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ftlegional Haze 5-Year Periodic RevieNt
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Preface: This document contains summaries of the technical analyses that will be used by
North Carolina's Division of Air Quality to support the regional haze 5-year periodic review
state implementation plan pursuant to §§ 107(d)(3)(D) and (E) of the Clean Air Act, as amended.
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EXECUTIVE SUMMARY
Regional haze is pollution that impairs visibility over a large region, including national parks,
forests, and wilderness areas. Regional haze is caused by sources and activities emitting fine
particles and their precursors, often transported over large regions. Particles affect visibility
through the scattering and absorption of light. Reducing fine particles in the atmosphere is an
effective method of improving visibility. In the southeast, the most important sources of haze -
forming emissions are coal-fired power plants, industrial boilers and other combustion sources,
but also include mobile source emissions, area sources, fires, and wind blown dust.
An easily understood measure of visibility is visual range. Visual range is the greatest distance,
in kilometers or miles, at which a dark object can be viewed against the sky. However, the most
useful measure of visibility impairment is light extinction, which affects the clarity and color of
objects being viewed. The measure used by the regional haze rule is the deciview (dv),
calculated directly from light extinction using a logarithmic scale.
In Section 169A of the 1977 Amendments to the Clean Air Act (CAA), the U.S. Congress
established a program for protecting visibility in 156 mandatory Federal "Class I" areas. Class I
areas consist of national parks exceeding 6000 acres, wilderness areas and national memorial
parks exceeding 5000 acres, and all international parks that were in existence on August 7, 1977.
In the 1990 Amendments to the CAA, Congress added 169B and called on the U.S.
Environmental Protection Agency (USEPA) to issue regional haze rules addressing regional haze
impairment from manmade air pollution and establishing a comprehensive visibility protection
program for Class I areas.
The USEPA promulgated the Regional haze Rule on July 1, 1999 (64 FR 35713). States are
required to submit state implementation plans (SIPS) to the USEPA that set out each states' plan
for complying with the regional haze rule. States must demonstrate reasonable progress toward
meeting the national goal of a return to natural visibility conditions by 2064. The rule directs
states to graphically show what would be a "uniform rate of progress", also known as the "glide
path", toward natural conditions for each Class I area within the State and certain ones outside
the State. The first regional haze SIPS were due December 17, 2007.
North Carolina's Class I areas
North Carolina has five Class I areas within its borders: Great Smoky Mountains National Park,
Joyce Kilmer- Slickrock Wilderness Area, Linville Gorge Wilderness Area, Shining Rock
Wilderness Area, and Swanquarter Wildlife Refuge. Both the Great Smoky Mountains National
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Park and Joyce Kilmer- Slickrock Wilderness Area are located in both North Carolina and
Tennessee. The figure below illustrates the location of these Class I areas.
Currently, the visibility on the worst days at the mountain sites is generally between 25 and 27
dv, and visibility at Swanquarter is about 24 dv. Natural background visibility on the worst days
is between 11 and 12 dv.
State Implementation Plan Requirements for the 5-Year Periodic Review
States are required to submit state implementation plans (SIPS) to the United States
Environmental Protection Agency (USEPA) five years after the initial regional haze SIP was
submitted evaluating the progress towards the reasonable progress goals for each Class I area
located within the state and located outside the state which may be affected by emissions from
within the state. Since North Carolina's original regional haze SIP was submitted on December
17, 2007, the 5-year periodic review is due December 17, 2012.
The SIP must include 1) the status of implementation of control measures included in the
original regional haze SIP, 2) a summary of emission reductions achieved through the
implementation of control measures, 3) an assessment of visibility conditions, 4) an analysis of
the changes in emission pollutants, 5) an assessment of significant changes in emissions that may
have limited or impeded progress in improving visibility, 6) an assessment of whether the current
SIP elements and strategies are sufficient to meet reasonable progress goals and 7) a review of
the state's visibility monitoring strategy.
Conclusion
The control strategy in the original regional haze SIP continues to be implemented. Although the
Clean Air Interstate Rule has been remanded back to the USEPA, it remains in effect until the
USEPA promulgates another regulation to replace it. The North Carolina Clean Smokestacks
Act (CSA) continues to be implemented and the coal-fired electric generating units subject to
this Act emitted only 73,454 tons per year of sulfur dioxide (SO2) and 39,292 tons per year of
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nitrogen oxide (NOx) in 2011, well below the Act's system caps and well below what was
modeled in the original regional haze SIP.
The CSA was the primary State control strategy in the original regional haze SIP. The projected
2018 SO2 emissions in the original plan from the sources subject to the CSA were 93,301 tons
per year. The current 2018 projection of emissions from these sources are 18,420 tons per year,
approximately 80% lower than the 2018 projected emissions in the original regional haze plan,
due to both Duke Energy and Progress Energy deciding to convert some units to natural gas and
shut down small uncontrolled coal units.
North Carolina's Class I areas have seen improvement on the 20% worst days and all but
Swanquarter Wildlife Refuge has seen improvement on the 20% best days. At Swanquarter,
there was a slight increase seen, less than I dv. This could be in part due to having no data
available for 2008 in Swanquarter, which could affect the 5-year average. Also in 2007, 2009
and 2010, there was at least one day in each year where high levels of particulate organic matter
and elemental carbon observed in the spring or fall when a wildfire or prescribed fire might have
occurred and impacted the visibility. Finally, none of the controls planned for the electric
generating units located in the eastern part of the State have taken place yet. Therefore, the
NCDAQ believes that improvement in the visibility on the 20% best days will occur by 2018.
The baseline and current visibility conditions as well as the reasonable progress goals for 2018
for the 20% worst and 20% best days are displayed in the table below.
Class I Area
Baseline
(2000-2004)
Current
(2006-2010)
2018
Reasonable
Progress Goal
20% Worst Days
Great Smoky Mountain National Park
30.3
26.6
23.5
Joyce Kilmer-Slickrock
30.3
26.6
23.5
Linville Gorge
28.6
25.1
21.7
Shining Rock
28.5
25.8
21.9
Swanquarter
24.7
24.2
20.3
20% Best Days
Great Smoky Mountain National Park
13.6
12.3
12.1
Joyce Kilmer-Slickrock
13.6
12.3
12.1
Linville Gorge
11.1
11
9.5
Shining Rock
8.2
7.25
6.9
Swanquarter
12.0
12.9
10.9
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Since the new projection for 2018 emissions from the electric generating units subject to the
CSA are significantly lower than the projected 2018 emissions in the original regional haze SIP,
the North Carolina Division of Air Quality believes the state is on track to meet the 2018
reasonable progress goals for the North Carolina Class I areas and will not impede a Class I area
outside of North Carolina from meeting their goals.
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1.0 INTRODUCTION ....................................................................................................................
I
1.1 What is regional haze? ..........................................................................................................
1
1.2 What are the requirements under the Clean Air Act for addressing regional haze? .............
1
1.3 Class I areas in North Carolina .............................................................................................
3
1.4 General overview of regional haze SIP requirements ..........................................................
4
1.5 Requirements for Periodic Reports .......................................................................................
5
2.0 STATUS OF IMPLEMENTATION OF CONTROL MEASURES .......................................
7
2.1 Emission Reduction Strategies Included in VISTAS Final Modeling .................................
7
2.1.1 Federal Programs .........................................................................................................
7
2.1.2 Electric Generating Units Control Strategies ............................................................
12
2.2 Emission Control Measures Not Included in the VISTAS Final Modeling ......................
14
2.2.1 North American Emission Control Area ...................................................................
15
2.2.2 Residual Risk Requirements .....................................................................................
15
2.2.3 Control Technique Guidelines ..................................................................................
15
2.2.4 New EGU Control Strategies ....................................................................................
16
2.3 North Carolina EGU Sources and Status of Controls ........................................................
17
3.0 S UNIMARY OF EMISSION REDUCTIONS ACHIEVED ..........................................
25
4.0 REASONABLE PROGRESS GOALS UPDATED ..............................................................
29
5.0 VISIBILITY CONDITIONS .................................................................................................
30
6.0 ANALYSES OF EMISSIONS ..............................................................................................
37
7.0 ASSESSMENT OF CURRENT SIP STRATEGY ...............................................................
40
8.0 ASSESSMENT OF CURRENT MONITORING STRATEGY ...........................................
41
9.0 CONCLUSIONS ....................................................................................................................
44
LIST OF APPENDICES
Appendix A — 2006-2010 Reconstructed Extinction for North Carolina's Class I Areas
Appendix B — Emission Inventory Documentation
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1.1 What is regional haze?
Regional haze is pollution from disparate sources that impairs visibility over a large region,
including national parks, forests, and wilderness areas (156 of which are termed mandatory
Federal "Class I" areas). Regional haze is caused by sources and activities emitting fine particles
and their precursors. Those emissions are often transported over large regions.
Particles affect visibility through the scattering and absorption of light, and fine particles —
particles similar in size to the wavelength of light — are most efficient, per unit of mass, at
reducing visibility. Fine particles may either be emitted directly or formed from emissions of
precursors, the most important of which are sulfur dioxides (SO2) and nitrogen oxides (NOx).
Reducing fine particles in the atmosphere is generally considered to be an effective method of
reducing regional haze, and thus improving visibility. Fine particles also adversely impact
human health, especially respiratory and cardiovascular systems. The United States
Environmental Protection Agency (USEPA) has set national ambient air quality standards for
daily and annual levels of fine particles with diameter smaller than 2.5 micrometers (µm)
(PM2.5). In the southeast, the most important sources Of PM2.5 and its precursors are coal-fired
power plants, industrial boilers and other combustion sources. Other significant contributors to
PM2.5 and visibility impairment include mobile source emissions, area sources, fires, and wind
blown dust.
1.2 What are the requirements under the Clean Air Act for addressing regional haze?
In Section 169A of the 1977 Amendments to the Clean Air Act (CAA), Congress set forth a
program for protecting visibility in Class I areas which call for the "prevention of any future, and
the remedying of any existing, impairment of visibility in mandatory Class I Federal areas which
impairment results from manmade air pollution." Congress adopted the visibility provisions to
protect visibility in these 156 national parks, forests and wilderness areas. On December 2,
1980, the USEPA promulgated regulations in the Federal Register (FR) to address visibility
impairment (45 FR 80084). The 1980 regulations were developed to address visibility
impairment that is "reasonably attributable" to a single source or small group of sources. These
regulations represented the first phase in addressing visibility impairment and deferred action on
regional haze that emanates from a variety of sources until monitoring, modeling and scientific
knowledge about the relationships between pollutants and visibility impairment improved.
In the 1990 Amendments to the CAA, Congress added section 169B and called on the USEPA to
issue regional haze rules. The regional haze rule that the USEPA promulgated on July 1, 1999
(64 FR 35713), revised the existing visibility regulations in order to integrate provisions
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addressing regional haze impairment and establishing a comprehensive visibility protection
program for Class I Federal areas. States are required to submit state implementation plans
(SIPs) to the USEPA that set out each states' plan for complying with the regional haze rule,
including consultation and coordination with other states and with Federal Land Managers
(FLMs). The timing of SIP submittal is tied to the USEPA's promulgation of designations for
the National Ambient Air Quality Standard (NAAQS) for fine particulate matter. States must
submit a regional haze implementation plan to the USEPA within three years after the date of
designation. The USEPA promulgated designation dates on December 17, 2004, therefore the
first regional haze SIPS were due December 17, 2007.
The regional haze rule addressed the combined visibility effects of various pollution sources over
a wide geographic region. This wide reaching pollution net meant that many states — even those
without Class I areas — would be required to participate in haze reduction efforts. The USEPA
designated five Regional Planning Organizations (RPOs) to assist with the coordination and
cooperation needed to address the visibility issue for the first regional haze SIPS. The RPO that
made up the southeastern portion of the contiguous United States is known as VISTAS
(Visibility Improvement — State and Tribal Association of the Southeast), and includes the
following states: Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South
Carolina, Tennessee, Virginia, and West Virginia.
Figure 1.2-1. Geographical Areas of Regional Planning Organizations
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1.3 Class I areas in North Carolina
North Carolina has five Class I areas within its borders: Great Smoky Mountains National Park,
Joyce Kilmer-Slickrock Wilderness Area, Linville Gorge Wilderness Area, Shining Rock
Wilderness Area, and Swanquarter Wildlife Refuge. The Great Smoky Mountains and Joyce
Kilmer- Sli ckrock are located in both Tennessee and North Carolina. For the Great Smoky
Mountains, both states are sharing the lead for setting goals and for Joyce Kilmer- Slickrock,
North Carolina is the lead. The North Carolina Division of Air Quality (NCDAQ) in the North
Carolina Department of Environment and Natural Resources is responsible for developing the
Regional Haze Periodic Review SIP. This SIP compares the current visibility conditions at each
of these Class I areas to the 2018 reasonable progress goals to determine if North Carolina is on
track with reaching these goals. Although 2018 reasonable progress goals were established in
the initial regional haze SIP submitted on December 17, 2007, the VISTAS modeling continued
and additional controls were modeled in Tennessee and other Southeast states that changed the
final modeled reasonable progress goals for the Class I areas that Tennessee and North Carolina
share. Therefore, the NCDAQ will compare the current visibility conditions to the VISTAS's
best and final modeling analysis and use the results to adopt the new reasonable progress goals
for the shared Class I areas. Finally, this SIP will review the long-term strategy to determine if
there have been any changes that need to be addressed.
Figure 1.3-1. North Carolina's Class I areas
In developing the initial regional haze SIP, the NCDAQ also considered that emission sources outside of
North Carolina may affect the visibility at these North Carolina Class I areas, and that emission sources
within North Carolina may affect the visibility at Class I areas in neighboring states. Through VISTAS,
the southeastern states worked together to assess state -by -state contributions to visibility impairment in
specific Class I areas, including those in North Carolina and those affected by emissions from North
Carolina. The sources identified in the initial regional haze SIP either impacting North Carolina's Class
I areas or Class I areas outside North Carolina will be reviewed as part of this progress report.
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1.4 General overview of regional haze SIP requirements
The regional haze rule is codified in the Code of Federal Regulations (CFR) at Title 40 CFR
51.308. At 40 CFR 51.308(d), the rule requires states to demonstrate reasonable progress toward
meeting the national goal of a return to natural visibility conditions by 2064. As a guide for
reasonable progress, the regional haze rule directs states to graphically show what would be a
"uniform rate of progress" toward natural conditions for each mandatory Class I Federal area
within the State and/or for each mandatory Class I Federal area located outside the State, which
may be affected by emissions from sources within the State. States are to establish baseline
visibility conditions for 2000-2004, natural background visibility conditions in 2064, and the rate
of uniform progress between baseline and background conditions. The uniform rate of progress
is also known as the "glidepath."
The regional haze rule then requires states to establish reasonable progress goals, expressed in
deciviews, for visibility improvement at each affected Class I area covering each
(approximately) 10-year period until 2064. The goals must provide for reasonable progress
towards achieving natural visibility conditions, provide for improvement in visibility for the
most impaired days over the period of the implementation plan, and ensure no degradation in
visibility for the least impaired days over the same period (see 40 CFR 51.308(d)(1)).
In order to ensure that visibility goals are properly met and set, SIN must include
determinations, for each Class I area, of the baseline visibility conditions (expressed in
deciviews) for the most impaired and least impaired days. The SIPS must also contain
supporting documentation for all required analyses used to calculate the degree of visibility
impairment under natural visibility conditions for the most impaired and least impaired days (see
40 CFR 51.308(d)(2)). In addition, states must include a monitoring strategy for measuring,
characterizing, and reporting of regional haze visibility impairment that is representative of all
mandatory Class I Federal areas within the state (see 40 CFR 51.308(d)(4)).
This first set of reasonable progress goals must be met through measures contained in the state's
long-term strategy covering the period from the present until 2018. The long-term strategy
includes enforceable emissions limitations, compliance schedules, and other measures as
necessary to achieve the reasonable progress goals, including all controls required or expected
under all federal and state regulations by 2009 and by 2018. During development of the long-
term strategy, states are also required to consider specific factors such as the above mentioned
ongoing control programs, measures to mitigate construction activities, source retirement and
replacement schedules, smoke management techniques for agriculture and forestry, and
enforceability of specific measures (see 40 CFR 5 1.308(d)(3)).
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In addition, a specific component of each state's first long-term strategy is dictated by the
specific best available retrofit technology (BART) requirements in 40 CFR 51.308(e) of the
regional haze rule. The regional haze rule at 40 CFR 51.308(e) requires states to include a
determination of BART for each BART-eligible source in the State that emits any air pollutant,
which may reasonably be anticipated to cause or contribute to any impairment of visibility in any
mandatory Class I Federal area. The Clean Air Act section 169A(b) defines BART-eligible
sources as sources in 26 specific source categories, in operation within a 15-year period prior to
enactment of the 1977 Clean Air Act Amendments. States must determine BART according to
five factors set out in section 169A(g)(7) of the Clean Air Act. Emission limitations representing
BART and schedules for compliance with BART for each source subject to BART must be
included in the long-term strategy.
As required by 40 CFR §51.308(i), the regional haze SIP must include procedures for continuing
consultation between the States and FLMs on the implementation of the visibility protection
program, including development and review of implementation plan revisions and 5-year
progress reports, and on the implementation of other programs having the potential to contribute
to impairment of visibility in any mandatory Class I Federal area within the State. The three
FLMs are the United States Department of Interior (USDI) Fish and Wildlife Service (FWS) and
National Park Service (NPS) and the United States Department of Agriculture (USDA) Forest
Service (FS).
The SIPS for the first review period were due December 17, 2007. These plans covered long-
term strategies for visibility improvement between baseline conditions in 2000-2004 and 2018.
States are required to evaluate progress toward reasonable progress goals every 5 years to assure
that installed emissions controls are on track with emissions reduction forecasts in each SIP. The
first interim review is due to the USEPA five years after the initial SIP was submitted, which for
North Carolina is December 17, 2012. If emissions controls are not on track to meet SIP
forecasts, then states would need to take action to assure emissions controls by 2018 will be
consistent with the SIP or to revise the SIP to be consistent with the revised emissions forecast.
This SIP is to address the first interim, or periodic, review.
MZM3=
The requirements for the periodic reports are outlined in 40 CFR 51.308(g). Each state must
submit a report to the USEPA every five years evaluating the progress towards the reasonable
progress goal for each Class I area located within the state and in each Class I area located
outside the state which may be affected by emissions from within the state. As stated earlier,
NC's first periodic report is due on December 17, 2012. The progress report must be a formal
SIP submittal and at a minimum, must contain the following elements:
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(1) A description of the status of implementation of all measures included in the SIP for
achieving reasonable progress goals for Class I areas both within and outside the state.
(2) A summary of the emission reductions achieved throughout the state through
implementation of the measures described in (1) above.
(3) For each Class I area within the state, the state must assess the following visibility
conditions and changes, with values for most impaired and least impaired days expressed
in terms of 5-year averages of these annual values
(i) The current visibility conditions for the most impaired and least impaired days;
(ii) The difference between current visibility conditions for the most impaired and
least impaired days and baseline visibility conditions;
(iii) The change in visibility impairment for the most impaired and least impaired
days over the past 5 years;
(4) An analysis tracking the change over the past 5 years in emissions of pollutants
contributing to visibility impairment from all sources and activities with the state.
Emissions changes should be identified by type of source or activity. The analysis must
be based on the most recent updated emissions inventory, with estimates projected
forward as necessary and appropriate, to account for emissions changes during the
applicable 5-year period.
(5) An assessment of any significant changes in anthropogenic emissions within or outside
the state that have occurred over the past 5 years that have limited or impeded progress in
reducing pollutant emissions and improving visibility.
(6) An assessment of whether the current SIP elements and strategies are sufficient to enable
the state, or other states with Class I areas affected by emissions from the state, to meet
all established reasonable progress goals.
(7) A review of the state's visibility monitoring strategy and any modifications to the
strategy as necessary.
In the sections to follow, the NCDAQ will address the various progress report requirements as
outlined above.
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This section provides a description of the emission reduction measures that were included in the
VISTAS regional haze best and final inventory and reasonable progress goal modeling effort. In
instances where implementation of a measure did not occur in a timely manner, information is
provided on the source category and its relative impact on the overall future year emissions
inventories.
The sections below also contain information on emissions strategies that were not included in the
best and final inventory and modeling effort. At the time of the best and final inventory
development process, these measures were not fully documented or had not yet been published
in final form, and therefore the benefits of these measures were not included in future year
inventories. Emission reductions from these measures will help ensure that each Class I area
meets or exceeds the visibility progress goal set in the regional haze SIP.
This section also includes a summary of the emission sources and status of controls installed that
were identified in the area of influence for each Class I area in North Carolina in the initial
regional haze SIP. Additionally, a summary of those emission sources and the status of controls
installed that were identified to impact Class I areas outside of North Carolina is provided.
rI I Tr MMMUMUMEM�M,
2.1.1 Federal Programs
The emission reductions associated with the federal programs that are described by the following
paragraphs were included in the VISTAS future year emissions estimates. Descriptions contain
qualitative assessments of emissions reductions associated with each program, and where
possible, quantitative assessments. In cases where delays or modification have altered emissions
reduction estimates such that the original estimates of emissions are no longer accurate,
information is also provided on the effects of these alterations.
2007 Heavy -Duty Highway Rule 40 CFR Part 86, Subpart P)
In this regulation, the USEPA set a particulate matter (PM) emissions standard for new heavy-
duty engines of 0.01 gram per brake horsepower -hour (g/bhp-hr), which took full effect for
diesel engines in the 2007 model year. This rule also included standards for nitrogen oxides
(NOx) and non -methane hydrocarbons (NMHC) of 0.20 g/bhp-hr and 0.14 g/bhp-hr,
respectively. These diesel engine NOx and NMHC standards were successfully phased in
together between 2007 and 2010. The rule also required that sulfur in diesel fuel be reduced to
facilitate the use of modern pollution -control technology on these trucks and buses. The USEPA
required a 97 percent reduction in the sulfur content of highway diesel fuel -- from levels of 500
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parts per million (ppm) (low sulfur diesel) to 15 ppm (ultra -low sulfur diesel). These
requirements were successfully implemented on the timeline in the regulation.
Tier 2 Vehicle and Gasoline Sulfur Program (40 CFR Part 80 Subpart H, Part 85, Part 86)
The USEPA's Tier 2 fleet averaging program for on -road vehicles, modeled after the California
low emitting vehicles (LEV) 11 standards, became effective in the 2005 model year. The Tier 2
program allows manufacturers to produce vehicles with emissions ranging from relatively dirty
to very clean, but the mix of vehicles a manufacturer sells each year must have average NOX
emissions below a specified value. Mobile emissions continue to benefit from this program as
motorists replace older, more polluting vehicles with cleaner vehicles.
Nonroad Mobile Diesel Emissions Program (40 CFR Part 89)
The USEPA adopted standards for emissions of NOx, hydrocarbons, and carbon monoxide (CO)
from several groups of nonroad engines, including industrial spark -ignition engines and
recreational nonroad vehicles. Industrial spark -ignition engines power commercial and industrial
applications and include forklifts, electric generators, airport baggage transport vehicles, and a
variety of farm and construction applications. Nonroad recreational vehicles include
snowmobiles, off -highway motorcycles, and all -terrain vehicles. These rules were initially
effective in 2004 and were fully phased in by 2012. Mobile emissions continue to benefit from
this program as motorists replace older, more polluting vehicles with cleaner vehicles.
The nonroad diesel rule set standards that reduced emissions by more than 90 percent from
nonroad diesel equipment and, beginning in 2007, the rule reduced fuel sulfur levels by 99
percent from previous levels. The reduction in fuel sulfur levels applied to most nonroad diesel
fuel in 2010 and applied to fuel used in locomotives and marine vessels in 2012.
Maximum Achievable Control Technology Programs (40 CFR Part 63)
VISTAS applied controls to future year emissions estimates from various maximum achievable
control technology (MACT) regulations for volatile organic compounds (VOC), S02, NOx, and
PM on source categories where controls were installed on or after 2002. Control estimates are
documented in the report entitled, "Control Packet Development and Data Sources", Alpine
Geophysics, July 14, 2004. Table 2-1 describes the MACTs used as control strategies for the
non -electric generating units point source emissions. The table notes the pollutants for which
controls were applied as well as the promulgation dates and the compliance dates for existing
sources.
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Table 2-1. MACT Source Categories with Compliance Dates on or after 2002
Existing
MACT Source Category
40CFR63
Date
Source
Pollutants
Subpart
Promulgated
Compliance
Affected
Date
Parts
Hazardous Waste Combustion
63(EEE),
9/30/99
9/30/03
PM
(Phase 1)
261 and
270
Oil & Natural Gas Production
HH
6/17/99
6/17/02
VOC
Polymers and Resins 111
000
1/20/00
1/20/03
VOC
Portland Cement Manufacturing
LLL
6/14/99
6/10/02
PM
Publicly Owned Treatment Works
VVV
10/26/99
10/26/02
VOC
(POTW)
Secondary Aluminum Production
RRR
3/23/00
3/24/03
PM
Combustion Sources at Kraft, Soda,
and Sulfite Pulp & Paper Mills (Pulp
Mm
1/12/01
1/12/04
VOC
and Paper MACT 11)
Municipal Solid Waste Landfills
AAAA
1/16/03
1/16/04
VOC
Coke Ovens
L
10/27/93
Phased from
VOC
1995-2010
Coke Ovens: Pushing, Quenching,
CCCCC
4/14/03
4/14/06
VOC
and Battery Stacks
Asphalt Roofing Manufacturing and
Asphalt Processing (two source
LLLLL
4/29/031
5/1/06
VOC
categories)
Metal Furniture (Surface Coating)
RRRR
5/23/03
5/23/06
VOC
Printing, Coating, and Dyeing of
0000
5/29/031
5/29/06
VOC
Fabrics
Wood Building Products (Surface
QQQQ
5/28/03
5/28/06
VOC
Coating)
Lime Manufacturing
AAAAA
1/5/04
1/5/07
PM, SO2
Site Remediation TSDF
GGGGG
10/8/031
10/8/06
VOC
Iron & Steel Foundries
EEEEE
4/22/04
04/23/07
VOC
Taconite Iron Ore Processing
RRRRR
10/30/03
10/30/06
PM, SO2
Miscellaneous Coating
HHHHH
12/11/03
12/11/06
VOC
Manufacturing
Pre -Draft Regional Haze 5 -Year Periodic Review SIP 9
For the North Carolina Class I Areas September 18, 2012
DEQ-CFW-00009231

Table 2-1. MACT Source Categories with Compliance Dates on or after 2002
Existing
MACT Source Category
40CFR63
Date
Source
Pollutants
Subpart
Promulgated
Compliance
Affected
Date
Metal Can (Surface Coating)
KKKK
11/13/03
11/13/06
VOC
Plastic Parts and Products (Surface
PPPP
4/19/04
4/19/07
VOC
Coating)
Miscellaneous Metal Parts and
MMMM
1/2/04
1/2/07
VOC
Products (Surface Coating)
Industrial Boilers, Institutional/
Commercial Boilers and Process
DDDDD
9/13/04
9/13/07
PM SO2
Heaters '
Plywood and Composite Wood
DDDD
7/30/04
10/1/07
VOC
Products
Reciprocating Internal Combustion
ZZZZ
6/15/04
6/15/07
NOx, VOC
Engines
Auto and Light -Duty Truck (Surface
1111
4/26/04
4/26/07
VOC
Coating)
Wet Formed Fiberglass Mat
HHHH
4/11/02
4/11/05
VOC
Production
Metal Coil (Surface Coating)
SSSS
6/10/02
6/10/05
VOC
Paper and Other Web Coating
Hij
12/4/02
12/4/05
VOC
(Surface Coating)
Petroleum Refineries
UUU
4/11/02
4/11/05
VOC
Miscellaneous Organic Chemical
FFFF
11/10/03
05/10/08
VOC
L Production (MON)
Use of the Industrial/Commercial/Institutional (ICI) boiler MACT standard was problematic in
that the U.S. Court of Appeals for the District of Columbia Circuit vacated and remanded that
regulation to the USEPA on June 8, 2007. However, VISTAS chose to leave the emissions
reductions associated with this regulation in place since the Clean Air Act required use of
alternative control methodologies under Section 1120) for uncontrolled source categories. The
applied MACT control efficiencies were 4 percent for SO2 and 40 percent for coarse particulate
matter (PM,o) and fine particulate matter (PM2.5) to account for the co -benefit from installation
of acid gas scrubbers and other control equipment to reduce hazardous air pollutants (HAPs).
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
10
September 18, 2012
DEQ-CFW-00009232

