charles yirka ncdenr division of air quality may 9 11 2007 epa title v permit managers meeting
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Charles Yirka NCDENR, Division of Air Quality May 9-11, 2007 EPA Title V Permit Managers Meeting. Regional Haze Rule and Reasonable Progress. Regional Haze Rule . CAA Section 169A 1999 Regional Haze Rule (40 CFR §51.308) BART, Reasonable Progress Goals, Ongoing 10 year SIP revisions

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charles yirka ncdenr division of air quality may 9 11 2007 epa title v permit managers meeting
Charles Yirka

NCDENR, Division of Air Quality

May 9-11, 2007

EPA Title V Permit Managers Meeting

Regional Haze Rule and Reasonable Progress
regional haze rule
Regional Haze Rule
  • CAA Section 169A
  • 1999 Regional Haze Rule (40 CFR§51.308)
    • BART, Reasonable Progress Goals, Ongoing 10 year SIP revisions
  • November 2005 Draft Guidance
  • Final Guidance expected “September 2006” (any day now)
bart update
BART Update
  • NCDAQ identified 17 facilities with BART eligible units
  • NC proposed exemptions for 8 facilities in June
  • NCDAQ has determined that the new IMPROVE equation can be used in BART evaluations
  • NCDAQ to submit to EPA request to use new IMPROVE equation as non-regulatory approach
  • NCDAQ plans to propose to exempt 7 more facilities, assuming EPA approval of new IMPROVE equation
  • NCDAQ is currently reviewing the 2 facilities with BART subject units
current status bart
Current Status BART
  • Application of BART is pretty clear
    • Some modelling issues
    • What happens to the exempted sources?
      • Do we apply reasonable progress (if we do that at all)

Regional Air



state responsibilities under regional haze rule
State Responsibilities under Regional Haze Rule
  • Submit State Implementation Plant – December 2007
  • Establish baseline visibility and goals for improving visiblity
  • Improve visibility on 20% haziest days and protect visibility on 20% clearest days
  • Develop long-term strategies for reducing emissions that cause haze
  • Demonstrate reasonable progress by 2018







Breton, LA*

Sipsey, AL

Dolly Sods, WV

Saint Marks, FL*

Everglades, FL

Cohutta, GA*

Shenandoah, VA

Shining Rock, NC*

Linville Gorge, NC

Swan Quarter, NC*

Mammoth Cave, KY

Okefenokee, GA

Cape Romain, SC

Chassahowitzka, FL

James Rvier Face, VA

Great Smoky Mtns, TN

Average Extinction for 20% Worst Extinction Days





Extinction (Mm-1 )




Existing State and Federal Regulations (VISTAS GSRM)

•Clean Air Interstate Rule (CAIR) + Clean Air Mercury Rule (CAMR)

–Utility projections based on Integrated Planning Model

•NOx SIP Call

•NC Clean Smokestacks Act

•Consent Agreements (TECO, VEPCO, Gulf Power Crist 7)

•1-hr ozone SIPs (Atlanta / Birmingham / Northern Kentucky)


•Heavy Duty Diesel (2007) Engine Standard

•Tier 2 Tailpipe

•Large Spark Ignition and Recreational Vehicle Rule

•Nonroad Diesel Rule

•Industrial Boiler/Process Heater/RICE MACT

•Combustion Turbine MACT

•VOC 2-, 4-, 7-, and 10-year MACT Standards

Uniform Rate of Progress Glide Path

Great Smoky Mountains - 20% Worst Days

New IMPROVE equation


Uniform rate of progress = 4.4 dv by 2018











Haziness Index (Deciviews)

























Glide Path

Natural Condition (Worst Days)


Method 1 Prediction

Similar results for Shining Rock, Linville Gorge, Cohutta, VA, WV sites

reasonable progress history
Reasonable Progress History(
  • For setting reasonable progress goals (RPGs) for each class I area, 1999 Regional Haze Rule limits:
    • The analysis to statutory factors [51.308(d)(1)(i)(A)] +
    • glidepath analysis [51.308(d)(1)(i)(B)].
  • 1999 rulemaking discussed the glidepath analysis at length, and promised additional guidance on applying the statutory factors.
    • “The EPA intends to issue guidance interpreting the statutory factors and providing examples of ways in which they may be applied.” 64 FR 35732
what are the caa statutory factors
What are the CAA Statutory Factors?

Clean Air Act section 169A(g)(1) identifies four factors that “shall be taken into consideration” in determining reasonable progress:

a. Cost of compliance

b. Time necessary for compliance

  • Energy and nonair quality environmental impacts of compliance; and

d. Remaining useful life of any existing source subject to such requirements.

reasonable progress current events
Reasonable Progress Current Events
  • The EPA released additional draft guidance for comment in late November 2005.
  • The draft contained additional guidance on assessing the reasonable progress statutory factors.
    • Comments from states, RPOs generally ok on overall approach, but raised additional issues not addressed in guidance, e.g. consultation, nontraditional sources.
    • Industry commented that statutory factor guidance is de facto rulemaking, and that RHR did not authorize States to exceed the glidepath based on the factors.
      • More recent letters from some states echoed industry view that glidepath should be the focus.
  • The EPA expects to issue final guidance in September, 2007.
what are the caa visibility goal and the uniform rate of progress glidepath
What are the CAA visibility goal and the Uniform Rate of Progress (“Glidepath”)?
  • CAA goal of natural visibility conditions at Class I areas
  • RHR establishes 60-year time horizon for attaining the goal
  • The uniform rate of progress (URP) for each 10-year long term strategy = the visibility improvement along the glide path for that planning period.
  • Does the URP = the reasonable progress goal?
so what is reasonable progress
So What is Reasonable Progress?
  • The Reasonable Progress Goal presumption is a rate of improvement over the first planning period sufficient to attain natural conditions by 2064 So is that the same as the URP?
  • Must States consider 4 Statutory Factors to determine what additional controls might be reasonable even if they are meeting the URP?
epa s response to comments on draft guidance
EPA's Response to Comments on Draft Guidance
  • Final guidance is drafted and expected at anytime now
ncdaq approach to reasonable progress
NCDAQ Approach to Reasonable Progress
  • VISTAS States concluded that SO2 is the appropriate pollutant to control for first round of RH SIP due in September 2007
  • After evaluating reductions and costs for NC EGU’s due to Clean Smokestacks Act (CSA) and Clean Air Interstate Rule (CAIR), NCDAQ deemed the planned controls to be reasonable
ncdaq approach to reasonable progress19
NCDAQ Approach to Reasonable Progress
  • NCDAQ then used the $/ton ($900-$2400/ton) values from CSA implementation to define “reasonable costs”
  • All large non-EGU units within a Class I area’s defined sulfate “area of influence” (AoI) was examined
  • No reasonable control measures were found (assuming this analysis is required)
current status reasonable progress
Current Status Reasonable Progress
  • States are developing long term strategies (LTS) to meet the first 10 year SIP implementation goal in light of the four statutory factors using EPA guidance.
  • RPOs are developing generic costs for various sources are the costs rebuttable?
  • Are previous exempted sources (including EGUs) subject to RP?
  • Final Guidance has been developed possible some changes in implementation of RH(?)
next steps
Next Steps
  • Complete modeling reruns
  • Complete documentation of RH SIP
  • Continue consultation process with neighboring states
  • Hold consultation meeting with FLM’s in summer
  • Hold public hearing in late September
  • Submit RH SIP by December 17, 2007
contact information
Contact Information
  • Charles Yirka
    • Title V Permit Coordinator of Permits Section
      • NC Division of Air Quality

(919) 715-6250

    • Visit our web site: