AQ_GEN_PLNG_20220404_SIP_RH-SIP_AppH1-H3

Appendix H
Federal Land Manager Consultation and Comments
Table of Contents

Appendix H-1 – Consultation with FLM PowerPoint Presentation (April 20, 2021)

Appendix H-2 – Comments received from NPS Air Resources Division (June 4, 2021)

Appendix H-3 – Comments received from USFS (June 3, 2021)

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Appendix H-1

Consultation with FLM PowerPoint Presentation
(April 20, 2021)

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Department of Environmental Quality
Division of Air Quality
April 20, 2021
Federal Land Manager Consultation
Regional Haze SIP
18 VISTAS and 6 Nearby Non-VISTAS Class I Areas
2
Department of Environmental Quality
Presentation Overview
•Introductions and Opening Remarks
•Past and Current Visibility Conditions for NC Class I Areas
•Air Quality Modeling to Establish Reasonable Progress Goals for 2028
•Reasonable Progress Analysis
•Area of Influence (AOI) analysis
•Source apportionment analysis with Particulate Source Apportionment
Technology (PSAT) modeling
•Four-Factor Analyses
•Schedule for completing SIP by July 31, 2021
•Next Steps
3
Department of Environmental Quality
Past and Current Visibility Conditions
Particle Contributions to Light Extinction and
Standard Visual Range
(from Interagency Monitoring of Protected Visual
Environments (IMPROVE) Monitoring Data)
4
Department of Environmental Quality
Visibility Improvements (20% Most Impaired Days)
Particle Contributions to Light Extinction and Standard Visual Range
5
0
10
20
30
40
50
60
0
50
100
150
200
250
2000200120022003200420052006200720082009201020112012201320142015201620172018Standard Visual Range (miles)Extinction (Mm-1)GSMNP / Joyce-Kilmer-Slickrock Wilderness Area
6
Great Smoky Mountains National Park
0
10
20
30
40
50
60
0
50
100
150
200
250
300
20012002200320042005200720082009201020112012201320142015201620172018Standard Visual Range (miles)Extinction (Mm-1)Linville Gorge Wilderness Area
Visibility Improvements (20% Most Impaired Days)
Particle Contributions to Light Extinction and Standard Visual Range
7
0
10
20
30
40
50
60
70
0
50
100
150
200
250
2001200220032004200520062007200820092012201320142015201620172018Standard Visual Range (miles)Extinction (Mm-1)Shining Rock Wilderness Area
Visibility Improvements (20% Most Impaired Days)
Particle Contributions to Light Extinction and Standard Visual Range
8
0
10
20
30
40
50
60
70
0
20
40
60
80
100
120
140
2001200220032004200620072009201020112012201320142015201620172018Standard Visual Range (miles)Extinction (Mm-1)Swanquarter Wilderness Area
Visibility Improvements (20% Most Impaired Days)
Particle Contributions to Light Extinction and Standard Visual Range
Annual and Rolling 5-Year Average Data
20% Clearest Days
Department of Environmental Quality
9
13.58
5
10
15
20
2000 2004 2008 2012 2016 2020Haziness Index (Deciviews)Great Smoky Mountains
11.11
5
10
15
2000 2004 2008 2012 2016 2020
Linville Gorge
7.7
0
5
10
15
2000 2004 2008 2012 2016 2020
Shining Rock
12.34
5
10
15
20
2000 2004 2008 2012 2016 2020
Swanquarter
Historical EGU Emissions
10
Department of Environmental Quality
NC SO2 Emissions Trends
11
0
20,000
40,000
60,000
80,000
100,000
120,000
140,000
2011 2017NEI 2028VISTASAnnual Emissions in Tons/YearChemical & Allied Product Mfg Fuel Comb. Elec. Util.Fuel Comb. Industrial
Fuel Comb. Other Highway Vehicles Metals Processing
Miscellaneous Off-Highway Other Industrial Processes
Petroleum & Related Industries Solvent Utilization Storage & Transport
Waste Disposal & Recycling
NC NOx Emissions Trends
12
0
50,000
100,000
150,000
200,000
250,000
300,000
350,000
400,000
2011 2017NEI 2028VISTASAnnual Emissions in Tons/YearChemical & Allied Product Mfg Fuel Comb. Elec. Util.Fuel Comb. Industrial
Fuel Comb. Other Highway Vehicles Metals Processing
Miscellaneous Off-Highway Other Industrial Processes
Petroleum & Related Industries Solvent Utilization Storage & Transport
Waste Disposal & Recycling
Conclusions
13
Department of Environmental Quality
•For NC and Nearby Class I areas:
•Ammonium sulfate continues to be the primary pollutant contributing
to visibility impairment on the most impaired and clearest days
•Stationary point sources are primary emission sources of sulfur
dioxide (SO2)
•Electricity generating units (EGUs)
•Industrial facilities (pulp and paper and phosphate
manufacturing)
•NOx emissions steadily decreasing but nitrate fraction starting
to increase in some Class I areas
•Need to evaluate why for next planning period
Air Quality Modeling to Establish Reasonable
Progress Goals for 2028
14
Department of Environmental Quality
VISTAS Modeling Domains
15
Department of Environmental Quality
•Started with EPA’s 2011/2028 modeling platform
o Version 6.3el
o CAMx v6.32
•Replaced CAMx v6.32 with CAMx v6.40
•Used 2011 meteorology
•Reasons for using EPA platform
o Time limited
o Budget limited
o Most source sectors acceptably represented in EPA platform
VISTAS Air Quality Modeling Platform
16
Department of Environmental Quality
Emissions Inventory Development
17
Department of Environmental Quality
•Used EPA’s 2011 modeling platform (Version 6.3el) as is
•Used EPA’s 2028 emissions for all sectors except for point sources
•Revised 2028 point-source emissions
•For EGUs, remove effects of Clean Power Plan (vacated) for all states
•Each VISTAS state revised its own EGU and non-EGU point emissions
•Non-VISTAS state EGU emissions taken from ERTAC v2.7 (for Area of
Influence analysis and initial PSAT modeling) but later revised to ERTAC
v16.0 or v16.1 for modeling reasonable progress goals
•Non-VISTAS state non-EGU emissions revised for some facilities based
on state input
•Compared model results to observations. Looked at
statistics, comparison plots, and spatial plots
•Ozone
•PM2.5 and light extinction
•Wet and dry deposition
•Overall, the model performance is generally within the
range deemed acceptable for regulatory applications
Model Performance Evaluation
18
•Calculation of relative response factors (RRFs)
•Gives average percent change in pollutant or species
concentrations due to emission changes between 2011
and 2028
•Percent change applied to monitor data (2009 –2013) by
species to calculate design values for 2028 (i.e.,
reasonable progress goals (RPGs) measured in
deciviews)
VISTAS Future Year (2028) Model Projections
19
Uniform Rate of Progress Glide Path
20
27.52
24.66
21.49
18.31
15.13
11.96
10.05
29.11
15.03
0
5
10
15
20
25
30
35
2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064Haziness Index (Deciviews)Year
Glide Path
Natural Condition (Most
Impaired)
Observation (Most
Impaired)
Model Projection (Most
Impaired)
Rolling Average (Most
Impaired)RPG
GSMNP / Joyce Kilmer-Slickrock Wilderness Area
20% Most Impaired Days
Uniform Rate of Progress Glide Path
21
26.52
23.77
20.71
17.65
14.59
11.54
9.70
28.05
14.25
0
5
10
15
20
25
30
35
2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064Haziness Index (Deciviews)Year
Linville Gorge Wilderness Area -20% Most Impaired Days
Glide Path
Natural Condition
(Most Impaired)
Observation (Most
Impaired)
Model Projection (Most
Impaired)
Rolling Average (Most
Impaired)
RPG
Uniform Rate of Progress Glide Path
22
26.64
23.96
20.98
18.00
15.02
12.04
10.25
28.13
13.31
0
5
10
15
20
25
30
35
2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064Haziness Index (Deciviews)Year
Shining Rock Wilderness Area -20% Most Impaired Days
Glide Path
Natural Condition
(Most Impaired)
Observation (Most
Impaired)
Model Projection
(Most Impaired)
Rolling Average (Most
Impaired)
RPG
Uniform Rate of Progress Glide Path
23
22.64
20.57
18.28
15.98
13.68
11.39
10.01
23.79
15.27
0
5
10
15
20
25
30
35
2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064Haziness Index (Deciviews)Year
Swanquarter Wilderness Area -20% Most Impaired Days
Glide Path
Natural Condition (Most
Impaired)
Observation (Most
Impaired)
Model Projection (Most
Impaired)
Rolling Average (Most
Impaired)
RPG
Annual and Rolling 5-Year Average Data
20% Clearest Days
Department of Environmental Quality
24
13.58
8.96
5
10
15
20
2000 2004 2008 2012 2016 2020 2024 2028Haziness Index (Deciviews)Great Smoky Mountains
11.11
8.21
5
10
15
2000 2004 2008 2012 2016 2020 2024 2028
Linville Gorge
7.7
4.54
0
5
10
15
2000 2004 2008 2012 2016 2020 2024 2028
Shining Rock
12.34
10.77
5
10
15
20
2000 2004 2008 2012 2016 2020 2024 2028
Swanquarter
Selection of Sources for
Reasonable Progress Analysis
25
Department of Environmental Quality
Reasonable Progress Analysis
26
Department of Environmental Quality
•States must identify one or more facilities for reasonable progress
analysis to determine if additional controls can be installed to reduce
emissions
•Four Statutory Factors (Clean Air Act, Section 169B)
•Costs of compliance,
•Time necessary for compliance,
•Energy and non-air quality environmental impacts of compliance, and
•Remaining useful life of any potentially affected anthropogenic sources
of visibility impairment
Reasonable Progress Screening Approach
27
Department of Environmental Quality
1.Started with Area of Influence (AOI) screening (Q/d * EWRT) to rank
facilities based on sulfate and nitrate contributions at each Class I area.
2.AOI rankings used to identify facilities for source apportionment (PSAT)
tagging to determine sulfate and nitrate contributions from each facility at
each Class I area
3.VISTAS states agreed to select facilities for reasonable progress evaluation
if PSAT contribution to a Class I area was ≥1.00% for sulfate or nitrate
Acronyms:
Q/d = tons of 2028 emissions / distance from facility to improve monitor (or centroid of Class I area
that does not have an IMPROVE monitor.
EWRT = extinction weighted residence time (HYSPLIT model used to determine residence time of
wind flow in grid cells.
PSAT = Particulate Matter Source Apportionment Technology in CAMx photochemical grid model.
HYSPLIT Trajectories
28
Department of Environmental Quality
•Trajectories were run using NAM-12 meteorology for the 20% most impaired days in 2011-2016 at 44 Class I areas
•Trajectories were run with starting heights of 100, 500, 1,000, and 1,500 meters
•Trajectories were run 72 hours backwards in time for each height at each location
•Trajectories were run with start times of 12AM (midnight of the start of the day), 6AM, 12PM, 6PM, and 12AM (midnight at the end of the day) local time
•44 Class I areas x 6 years x 24 days/year x 4 heights x 5start times = 126,720 trajectories
AOI Screening Summary
29
Department of Environmental Quality
State Threshold Notes
AL 2%Sulfate only
FL 5%Sulfate or nitrate, plus Gulf Crist, Mosaic Bartow, Mosaic New Wales, and
Mosaic Riverview
GA 2% -4%Sulfate or nitrate, 2% threshold for GA facilities, 4% threshold for facilities
outside GA
KY 2%Sulfate or nitrate
MS 2%Sulfate or nitrate
NC 3%Sulfate + nitrate
SC 2% -5%2% for sulfate, 5% for nitrate, plus Santee Cooper Winyah, International
Paper Georgetown, and SCE&G Williams
TN 3%Sulfate + nitrate, plus CEMEX
VA 2%Sulfate + nitrate
WV 0.2%Sulfate or nitrate
NC Facilities with AOI Contributions >3% SO4 + NO3Combined Tagged for PSAT Modeling
30
Department of Environmental Quality
County Facility
NO3 2028
Contribution
(%)
SO4 2028
Contribution
(%)
Combined
SO4 and NO32028
Contribution
(%)
Class I
Area
Haywood Blue Ridge Paper Products -
Canton Mill 6.64 41.28 47.93 SHRO
Beaufort PCS Phosphate Company,
Inc. -Aurora 0.57 37.89 38.47 SWAN
Catawba Duke Energy Carolinas, LLC
-Marshall Steam Station 0.41 6.32 6.73 LIGO
Burke SGL Carbon LLC 0.01 4.05 4.06 LIGO
Martin Domtar Paper Company,
LLC 1.02 2.27 3.29 SWAN
•Quantifies visibility impacts from individual point sources,
source sectors, and geographic regions for SO2 and NOX
•Used for further evaluation of AOI results
•Refines information on contributions to visibility impairment
•Can be used to adjust future year visibility projections to
account for additional emission controls
PSAT Source Apportionment Modeling
31
PSAT SO2 and NOx Tags (209)
32
State, RPO, and Modeling Boundary Tags
•Total SO2 tags for 10 individual VISTAS states + 3 RPOs = 13 tags
•Total NOx tags for 10 individual VISTAS states + 3 RPOs = 13 tags
•EGU point SO2 tags for 10 individual VISTAS states + 3 RPOs = 13 tags
•EGU point NOx tags for 10 individual VISTAS states + 3 RPOs = 13 tags
•Non-EGU point SO2 for 10 individual VISTAS states + 3 RPOs = 13 tags
•Non-EGU point NOx for 10 individual VISTAS states + 3 RPOs = 13 tags
•SO2 and NOx for N/S/W/E boundaries = 8 tags
Facility Tags (Total 87 Separate Facilities)
•SO2 tags for individual VISTAS facilities = 60 tags
•NOx tags for individual VISTAS facilities = 36 tags
•SO2 tags for individual non-VISTAS facilities = 17 tags
•NOx tags for individual non-VISTAS facilities = 10 tags
Great Smoky Mountains National Park
33
Department of Environmental Quality
Linville Gorge Wilderness Area
34
Department of Environmental Quality
Shining Rock Wilderness Area
35
Department of Environmental Quality
Swanquarter
36
Department of Environmental Quality
Great Smoky Mountains National Park (NC/TN)
(PSAT Modeling Results for Sulfate and Nitrate (≥ 1.00%))
37
Department of Environmental Quality
State Facility ID Facility Name DISTANCE_kmFINAL Revised Sulfate PSAT Mm-1FINAL Revised EGU + NEGU Mm-1FINAL Revised Sulfate PSAT %FINAL Revised Nitrate PSAT Mm-1FINAL Revised EGU + NEGU Mm-1FINAL Revised Nitrate PSAT %OH 39053-8148511 General James M. Gavin Power Plant
(0627010056)400.5 0.520 13.916 3.73%0.003 13.916 0.02%
KY 21145-6037011 Tennessee Valley Authority (TVA) -Shawnee
Fossil Plant 465.3 0.183 13.916 1.32%0.011 13.916 0.08%
TN 47163-3982311 EASTMAN CHEMICAL COMPANY 160.1 0.170 13.916 1.22%0.007 13.916 0.05%
PA 42005-3866111 GENON NE MGMT CO/KEYSTONE STA 688.2 0.166 13.916 1.19%0.001 13.916 0.01%
IN 18147-8017211 INDIANA MICHIGAN POWER DBA AEP
ROCKPORT 375.5 0.166 13.916 1.19%0.035 13.916 0.25%
IN 18051-7363111 Gibson 456.3 0.146 13.916 1.05%0.037 13.916 0.27%
Facilities in VISTAS states are highlighted in red.
Linville Gorge Wilderness Area (NC)
(PSAT Modeling Results for Sulfate and Nitrate (≥ 1.00%))
38
Department of Environmental Quality
Facilities in VISTAS states are highlighted in red.
State Facility ID Facility Name DISTANCE_kmFINAL Revised Sulfate PSAT Mm-1FINAL Revised EGU + NEGU Mm-1FINAL Revised Sulfate PSAT %FINAL Revised Nitrate PSAT Mm-1FINAL Revised EGU + NEGU Mm-1FINAL Revised Nitrate PSAT %TN 47163-3982311 EASTMAN CHEMICAL COMPANY 81.9 0.522 12.884 4.05%0.013 12.884 0.10%
OH 39053-8148511 General James M. Gavin Power Plant
(0627010056)329.2 0.446 12.884 3.46%0.002 12.884 0.02%
PA 42005-3866111 GENON NE MGMT CO/KEYSTONE STA 567.5 0.235 12.884 1.82%0.000 12.884 0.00%
KY 21145-6037011 Tennessee Valley Authority (TVA) -Shawnee
Fossil Plant 626.3 0.172 12.884 1.34%0.002 12.884 0.02%
TN 47161-4979311 TVA CUMBERLAND FOSSIL PLANT 516.6 0.154 12.884 1.20%0.001 12.884 0.01%
GA 13015-2813011 Ga Power Company -Plant Bowen 340.9 0.146 12.884 1.13%0.000 12.884 0.00%
IN 18147-8017211 INDIANA MICHIGAN POWER DBA AEP
ROCKPORT 503.5 0.142 12.884 1.10%0.012 12.884 0.09%
IN 18051-7363111 Gibson 582.3 0.138 12.884 1.07%0.008 12.884 0.07%
MO 29143-5363811 NEW MADRID POWER PLANT-MARSTON 688.6 0.134 12.884 1.04%0.000 12.884 0.00%
VA 51027-4034811 Jewell Coke Company LLP 140.4 0.132 12.884 1.02%0.000 12.884 0.00%
Shining Rock Wilderness Area (NC)
(PSAT Modeling Results for Sulfate and Nitrate (≥ 1.00%))
39
Department of Environmental Quality
Facilities in VISTAS states are highlighted in red. NC facilities highlighted in green.
State Facility ID Facility Name DISTANCE_kmFINAL Revised Sulfate PSAT Mm-1FINAL Revised EGU + NEGU Mm-1FINAL Revised Sulfate PSAT %FINAL Revised Nitrate PSAT Mm-1FINAL Revised EGU + NEGU Mm-1FINAL Revised Nitrate PSAT %OH 39053-8148511 General James M. Gavin Power Plant (0627010056)397.3 0.297 12.313 2.41%0.001 12.313 0.01%
KY 21145-6037011 Tennessee Valley Authority (TVA) -Shawnee Fossil Plant 573.4 0.201 12.313 1.63%0.003 12.313 0.02%