To determine how the vacature of this regulation may have affected the VISTAS future year
inventories, VISTAS created an analysis of inventory data to determine the level Of S02, PM10,
and PM2.5 reductions associated with the vacated regulation. Table 2-2 compares the level of
emission reductions for VISTAS in 2009 and 2018 estimated to be derived from the vacated
regulation to the total non -electric generating unit point source inventory for those years and to
the total annual inventory for those years.
Table 2-2. ICI Boiler MACT Reductions Compared to the 2009 and 2018 VISTAS
Inventory
— 11LIS I
Primary PM2.5, tpY
_3468,899
2,169,773
"'ICI Boiler MACT reduction estimates taken from VISTAS Boiler MACT 20080611.)Cll-
(2)Data from Documentation of the Base G2 and Best & Final 2002 Base Year, 2009 and 2018
Emission Inventories for VISTAS -Revision 1, April 9, 2008 (Table 2.1-15, Table 2.1-19, Table
2.1-20, and Appendix A).
The emission reductions associated with the vacated ICI Boiler MACT were a very small
percentage of overall non -electric generating units and total inventory emissions for each of the
affected pollutants. The USEPA finalized the revised ICI Boiler MACT on February 21, 2011.
However, in March of 2011, the USEPA published a notice stating their intention to reconsider
certain aspects of the boiler and commercial and industrial solid waste incinerator rules and
subsequently proposed the relevant changes on December 2, 2011. The final rulemaking is
expected to be made by fall 2012. The final compliance date is then expected to be three years
later in late 2015. The USEPA estimates that implementation of the revised rulemaking will
reduce emissions nationwide from major source boilers and process heaters by 47,000 tons per
year (tpy) of PM, 440,000 tpy Of S02, and 7,000 tpy of VOCs.
Federal Consent Agreements
The VISTAS 2009 and 2018 emissions inventories took into account unit specific requirements
from several federal consent orders applicable to source types other than electrical generation, as
described below.
•Dupont (US District Court for the Southern District of Ohio): A 2007 agreement called for
the James River plant, located in Virginia, to install dual absorption pollution control
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
II
September 18, 2012
DEQ-CFW-00009233

equipment by September 1, 2009, resulting in emission reductions of approximately
1,000 tons Of SO2 annually. The sulfuric acid plant emitted 1,145 tons of SO2 in 2002.
In 2009, the year in which controls were applied, the plant emitted 379 tons Of S02, and
in 2010 the plant emitted 42 tons of S02.
•Stone Container (US District Court, Eastern District of Virginia): A 2004 agreement called
for the West Point Paper Mill, owned by Smurfit/Stone Container and located in West
Point, Virginia, to control SO2 emissions from the 48 Power Boiler with a wet scrubber.
This device was installed and operational in October of 2007. Emissions Of SO2 from the
facility during 2002 were 4,575 tons. Emissions Of SO2 from the facility during 2009,
after installation of the scrubber, were 1,009 tons. Emissions Of SO2 in 2010 from the
facility were 1,252 tons.
2.1.2 Electric Generating Units Control Strategies
Emissions from electric generating units (EGUs) have been regulated through a number of
mechanisms, including Clean Air Interstate Rule (CAIR), Cross State Air Pollution Rule
(CSAPR), State programs, and federal consent agreements. Reductions associated with many of
these mechanisms were used to estimate the 2018 visibility improvements at the VISTAS Class I
areas.
North Carolina Clean Smokestacks Act
In June of 2002, the North Carolina General Assembly enacted the Clean Smokestacks Act
(CSA), which required significant actual emissions reductions from coal-fired power plants in
North Carolina. These reductions were included as part of the VISTAS 2018 Best and Final
modeling effort. Under the act, power plants were required to reduce their NOx emissions by
77% in 2009 and their SO2 emission by 73% in 2013. Actions taken to date by facilities subject
to these requirements comply with the provisions of the CSA, and compliance plans and
schedules will allow these entities to achieve the emissions limitations set out by the Act. This
program has been highly successful. In 2009, regulated entities emitted less than the 2013
system annual cap of 250, 000 tons Of SO2 and less than the 2009 system annual cap of 56,000
tons of NOx. In 2002, the sources subject to CSA emitted 459,643 tons Of SO2 and 142,770 tons
of NOx. In 2011, these sources emitted only 73,454 tons Of SO2 and 39,284 tons of NOx, well
below the Act's system caps.
Georgia Multi -Pollutant Control for Electric Utility Steam Generating Units
Georgia rule 391-3-1.02(2)(sss), enacted in 2007, requires flue -gas desulphurization (FGD) and
selective catalytic reduction (SCR) controls on coal fired EGUs in Georgia. Reductions from
this regulation were included as part of the VISTAS 2018 best and final modeling effort. These
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
12
September 18, 2012
DEQ-CFW-00009234

