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Pre-Hearing Draft Regional Haze 5-Year Periodic Review State Implementation Plan for North Carolina Class I Areas Prepared by North Carolina Department of Environment and Natural Resources Division of Air Quality May 31, 2013 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. Acknowledgement: This document is dedicated to our friend and colleague Laura Boothe, who worked on this report with the same spirit and commitment given to all of North Carolina’s air quality plans. Laura’s love for the environment and vision for improving and maintaining air quality for the citizens of North Carolina is a testament to us all. We will miss her, and carry on with the mission of meeting our state’s air quality goals. Regional Haze 5-Year Periodic Review SIP i For the North Carolina Class I Areas May 31, 2013 EXECUTIVE SUMMARY Introduction 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 Regional Haze 5-Year Periodic Review SIP 1 For the North Carolina Class I Areas May 31, 2013 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. This SIP revision addresses each requirement based on visibility improvements observed in the 2006-2010 period. In the December 2007 Regional Haze Implementation Plan, the NCDAQ committed “to ongoing consultation with the FLMs throughout the implementation process, including annual discussion of the implementation process and the most recent IMPROVE monitoring data and VIEWS Regional Haze 5-Year Periodic Review SIP 2 For the North Carolina Class I Areas May 31, 2013 data.” The NCDAQ hosted a conference call with National Park Service and US Forest Service to discuss progress in western North Carolina. The NCDAQ plans to host a similar conference call with the Fish and Wildlife Service to discuss visibility improvements in eastern North Carolina. Progress Towards Reasonable Progress Goals (40 CFR 51.308(g)) 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 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, a slight increase in the haze index was measured - less than 1 dv. This could be in part due to having incomplete data for 2008 in Swanquarter, which could affect the 5-year average. Additionally, there are electric generating units (EGU) located in the eastern part of the state that have yet to be retired, controlled or converted to natural gas as of the end of 2010. These facilities are scheduled to undergo operational changes between the 2012-2013 timeframe. The associated reduction in emissions at EGU sources and other improvements occurring at non- electric generating units indicate that improvement in the visibility on the 20% best days will occur by 2018. Indeed, early preview of 2011 data shows a significant improvement, with annual average being less than the baseline for the first time since 2002. 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. Regional Haze 5-Year Periodic Review SIP 3 For the North Carolina Class I Areas May 31, 2013 2018 Baseline Current Class I Area Reasonable (2000-2004) (2006-2010) 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 12.9a 10.9 a The average measurement for 2011 was 10.5 dv, resulting in the most recent 5-year average haze index of 12.1 dv. 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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