TN 47161-4979311 TVA CUMBERLAND FOSSIL PLANT 454.1 0.162 12.313 1.32%0.002 12.313 0.02%
GA 13015-2813011 Ga Power Company -Plant Bowen 241.6 0.159 12.313 1.29%0.001 12.313 0.01%
MO 29143-5363811 NEW MADRID POWER PLANT-MARSTON 625.2 0.158 12.313 1.28%0.001 12.313 0.01%
IN 18147-8017211 INDIANA MICHIGAN POWER DBA AEP ROCKPORT 473.3 0.156 12.313 1.27%0.012 12.313 0.09%
PA 42005-3866111 GENON NE MGMT CO/KEYSTONE STA 657.6 0.151 12.313 1.23%0.000 12.313 0.00%
IN 18051-7363111 Gibson 554.2 0.151 12.313 1.23%0.008 12.313 0.07%
NC 37087-7920511 Blue Ridge Paper Products -Canton Mill 16.9 0.133 12.313 1.08%0.012 12.313 0.10%
OH 39025-8294311 Duke Energy Ohio, Wm. H. Zimmer Station (1413090154)406.7 0.129 12.313 1.05%0.002 12.313 0.01%
AR 05063-1083411 ENTERGY ARKANSAS INC-INDEPENDENCE PLANT 783.3 0.129 12.313 1.04%0.001 12.313 0.01%
TN 47163-3982311 EASTMAN CHEMICAL COMPANY 126.9 0.128 12.313 1.04%0.003 12.313 0.02%
Swanquarter Wilderness Area (NC)
(PSAT Modeling Results for Sulfate and Nitrate (≥ 1.00%))
40
Department of Environmental Quality
Facilities in VISTAS states are highlighted in red. NC facilities highlighted in green.
State Facility ID Facility Name DISTANCE_kmFINAL Revised Sulfate PSAT Mm-1FINAL Revised EGU + NEGU Mm-1FINAL Revised Sulfate PSAT %FINAL Revised Nitrate PSAT Mm-1FINAL Revised EGU + NEGU Mm-1FINAL Revised Nitrate PSAT %PA 42005-3866111 GENON NE MGMT CO/KEYSTONE STA 640.2 0.375 10.894 3.44%0.009 10.894 0.09%
NC 37013-8479311 PCS Phosphate Company, Inc. -Aurora 52.5 0.329 10.894 3.02%0.007 10.894 0.06%
OH 39053-8148511 General James M. Gavin Power Plant (0627010056)651.5 0.219 10.894 2.01%0.005 10.894 0.05%
OH 39081-8115711 Cardinal Power Plant (Cardinal Operating Company)
(0641050002)659.6 0.203 10.894 1.86%0.007 10.894 0.06%
MD 24001-7763811 Luke Paper Company 512.5 0.191 10.894 1.75%0.008 10.894 0.07%
WV 54033-6271711 ALLEGHENY ENERGY SUPPLY CO, LLC-HARRISON 568.6 0.186 10.894 1.71%0.013 10.894 0.12%
PA 42063-3005211 HOMER CITY GEN LP/ CENTER TWP 620.1 0.151 10.894 1.38%0.008 10.894 0.07%
WV 54073-4782811 MONONGAHELA POWER CO-PLEASANTS POWER
STA 625.7 0.127 10.894 1.17%0.005 10.894 0.05%
GA 13015-2813011 Ga Power Company -Plant Bowen 810.6 0.112 10.894 1.03%0.003 10.894 0.03%
NC 37117-8049311 Domtar Paper Company, LLC 69.0 0.109 10.894 1.00%0.022 10.894 0.20%
41
Reasonable Progress Screening Results
Department of Environmental Quality
•NC facilities selected for 4-factor analysis (≥1.00% PSAT for sulfate)
•PCS Phosphate and Domtar Paper Co (Swanquarter Wilderness Area)
•Blue Ridge Paper Products (Shining Rock Wilderness Area)
•NC facilities below 1.00% PSAT threshold
•Duke Energy Marshall and SGL Carbon
•No NC facilities with ≥1.00% sulfate or nitrate contribution to Class I Areas in
other states
•NC Requested Reasonable Progress Analysis for 16 facilities in 10 States:
•7 facilities in 5 VISTAS States
•9 facilities in 5 Non-VISTAS States
41
•AOI tends to overestimate impacts for facilities near
Class I area (<100 km)
•AOI tends to underestimate impacts for facilities far away
from the Class I area (>100 km)
•AOI uses 72-hour back trajectories, sulfate can last for
weeks and travel hundreds to thousands of km
•PSAT is the most reliable modeling tool for tracking
facility contributions to visibility impairment at Class I
areas
AOI vs. PSAT Summary
4242
Four-Factor Analysis
43
Department of Environmental Quality
BRPP -Four-Factor Analysis
(Preliminary Results)
Department of Environmental Quality
44
Unit
2028
Emissions
(tons SO2)
Control
Technology*
SO2Reduction
(%)
Cost
Effectiveness
of Control
($/ton SO2)**
Riley Coal
Boiler 183.77
ULSD Conversion 99%$126,061
Trona DSI 50%$17,042
No. 4 Power
Boiler 195.21 ULSD Conversion 99%$167,105
Trona DSI 50%$18,106
Riley Bark
Boiler 64.75 ULSD Conversion 85%$185,553
* ULSD = ultra-low sulfur diesel; DSI = dry-sorbent injection
** 2020 dollars
BRPP –Four-Factor Analysis
(Preliminary Results)
•Conclusion
•Existing controls demonstrate reasonable progress
•SO2 controls installed 2017 –2019 to comply with 2010 1-hour SO2 NAAQS
•Reduced SO2 emissions by 93% (5,470 tons)
•SO2 Source-Specific SIP
•Additional controls (ULSD and DSI) not cost-effective
•RPG Improvement
•Shining Rock WA = 0.46 dv (2.87 miles)
•GSMNP = 0.04 (0.23 miles)
45
Department of Environmental Quality
Domtar -Four-Factor Analysis
(Preliminary Results)
Department of Environmental Quality
46
Wet Scrubber*Dry Sorbent Injection*
Capital Cost $13,341,296 $13,813,979
Annualized Cost $4,106,120 $11,647,397
SO2 Reduction (%)95%50%
Annual Emission
Reduction 959.1 tons 504.8 tons
Cost-effectiveness $4,281/ton $23,074/ton
* 2020 dollars
Controls Evaluated for No. 2 Hog Fuel Boiler (HFB)
Domtar –Four-Factor Analysis
(Preliminary Results)
•Conclusion
•No. 1 HFB –Conversion from high-sulfur mill gas to low-
sulfur fuel (natural gas or bio-mass) demonstrates best
control (did not operate in 2020)
•No. 2 HFB –$13MM capital investment for wet scrubber
does not justify visibility improvement
•RPG Improvement
•Swanquarter = 0.03 dv (0.16 mile)
47
Department of Environmental Quality
PCS Phosphate -Four-Factor Analysis
(Controls Installed 2017-2019 per EPA Consent Decree)
Department of Environmental Quality
48
Unit
2028
Emissions
(tons SO2)
Shutdown
date (if
applicable)
Control
Technology
SO2Reduction
(%)
Cost
Effectiveness
of Control
($/ton SO2)
Sulfuric
Acid Plant
No. 5
792 Unspecified Dual-absorption
process 63%
$6,097
Sulfuric
Acid Plant
No. 6
852 Unspecified Dual-absorption
process 51%
Sulfuric
Acid Plant
No. 7
1,232 Unspecified Dual-absorption
process 24%
BRPP –Four-Factor Analysis
(Preliminary Results)
•Conclusion
•Existing controls demonstrate reasonable progress
•Reduced SO2 emissions by 37% (1,801 tons)
•Additional controls evaluated not technically feasible
•RPG Improvement
•Swanquarter = 0.02 dv (0.11 mile)
49
Department of Environmental Quality
EPA Preliminary Comments on Four-Factor Analyses
•Domtar and BRPP
•Capital Recovery Factor
•Revise interest rate from 4.75% to 3.25% (current prime
rate)
•Revise equipment life to 30 years from:
•DSI –20 years (Domtar and BRPP)
•Wet scrubber –15 years (Domtar)
50
Department of Environmental Quality
Long Term Strategy (LTS)
•Elements of LTS:
•Include control programs that will demonstrate
“reasonable” progress toward meeting 2028 RPGs
•Demonstrate completion of four-factor analyses
•Include federal and state control programs included in
2028 projections (build on programs included in first
planning period)
•Other programs that support progress
51
52
What We’ve Learned
Department of Environmental Quality
52
•The major facility landscape continues to change
•Shutdowns, fuel switches, additional emission controls
•Emissions continue to go down
•SO2 emissions are still the major haze contributor
•NOx emissions are becoming more important (further
research needed)
•Regional haze levels continue to be reduced
•Visibility improvement is well ahead of schedule
Increase in Visual Range on 20% Most Impaired Days
Compared to the Uniform Rate of Progress
Department of Environmental Quality
53
0
10
20
30
40
50
60
70
Great Smoky Mountains Linville Gorge Shining Rock SwanquarterVISUAL RANGE (MILES)Monitored Visual Range, 5-year average Model Projected Visual Range, 2028 URP-Equivalent Visual Range
2004 2004 2004
2004
2008 2008 2008
2008
2018
2018
2018 2018
2028
2028
2028
2028
Schedule (Preliminary)
Department of Environmental Quality
54
Estimated Due
Date Milestone
Monday, April 5 Pre-draft SIP to FLMs to start 60-day consultation process
(also submit to EPA for review)
Friday, June 4 Complete FLM 60-day consultation process
Monday, June 7 Start Public Comment Period (45 days)
July 7-14 Public Hearing
Thursday, July 22 Close Public Comment Period
Friday, July 30 Final to EPA
Next Steps?
55
•NCDAQ:
•Complete Section 13 (Progress Report)
•Revise four-factor analyses per EPA comments
•FLMs
•How can DAQ support your review?
•Timing for comments