controls will reduce SO2 emissions from the affected emissions units by at least 95 percent and
will reduce NOx emissions by approximately 85 percent. Control implementation dates vary by
EGU, starting on December 31, 2008.
Marvland Healthy Air Act
The Maryland Healthy Air Act (HAA) regulations became effective on July 16, 2007 and
required reductions in NO-,,,, S02, and mercury emissions from large coal burning power plants in
Maryland. Emission reductions from the HAA come in two phases. The first phase required
reductions in the 2009/2010 timeframe, and compared to a 2002 emission baseline, reduced NOX
emission by almost 70 percent and SO2 emission by 80 percent. The second phase of emissions
controls occurs in the 2012/2013 time frame. At full implementation, the HAA will reduce NOX
emissions by approximately 75 percent from 2002 levels and SO2 emissions by approximately 85
percent from 2002 levels. Maryland is not a VISTAS participant. However, Maryland borders
two VISTAS states, and Maryland facilities have calculated sulfate visibility impairment
contributions to several VISTAS Class I areas. The first phase of the HAA was successfully
implemented, and the second phase of the program is expected to be implemented in a timely
manner. Reductions associated with this program were included as part of the VISTAS 2018
Best and Final modeling effort.
Clean Air Interstate Rule and Cross State Air Pollution Rule
On May 12, 2005, the USEPA promulgated CAIR, which required reductions in emissions of
NOx and SO2 from large fossil fuel fired EGUs. These emission reductions were included as
part of the VISTAS 2018 best and final modeling effort. The U.S. Court of Appeals for the D.C.
Circuit ruled on petitions for review of CAIR and CAIR Federal Implementation Plans, including
their provisions establishing the CAIR NOx annual and ozone season and SO2 trading programs.
On July 11, 2008, the Court issued an opinion vacating and remanding these rules. However,
parties to the litigation requested rehearing of aspects of the Court's decision, including the
vacatur of the rules. On December 23, 2008, the Court remanded the rules to the USEPA without
vacating them. The December 23, 2008 ruling left CAIR in place until the USEPA issues a new
rule to replace CAIR in accordance with the July 11, 2008 decision.
On July 6, 2011, the USEPA finalized the Cross -state Air Pollution Rule (CSAPR). This rule
replaces CAIR beginning 2012 and requires 27 states in the eastern half of the United States to
reduce power plant emissions. The USEPA also issued a supplemental proposal for six states to
make summer time NOx reductions. This supplemental proposal, when finalized, would bring
the total number of states participating in the program to 28. CSAPR was estimated to reduce
2005 emissions from EGUs by 6,500,000 tons of SO2 annually and 1,400,000 tons of NOx
annually in the covered states. These estimates represent a 71 percent reduction in SO2 and a 52
percent reduction in NOx from 2005 levels.
Pre -Draft Regional Haze 5-Year Periodic Review SIP
For the North Carolina Class I Areas
13
September 18, 2012
DEQ-CFW 00009235

On December 30, 2011, the U.S. Court of Appeals for the D.C. Circuit issued a ruling to stay the
CSAPR pending judicial review. The court heard oral arguments on April 13, 2012, and issued a
decision on August 21, 2012, vacating the CSAPR. Further, the court remanded the case to EPA
for action consistent with the decision. The court directed EPA to continue implementing CAIR
while the agency works on a replacement rule.
Utilitv Federal Consent Orders
Federal consent agreements with major utilities contained remedies that imposed control
requirements or other reductions in future year emissions. These requirements were taken into
account in the VISTAS 2018 Best and Final Inventory.
•Under a settlement agreement, Tampa Electric installed permanent emissions control
equipment by 2008 to meet stringent pollution limits; implemented a series of
interim pollution -reduction measures to reduce emissions while the permanent
controls were designed and installed; and retired pollution emission allowances
that Tampa Electric or others could use, or sell to others, to emit additional NO.x,
•In the VEPCO (Dominion Power) consent agreement, the utility agreed to spend
$1.2 billion by 2013 to eliminate 237,000 tons Of S02 and NOx emissions each
year from eight coal-fired EGUs in Virginia and West Virginia. Installation of
these controls proceeded well ahead of schedule.
•The Gulf Power agreement required Gulf Power to upgrades to cut NOx emission
rates by 61 percent at its Cri st generating plant by 2007.
•American Electric Power agreed to spend $4.6 billion dollars to eliminate 72,000
tons of NOx emission annually by 2016 and 174,000 tons Of SO2 emissions
annually by 2018 from sixteen plants located in Indiana, Kentucky, Ohio,
Virginia, and West Virginia.
2.2 Emission Control Measures Not Included in the VISTAS Final Modeling
Since development of the 2018 Best and Final inventory effort, a number of regulations and
requirements have been promulgated that were not included in 2018 estimates. The sections
below provide information on these requirements, and where possible, estimates of additional
reductions are provided. These reductions provide extra assurances that the VISTAS Class I
areas will meet their reasonable progress goals in a timely manner.
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
14
September 18, 2012
DEQ-CFW-00009236

2.2.1 North American Emission Control Area
On March 26, 2010, the International Maritime Organization officially designated waters off
North American coasts as an area in which stringent international emission standards will apply
to ships. These standards will reduce air pollution from ships and deliver air quality benefits that
extend hundreds of miles inland. In 2020, the USEPA expects emissions from ships operating in
the designated area to be reduced by 320,000 tons for NOx, 90,000 tons for PM2.5, and 920,000
tons for S02, which is 23 percent, 74 percent, and 86 percent, respectively, below predicted
levels in 2020 absent the Emissions Control Area designation.
Implementation of the Emission Control Area means that ships entering the designated area
would need to use compliant fuel for the duration of their voyage that is within that area,
including time in port as well as voyages whose routes pass through the area without calling on a
port. The requirements for quality of fuel change over time. From the effective date in 2012
until 2015, fuel used by all vessels operating in designated areas cannot exceed 10,000 ppm
sulfur content. Beginning in 2015, fuel used by vessels operating in these areas cannot exceed
1,000 ppm sulfur content, and beginning in 2016, NO_x after -treatment requirements become
applicable.
"PEN [R=1 #�. =
The Clean Air Act requires the USEPA to assess the risk remaining after application of final
technology -based air toxics standards to any source category within 8 years of setting the
technology based MACT standards. In the residual risk process, the USEPA must assess the
remaining health risks from each source category to determine whether the MACT standards
provide an ample margin of safety to protect public health and protect against adverse
environmental effects. Final rules for this Clean Air Act requirement are expected for 28 source
categories between 2011 and 2013. Additional requirements to reduce toxic air emissions under
the residual risk assessment may also have co -benefits for the reduction of VOC and other
criteria pollutant emissions between now and 2018.
2.2.3 Control Technique Guidelines
The federal Clean Air Act (§ 172(c)(1)) provides that SIPs for nonattainment areas must include
reasonably available control techniques (RACT) for control of emissions that contribute to the
formation of ozone air pollution. Section 182(b)(2) provides that for certain nonattainment
areas, states must revise their SIPS to include RACT for sources of VOC emissions covered by a
control techniques guidelines document (CTG). Section 183(e) then directs the USEPA to list
for regulation those categories of products that account for at least 80 percent of the VOC
emissions from commercial products in ozone nonattainment areas.
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
15
September 18, 2012
DEQ-CFW-00009237

RACT controls for source categories controlled by a CTG are known as CTG RACTs. CTG
RACTs have been issued for various printing, coating, and cleaning operations. In 2006, 2007,
and 2008, the USEPA published CTGs as listed in Table 2-3. These regulations, which must be
implemented in ozone nonattainment areas and the Ozone Transport Region within I year of
becoming final, will reduce emissions of VOCs from areas in which they are required.
Table 2-3. CTGs Promulgated in 2006, 2007, and 2008
Category
EPA Document Number
Industrial Cleaning Solvents
EPA-453/R-06-001
Offset Lithographic Printing and Letterpress Printing
EPA-453/R-06-002
Flexible Package Printing
EPA-453/R-06-003
Flat Wood Paneling Coatings
EPA-453/R-06-004
Paper, Film, and Foil Coatings
EPA-453/R-07-003
Large Appliance Coatings
EPA-453/R-07-004
Metal Furniture Coating
EPA-453/R-07-005
Miscellaneous Metal and Plastic Parts Coatings
EPA-453/R-08-003
Fiberglass Boat Manufacturing Materials
EPA-453/R-08-004
Miscellaneous Industrial Adhesives
EPA-453/R-08-005
Automobile and Light -Duty Truck Assembly Coatings
EPA-453/R-08-006
2.2.4 New EGU Control Strategies
Two federal programs and one federal consent agreement will provide further reductions in SO2
from the EGU source sector, either as a result Of SO2 requirements or as co -benefit from the
reduction of HAPs. These benefits were not considered in the development of the VISTAS Best
and Final 2018 inventories. Any additional SO2 emission reduction benefits achieved by the
implementation of these requirements will help to ensure that all Class I areas in VISTAS meet
their reasonable progress goals in a timely manner.
Mercury and Air Toxics Rule
On December 16, 2011, the USEPA finalized national CAA standards to reduce mercury and
other toxic air pollution from coal and oil -fired power plants. The final rule established power
plant emission standards for mercury, acid gases, and non -mercury metallic toxic pollutant that
will prevent 90 percent of the mercury in coal burned in power plants from being emitted to the
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
16
September 18, 2012
DEQ-CFW-00009238

air; reduce by 88 percent the acid gas emissions from power plants; and cut power plant SO2
emissions by 41 percent beyond the reductions expected from CSAPR. These reductions are
expected in the 2016 time frame.
On June 2, 2010, the USEPA strengthened the primary NAAQS for SO2 by revising the primary
SO2 standard to 75 parts per billion (ppb) averaged over one hour. This short term standard is
significantly more stringent than the revoked standards of 140 ppb averaged over 24 hours and
30 ppb averaged annually. Under the new standard, facilities with significant emissions Of S02,
many of which are EGUs, may be required to demonstrate compliance with the standard no later
than 2017.
Tennessee Valley Authority Federal Consent Agreement
In April of 2011, the USEPA announced a settlement with the Tennessee Valley Authority
(TVA) to resolve alleged Clean Air Act violations at 11 of its coal fired plants in Alabama,
Kentucky, and Tennessee. The settlement requires TVA to invest $3 billion to $5 billion on new
and upgraded state-of-the-art pollution controls. Once fully implemented, the pollution controls
and other required actions will address 92 percent of TVA's coal-fired power plant capacity,
reducing emissions of NO.x by 69 percent and SO2 by 67 percent from TVA's 2008 emissions
levels.
2.3 North Carolina EGU Sources and Status of Controls
As determined in the initial regional haze SIP, ammonium sulfate is the largest contributor to
visibility impairment at the North Carolina Class I areas, and reduction Of SO2 emissions is the
most effective means of reducing ammonium sulfate. The coal-fired EGUs were the largest
contributors to SO2 emissions and the focus in the initial regional haze SIP was on controlling
these sources. Table 2-4 lists the coal-fired EGU sources owned by Duke Energy or Progress
Energy in North Carolina, the SO2 emission controls included in the initial regional haze SIP and
the status of those controls. As illustrated in Table 2-4, all of the coal-fired units will either be
controlled with a scrubber or retired by January 2015. This will result in significantly more SO2
emission reductions than what was demonstrated in the initial regional haze SIP.
Table 2-5 displays the sources located in the area of influence for each of the North Carolina
Class I areas, the SO2 emission controls included in the initial regional haze SIP and the status of
those controls. One coal-fired EGU in North Carolina was determined to be in the area of
influence of the James River Face Class I area in Virginia (Table 2-6). This plant was retired in
April 2012 and replaced with combustion turbines in August 2012.
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
17
September 18, 2012
DEQ-CFW-00009239

Table 2-4. North Carolina EGUs and Status of Controls
Emission
SIP
Facility
Emission
Controls
Required
Status of Controls*
Unit
Included
Control
in SIP
Date
1
Scrubber
2005
Controls installed 2005 and
Progress Energy -
operational
Controls installed 2006 and
Asheville
2
Scrubber
2006
operational
Progress Energy -
5
Scrubber
2011
No control - Retired Oct 2012
6
Scrubber
2012
No control - Retired Oct 2012
Cape Fear
1
None
Retire fall 2012
Progress Energy -
2
None
Retire fall 2012
H.F. Lee
3
None
Retire fall 2012
1
Scrubber
2008
Controls installed 2008 and
operational
2
Scrubber
2007
Controls installed 2007 and
operational
3A
Scrubber
2008
Controls installed 2008 and
Progress Energy -
operational
Controls installed 2008 and
Roxboro
3B
Scrubber
2008
operational
4A
Scrubber
2007
Controls installed 2007 and
operational
4B
Scrubber
2007
Controls installed 2007 and
operational
1
None
Retire end 2013
Progress Energy -
2
None
Retire end 2013
L.V. Sutton
3
Scrubber
2012
No control - Retire 2013
1
None
Retired fall 2011
Progress Energy -
2
None
Retired fall 2011
Weatherspoon
3
None
Retired fall 2011
1
Scrubber
2009
Controls installed 2009 and
operational
2
Scrubber
2009
Controls installed 2009 and
operational
3
Scrubber
2009
Controls installed 2009 and
Duke Energy -
Allen Steam Station
operational
4
Scrubber
2009
Controls installed 2009 and
operational
5
Scrubber
2009
Controls installed 2009 and
operational
Pre -Draft Regional Haze 5-Year Periodic Review SIP
For the North Carolina Class I Areas
18
September 18, 2012
DEQ-CFW 00009240

Table 2-4. North Carolina EGUs and Status of Controls
Emission
SIP
Facility
Emission
Unit
Controls
Included
Required
Control
Status of Controls
in SIP
Date
5
None
Retired mid 2011
6
None
Retired mid 2011
Duke Energy - Buck
Steam Station
7
None
Retired mid 2011
8
None
Retire Jan 2015
9
None
Retire Jan 2015
1
None
Retired Oct 2011
2
None
Retired Oct 2011
Duke Energy -
Cliffside
3
None
Retired Oct 2011
4
None
Retired Oct 2011
5
Scrubber
2010
Controls installed 2010 and
operational
6
Scrubber
2011
Controls installed in 2012
1
None
Retire April 2012
Duke Energy -Dan
River
2
None
Retired April 2012
3
None
Retire April 2012
1
Scrubber
2007
Controls installed 2007 and
operational
2
Scrubber
2007
Controls installed 2007 and
operational
Duke Energy -
3
Scrubber
2007
Controls installed 2007 and
operational
Marshall
4
Scrubber
2006
Controls installed 2006 and
operational
7
None
Retire Jan 2015
Duke Energy -
8
None
Retire Jan 2015
9
None
Retire Jan 2015
Riverbend
10
None
Retire Jan 2015
Progress Energy -
lA
Scrubber
2009
Controls installed 2009 and
operational
I
Scrubber
2009
Controls installed 2009 and
operational
Mayo
Duke Energy -
1
Scrubber
2008
Controls installed 2008 and
operational
2
Scrubber
2008
Controls installed 2008 and
operational
Belews Creek
Pre -Draft Regional Haze 5-Year Periodic Review SIP
For the North Carolina Class I Areas
19
September 18, 2012
DEQ-CFW 00009241

Offilf-29M-TIM1
SIP
State
Facility
Emission
Class I Area
Emission Controls
Required
Status of Controls*
Unit
Impacted
Included in SIP
Control
Date
Alabama
TVA —
008
JOKI
Scrubber
Operational
Scrubber installed and
Widow Creek
in base year
operational
Georgia
Georgia
SG06,
JOKI
Scrubbers
By 2018
Scheduled to be completed by
Power — Yates
SG07
6/1/2015
Georgia
SGO1,
Unit 3 in place 7/2011
Georgia
Power —
SG02,
SG03,
JOKI
Scrubbers
By 2018
Units 1, 2, & 4 to be in place
Scherer
SG04
by 2015, 2014 & 2013
Georgia
SG03
All in place and operational
Georgia
Power -
SG04
JOKI
Scrubbers
By 2018
last unit started 6/ l/2010
Bowen
G-25, G-
North
Blue Ridge
65 G-24
JOKI, LIGO,
Carolina
Paper
GG-
SHRO
None
NIA
N/A
G26, G-
31, G32
Units lthrough 4 retired
North
Duke Energy
Units 3 & 4 —None
N/A
2011; Unit 5 scrubber in
Carolina
— Cliffside
3, 4, 5
LIGO
Unit 5 — Scrubber
2010
operation 2010; Unit 6 to
begin operation with scrubber
in 2012.
North
Duke Energy
416,7
LIGO
None
N/A
All coal-fired units to be
Carolina
— Riverbendretired
by 1/1/2015
North
Duke Energy
#3 — 2007
Controls installed and
Carolina
— Marshal
3, 4
LIGO
Scrubbers
#4 — 2008
operational by SIP control
date
North
Duke Energy
8,9
LIGO
None
N/A
Units to be retired by
DEQ-CFW 00009242

Table 2-5. Source in Area Influence of North Carolina Class I Areas
SIP
State
Facility
Emission
Class I Area
Emission Controls
Required
Status of Controls*
Unit
Impacted
Included in SIP '
Control
Date
Carolina
—Buck
1/1/2015
North
Ecusta
G-28, G-
SHRO
None
N/A
Facility shutdown
Carolina
29
North
Progress
#1 — 2005
Controls installed and
Carolina
Energy —
1,2
SHRO
Scrubbers
#2 — 2006
operational by SIP control
Asheville
date
North
PCs
Units 3 & 4 shutdown so that
Carolina
Phosphate
314, 5,6
SWAN
None
N/A
new Unit 7 could be brought
on-line.
North
Weyerhaeuser
Carolina
Plymouth
31, 32, 40
SWAN
None
N/A
N/A
(Domtar)
North
Weyerhaeuser
1
SWAN
None
N/A
N/A
Carolina
Vanceboro
North
Progress
All coal-fired units to be
Carolina
Energy -
3
SWAN
Scrubber
2012
retired by 2013; fuel
Sutton
switching to natural gas
North
Progress
All coal-fired units to be
Carolina
Energy - Lee
2 3
SWAN
None
N/A
retired by fall 2012, switching
to natural gas
The company is currently
Cogentrix
burning wood. They retain
North
Kenansville
coal as a permitted fuel, with
Carolina
(Coastal
Genl
SWAN
None
N/A
no immediate plans to use it.
Carolina
Their new business plan is to
Clean Power)
continue as part of the "green
power" movement in NC.
DEQ-CFW 00009243

Table 2-5. Source in Area Influence of North Carolina Class I Areas
SIP
State
Facility
Emission
Class I Area
Emission Controls
Required
Status of Controls*
Unit
Impacted
Included in SIP
Control
Date
TVA Bull
GSMNP,
Install FGD or retire by
Tennessee
Run Fossil
001
JOKI, LIGO,
Wet Scrubber
By 2018
December 31, 2018
Plant
SHRO
Alcoa —
Primary
Tennessee
South Plant
Aluminum
GSNINP,
Coke Sulfur content
2017
Permit condition in place to
(BART
Smelting
JOKI
not to exceed 3%
meet scheduled control date
Source)
Operation
A.E. Staley
GSMNP,
Tennessee
Manufacturin
005
JOKI
None
N/A
N/A
g Company
Eastman
Powerhou
Permit condition place to
Chemical
se B-253-
-
GSMNP,
Reduce SO2
2017/
meet scheduled control date.
Tennessee
Company
1, Boilers
JOKI, LIGO,
emissions by 92%
2018
Alternative control of
(BART
SHRO
converting to natural gas
Source)
25-29
given to 2018 if chosen.
Apac-Tn,
Tennessee
Inc./Harrison
002
GS?vINP
None
N/A
N/A
Construction
Tennessee
YS12.DOE,002
GSMNP,None
N/A
N/A
- Plant
JOKI
Entered into Consent Decree
Tennessee
Bowater
to
GSMNP,
None
N/A
to lower allowable S02
Newsprint
JOKI
emissions to 4,562 tons per
year
Tennessee
Intertrade
001
JOKI
None
N/A
N/A
Holdings
DEQ-CFW-00009244

Table 2-5. Source in Area Influence of North Carolina Class I Areas
SIP
State
Facility
Emission
Class I Area
Emission Controls
Required
Status of Controls*
Unit
Impacted
Included in SIP
Control
Date
South
Duke Energy
1,2,3
JOKI,SHRO
None
N/A
Retiring units by 10/2014
Carolina
Lee
South
Santee
Carolina
Cooper —
3,4
SWAN
None
N/A
N/A
Jefferies
American
Facility has met cap early and
Virginia
Electric
1,2,3
LIGO
Facility -wide cap
2015
has announced plans to gasify
Power —
units I & 2 and potentially
Clinch River
retire unit 3.
International
Converted to wood and
Virginia
Paper
4
SWAN
Scrubber
By 2018
maybe shutting down coal-
fired units.
GSXINP = Great Smoky Mountains National Park
JOKI = Joyce Kilmer- Sli ckrock
LIGO = Linville Gorge
SHRO = Shining Rock
SWAN = Swanquarter
DEQ-CFW-00009245

