# Appendix F EPA Comments to Pre-hearing SIP and Department Response

Revision to the South Carolina Air Quality Implementation Plan Appendix F

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RFATS Redesignation Demonstration and Maintenance Plan

May 31, 2011

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Revision to the South Carolina Air Quality Implementation Plan Appendix F

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RFATS Redesignation Demonstration and Maintenance Plan

May 31, 2011Comments from EPA included in a letter from Dick Schutt on 5/2/2011.

Comment: The contingency plan section should be strengthene d to meet the requirements of the Clean Air Act (CAA) section 175A and the September 4, 1992, U. S. Environmental Protection Agency Redesignation Guidance (Procedures for Processing Re quests to Redesignate Areas to Attainment, aka, the Calcagni memo). The South Carolina maintenance plan iden tifies only one trigger - a Quality Assured/Quality Controlled design value that exceeds the 1997 8-hour ozone National Ambient Air Quality Standards (NAAQS) at the York County monitor. After a viol ation at any monitor within the nonattainment area, South Carolina is obligated to, at a minimum, consult with North Carolina to determine which state, North Carolina and/or South Carolina will implemen t a contingency measure(s) within a time-frame, specified in the maintenance plan, to bring the area back into attainment.

Response: The primary trigger has been updated to specify that an exceedance of the desi gn value at ANY monitor

in the nonattainment area will result in consultati on with NC to assess appropriate contingency measure action if necessary. SCDHEC will continue our commitment to work with local stakeholders to maintain the NAAQS as required. Monitoring trends will be ev aluated as stakeholders continue to pursue emission reduction activities that improve air quality in genera l. SCDHEC will continue to encourage proactive, voluntary emission reduction activities. As proven in SC , proactive efforts may be able to prevent any actual violations of the NAAQS.

Comment: The Calcagni memo also states that "The plan s hould clearly identify the measures to be adopted, a schedule and procedure for adoption and implementati on, and a specific time limit for action by the state." The South Carolina maintenance plan does not provide a firm commitment to adopt any measures but only states that measures will be considered for adoption upon a trigger. Please state that South Carolina will, upon a trigger, adopt and implement c ontingency measures within a specified time frame.

Response: The Department has updated the ma intenance plan to specify that it will develop and implement necessary regulations as soon as practicable and with in the guidelines established in the South Carolina Administrative Procedures Act or no more than two years after selection of the appropriate measure.

Comment: According to section 107(d)(3)(E) of the CAA, re designation submittals must show permanent and enforceable emission reductions for ozone precursors that led to attainment in the area. The redesignation request should estimate the percent reduction or to ns of volatile organic compounds (VOC) and/or nitrogen oxides (NO X ) (from the year that was used to determ ine the design value for designation and classification) achieved from federal and state control measures in the nonattainment area. In addition, the language in the discussion of the Clean Air Interstate Rule (CAIR) appears to suggest that South Carolina favors including a discussion of the CAIR benefits that have led to redesignation and maintenance in the

Charlotte Area. EPA feels that South Carolina shoul d not rely on CAIR and instead should focus its

discussion on NO X reductions as a result of the NO X SIP Call as a means to demonstrate attainment.

Response: The maintenance plan has been amended to focus on those NO X reductions which occurred as a result of

the NO X SIP call.

Comment:

Revision to the South Carolina Air Quality Implementation Plan Appendix F

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RFATS Redesignation Demonstration and Maintenance Plan

May 31, 2011The Calcagni memo recommends that there be anothe r trigger prior to a violation of the NAAQS such as an increase in emissions. This indicator would allow a state to take early action to address potential violations of the NAAQS before they occur and prevent any actual violation of the NAAQS. However, the pre-violation trigger would not necessarily require the implementation of any specific contingency

measure.

Response: The Department has committed in the maintenance plan to monitor periodic emissions inventory updates and compare these to projected emissions. If projected emissions in this maintenance plan are significantly less, SCDHEC will investigate the diffe rences and develop an appropriate strategy for addressing these differences.

Comment: One of the contingency measures listed in the South Carolina maintenance plan is Reasonably Available Control Technology (RACT) for NO X and VOC on existing stationary sources. RACT for NO X and VOC is already required for 100 tpy sources so this woul d not be appropriate for a contingency measure. Please specify the size of the source where RACT would be required as a contingency measure.