Appendix H-2

Comments received from NPS (June 4, 2021)

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From: Peters, Melanie <[e-mail]>
Sent: Friday, June 04, 2021 3:44 PM
To: Strait, Randy P; Bartlett, Joshua W; Manning, Tammy; Tardif, Elliot M; Wylie, Heather K;
Abraczinskas, Michael; Pjetraj, Michael
Cc: King, Kirsten L; Shepherd, Don; Stacy, Andrea; Miller, Debra C; Cheek, Denesia; Renfro, Jim;
Allen, Tim; Ming, Jaron E; Pitrolo, Melanie -FS; Notarianni, Michele; Brian Timin; [e-mail]
Subject:[External] NPS North Carolina Regional Haze Consultation Documentation
Attachments: NPS-NC_RH_ConsutlationDocumentation_06.04.2021.pdf

CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious
email as an
attachment to Report Spam.

Hello Randy,

The National Park Service (NPS) appreciates the opportunity to review the April 2021 pre-draft
of the Regional Haze State Implementation Plan (SIP) for North Carolina Class I Areas (2018–
2028 Planning Period). On May 25, 2021, staff from the NPS Air Resources Division (ARD), NPS
Interior Region 2, and Great Smoky Mountains National Park hosted a regional haze SIP review
consultation meeting with North Carolina Department of Environmental Quality, Division of Air
Quality staff to discuss NPS input on the draft North Carolina SIP. Representatives from the U.S.
Forest Service, U.S. Fish and Wildlife Service also attended. An annotated set of slides shared
during this meeting are attached. This email and attachment documents NPS conclusions and
recommendations presented during our formal regional haze consultation opportunity, as
required by 42 U.S.C. §7491(d).

As you know, North Carolina is home to five Class I areas: Great Smoky Mountains National Park
(NP), Joyce Kilmer-Slickrock Wilderness Area, Linville Gorge Wilderness Area, Shining Rock
Wilderness Area, and Swanquarter Wilderness Area. Of these, only Great Smoky Mountains NP
is managed by the NPS and is the focus of our review–we do not speak for or represent non-
NPS Class I areas.

We commend North Carolina for developing an organized, detailed SIP, and for engaging with
the NPS during the FLM consultation period. We also recognize and appreciate the significant
emission reductions and visibility improvements that North Carolina has achieved in the last
decade. Still, significant additional progress is necessary before the ultimate visibility goal of no
human caused visibility impairment is realized at Great Smoky Mountains NP. It is with this in
mind that we provided SIP review feedback during our consultation call, summarized here.

In a May 17th, 2021 email to North Carolina and other VISTAS states, NPS ARD outlined several
concerns with the VISTAS and North Carolina analysis methods/approaches and outcomes in
this round of SIP development. Our primary concerns relevant to the North Carolina draft SIP
are the exclusion of NOx from reasonable progress four-factor analyses and the screening
thresholds used for source selection. These are briefly outlined below. Please refer to the
attachment and our May 17th, 2021 communication for additional details and discussion.

Exclusion of NOx
Ammonium nitrate from NOx emissions is a significant anthropogenic haze
causing pollutant. Over the past ten years the importance of ammonium nitrate
on the 20% most-impaired days has increased for many Class I areas in the
VISTAS region, including at Great Smoky Mountains NP. As SO2 emissions decline
and the seasonality of most-impaired days shifts, NOx emissions are increasingly
important for many VISTAS Class I areas.

The North Carolina rationale for excluding NOx emissions from reasonable
progress four-factor analyses is based on an outdated modeling base year (2011)
and associated inaccurate assumptions about the current and future distribution
of most-impaired days in the modeling assessment. We recognize that the
modeling methods follow EPA guidance and are technically correct, however the
result is not representative of current conditions. The importance of ammonium
nitrate and the distribution of most-impaired days has changed significantly
since the 2011 base year. In 2011, ammonium sulfate-dominated extinction on
the 20% most-impaired days which occurred mostly during the warmer, summer
months. Currently, ammonium nitrate extinction which is highest during the
cooler months of the year is now included among the 20% most-impaired days.
As a result, 2028 projections based on the 2011 most-impaired days miss the
importance of ammonium nitrate extinction. This is supported by the past five-
years of IMPROVE monitoring data.

The NPS recommends that North Carolina acknowledge more recent monitoring
data in their source selection process and consider NOx emission reduction
opportunities as relevant to addressing regional haze during this planning period.
Reducing NOx emissions would have additional regional co-benefits for ozone
and nitrogen deposition. Great Smoky Mountains NP is currently part of two
limited maintenance plans for ozone and has 12 acidified streams on the Clean
Water Act 303(d) list for pH-impaired surface waters from excessive atmospheric
nitrogen and sulfur deposition. A total maximum daily load (TMDL) of nitrogen
and sulfur deposition was established to restore these streams which will require
additional nitrogen and sulfur reductions to reach these protective critical loads.
While much of the region’s NOx emissions come from mobile sources, emissions
inventories also show a significant quantity of NOx emissions from point sources
in North Carolina that could be addressed under the regional haze program.

Source Selection
When identifying emission sources to evaluate for haze reduction opportunities,
VISTAS and NC evaluated the potential visibility effects of individual facilities on
Class I areas using extinction weighted residence times (EWRT) combined with
emissions over distance (Q/d) for individual facilities in an area of influence
analysis (AoI). Despite NPS concerns regarding 2028 projections (discussed
above), we find this approach is more robust than a simple emissions divided by
distance (Q/d) approach, as it accounts for meteorology on the 20% most-
impaired days. In June 2019 NPS recommended that North Carolina evaluate 20
facilities based upon Q/d).

Our source selection concern stems from the screening thresholds used that
resulted in the selection of very few sources for analysis and offers less
protection for the more-impacted Class I areas. We advised VISTAS states of this
concern in April 2020. VISTAS states, including North Carolina, used a two-part
screening process. Both steps used an individual-facility-percent-of-total-impact
screening metric. This type of metric biases the results against the more-visually-
impacted Class I areas. In fact, source impacts would have to be 80 times larger
to identify a source for analysis in the most-visually-impaired VISTAS Class I area
compared to the least-visually-impaired Class I area. The absolute value of the
VISTAS thresholds to identify a source affecting Great Smoky Mountains NP is 19
times higher than was needed to identify a source affecting Everglades NP in
Florida (the least-visually-impaired VISTAS Class I area).

We recommend that North Carolina reconsider their source selection decisions
by using the underlying VISTAS EWRT*Q/d analysis and applying different
thresholds. As we shared during our consultation meeting, this approach
identifies five Duke Energy facilities in addition to Blue Ridge Paper Products
(already identified by North Carolina) as affecting visibility at Great Smoky
Mountains NP. We agree that Blue Ridge Paper Products and the Duke Energy
sources identified are already effectively controlled for SO2. However, our initial
evaluation indicates that NOx controls at these facilities could be improved. We
recommend that North Carolina undertake or require full four-factor analysis on
the six identified facilities to assess the NOx control opportunities available in
this planning period. Specifically, we recommend that North Carolina evaluate
options to improve on the current NOx control efficiencies, especially the 35–39%
NOx emission control efficiency achieved by the existing SNCR at Duke Energy
Marshall Steam Station units 1, 2, and 4.
Clean air and clear views are essential to the purpose and enjoyment of our national
parks. There is still progress needed to achieve the regional haze goal of no human-caused
visibility impairment at Great Smoky Mountains NP and other Class I areas in the VISTAS region.
We look forward to continuing working to improve air quality in partnership with North
Carolina into the future. If you have any questions, do not hesitate to reach out to us. Also, feel
free to let us know if you have any edits to this summary and especially if any corrections are
needed.
Best,
Melanie
--
Melanie V. Peters
NPS, Air Resources Division
Office: 303-969-2315
Cell: 720-644-7632

Our National Parks North Carolina Regional Haze Consultation – 5/25/2021
NPS, Air Resources Division, Great Smoky Mtns NP, SE Region &
North Carolina Department of Environmental Quality
5/25/2021
NPS  Formal  Consultation  Call  with  North  Carolina  DEQ  for  Regional  Haze  SIP  Development
Attendees:
• National  Park  Service
• Denesia Cheek,  Southeast  Regional  Office  – Atlanta,  GA
• Kirsten  King,  Air  Resources  Division  (ARD)  –Denver, CO
• Debbie Miller, ARD –Denver, CO
• Melanie Peters, ARD –Denver, CO
• Jim Renfro, Great Smoky Mountains NP
• Don Shepherd, ARD –Denver, CO
• Andrea Stacy, ARD –Denver, CO
• North Carolina DEP
• Michael Abraczinskas
• Joshua Bartlett
• Tammy Manning
• Michael Pjetraj
• Randy Strait
• Elliot Tardif
• Heather Wylie
• FWS
• Tim Allen
• Jaron Ming
• USFS
• Melanie Pitrolo
NPS photos from left to right: Great Smoky Mountains NP, Denali NP, Yellowstone NP, Grand Canyon NP
1

Agenda
• Welcome & Introductions
• NPS Regional Haze Background
• NPS Areas in North Carolina
• Great Smoky Mountains National Park
• NPS Concerns with VISTAS Approaches
to RH & Feedback for North Carolina
o Exclusion of NOx/Nitrate
o Source Selection
o Visibility Benefit and URP Considerations
• Next‐Steps
We welcome discussion at any time during this presentation. Please feel free to ask questions or
add information along the way.
NPS Photo, Great Smoky Mountains NP
2

By the Numbers
• 423 national park units
• 328 million park visitors
• $21.0 billion spent in local
gateway regions
Nationally in 2019 (a 2020 report was not completed due to the pandemic)
328 million park visitors spent an estimated $21 billion in local gateway regions while visiting
National Park Service lands across the country.
These expenditures supported a total of
• 341 thousand jobs,
• $14.1 billion in labor income,
• $24.3 billion in value added, and
• $41.7 billion in economic output in the national economy.
https://www.nps.gov/subjects/socialscience/vse.htm
3
By the Numbers
• 48 Class I areas
• In 24 states
• 90% of visitors surveyed say
that scenic views are
extremely to very important
• 100% of visitors surveyed rate
clean air in the top 5 attributes
to protect in national parks

List of Class I areas: https://www.nps.gov/subjects/air/npsclass1.htm
States with at least one Class I area:
AK, AZ, CA, CO, FL, HI, ID, KY, ME, MI, MN, MT, NC, ND, NM, OR, SD, TN, TX, UT, VA, VI, WA, WY
Statistics citation:
Kulesza C and Others. 2013. National Park Service visitor values & perceptions of clean air, scenic
views, & dark night skies; 1988–2011. Natural Resource Report. NPS/NRSS/ARD/NRR—2013/622.
National Park Service. Fort Collins, Colorado
NPS photo of Great Smoky Mountains NP, NC & TN
4

1970 Clean Air Act
1916 NPS Organic Act
1977 Clean Air Act Amendments 1990 Clean Air Act
Amendments

The NPS has an affirmative legal responsibility to protect clean air in national parks.
• 1916 NPS Organic Act: created the agency with the mandate to conserve the scenery, natural
and cultural resources, and other values of parks in a way that will leave them unimpaired for
the enjoyment of future generations. This statutory responsibility to leave National Park Service
units “unimpaired,” requires us to protect all National Park Service units from the harmful
effects of air pollution.
• In the 1970 Clean Air Act: authorized the development of comprehensive federal and state
regulations to limit emissions from both stationary (industrial) sources and mobile sources. The
Act also requires the Environmental Protection Agency to set air quality standards.
• 1977 Clean Air Act Amendments: these amendments to the Clean Air Act provide a framework
for federal land managers such as the National Park Service to have a special role in decisions
related to new sources of air pollution, and other pollution control programs to protect visibility,
or how well you can see distant views. The Act established a national goal to prevent future and
remedy existing visibility impairment in national parks larger than 6,000 acres and national
wilderness areas larger than 5,000 acres that were in existence when the amendments were
enacted. (Class I areas)
• 1990 Clean Air Act Amendments: created regulatory programs to address acid rain and
expanded the visibility protection and toxic air pollution programs. The acid rain regulations
began a series of regional emissions reductions from electric generating facilities and industrial
sources that have substantially reduced air pollutant emissions.
NPS photo of Washington DC: https://npgallery.nps.gov/AirWebCams/wash
5

Visibility goal:
Restore natural conditions by 2064
Yosemite NP, California and Great Smoky Mountains NP, Tennessee and North Carolina
Left to right images illustrate hazy to clear conditions.
Haze obscures the color and detail in distant features.
NPS photos
6

As you know, the NPS is one of three Federal Land Managers (FLMs) with responsibility for the 156
Class I areas nationwide. The NPS manages 48 Class I areas including Great Smoky Mountains
National Park in North Carolina & Tennessee.
NPS map of Class I areas, 2020
7

North Carolina by the numbers
10 National Parks
18,230,958 Visitors to National Parks
$2,055,500,000 Economic Benefit
from National Park Tourism
2 National Heritage Area
2 Wild & Scenic Rivers
3 National Trails
3,031 National Register of Historic
Places Listings
39 National Historic Landmarks
13 National Natural Landmarks
1 World Heritage Site
‐nps.gov/state/nc
Units managed by the National Park Service in North Carolina
1. Appalachian National Scenic Trail; Maine to Georgia,
CT,GA,MA,MD,ME,NC,NH,NJ,NY,PA,TN,VA,VT,WV
2. Blue Ridge Parkway; Blue Ridge Mountains of Virginia and North Carolina, NC,VA
3. Cape Hatteras National Seashore; Nags Head, Buxton, Ocracoke, NC
4. Cape Lookout National Seashore; Harkers Island, NC
5. Carl Sandburg Home National Historic Site; Flat Rock, NC
6. Fort Raleigh National Historic Site; Manteo, NC
7. Great Smoky Mountains National Park; the states of NC,TN
8. Guilford Courthouse National Military Park; Greensboro, NC
9. Moores Creek National Battlefield; Currie, NC
10. Wright Brothers National Memorial; Kill Devil Hills, NC
• Overmountain Victory National Historic Trail; NC,SC,TN,VA
• Trail Of Tears National Historic Trail; AL,AR,GA,IL,KY,MO,NC,OK,TN
2019 Visitor Spending Effects ‐Economic Contributions of National Park Visitor Spending ‐Social
Science (U.S. National Park Service) (nps.gov)
NPS photo of Cades Cove Visitor Center in Great Smoky Mountains NP, May 2013 by Warren
Bielenberg.
8
Great Smoky Mountains National Park        

Great Smoky Mountains National Park Ridge straddles the border between North Carolina and
Tennessee. With over 500,000 acres, it is world renowned for its diversity of plant and animal life,
the beauty of its ancient mountains, and the quality of its remnants of Southern Appalachian
mountain culture, this is America's most visited national park, with about 13 million visits annually,
providing nearly $1 billion in the local economy. It’s one of the most biologically diverse national
parks in the NP system (with approximately 20,000 known species). The park is a UNESCO World
Heritage Site and an International Biosphere Reserve.
The park’s enabling legislation from 1926 states the park was established for the enjoyment of the
people.
The park’s significance is rooted in its scenery. The park is the finest example of the ruggedness,
magnitude, height, and scenic grandeur of the southern Appalachian Mountains, known for its
historic landscapes, panoramic mountain vistas and the changing of the seasons.
Air quality is the number one Fundamental Resource Value listed in the park’s Foundation
Document. The Foundation Document identifies the park's purpose, significance, fundamental
resources and values. Air quality contributes to the ecological health of the park’s flora and fauna
and is critical to maintaining quality visitor experiences.
NPS photo of a summer view near the Boulevard Trail in Great Smoky Mountains NP, June 2016.
9

Great Smoky Mountains National Park
The Views are Getting Clearer!
Haziest & Clearest Days, 1990‐2018
1990 2018
There is a long history of visibility monitoring at Great Smoky Mountains National Park
(over 40 years!)
Monitoring data show significant improvement on both the haziest and clearest days since the late
1990’s. The regional haze metric is now based on most‐impaired days rather than haziest but, it is
still interesting to see the range of visibility conditions experienced by park visitors and monitored
in the park.
Progress has been made since the first Regional Haze planning phase, and we want to continue to
make progress over this second planning phase as well.
Long term visibility trend graph from:
https://www.nps.gov/subjects/air/park‐conditions‐
trends.htm?tabName=trends&parkCode=GRSM&paramCode=Visibility&startYr=1990&endYr=2018
&monitoringSite=GRSM1%20(IMPROVE)&timePeriod=Long‐term
10

Great Smoky Mountains National Park
As Impairment Drops Composition Changes
2009—2019
Annual contributions to light
extinction by particle mass type
on the most‐impaired days from
2009 through 2019. The relative
and absolute contribution of
ammonium nitrate to light
extinction on the most‐impaired
days generally increased during
this period.
(http://vista.cira.colostate.edu/I
mprove/aqrv‐summaries/)
This annual extinction bar graph shows that over the past last 11 years, as overall impairment
improves (decreases), the chemical composition is changing on the 20% most‐impaired days.
Sulfate continues to drop, but nitrate is increasing both in the absolute and relative contribution to
light extinction on the 20% most‐impaired days.
Most‐impaired days annual light extinction composition stacked bar graph from:
http://vista.cira.colostate.edu/Improve/aqrv‐summaries/
11