Table 2-6. North Carolina Source in Area Influence of Other States Class I Areas
SIP
Facility
Emission
Class I Area
Emission Controls
Required
Status of Controls*
Unit
Impacted
Included in SIP
Control
Date
Duke Energy — Dan River
3
JARI
None
N/A
Retired April 2012, switching
to natural gas
JARI = James River Face in Virginia
DEQ-CFW-00009246

The next requirement is 40 CFR 51.308(g)(2), is a summary of the emission reductions achieved
throughout the state through the implementation of the measures described above in Section 2.
Table 3-1 lists the electric generating units in North Carolina that were projected to have controls
installed by 2018 in the original regional haze SIP and units that will be retiring by 2018. This
table provides typical year 2002 emissions and the Integrated Planning Model (IPM) predicted
2018 emissions used in the modeling for the original regional haze SIP, as well as the estimated
tons reduced between 2002 and 2018. The actual 2011 emissions data for these sources was
obtained from the USEPA's Clean Air Markets database. An estimate of the current projection
for 2018 SO2 emissions was developed using the projected 2013 emissions from the 2012 Clean
Smokestacks Act implementation plan for those sources expected to be in operation in 2018.
As can be seen in Table 3- 1, the current SO2 emission reductions from 2002 to 2011 are higher
than the estimated SO2 tons reduced in the original regional haze SIP between 2002 and 2018.
Additionally, the new projected 2018 SO2 emissions are approximately 80% lower than the
projected 2018 SO2 emissions in the original regional haze SIP. This is a clear sign that the
Class I areas in North Carolina are on track to meet or exceed their reasonable progress goals.
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
25
September 18, 2012
DEQ-CFW-00009247

Table 3-1. Estimated S02 emissions for North Carolina's Major Electric Generating Utility Sources (tons/year)
Facility
Emission
Unit
2002
VISTAS
2018 IPM
Estimated
Tons
Reduced in
SIP
Actual
Emissions
(2011
CAMD)
Current
Emission
Reductions
(2002-
2011)
Current
Estimate of
2018
Emissions
Current
Estimate of
2018
Emission
Reductions
Progress Energy -
1
8,489
576
7,913
1,039
7,450
401
8,088
Asheville
2
8,074
499
7,575
1,203
6,871
447
7,627
Progress Energy -
5
5,486
3,379
2,107
3,415
2,071
0
5,486
Cape Fear
6
6,101
4,300
1,801
4,688
1,413
0
6,101
1
2,744
2,918
-174
1,545
1,199
0
2,744
Progress Energy -
H.F. Lee
2
2,719
2,363
356
1,015
1,704
0
2,719
3
9,218
6,976
2,242
7,047
2,171
0
9,218
Progress Energy -
1A
13,673
954
12,719
4,053
9,620
653
13,020
Mayo
IB
13,122
953
12,169
3,182
9,940
653
12,469
1
15,596
999
14,597
1,650
13,946
543
15,053
2
29,504
2,438
27,066
1,864
27,640
981
28,523
Progress Energy -
3A
16,082
1,071
15,011
1,383
14,699
466
15,616
Roxboro
31 B
15,835
1,071
14,764
1,336
14,499
467
15,368
4A
11,207
1,253
9,954
1,610
9,597
331
10,876
4B
10,625
1,253
9,372
1,491
9,134
331
10,294
1
2,805
2,357
448
2,048
757
0
2,805
Progress Energy -
L.V. Sutton
2
3,470
3,711
-241
2,083
1,387
0
3,470
3
14,902
1,037
13,865
8,850
6,052
0
14,902
Progress Energy -
1
1,927
912
1,015
226
11701
0
1,927
DEQ-CFW-00009248

Table 3-1. Estimated S02 emissions for North Carolina's Major Electric Generating Utility Sources (tons/year)
Facility
Emission
Unit
2002
VISTAS
2018 IPM
Estimated
Tons
Reduced in
SIP
Actual
Emissions
(2011
CAMD)
Current
Emission
Reductions
(2002-
2011)
Current
Estimate of
2018
Emissions
Current
Estimate of
2018
Emission
Reductions
Weatherspoon
2
2,084
1,151
933
545
1,539
0
2,084
3
3,009
2,756
253
1,143
1,866
0
3,009
1
4,435
173
4,262
225
4,210
34
4,401
Duke Energy -
2
4,986
216
4,770
202
4,784
27
4,959
Allen Steam
3
8,810
741
8,069
366
8,444
374
8,436
Station
4
9,623
728
8,895
400
9,223
454
9,169
5
8,424
715
7,709
472
7,952
212
8,212
5
572
1,104
-532
0
572
0
572
Duke Energy -
6
537
1,064
-527
0
537
0
537
Buck Steam
7
746
610
136
0
746
0
746
Station
8
3,752
3,155
597
1,932
1,820
0
3,752
9
4,042
4,001
41
1,907
2,135
0
4,042
1
862
1,049
-187
0
862
0
862
2
1,027
882
145
0
1,027
0
1,027
Duke Energy -
3
1,487
1,962
-475
0
1,487
0
1,487
Cliffside
4
1,299
2,014
-715
0
1,299
0
1,299
5
25,124
1,952
23,172
308
24,816
760
24,364
6
0
0
0
0
0
1,571
-1,571
DEQ-CFW-00009249

Table 3-1. Estimated S02 emissions for North Carolina's Major Electric Generating Utility Sources (tons/year)
Estimated
Actual
Current
Current
Current
Emission
2002
Tons
Emissions
Emission
Estimate of
Estimate of
Facility
Unit
VISTAS
2018 IPM
Reduced in
(2011
Reductions
2018
2018
SIP
CAMD)
(2002-
Emissions
Emission
2011)
Reductions
1
2,621
3,464
-843
438
2,183
0
2,621
Duke Energy -
2
921
1,498
-577
440
481
0
921
Dan River
3
1,026
1,837
-811
1,069
-43
0
1,026
1
26,469
2,243
24,226
577
25,892
626
25,843
Duke Energy -
2
25,869
2,208
23,661
681
25,188
730
25,139
Marshall
3
14,931
485
14,446
1,291
13,640
1,389
13,542
4
15,042
470
14,572
1,305
13,737
1,710
13,332
7
3,321
2,592
729
1,128
2,193
0
3,321
Duke Energy -
8
3,435
1,511
1,924
1,204
2,231
0
3,435
Riverbend
9
5,686
3,973
1,713
2,381
3,305
0
5,686
10
5,677
3,973
1,704
2,406
3,271
0
5,677
Duke Energy -
1
39,667
2,536
37,131
1,676
37,991
2,474
37,193
Belews Creek
2
43,766
3,218
40,548
1,632
42,134
2,786
40,980
Totals
460,829
93,301
367,528
73,456
387,373
18,420
442,409
DEQ-CFW-00009250

Although the North Carolina's regional haze SIP was submitted in December 2007, the VISTAS
modeling continued with neighboring states including additional control measures. The VISTAS
best and final modeling concluded in Spring 2008 and the modeled progress for 2018 changed
for the North Carolina Class I areas. North Carolina is adopting the new reasonable progress
goals for all Class I areas in the state in this mid -course review. Additionally, the baseline
visibility for the 20% best days for Shining Rock in the original regional haze SIP reported the
2001-2005 visibility (7.7 deciviews) instead of the 2000-2004 baseline visibility (8.2 deciviews).
This is corrected in the table below. Table 4-1 lists the reasonable progress goals that were
stated in the original regional haze SIP.
Class I Area
Baseline
Visibility for
20% Worst Days
Reasonable
Progress Goal
20% Worst Days
Baseline
Visibility for
20% Best Days
Reasonable
Progress Goal
20% Best Days
GSMNP
30.3
23.7
13.6
12.2
JOKI
30.3
23.7
13.6
12.2
LIGO
28.6
22.0
11.1
9.6
SHRO
28.5
22.1
8.2
6.9
SWAN
24.7
20.4
12.0
11.0
The new reasonable progress goals for North Carolina's Class I areas are listed in Table 4-2.
The plots in Section 5 will include these new reasonable progress goals.
Table 4-2. New Reasonable Progress Goals for North Carolina Class I Areas
Class I Area
Reasonable Progress Goal
20% Worst Days
Reasonable Progress Goal
20% Best Days
GSNINP
23.5
12.1
JOKI
23.5
12.1
LIGO
21.7
9.5
SHRO
21.9
6.9
SWAN
2 0. 31
10.9
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
29
September 18, 2012
DEQ-CFW-00009251

Section 51.308(g)(3) requires the state to assess the visibility conditions for the most impaired
and least impaired days expressed in terms of the 5-year averages. The visibility conditions that
must be reviewed include 1) the current visibility conditions, 2) the difference between current
visibility conditions compared to the baseline, and 3) the change in visibility impairment for the
most and least impaired days over the past 5 years. Table 5-1 addresses the current visibility
conditions and the difference between the current visibility and the baseline condition expressed
in terms of the 5-year averages. The baseline conditions are for 2000 through 2004 and the
current conditions are for 2006 through 2010 since 2010 is the latest data available. Joyce
Kilmer- Sli ckrock Wilderness Area does not have a monitor in the wilderness area so the Great
Smoky Mountains National Park visibility data is used for this Class I area.
Table 5-1. Current Visibility and Differences from the Baseline (deciviews)
Class I Area
Baseline
(2000-2004)
Current
(2006-20 10)
Difference
20% Worst Days
Great Smoky Mountain National Park
30.3
26.6
-3.7
Joyce Kilmer- Sli ckrock
3 0. 31
26.6
-3.7
Linville Gorge
28.6
25.1
-3.5
Shining Rock
28.5
25.8
-2.7
Swanquarter
24.7
24.2
-0.5
20% Best Days
Great Smoky Mountain National Park
13.6
12.3
-1.3
Joyce Kilmer- Sli ckrock
13.6
12.3
-1.3
Linville Gorge
11.1
11
-0.1
Shining Rock
8.2
7.25
-0.95
Swanquarter
12
12.9
0.9
The data shows that all Class I areas saw an improvement in visibility on the 20% worst days and
all but Swanquarter Wildlife Refuge saw an improvement in visibility on the 20% best days. At
Swanquarter, a slight increase was seen (less than I deciview). This could be in part due to
having no data available for 2008 in Swanquarter, which could affect the 5-year average. Also,
in 2007, 2009 and 2010 there are at least one day in each year where high levels of particulate
organic matter (POM) and elemental carbon (EC) observed in the spring or fall when a wildfire
or prescribed fire might have occurred and impacted the visibility (see Figure 5-1). Finally, none
Pre -Draft Regional Haze 5 -Year Periodic Review SIP 30
For the North Carolina Class I Areas September 18, 2012
DEQ-CFW-00009252

of the controls planned for the eastern part of the State have taken place yet. Therefore, the
NCDAQ believes that improvement in the visibility on the 20% best days will occur by 2018.
Figure 5-1. 2006-2010 reconstructed light extinction, using the new IMPROVE equation,
for the 20% best days at Swanquarter Wildlife Refuge.
Table 5-2 displays the change in visibility impairment for the most and least impaired days over
the past 5 years in terms of the 5-year averages. For the 20% worst days, the overall trend is
towards improvement in visibility, although from year to year there may be slight increases
followed by decreases the following year. On the 20% best days, a similar trend towards
improvement is seen. The only Class I area not to have an improved visibility in 2010 compared
to 2006 (i.e., a lower deciview value) is Swanquarter Wildlife Refuge. Both 2005 and 2008 had
incomplete data and therefore are not included in any 5-year averages. This can greatly impact
the 5-year average especially for 2008 where only three years of data is used to calculate the
average. The 2010 five-year average saw a slight improvement in visibility. The missing data
coupled with the fact that S02 controls and coal-fired unit retirements in eastern North Carolina
will occur starting in 2012 leads the NCDAQ to believe future years will see an improvement in
visibility on the 20% best days.
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
31
September 18, 2012
DEQ-CFW-00009253