Response: The Department has amended the maintenance plan to specify that it will evaluate RACT for NO

x on existing stationary sources not subject to existing requirements.

Comment: Please clarify in the Control Techniques Guidelines (CTG) section on page 19 that the SC CTG RACT analysis included a search/review of all sources in each CTG source category and that no CTG sources

were found.

Response: This language has been amended as requested to clar ify that all sources in the Nonattainment Area have been evaluated for CTG applicability.

Comment:

Due to the fact that the Charlotte 1997 8-hour oz one nonattainment area is a multistate area, the redesignation request and maintenance plan for the SC portion should provide adequate details and discussion on how the SC portion fits into the entire Area's eligibility for redesignation. Specifically, on page 16 - South Carolina provides their plan for ma intaining compliance with the NAAQS in the South Carolina portion of the Charlotte nonattainment area. The maintenance plans are to address the entire nonattainment area and the state should make an effort to provide emissions inventories for the entire

nonattainment area.

Response: In conjunction with the SC main tenance plan, the NCDAQ has developed its own separate maintenance plan for the NC portion of the nonattainment area. Th is request is overly burdensome within the current redesignation timeline. In a multis tate nonattainment area, requiring both states to submit emissions summaries for the other state is not only repetitive and redundant but is also a waste of valuable

resources. For emissions summaries for the North Caro lina portion of the Metrolina nonattainment area, refer to the redesignation demonstration and main tenance plan submitted by the NCDAQ.

Revision to the South Carolina Air Quality Implementation Plan Appendix F

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RFATS Redesignation Demonstration and Maintenance Plan

May 31, 2011Revision to the South Carolina Air Quality Implementation Plan Appendix F

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RFATS Redesignation Demonstration and Maintenance Plan

May 31, 2011 Comment:

The discussion and conclusion that weather was not a c ontributing factor for the attainment of the 1997 8- hour ozone standards in the Charlotte Area should be strengthened to further support the state's assertion that permanent and enforceable controls are th e basis for air quality improvements in the area.

Response: The Department has amended this section of the maintena nce plan to abbreviate this analysis based on the understanding that the state cannot control weather patte rns. However, the Depart ment maintains that the dramatic rise in temperatures coupled with the low number of exceed ences in the Metrolina nonattainment area indicate that the air quality impr ovements are based on permanent and enforceable

controls.

Comment: Section 172(c)(3) requires the submittal of a comprehe nsive, accurate and current inventory of actual emissions from all sources of the relevant pollutant in the Nonattainment Area (NAA) and requires the submittal of a comprehensive, accurate and current in ventory of actual emissions from all sources of the relevant pollutant in the NAA as a part of the Atta inment SIP that was due from South and North Carolina

in 2007. Since we have not acted on the attainment SI P, we still need to approve the 2002 attainment SIP inventory. This would normally be the inventor y from which permanent and enforceable reductions occurred for the areas to attain the 1997 ozone NAAQS. We need for the state to tell us how they want the 172(c)(3) and 182(a)( I) requirements to be addressed in this redesignation SIP.

Response: The maintenance plan is relying on the 2002 invent ory for the base year. The EPA should move forward to approve the previously submitted Attainme nt Demonstration’s emissions inventory.

Comment: Base Year for Nonattainment Area: For the purposes of redesignation, a state must meet all requirements of Section 110 and Part D that were applicable pr ior to submittal of the complete redesignation request.

South Carolina should declare the base year used for their projection/future year inventories. The base year emissions invent ory should represent actual emissions for the NAA. For redesignation purposes the SIP should discuss in general terms how the base year (if it is the same as the submitted attainment SIP base year) was developed and if we are approving the attainment SIP inventory. In particular, the redesignation SIP should provide documentation of any revisions th at may have been made to any source categories. For example, we expect that th ere may be differences in the attainment SIP base year inventory that st ates submitted per the AERR.

A comprehensive documentation is necessary if a year different from the attainment SIP is being used for the redesi gnation base year inventory.

The redesignation base year was chosen to be 2010 si nce it is one of the most recent three years (2008, 2009 and 2010) for which the Charlotte area has clean air quality data for the 1997 8-hour ozone NAAQS. Please clarify, where necessary, that the 20 10 inventories represent actual emissions for that

year.

Response: The maintenance plan has been amended to clarif y that 2010 inventories are based on actual emissions.