Looking at annual light extinction on most‐impaired days since 1990 highlights the massive
reductions in ammonium sulfate as well as the recent increase in the importance of ammonium
nitrate on most‐impaired days.
Most‐impaired days annual light extinction composition stacked bar graph from:
http://vista.cira.colostate.edu/Improve/aqrv‐summaries/
12

Percent contributions to light extinction by particle mass type on the most‐impaired days during two five‐year
periods, 2009‐2013 (left) and 2015‐2019 (right). The contribution of ammonium nitrate to light extinction increased
from 5% during 2009‐2013 to 17% during 2015‐2019. (http://vista.cira.colostate.edu/Improve/aqrv‐summaries/)
Great Smoky Mountains National Park
2009—2013 2015—2019
Nitrate is Increasingly Important
The relative or percent contribution of ammonium nitrate to light extinction has significantly
increased over the past 10 years. During the five‐year period around the 2011 base year,
ammonium nitrate accounted for less than 5% of total light extinction. In the most recent five‐year
period (2015‐2019) that has increased to 17%.
Most‐impaired days haze composition pie charts from:
http://vista.cira.colostate.edu/Improve/aqrv‐summaries/
13

Great Smoky Mountains National Park
Seasonal Changes for
Impairment
1995
2009— 2013 2015—2019
Monthly distribution of the most‐impaired days during two five‐year periods, 2009‐2013 (left) and 2015‐2019 (right). The number of most‐impaired days
occurring in the cooler months (January‐April and October‐December) was higher during 2015‐2019 (46 days) than in 2009‐2013 (30 days).
(http://vista.cira.colostate.edu/Improve/aqrv‐summaries/). Note in 1995, most‐impaired days only occurred May‐Sep.
Additionally, the annual distribution of when the most‐impaired days occur has changed.
Historically the most‐impaired days were concentrated during the summer months. For example, in
1995 all of the 20% most‐impaired days occurred between May and September. As recently as
2009‐2013 (the five‐year period surrounding the 2011 base year used for VISTAS modelling) the
most‐impaired days were still concentrated during the warmer months (June‐September).
However, in the most recent five‐year period, the 20% most‐impaired days are shown to occur
anytime of year and frequently include days in the winter months.
This is key to our comments regarding North Carolinas reliance on an outdated base year in their
source selection modeling analysis, as it is not likely to capture high nitrate days.
Month‐wise distribution of most‐impaired days bar graphs from:
http://vista.cira.colostate.edu/Improve/aqrv‐summaries/
14

Great Smoky Mountains National Park
Annual changes in the relative contribution of particles to light extinction on the 20% most‐
impaired days show the reduction in sulfate and the increase in nitrate. Nitrate is now the 2nd
largest contributor to the most‐impaired days at GRSM and can be the primary pollutant on some
of the most‐impaired days (up to 60% on some days). 2011 monitoring data (the base modeling
year) is representative of monitoring data and conditions from 1990‐2011 but is not representative
of current data (and likely future days in 2028) as nitrate is playing a much greater role In light
extinction on the most‐impaired days throughout the entire year, not just the warmer months.
Most‐impaired days haze composition pie charts from:
http://vista.cira.colostate.edu/Improve/aqrv‐summaries/
15
2018 NO3 = 26%
Nitrate can
contribute up to
60% of the light
extinction on the
most‐impaired days.
2011 NO3 = 3%

Nitrate can
dominate light
extinction on
some most‐
impaired days
Individual sample days in 2011 were rarely dominated by extinction from ammonium nitrate.
However, there were several days in 2018 when light extinction from ammonium nitrate was the
single biggest contributor to haze.
Sample day light extinction composition stacked bar graph from:
http://vista.cira.colostate.edu/Improve/pm‐and‐haze‐composition/
16

VISTAS Approach Concerns
Exclusion of NOx/Nitrate
• The VISTAS analyses justifying exclusion of NOx do not adequately
account for current conditions on the 20% most‐impaired days.
• As SO2 emissions decline and the seasonality of most‐impaired days
shifts, Nitrate is increasingly important in many VISTAS Class I areas.
• States should evaluate NOx and SO2 control opportunities in this
planning period.
17

This map shows the most recent emissions inventory data (2020‐CAMD/2017‐NEI) for VISTAS
sources identified by the earlier (2020) NPS Q/d methodology. Although we are now
recommending VISTAS states consider alternate approaches to source selection using the VISTAS
EWRT*Q/d results, this map illustrates the current distribution and scale of NOx and SO2 stationary
sources in the region.
For North Carolina, we observe that the point source emissions are relatively high and
predominantly NOx.
NPS produced map, April 2021
18

19
VISTAS emissions projections for 2028 show that there will be 1.5 million tons of NOx (3 times the
amount of SO2) at the end of this planning period. Increasing trends in nitrate haze on most‐
impaired days will likely continue. We encourage North Carolina to expand focus from SO2 and
explore opportunities to further reduce NOx emissions in this planning period.
VISTAS Graphic (Slide 9 from 8/4/2020 EPA, FLM, RPO Briefing presentation)
19

North Carolina Draft SIP Feedback
Exclusion of NOx/Nitrate
• Ammonium nitrate is a significant anthropogenic haze causing pollutant.
• Over the past 10 years the importance of ammonium nitrate on the 20%
most‐impaired days has increased at Great Smoky Mountains NP.
• North Carolina rationale for excluding NOx emissions from reasonable
progress is based on an outdated modeling base year and inaccurate
assumptions about the current and future distribution of most‐impaired
days.
• NPS recommends that North Carolina abandon this rationale and consider
NOx emission reduction opportunities in this round of RH SIP development.
• Reducing NOx emissions would have additional regional co‐benefits for ozone
and acid deposition.
Ammonium nitrate from NOx emissions is a significant anthropogenic haze causing pollutant. Over
the past 10‐years the importance of ammonium nitrate on the 20% most‐impaired days has
increased for many Class I areas in the VISTAS region, including at Great Smoky Mountains NP. As
SO2 emissions decline and the seasonality of most‐impaired days shifts, NOx emissions are
increasingly important for many VISTAS Class I areas.
We find that the North Carolina rationale for excluding NOx emissions from reasonable progress
four factor analyses is based on an outdated modeling base year (2011) and inaccurate modeling
assumptions about the current and future distribution of most‐impaired days.
Based on discussion during the meeting we would like to clarify that we agree the modelling
methods by North Carolina and VISTAS follow EPA guidance and are technically correct.
The issue is that the importance of ammonium nitrate and the distribution of most‐impaired days
has changed significantly since the 2011 base year. As a result, 2028 projections based on the 2011
most‐impaired days (which were ammonium sulfate dominated and occurred during the summer)
miss the importance of nitrogen oxide emissions and ammonium nitrate extinction during the
cooler months of the year that are now the most‐impaired.
NPS recommends that North Carolina acknowledge the relevance of recent monitoring data and
consider NOx emission reduction opportunities for additional facilities to address regional haze
during this planning period. Reducing NOx emissions would have additional regional co‐benefits for
ozone and nitrogen deposition.
20

VISTAS Approach Concerns
Source Selection
• The individual facility percent‐of‐total‐impact metrics are arbitrarily
high and inherently less protective of the more‐impacted Class I
areas in the VISTAS region.
• The threshold for selecting an individual facility is 80 times higher in
the most‐impacted Class I area than in the least‐impacted Class I
area in the VISTAS region.
Our source selection concern stems from the choice to select individual facilities contributing 1% or
more to the total of visibility impairing pollutants at a Class I area.
Identifying sources based on this metric biases the results against the more visually impacted Class I
areas. In fact, source emissions would have to be 80 times larger to identify a source for analysis in
the most visually impaired VISTAS Class I area (Dolly Sods Wilderness Area) compared to the least
visually impaired Class I area (Everglades NP). The threshold to identify a source affecting Great
Smoky Mountains NP is 19 times higher than was needed to identify a source affecting Everglades
NP in Florida.
21