Table 5-2. Visibility Change over the Past 5 years in terms of 5-year averages (deciviews)
006
2007
2008
2009
2010
20% Worst Days
GSMNP
30.4
30.6
29.8
28.5
26.6
JOKI
30.4
30.6
29.8
28.5
26.6
LIGO
29.4
29.7
28.8
27.4
25.1
SHRO
28.8
28.5
27.5
26.6
25.8
SWAN
25.0
24.9
25.5
24.6
24.2
20% Best Days
GSNINP
13.3
13.2
13.1
12.4
12.3
JOKI
13.3
13.2
13.1
12.4
12.3
LIGO
11.3
11.3
11.6
11.3
11.0
SHRO
7.4
7.6
7.6
7.3
7.2
SWAN
12.2
12.2
12.6
13.0
12.9
The figures that follow displays the data listed in Tables 4-2, 5-1 and 5-2 , as well as the uniform
rate of progress towards natural background for 20% worst and 20% best days for the Class I
areas in North Carolina. The blue diamonds are the average 20% worst/best days observed
annually, the lighter blue line with asterisks is the 5-year averages, the pink line is the uniform
rate of progress and the light purple line with triangles is the modeled predictions used to
establish the reasonable progress goals listed in Table 4-2.
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
32
September 18, 2012
DEQ-CFW-00009254

Uniform Rate of Reasonable Progress Glide Path
Great Smoky Mountains ® 20% Worst Days
35
ME
30 11*#+�-
*29 R7
>iwf,
25
72 25.79
2♦
22.59
23.50
!a
20 -
---------------------------------------------------------------------------------------------------------------------------19.38-----------------------------------------------
x
all
15
1105
10
M
5 -
---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
0
2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 204E 2G44 2048 2052 2056 2060 2064
Year
--*-Gi;dePath —Natural Condition (Worst Days) * Observation Method I Prediction Rolling ,Average
Uniform Rate of Reasonable Progress Glide Path
Great Smoky Mountains - 20% Best Days
35 -
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
30
25 -
--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
20
♦
10
4.54
0
2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064
Year
F—Baseline—�x'­Natural Condition (20% Best Days) ♦ Observation :Method 1 Prediction Rolling Average
Figure 5-2. Visibility conditions at Great Smoky Mountains National Park for the most
impaired days (top) and least impaired days (bottom).
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
33
September 18, 2012
DEQ-CFW-00009255

Uniform Rate of Reasonable Progress Glide Path
Linville Gorge - 20% Worst Days
35
...................................................................................................................................................................................................................................................
30
31
3
25
24.67
i1�14
�2165
20
x
15.88
C15
---------------------------------- ---------------------------------------------------------------------------------------------------- ---------------------------------------------------------------- ------------------- -----------------
10
0
2000 2004 2008 2012 2016 2020 2024 2028 2032 2036. 2040 2044 201481 2052 2056 2660 2064
Year
--*-GlidePath —Natural Condition (Worst Days) + Observation Method I Prediction Rolling Average
Uniform Rate of Reasonable Progress Glide Path
Linville Gorge - 20% Best Days
35
30
25
20
x
15
10
...........
........... 9.50
5
4. b8
0
2000 2004 2008 2012 20116 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064
Year
--�r-Baseline —,i­Namral Condition (20% Best Days) * Observation .: :Method I Prediction Rolling Averaq
Figure 5-3. Visibility conditions at Linville Gorge for the most impaired days (top) and
least impaired days (bottom).
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
34
September 18, 2012
DEQ-CFW-00009256

LE.
Uniform Rate of Reasonable Progress Glide Path
Shining Rock - 20% Worst Days
35
30
2A 7.
27.22
24.65
25
-------- -- -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- -
2�
21.78
ai
21.92
20
18.92
1&05
15 -
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ ---------------- ---------- ------- I
en
11: 7
10
ea
0
2000 2004 2008 2012 2016 2020 2024 2026 2032 2036 2040 2044 2046 2052 2056 2060 2064
Year
--*— Glide Path —Natural Condition iWorst Days) * Observation Method 1 Prediction —Rolling Average
Uniform Rate of Reasonable Progress Glide Path
Shining Rock - 20% Best Days
35
-T ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
30
25
20
x
15
10
4 921 8.211
C5
_9_21
T
6.89
0
2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064
Year
-----------------------------------------
—*—Baseline —�\�—Natural Condition (20% Best Days) * Observabon Method I Pred;�cjop . .... Rolling Average
ure 5-4. Visibilitv conditions at Shinin,2 Rock for the most imnaired days (ton) and
mn,
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
35
September 18, 2012
DEQ-CFW-00009257

Uniform Rate of Reasonable Progress Glide Path
Swanquarter - 20% Worst Days
35
30
25
2
4
.62
► 21.64
all
22j.?. 45
20 -
------------------ 0.2 ---------- ------- ---------------------------------------------------------------------------------- ------------------------------------------------------------
1725
6
15
10
5 -
---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
0
20100 2004 2008 2012 2016 2020 2024 2028 20132 2036 2040 2044 2048 2052 2CII56 2060 20164
Year
-----------
--A—Glide Path —Natural Condition (Worst Days) * Observation , Method I Prediction Rolling average
Uniform Rate of Reasonable Progress Glide Path
Swanquarter - 20% Best Days
35
---------------------------------------
30
25
--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
20
15
++12.02+ 12.02 12.02
U)
10
110�92
5.46
r
0
2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064
Year
--*.—Baselme --O—Natuml Condition (20% Best Days) + Obse¢vation Method 1 PreOctiorRoiling Average
Figure 5-5. Visibility conditions at Swanquarter Wildlife Refuge for the most impaired
days (top) and least impaired days (bottom
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
36
September 18, 2012
DEQ-CFW-00009258

There are five different emission inventory source classifications: stationary point and area
sources, off -road and on -road mobile sources, and biogenic sources. Stationary point sources are
those sources that emit greater than a specified tonnage per year, with data provided at the
facility level. Electric generating utilities and industrial sources are the major categories for
stationary point sources. Stationary area sources are those sources whose individual emissions
are relatively small, but due to the large number of these sources, the collective emissions from
the source category could be significant (i.e., dry cleaners, service stations, agricultural sources,
prescribed fire emissions). These types of emissions are estimated on a countywide level. Off -
road (or non -road) mobile sources are equipment that can move, but do not use the roadways
(i.e., lawn mowers, construction equipment, railroad locomotives, aircraft). The emissions from
these sources, like stationary area sources, are estimated on a countywide level. On -road mobile
sources are automobiles, trucks, and motorcycles that use the roadway system. The emissions
from these sources are estimated by vehicle type and road type and are summed to the
countywide level. Biogenic sources are the natural sources like trees, crops, grasses and natural
decay of plants. The biogenic emissions are not included in this mid -course review since they
were held constant as part of the original regional haze SIP modeling and are not controllable
emissions.
For the typical 2002 stationary point source emissions inventory, only those sources that reported
emissions for 2002 to the NCDAQ were included in the emissions inventory. The Typical 2002
stationary point source emissions inventory was developed jointly with VISTAS States for
emission projection purposes. For the typical year emissions, the electric generating units are
adjusted to be for a typical year so that if sources were shut down or operating above or below
normal, the emissions were to be normalized to a typical inventory year. This is necessary since
the future year emissions represent a projected typical future year inventory. The 2009 point
source emissions were estimated using the Integrated Planning Model (IPM) model for the
electric generating units and economic growth factors for the remaining sources.
The 2002 area source emissions were estimated by taking an activity factor and multiplying by
an emission factor. The 2009 area source emissions were projected using economic growth
factors. The exception to this is the wildfire and prescribed fire emissions, in which typical year
emissions were used for both 2002 and 2009. For the non -road mobile source inventory, all but
the aircraft, locomotive and commercial marine emissions were estimated using the USEPA's
NONROAD2005c model for both the typical 2002 and 2009 inventory years. The remaining
non -road mobile sources were estimated the traditional way by taking an activity level and
multiplying it by an emission factor and these sources were projected to 2009 using economic
growth factors. The on -road mobile source emissions were estimated using the USEPA's
MOBILE6.2 mobile model for both the typical 2002 and projected 2009 inventory years.
Pre -Draft Regional Haze 5 -Year Periodic Review SIP
For the North Carolina Class I Areas
37
September 18, 2012
DEQ-CFW-00009259

