Appendix F

EPA Comments to Pre-hearing SIP and 

Department Response

Revision to the South Carolina Air Quality Implementation Plan    Appendix F – Page 1

RFATS Redesignation Demonstration and Maintenance Plan

May 31, 2011
This page intentionally left blank 

Revision to the South Carolina Air Quality Implementation Plan    Appendix F – Page 2

RFATS Redesignation Demonstration and Maintenance Plan

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

Comment: 

The contingency plan section should be strengthened 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 Requests to Redesignate Areas to Attainment, aka, the Calcagni 

memo). The South Carolina maintenance plan identifies 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 violation 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 implement 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 design value at ANY monitor 

in the nonattainment area will result in consultation 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 evaluated as stakeholders continue to pursue emission 

reduction activities that improve air quality in general. 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 should clearly identify the measures to be adopted, a 

schedule and procedure for adoption and implementation, 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 contingency measures within a specified time frame. 

Response: 

The Department has updated the maintenance plan to specify that it will develop and implement 

necessary regulations as soon as practicable and within 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, redesignation 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 tons of volatile organic compounds (VOC) and/or 

nitrogen oxides (NOX) (from the year that was used to determine 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 should not rely on CAIR and instead should focus its 

discussion on NOX reductions as a result of the NOX SIP Call as a means to demonstrate attainment. 

Response: 

The maintenance plan has been amended to focus on those NOX reductions which occurred as a result of 

the NOX SIP call. 

Comment: 

Revision to the South Carolina Air Quality Implementation Plan    Appendix F – Page 3

RFATS Redesignation Demonstration and Maintenance Plan

May 31, 2011
The Calcagni memo recommends that there be another 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 differences 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 NOX and VOC on existing stationary sources. RACT for NOX and VOC 

is already required for 100 tpy sources so this would 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 NOx 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 clarify that all sources in the Nonattainment Area have 

been evaluated for CTG applicability. 

Comment: 

Due to the fact that the Charlotte 1997 8-hour ozone 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 maintaining 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 maintenance plan, the NCDAQ has developed its own separate maintenance 

plan for the NC portion of the nonattainment area. This request is overly burdensome within the current 

redesignation timeline. In a multistate 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 Carolina portion of the Metrolina nonattainment area, 

refer to the redesignation demonstration and maintenance plan submitted by the NCDAQ. 

Revision to the South Carolina Air Quality Implementation Plan    Appendix F – Page 4

RFATS Redesignation Demonstration and Maintenance Plan

May 31, 2011
Revision to the South Carolina Air Quality Implementation Plan    Appendix F – Page 5

RFATS Redesignation Demonstration and Maintenance Plan

May 31, 2011

Comment: 

The discussion and conclusion that weather was not a contributing 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 the basis for air quality improvements in the area. 

Response: 

The Department has amended this section of the maintenance plan to abbreviate this analysis based on the 

understanding that the state cannot control weather patterns. However, the Department maintains that the 

dramatic rise in temperatures coupled with the low number of exceedences in the Metrolina 

nonattainment area indicate that the air quality improvements are based on permanent and enforceable 

controls. 

Comment: 

Section 172(c)(3) requires the submittal of a comprehensive, 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 inventory of actual emissions from all sources of the 

relevant pollutant in the NAA as a part of the Attainment SIP that was due from South and North Carolina 

in 2007. Since we have not acted on the attainment SIP, we still need to approve the 2002 attainment SIP 

inventory. This would normally be the inventory 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 inventory for the base year. The EPA should move forward 

to approve the previously submitted Attainment 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 prior 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 inventory 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 that may have been made to any source 

categories. For example, we expect that there may be differences in the attainment SIP 

base year inventory that states submitted per the AERR. 

A comprehensive documentation is necessary if a year different from the attainment SIP 

is being used for the redesignation base year inventory. 

The redesignation base year was chosen to be 2010 since 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 2010 inventories represent actual emissions for that 

year. 

Response: 

The maintenance plan has been amended to clarify that 2010 inventories are based on actual emissions.
Revision to the South Carolina Air Quality Implementation Plan 

RFATS Redesignation Demonstration and Maintenance Plan 

May 31, 2011 

Appendix F - Page 6
Revision to the South Carolina Air Quality Implementation Plan 

RFATS Redesignation Demonstration and Maintenance Plan 

May 31, 2011 

Appendix F - Page 7
Revision to the South Carolina Air Quality Implementation Plan 

RFATS Redesignation Demonstration and Maintenance Plan 

May 31, 2011 

Appendix F - Page 8
Revision to the South Carolina Air Quality Implementation Plan 

RFATS Redesignation Demonstration and Maintenance Plan 

May 31, 2011 

Appendix F - Page 9