including:

A PM2.5 FRM monitor70

The IMPROVE measurements are central to Alabama‟s Regional Haze Monitoring Strategy, and it is difficult to visualize how the objectives listed above could be met without the monitoring data pr ovided by IMPROVE. Any reduction in the scope of the IMPROVE network in Alabama and neighboring Class I areas would jeopardize the state‟s ability to demonstrate reasonable progress toward visibility improvement in its71

Class I areas and plan for appropriat e future programs. In particular, Alabama‟s Regional Haze strategy relies on emission reductions that will result from CAIR and reductions in neighboring states, which occur on different time scales and will most likely not be spatially uniform. Monitoring at Class I areas is important to document the different air quality responses to the emissions reductions.

Because the current IMPROVE monitor in Alabama represents a unique airshed and a significant component of the contributions are regional, reductio n of the IMPROVE network by shutting down these monitoring sites impedes tracking progress or planning improvements at the affected Class I areas. If this occurs, Alabama, in consultation with EPA and the relevant Federal Land Managers, will develop an alt ernative approach for meeting the tracking goal, perhaps by seeking contingency funding to carry out limited monitoring, or by relying on data from nearby urban monitoring sites to demonstrate trends in speciated PM2.5 mass.

Data produced by the IMPROVE monitoring network will be used nearly continuously for preparing the 5

- year progress reports and the 10

- year SIP revisions, each of which relies on analysis of the preceding five years of data. Consequently, the monitoring data from the IMPROVE sites need s to be readily available and up to date. Presumably, IMPROVE will continue to process information from its own measurements at about the same pace and with the same attention to quality as it has shown to date. The Visibility Information Exchange Web Syst em (VIEWS) website has been maintained by VISTAS and the other Regional Planning Organizations (RPOs) to provide ready access to the IMPROVE data and data analysis tools. Alabama is encouraging VISTAS and the other

RPOs to maintain VIEWS or a similar data management system to facilitate analysis of

the IMPROVE data.

EPA Findings : EPA proposes to find that Alabama has adequately addressed this provision.72

III. Evaluation of Regional Haze Submittal

G

. Emission Inventory (40 CFR 51.308(d)(4)(v) (See also TSD Section III.C.) )

The SIP must include a statewide inventory of emissions of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any mandatory Class I

Federal area within the S tate . The inventory must include e missions for a baseline year, emissions for the most recent year for which data are available, and estimates of future projected emissions

, and a commitment to update the inventory periodically.

State Regional Haze Submittal AL SIP Narrative, Pages 17, 20

, 51

- 52 (additional details are located in Appendix D and K):

There are five different emission inventory source classifications: stationary point and area sources, off

- road and on

- road mobile sources, and biogenic sources. Stationary point sources are th ose sources that emit greater than a specified tonnage per year, with data provided at the facility level. Electric generating utilities (EGUs) and industrial sources are the major categories for stationary point sources. Stationary area sources

are those sources whose individual emissions are relatively small, but due to the large number of these sources, the collective emissions from the source category could be significant (i.e., dry cleaners, service stations, agricultural sources, fire emissions, etc.)

. These types of emissions are estimated on a countywide level. Non

- road (or off

- road) mobile sources are equipment that can move but do not use the roadways, (i.e., lawn mowers, construction equipment, railroad locomotives, aircraft, etc.) The emissions f rom these sources, like stationary area sources, are estimated on a countywide level. On

- road mobile sources are automobiles, trucks, and motorcycles that use the roadway system. The emissions from these sources are estimated by vehicle type and road type and are summed to the countywide level. Biogenic sources are natural sources like trees, crops, grasses and the natural decay of plants. The emissions from these sources are also estimated on a countywide level.

In addition to the various source classifications, there are also various types of emission inventories. The first is the actual base year inventory. This inventory is the base year emissions that correspond to the meteorological data used, which for this modeling effort is data from 2002. These emissions are used for evaluating air quality model performance.

The second type of inventory is the typical base year inventory. This inventory is similar to the actual base year inventory, except that for source s whose emissions change significantly from year to year, a more typical emission value is used. In this modeling effort, typical emissions were developed for the EGUs and the wildland fire emissions. The air quality modeling runs using the typical base ye ar inventory provide results which are then used to calculate Relative Response Factors (RRFs) for future years. These RRFs for future years are then used to demonstrate reasonable progress toward visibility goals.73

Below is an overview of the inventories used for each source classification. A more detailed discussion of the emissions inventory development is contained in Appendix D.74

AL SIP Narrative, Page 101:

The requirements listed in 51.308(g) include the following:

... Summary of emission reductions achieved thus far, including the status of implementation of the CAIR compliance plans for EGUs compared to the control assumed in the75

modeling. [ADEM recognizes that the 2018 projections of EGU controls from the IPM

runs rep resent one solution to how the CAIR requirements will be met. By the time of the first periodic report, ADEM anticipates that the actual compliance strategy for the various utility companies will be much more defined. An assessment of those actual complian ce plans will be completed for the first periodic report.]

... All requirements listed in 51.308(g) shall be addressed in the SIP revision for reasonable

progress.

E PA Findings : EPA proposes to find that Alabama has adequately addressed this provision of the RHR. The Alabama SIP submittal includes a statewide inventory of emissions of pollutants that are reasonably anticipated to cause or contribute to visibility impairment in any mandatory Class I Federa l area within the S tate. The inventory includes emissions for a 2002 baseline year and estimates of future projected emissions (i.e., 2018) and a commitment to update the inventory periodically (see also Appendix K). The VISTAS s tates collaborated with th e other RPOs to utilize the regional emissions inventories that were developed by those organizations for their air quality modeling. This ensured that the most current and RPO

- specific data that was being used across the nation was incorporated into the VISTAS analyses. The VISTAS emissions inventories were developed consistently with EPA guidance. The VISTAS emissions data underwent several iterations before the technical analyses were completed and

submitted in the SIP. The VISTAS emissions data were also developed consistent with EPA quality assurance guidance. An emissions inventory quality assurance project plan for VISTAS was developed and approved by EPA on August 29, 2005. See the Alabama

SIP and associated EPA TSD f or additional documentation on the tools and assumptions used to develop the emissions inventory to support the RH LTS technical analyses.

References used in the EPA review:

" QAPP for VISTAS Emissions and Air Quality Modeling", Revision 0, dated November 17, 2004, approved 8

- 29

- 05 by EPA Region 4.7 6

I V. Conclusion EPA is proposing a limited approval of a revision to the Alabama SIP submitted by the State of Alabama on July 15, 2008 , as meeting some of the applicable regional haze requirements as set forth in sections 169A an d 169B of the CAA and in 40 CFR 51.300

- 308, as described previously in this action. Also in this action, EPA is proposing to rescind the federal regulations in 40 CFR 52.61 that were approved into the Alabama SIP on November 24, 1987, and to rely on the p rovisions in Alabama’s July 15, 2008, SIP

submittal to meet the LTS requirements for RAVI at 40 CFR 51.306.77