The emissions that were in the original regional haze SIP for the typical year 2002 and the
projected year 2009 are listed in Tables 6-1 and 6-2, respectively.
Table 6-1. Projected Typical 2002 Annual Emission Summary for North Carolina (tons)
Source Category
VOC
NOx
SO2
PM2.5
Point
61,484
196,731
522,093
26,953
Non -road Mobile
94,480
84,284
7,693
7,348
Area
250,044
41,517
5,815
83,520
On -road Mobile
263,766
327,329
12,420
4,623
Total Emissions
669,774
649,861
548,021
122,444
Table 6-2. Projected 2009 Annual Emission Summary for North Carolina (tons)
Source Category
VOC
NOx
SO2
PM2.5
Point
62,161
101,236
284,802
26,360
Non -road Mobile
74,056
70,997
1,892
5,760
Area
200,873
45,382
6,281
90,729
On -road Mobile
168,676
201,609
1,503
3,493
Total Emissions
505,766
419,224
294,478
126,342
Table 6-3 lists the emissions for 2010 (see Appendix B for complete documentation). The 2010
point source emissions were estimated by taking the emissions reported by sources for 2010 and
adding the latest emissions for the small sources that only report emissions every 5 years. This is
a different procedure than what was used in the original Regional Haze SIP which included only
those sources that reported emissions in 2002 (small sources that did not report are estimated to
contribute 1%, 7%, 1%, and 7% of total NOx, VOC, S02, and PM2.5 emissions, respectively).
The area source emissions were estimated by growing the existing 2007 emissions inventory to
2010. The non -road mobile source emissions were estimated using the USEPA's
NONROAD2008 model for those sources covered by the model and growing the 2007 airport,
locomotive and commercial marine emissions to 2010. The on -road mobile source emissions
were estimated using the USEPA's mobile model MOVES2010a with the latest vehicle miles
traveled (VMT) and speed data that was available. If 2010 speeds and VMT were not available
for a particular county, interpolated or projected 2010 data was used. Both the non -road mobile
and on -road mobile models have been updated to newer models for the 2010 estimated
emissions. The MOVES model tends to estimate higher emissions than its previous counterpart,
especially for NOx emissions.
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Table 6-3. 2010 Annual Emissions Summary for North Carolina (tons)
Source Category
VOC
NOx
SO2
PM2.5
Point
41,358
90,322
151,707
14,072
Non -road Mobile
131,444
65,353
2,829
5,455
Area
109,745
13,030
8,336
19,557
On -road Mobile
101,819
256,559
1,205
8,905
Total Emissions
384,3166
425,264
164,077
47,989
As can be seen from the emissions data, the 2010 emissions are significantly lower than the
typical 2002 emissions inventory. The VOC emissions are 43% or lower, the NOx emissions are
35% lower, the SO2 emissions are 70% lower and the PM2.5 emissions are 61% lower. The 2010
emissions are lower despite including additional stationary point sources and the use of the
USEPA's mobile model MOVES, which predicts much higher NOx emissions than its
predecessor MOBILE6.2.
When comparing the 2010 emissions with the projected 2009 emissions, all emissions are lower
in 2010. The VOC emissions are 24% lower, the SO2 emissions are 44% lower and the PM2.5
emissions are 62% lower. The 2010 NOx emissions were essentially the same as the projected
2009 NOx emissions.
Figure 6-1 displays the average light extinction for the 20% worst days over the 5-year period
2006 through 2010 for all Class I areas in the Southeast. This figure demonstrates that on the 20
percent worst days in the Class I areas in North Carolina, sulfates (SO4) continue to be the major
concern, which is formed from the SO2 emissions. Since the stationary point sources are the
largest contributor Of SO2 emissions, 98% of the SO2 emissions in North Carolina, only the past
5 years of point source emissions are provided in Table 6-4.
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September 18, 2012
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25a
2aa
53
southeastc,aastal
Southeast Inland
and
0 se a sak
0 Apy, ai- ?Q 03
UArnm. 504
W RayEQigh
Ne fig hb o ri ng no n- So uth e ast
Figure 7-2. Average light extinction for the 20% worst days in 2006-2010 at Southeast and
neighboring Class I areas using the IMPROVE equation.
Year
VOC
NOx
S02
PM2.5
2006
62,359
148,707
520,116
26,403
2007
55,140
104,328
427,620
29,804
2008
48,202
97,723
277,592
26,888
2009
40,427
75,733
1 148,613
14,821
2010
41,358
90,3122
1 151,707
14,072
There does not appear to be any anthropogenic emissions within North Carolina that would have
limited or impeded progress in reducing pollutant emissions or improving visibility.
40 CFR 51.308(g)(6) requires an assessment of whether the current SIP elements and strategies
are sufficient to enable the state, or other Class I areas affected by emissions from the state, to
meet all established reasonable progress goals.
Figure 7-1 displays the reconstructed extinction for the 20 percent worst days at the Great Smoky
Mountains National Park during 2006 through 2010. Similar results are seen at the other Class I
areas in North Carolina (Appendix A). This figure, along with Figure 5-1, demonstrate that on
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the 20 percent worst days in the Class I areas in North Carolina, sulfates continue to be the major
concern, which are formed from the S02 emissions. As seen in Table 6-3, stationary point
sources are the greatest source Of S02 emissions in North Carolina, with the electric generating
units being the largest contributor.
Figure 7-1. The 2006 — 2010 reconstructed extinction, using the IMPROVE equation, for
the 20% worst days at Great Smoky Mountains National Park, NC.
Table 3-1 lists the electric generating units estimated 2018 emissions. The new projected 2018
emissions are significantly lower than the projected 2018 emissions in the original regional haze
SIP. Additionally, the estimated 2010 emissions are lower than the 2009 modeled emissions
from the original regional haze SIP for all pollutants except NOx, which can be attributed to
different on -road mobile models. The NCDAQ believes the state is on track to meet the 2018
reasonable progress goals for the North Carolina Class I areas and will not impede a Class I area
outside of North Carolina from meeting their goals.
The primary monitoring network for regional haze, both nationwide and in North Carolina, is the
Interagency Monitoring of Protected Visual Environments (IMPROVE) network. Given that
IMPROVE monitoring data from 2000-2004 serves as the baseline for the regional haze
program, the future regional haze monitoring strategy must necessarily be based on, or directly
comparable to, IMPROVE. The IMPROVE measurements provide the only long-term record
available for tracking visibility improvement or degradation and therefore North Carolina intends
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to continue reliance on the IMPROVE network for complying with the regional haze monitoring
requirement in the regional haze Rule.
There are currently 3 IMPROVE sites in North Carolina (2 at distinctly different locations in the
mountains and one on the coast). In addition, as Table 8-1 shows, an IMPROVE site just across
the border in Tennessee serves as the monitoring site for both the Great Smoky Mountains
National Park and Joyce Kilmer- Slickrock Wilderness Area, both of which lie partly in
Tennessee and partly in North Carolina.
Table 8-1. North Carolina Class I Areas and Representative IMPROVE Monitors
Class I Area
IMPROVE Site Designation
Great Smoky Mountains National Park
GRSMI (TN)
Joyce Kilmer- Sli ckrock Wilderness Area
GRSMI (TN)
Linville Gorge Wilderness Area
LIGO I (NC)
Shining Rock Wilderness Area
SHRO I (NC)
Swanquarter Wildlife Refuge
SWAM (NC)
In addition to the IMPROVE measurements, some ongoing long-term limited monitoring
supported by Federal Land Managers provides additional insight into progress toward regional
haze goals. North Carolina benefits from the data from these measurements, but is not
responsible for associated funding decisions to maintain these measurements into the future.
Such measurements include:
Web cameras operated by the National Park Service at Look Rock, Tennessee and
Purchase Knob, North Carolina in Great Smoky Mountains National Park and by the
United States Forest Service at Frying Pan Mountain in the Shining Rock Wilderness
Area.
• An integrating nephelometer for continuously measuring light scattering, operated by the
National Park Service at Look Rock, Tennessee.
• A Tapered Element Oscillating Microbalance (TEOM) for continuously measuring PM2.5
mass concentration, operated by the National Park Service at Look Rock, Tennessee.
A continuous nitrate monitor continues to operate at the Millbrook site in Raleigh. Additionally,
a second continuous nitrate monitor is in operation at the Rockwell monitoring site in Rowan
County. The vendor no longer supports these monitors and it may be difficult to obtain the
expendables for the monitors in the future. The NCDAQ plans to operate these monitors as long
as funding and supplies allow. The NCDAQ began operating a continuous sulfate monitor at the
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Millbrook in August 2007. The continuous sulfate monitor for the Rockwell site has been
purchased but will most likely not start operation until in January 2013. The NCDAQ was
operating a 5400 R&P monitor for organic, total, and elemental carbon at the Millbrook site.
However, the monitor has failed and no funding was available to replace this monitor. The
NCDAQ is currently operating aethalometers at the Millbrook and Rockwell sites.
The NCDAQ will use the continuous speciation data from the sites discussed above to further the
understanding of both PM2.5 and visibility formation and trends in North Carolina. The NCDAQ
will operate the units discussed above as long as funds allow.
In addition, the NCDAQ and the local air agencies in the State operate a fairly comprehensive
PM2.5 network of the filter based Federal reference method monitors, continuous mass monitors
(TEOMs and Beta Attenuation Mass monitors), filter based speciated monitors and the
continuous speciated monitors described above. A map of the various locations around the State
is included in Figure 8-1. These PM2.5 measurements help the NCDAQ characterize air pollution
levels in areas across the state, and therefore aid in the analysis of visibility improvement in and
near the Class I areas.
0
01 0
Legend
* FHA O: ii�
* T OMi Orily
* BAM Only
* FRM & TEOM
0 FRM & SMA
* FRM TEOM & SPECMTED I1 HR & 24-HR)
* FRM, TEOM & 24-HR SPECIATED
* FRK 13ANA & SPECIATED, (1-HR & 24-HR,
Figure 8-1. PM7_5 Monitoring Network in North Carolina
The IMPROVE measurements are central to North Carolina's regional haze monitoring strategy,
and it is difficult to visualize how the objectives listed above could be met without the
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monitoring provided by IMPROVE. Any reduction in the scope of the IMPROVE network in
North Carolina would jeopardize the State's ability to demonstrate reasonable progress toward
visibility improvement in some of its Class I areas. In particular, North Carolina's regional haze
strategy relies on emission reductions that will result from the CAIR and the CSA, which occur
on different time scales and will most likely not be spatially uniform. Monitoring at every Class I
area is important to document the different air quality responses to the emissions reductions.
Since each of the current IMPROVE monitors in North Carolina represents a different airshed,
reduction of the IMPROVE network by shutting down one of these monitoring sites impedes
tracking progress at reducing haze at the affected Class I area. In the event this occurs, North
Carolina, in consultation with the USEPA and relevant Federal Land Managers, will develop an
alternative approach for meeting the tracking goal, perhaps by seeking contingency funding to
carry out limited monitoring or by relying on data from nearby urban monitoring sites to
demonstrate trends in speciated PM2.5 mass.
Data produced by the IMPROVE monitoring network will be used nearly continuously for
preparing the 5-year progress reports and the 10-year SIP revisions, each of which relies on
analysis of the preceding five years of data. Consequently, the monitoring data from the
IMPROVE sites needs to be readily accessible and to be kept up to date. Presumably, IMPROVE
will continue to process information from its own measurements at about the same pace and with
the same attention to quality as it has shown in the recent past. The VIEWS web site has been
maintained by VISTAS and the other Regional Planning Organizations to provide ready access
to the IMPROVE data and data analysis tools. North Carolina is encouraging continued
maintenance of VIEWS or a similar data management system to facilitate analysis of the
IMPROVE data.
O1X4111011"IMINIP
The NCDAQ has provided the information required under 40 CFR 51.308(g) in this 5-year
periodic review. Based upon this information, the NCDAQ believes the state is on track to meet
the 2018 reasonable progress goals for the North Carolina Class I areas and will not impede a
Class I area outside of North Carolina from meeting their goals.
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