VISTAS Approach Concerns
Source Selection
• Underlying EWRT*Q/d analysis *
• Updated NPS lists of facilities
• 80% of total
• Absolute Value Threshold
We acknowledge that an EWRT*Q/d approach is more robust than a simple Q/d approach because
it also considers extinction and meteorology on the 20%. Accordingly, we updated our approach
using the VISTAS EWRT*Q/d results and evaluated two alternative threshold metrics that could be
used in lieu of the VISTAS individual facility percent‐of‐total‐impact thresholds.
• Clarification Note: While we agree with using AOI approaches as opposed to a simple Q/d, this
is not a wholesale endorsement of the VISTAS methods. We still have technical objections to the
reliance on an outdated base year that underpins the AOI & CAMx analyses. Because of this, the
outdated MIDs used in the analysis likely underestimate the role of NOx and assumes this will be
the case into the future—IMPROVE data suggest otherwise. This affects the facility selection
process by failing to account for the role of ammonium nitrate on the recent MID and biases the
analysis against selecting NOx sources. Adjusting the selection thresholds does not address this
issue. Regardless, we used the VISTAS EWRT*Q/d in our revised source screening analyses.
Our first approach applied a threshold that captures 80% of the total Class I Area impact (e.g., 80%
of the TCI) for sulfate & nitrate, as was recommended in the 2016 draft regional haze guidance. This
produced a list of all the facilities that contribute up to 80% of the TCI in a given NPS VISTAS Class I
area. We are calling these results the “80% cut‐off results.”
The second alternative approach applied an absolute value threshold of
[(EWRT(SO4)*Q/d(SO2))+(EWRT(NO3)*Q/d (NOx))] = 0.0067 for an individual facility impact. This
was the lowest absolute value of EWRT*Q/d for sources Florida selected for 4FA at Everglades NP—
a Mosaic fertilizer plant. We are calling these results the “absolute value threshold results.”
Because Everglades NP is the least‐impacted Class I Area in the VISTAS region (based on TCI), this
likely represents the lowest absolute value threshold used to select a facility for 4FA within the
VISTAS region.
Based on calculated efficiency metrics, we recommend the absolute value threshold makes the
most sense for Great Smoky Mountains NP.
22

North Carolina Draft SIP Feedback
Source Selection
• New NPS list of sources for North Carolina:
FACILITY NAME
NPS Class I Areas
Affected
1 Blue Ridge Paper Products ‐Canton Mill GRSM
2 Duke Energy Carolinas, LLC ‐Belews Creek Steam Station GRSM, SHEN
3 Duke Energy Carolinas, LLC ‐Cliffside Steam Station GRSM
4 Duke Energy Carolinas, LLC ‐Marshall Steam Station GRSM, MACA, SHEN
5 Duke Energy Progress, LLC ‐Mayo Electric Generating Plant SHEN
6 Duke Energy Progress, LLC ‐Roxboro Steam Electric Plant GRSM, SHEN
• Only one of these was selected by North Carolina.
• Blue Ridge Paper Products, Canton Mill
Using the absolute value threshold approach to analyzing VISTAS source selection data identifies 5
Duke Energy facilities in addition to Blue Ridge Paper Products (already identified by North
Carolina) as affecting visibility at Great Smoky Mountains NP and other NPS Class I areas.
Acronyms:
• GRSM, Great Smoky Mountains NP (North Carolina & Tennessee)
• SHEN, Shenandoah NP (Virginia)
• MACA, Mammoth Cave NP (Kentucky)
Note, our analysis only considered NPS Class I areas.
23

North Carolina Draft SIP Feedback
Blue Ridge Paper
• Four‐factor analysis demonstrates that this source is well controlled for
SO2 • NPS agrees with the NC DEQ determination that no new SO2 emission controls are
warranted at the Blue Ridge Paper facility during this round of SIP development.
• North Carolina did not require a four‐factor analysis for NOx emissions
from Blue Ridge Paper.
• NPS recommends that North Carolina undertake or require a four‐factor
analysis of NOx emission reduction opportunities in this round.
• Similar pulp and paper facilities across the country are evaluating NOxemissions and finding technically feasible and cost‐effective emission
reduction opportunities.
Blue Ridge Paper is the only source evaluated by North Carolina that is relevant to a NPS Class I area
(Great Smoky Mountains NP).
NPS ARD staff have reviewed the four‐factor analysis for Blue Ridge Paper Products and note the
findings above.
The Domtar Paper and PCS Phosphate facilities primarily affect non‐NPS class I areas. As such, we
have not provided a detailed four‐factor analysis review at this time.
24

North Carolina Draft SIP Feedback
A closer look at Duke Energy sources
Facility Name Unit ID
Avg, SO2
(tons)
Avg. SO2 Rate
(lb/MMBtu)
Avg, SO2
Efficiency
SO2
Control
Avg. NOx
(tons)
Avg. NOx Rate
(lb/MMBtu)
Avg, NOx
Efficiency
NOx
Control
Belews Creek 1 1,583 0.094 92% WLSS 3,410 0.202 80% SCR
Belews Creek
Belews Creek
Cliffside
2
Total
5
1,538
3,121
463
0.100
0.064
92%
96%
WLSS
WLS
2,393
5,802
1,040
0.155
0.143
84%
70%
SCR
SCR
Cliffside
Cliffside
Marshall
6
Total
1
767
1,230
579
0.037
0.125
*
91%
WLS
WLS
1,161
2,201
1,189
0.056
0.258
*
39%
SCR
SNCR
Marshall 2 629 0.132 91% WLS 1,248 0.262 35% SNCR
Marshall 3 1,442 0.113 92% WLS 1,678 0.131 69% SCR
Marshall
Marshall
Mayo
4
Total
1A
1,212
3,862
626
0.081
0.146
94%
86%
WLS
WLS
3,742
7,857
647
0.249
0.151
38%
65%
SNCR
SCR
Mayo
Mayo
Roxboro
1B
Total
1
509
1,134
308
0.149
0.085
86%
94%
WLS
WLS
499
1,146
492
0.146
0.136
63%
74%
SCR
SCR
Roxboro 2 854 0.109 89% WLS 1,195 0.152 72% SCR
Roxboro 3A 537 0.109 92% WLSS 783 0.158 83% SCR
Roxboro 3B 545 0.108 93% WLSS 807 0.160 83% SCR
Roxboro 4A 645 0.116 89% WLSS 761 0.137 76% SCR
Roxboro
Roxboro
4B
Total
572
3,461
0.121 88% WLSS 661
4,700
0.139 75% SCR
This spreadsheet that shows the SO2 and NOx emissions, controls, and control efficiencies for the
five additional North Carolina sources, all power plants (consisting of 16 active EGUs) that NPS
identified using VISTAS source selection data (EWRT*Q/d) and the Florida absolute value threshold.
We used annual CAM data dating back to 1980 to estimate uncontrolled emissions and compared
those to the most‐recent three years of emissions (2018‐2020 CAMD) to estimate control
efficiency.
25

North Carolina Draft SIP Feedback
Additional Analysis Recommendations
SO2
• All but five EGUs are achieving > 90% control for SO2, and all are below the
0.2 lb/MMBtu MATS off‐ramp. No additional analyses for SO2 are needed.
NOx
• Our estimates reveal that all but Cliffside Unit #6 have NOx controls that
achieve < 90% control and are not effectively‐controlled.
• NPS recommends that North Carolina confirm these efficiency estimates
and require four factor analyses to evaluate opportunities to improve NOx
controls for all sources achieving < 90% control efficiency.
• In particular, we recommend that North Carolina explore the technical
feasibility and costs associated with upgrading NOx emission controls from
SNCR to SCR at Duke Energy’s Marshall Station.
NPS recommends that additional analyses for NOx emission reduction opportunities for the point
sources identified are warranted and would improve North Carolina’s Round 2 Regional Haze SIP.
We note that some of these facilities affect several NPS Class I areas. For instance, Duke Energy’s
Marshall station is affecting three NPS Class I areas (Great Smoky Mountains, Shenandoah, and
Mammoth Cave NPs). This specific facility is the least effectively controlled with SNCR NOx controls
operating at 35‐39% control efficiency.
Clarification Note: As discussed during our call, we are not suggesting that VISTAS should revise or
redo their modeling analyses at this time. We recognize the timing considerations and the approval
deadlines the states are subject to. We also appreciate that the AOI or Q/d analyses are not more
robust than photochemical modeling. We are suggesting that given the identified shortcomings in
the VISTAS analyses, the states should rely on additional information, including more recent
IMPROVE data, to make their source selection and reasonable progress determinations for
individual facilities. We recommend that VISTAS states consider alternate screening thresholds to
select sources. Specifically, we recommend that North Carolina evaluate whether NOx controls are
reasonable using the four statutory factors identified in the CAA for the six sources identified by the
NPS. In our view, additional CAMx PSAT modeling is not necessary to make these individual facility
decisions, as the degree of visibility improvement is not one of the four statutory factors congress
intended regulatory authorities to consider when making reasonable progress determinations. This
recognizes the cumulative nature of visibility impairment and the fact that no one source is solely
responsible for impairment, but that it is generated by many sources over a large geographic area.
Finally, we reiterate that NOx reductions would have additional environmental benefits for Great
Smoky Mountains NP, including reductions in pollutant deposition. As noted in the guidance, while
“the CAA does not require states to consider air deposition impacts, including effects on water,
soils, and vegetation, when determining reasonable progress,” states are not prohibited from
considering such benefits in their determinations. As environmental leaders in the southeast region,
we urge North Carolina to consider additional reductions in this round of regional haze planning,
which will have added benefits in the Class I areas.
26

VISTAS Approach Concerns
Visibility Benefit & URP Considerations
• Emission control decisions should be based upon the four factors
identified in the Clean Air Act and not introduce an unintended fifth
visibility factor.
• 2028 projections below the URP glidepath do not represent a “safe
harbor” for avoiding otherwise reasonable emission controls.
North Carolina Draft SIP Feedback
• North Carolina used this rationale for not implementing new
emission controls at Domtar Paper and PCS Phosphate despite
finding cost effective SO2 control opportunities for Domtar Paper.
27
National Park Service RHR - Round 2

• Thank you for meeting with us!
• Please share:
• Anticipated SIP schedule
• How you will respond to NPS comments
• Please let us know:
• When public comment period opens
• If/when a public hearing will be held
• The NPS will:
• Email call summary & any add’l information
• By June 4, 2021
• Share our comments with EPA Region 4
The NPS will submit an email summary of our May 25, 2021 consultation call along with final review
comments by June 4, 2021.
The NPS requests that the state notify us when the draft SIP will be open for public review and
comment, and alert us to any public hearing dates.
North Carolina DEQ staff agreed and shared their intent to summarize NPS input and respond to it
in the public review draft.
28

NPS Contacts
Great Smoky Mountains National Park
• Jim Renfro; [e-mail]
NPS Southeast Region
• Denesia Cheek; [e-mail]
Air Resources Division
• Melanie Peters; [e-mail]
• Don Shepherd; [e-mail]
• Andrea Stacy; [e-mail]
Please reach out to us with any questions.
For any formal notifications of public documents, please include the above list of NPS staff.
NPS acknowledges and very much appreciates the impressive emission reductions that North
Carolina has made since the beginning of the Regional Haze program. We also see that there is still
significant progress to be made before we can reach the goal of unimpaired visibility. We welcome
future opportunities to engage with North Carolina and work together on efforts to reduce haze
causing pollution and promote clean air and clear views in our national parks.
NPS photo of night sky at Clingmans Dome, March 2018 by Thom McManus, Great Smoky
Mountains NP.
29

Appendix H-3

Comments received from USFS (June 3, 2021)

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Caring for the Land and Serving People Printed on Recycled Paper
Logo Department Name Agency Organization Organization Address Information

United States
Department of
Agriculture
Forest
Service
National Forests in North Carolina 160A Zillicoa Street
Asheville, NC 28801
828-257-4200
Fax: [phone]
File Code: 2580
Date: June 3, 2021

Mr. Michael Abraczinskas
Director, North Carolina Division of Air Quality
1641 Mail Service Center
Raleigh, NC 27699-1641

Dear Mr. Abraczinskas:
On April 5, 2021, the State of North Carolina submitted a draft Regional Haze State
Implementation Plan describing your proposal to continue improving air quality by reducing
regional haze impacts at mandatory Class I areas across the region. We appreciate the
opportunity to work closely with your State through the initial evaluation, development, and
subsequent review of this plan. Cooperative efforts such as these ensure that, together, we will
continue to make progress toward the Clean Air Act’s goal of natural visibility conditions at our
Class I areas.
This letter acknowledges that the U.S. Department of Agriculture, U.S. Forest Service, has
received and conducted a substantive review of your proposed Regional Haze State
Implementation Plan. This review satisfies your requirements under the federal regulations 40
C.F.R. § 51.308(i)(2). Please note, however, that only the U.S. Environmental Protection Agency
(EPA) can make a final determination about the document's completeness, and therefore, only
the EPA has the authority to approve the document.
We have attached comments to this letter based on our review. We look forward to your
response required by 40 C.F.R. § 51.308(i)(3). For further information, please contact Melanie
Pitrolo ([e-mail]) or Bret Anderson ([e-mail]).
Again, we appreciate the opportunity to work closely with the State of North Carolina. The
Forest Service compliments you on your hard work and dedication to significant improvement in
our nation's air quality values and visibility.
Sincerely,

JAMES E. MELONAS
Forest Supervisor

cc: Randy Strait, NC DAQ; Margarett Boley, USFS; Melanie Pitrolo, USFS

North Carolina Draft Regional Haze State Implementation Plan (RH SIP) - Specific Comments
The USDA Forest Service recognizes and applauds the significant emission reductions made in North
Carolina over the past decade that have resulted in substantial improvements in visibility at all Forest
Service Class I Areas within the state. We understand that many of the emission reductions have been
above and beyond those required by federal rules and regulations, and that North Carolina Division of
Air Quality (NC DAQ) has historically been a leader among state and local regulatory agencies in
exemplifying both the letter and the spirit of the Clean Air Act. Further, we appreciate the strong
working relationship among our respective staff.
Overall, the USDA Forest Service finds that the draft RH SIP is well organized and comprehensive. The
Long Term Strategies for this planning period appear to indicate that each NC Forest Service Class I Area
will continue to show visibility improvements better than the Uniform Rate of Progress (URP) through
2028, and we appreciate the commitment by NC DAQ to evaluate progress in meeting the visibility goals
during the 5-year progress reports. However, we offer these specific comments on the draft RH SIP for
NC DAQ’s review and consideration.
Screening of Sources for Reasonable Progress Evaluation / 4-Factor Analysis
Section 7.8 of NC’s draft RH SIP discusses the methodology that NC DAQ used to determine which
sources to analyze for additional controls. Sources both within and out of North Carolina were included
in the screening (i.e., in the ‘denominator’ of the contribution evaluation), and a source was selected for
reasonable progress evaluation / four-factor analysis if the facility was estimated to have a ≥ 1.00%
sulfate or ≥ 1.00% nitrate contribution to visibility impairment in 2028 at one or more NC Class I Areas.
Three NC facilities were selected for further evaluation, and 12 additional out-of-state facilities were
identified as having a ≥ 1.00% sulfate contribution to visibility impairment. USDA Forest Service
understands and recognizes that EPA has afforded states the flexibility to screen facilities for additional
analysis if that screening is based on reasonable methods. However, we request that NC consider only
in-state facilities in the denominator of the contribution equation when screening for sulfate and nitrate
visibility contributions at a Class I Area. This methodology would result in a more robust reasonable
progress evaluation by focusing on sources permitted by NC DAQ. Additionally, since evaluations / four-
factor analyses are time consuming and require additional resources, we would also suggest that NC
DAQ consider conducting four-factor analysis on a source category basis rather than on an individual
facility basis when warranted.
Evaluation of Nitrogen Oxide Emission Sources for Additional Controls
The draft RH SIP only evaluates SO2 emission sources for reasonable progress evaluations / four-factor
analyses. USDA Forest Service appreciates the discussion within the draft RH SIP regarding nitrate
formation in the VISTAS region. We understand that nitrate formation in the VISTAS region is limited by
the availability of ammonia (which preferentially reacts with SO2 and sulfates before reacting with NOx)
and by temperature, with particle nitrate concentrations highest in the winter months. We also
recognize that sulfates have been the main contributor to visibility impairment at Class I Areas within
the southern US. Additionally, the substantial emission reductions of both SO2 and NOx from coal-fired
power plants over the past decade within NC as a result of the Clean Smokestacks Act are admirable and
a model for other states. The emissions data show that most NOx emissions within NC are from the
mobile sector. However, the nitrate contribution to visibility impairment is increasing as sulfur dioxide
emissions decrease, and there are still significant NOx sources within the point sector in NC. We request
that NC DAQ consider evaluating NOx sources, along with SO2 sources, for reasonable progress during
this planning period.
Prescribed Fire Emissions
Fire plays an important role in shaping the vegetation and landscape in western North Carolina.
Recurring fire has been a part of the landscape for thousands of years. Aggressive fire suppression,
coupled with an array of other disturbances (e.g., logging and chestnut blight), has changed the historic
composition and structure of the forests. Periodic prescribed burning and other vegetation
management can recreate the ecological role of fire in a controlled manner. Fire and fuels management
supports a variety of desired conditions and objectives across the Forests (e.g., community protection,
hazardous fuels reduction, native ecosystems restoration, historic fire regimes restoration, wildlife
openings, and open woodland creation, etc.). The Land Management Plan for the Pisgah and Nantahala
National Forests calls for an increase in the use of prescribed fire to increase forest resilience. The 2017
Regional Haze Rule includes a provision to allow states to adjust the glidepath to account for prescribed
fire. The draft NC RH SIP states that prescribed fire emissions were taken from the 2011 National
Emissions Inventory (NEI) and were carried forward into the 2028 future year emissions without any
changes. Recent data on prescribed fire activity, especially within the USDA Forest Service, show that
the number of acres burned in prescribed fires during 2011 were lower than all other recent years. For
example, within the southern region of the Forest Service a total of 749,080 acres were treated with
prescribed fire in 2011, while the average number of acres treated annually from the years 2007-2019
was 980,422. The 2021 target for treatment by prescribed fire within the USDA Forest Service southern
region is well over 1 million acres. Furthermore, the Land Management Plans for each of the southern
Forests call for a cumulative total of up to 2.1 million acres per year to be treated with prescribed fire in
the future. Therefore, keeping prescribed fire emissions steady from to 2028 undercounts emissions in
the VISTAS states by up to fifty percent. At this point in the draft RH SIP review process, a quantitative
analysis to adjust the glidepaths for actual prescribed fire projections is not practical. While prescribed
fire is currently a minor contributor to visibility impairment on the 20% most impaired days, the USDA
Forest Service would like assurances that NC DAQ will continue to recognize the important ecological
role of prescribed fire and in the future adjust the glidepath to account for prescribed fire emissions
accordingly.