March
31,
2004
Mr.
J.
I.
Palmer,
Jr.,
Regional
Administrator
U.
S.
EPA,
Region
4
Sam
Nunn
Atlanta
Federal
Center
61
Forsyth
Street,
SW
Atlanta,
GA
30303
Dear
Mr.
Palmer:

The
Early
Action
Compact
requires
local
areas
to
submit
Early
Action
Plans
to
the
United
States
Environmental
Protection
Agency
(
EPA)
by
March
31,
2004.
To
fulfill
that
required
milestone,
this
package
contains
the
local
area
plans
as
well
as
information
regarding
statewide
activities
that
contribute
to
bringing
cleaner
air
to
the
citizens
of
South
Carolina.

Both
the
2007
future
year
modeling
emissions
inventory
and
the
attainment
maintenance
analysis
have
been
completed.
Information
regarding
these
two
Early
Action
Compact
(
EAC)
milestones,
as
well
as
information
regarding
the
modeled
control
cases
is
contained
in
the
DRAFT
8­
hour
Ozone
Modeling
Analysis
and
Attainment
Demonstration
for
South
Carolina's
Early
Action
Compact,
Technical
Support
Document,
March
2004.
This
document
will
be
finalized
and
submitted
to
EPA
as
a
part
of
the
Early
Action
SIP,
December
2004.
A
copy
of
the
Technical
Support
Document,
Executive
Summary
can
be
found
in
Enclosure
1.
The
Technical
Support
Document
and
associated
files
can
be
found
on
the
enclosed
disk.
South
Carolina
has
invested
significant
resources
to
conduct
a
statewide
8­
hour
ozone
modeling
analysis.
Modeling
results
demonstrate
that
all
areas
of
South
Carolina
will
attain
the
8­
hour
ozone
standard
by
2007.
In
fact,
modeling
results
indicate
a
12
percent
statewide
average
decrease
in
ozone
levels.
In
addition,
a
modeling
analysis
for
2012
demonstrates
continued
attainment.
The
results
of
this
modeling
validate
the
regional
modeling
done
by
EPA,
which
also
demonstrated
attainment
for
all
South
Carolina
areas.
Work
is
currently
underway
on
a
modeling
run
using
estimated
2017
emissions.
This
work
is
being
done
to
review
attainment
issues
beyond
the
mandated
2012
time
frame.

South
Carolina
has
also
implemented
a
comprehensive
ozone­
forecasting
program
that
covers
twentynine
of
the
state's
forty­
six
counties,
including
those
most
vulnerable
to
higher
ozone
levels.
Citizens
in
those
counties
are
advised
on
a
daily
basis
about
predicted
air
quality
so
that
they
can
take
actions
to
protect
their
health.
In
addition,
South
Carolina
is
an
original
partner
with
EPA
on
the
AIRNow
project,
which
allows
the
current
and
forecast
ozone
and
particulate
matter
air
quality
information
to
be
available
to
citizens
statewide.

The
South
Carolina
General
Assembly
passed,
and
Governor
Sanford
signed,
a
joint
resolution
endorsing
Early
Action
Compacts
and
encouraging
state
agencies
to
lead
by
example
and
develop
programs
that
focus
on
reduction
in
ground­
level
ozone.
At
the
end
of
2002,
45
of
South
Carolina's
46
counties
had
entered
into
Early
Action
Compacts
to
implement
ozone
reduction
strategies
earlier
than
federally
required.
These
counties,
along
with
other
government
entities,
industry,
environmental
groups,
and
other
stakeholders
have
worked
together
both
at
the
local
level
and
state
level
to
develop
strategies
to
reduce
ozone
pollution.
These
efforts
affirm
our
commitment
to
improve
air
quality
for
all
of
South
Carolina.
In
fact,
the
stakeholders
involved
in
this
early
action
process
identified
675
initiatives
to
obtain
ozone
reductions
at
a
local
level.
To
ensure
that
future
growth
does
not
adversely
affect
South
Carolina's
ability
to
meet
the
8­
hour
ozone
standard,
the
state
is
on
schedule
to
impose
regulations
to
address
NOx
Letter
to
Mr.
Palmer
March
31,
2004
Page
2
emissions
from
new
and
existing
stationary
sources
and
open
burning
activities
statewide.
These
requirements
will
have
the
potential
of
reducing
and
preventing
the
addition
of
over
5,500
tons
of
NOx
to
the
state's
current
emissions
inventory.

The
South
Carolina
Department
of
Health
and
Environmental
Control
(
Department)
has
also
been
working
with
the
largest
existing
industrial
sources
in
the
more
vulnerable
areas
of
South
Carolina
to
reduce
NOx
emissions.
These
efforts
will
result
in
a
reduction
of
12,458
tons
per
year
in
NOx
emissions
from
8
facilities,
and
these
reductions
will
be
captured
through
permit
limits.
Detailed
information
regarding
the
specific
facilities
and
the
respective
reductions
will
be
included
in
South
Carolina's
Early
Action
SIP
submittal,
December
2004.

Department
air
officials
have
been
proactive
in
planning
for
improved
air
quality
in
the
state
and
in
the
region.
In
2001,
it
became
apparent
that
there
was
a
significant
interest
by
the
utility
industry
in
the
I­
85
corridor
of
South
Carolina
due
to
the
location
of
the
natural
gas
pipeline
and
access
to
the
electrical
power
grid.
The
Department
began
to
receive
numerous
power
plant
permit
applications.
As
this
was
a
vulnerable
area
with
regards
to
ground­
level
ozone,
the
numbers
of
permit
applications
and
the
potential
impact
of
these
sources
on
the
area's
ability
to
meet
the
8­
hour
ozone
standard
became
an
utmost
concern.
The
Department
determined
that
authorizing
the
large
amounts
of
additional
NOx
emissions
that
were
proposed
by
these
and
other
similar
large
NOx
sources
would
not
be
appropriate
without
a
showing
that
these
additional
emissions
would
not
adversely
impact
this
area.
As
a
result
of
this
determination,
NOx
emissions
estimated
at
3610
tons
per
year
have
not
been
authorized.

In
addition
to
the
milestones
for
identifying
and
adopting
early
control
measures
established
in
the
EAC,
one
condition
set
by
EPA
Region
4
for
York,
Chester,
and
Lancaster
counties
participation,
requires
that
South
Carolina
continue
to
actively
participate
in
the
Charlotte
Region
Integrated
Air
Quality
Management
Pilot
Project.
This
project
has
since
been
renamed
"
Sustainable
Environment
for
Quality
of
Life"
(
SEQL)
and
the
Department
is
an
active
partner
in
this
project.
Further,
the
Department
has
entered
into
a
Memorandum
of
Understanding
with
the
North
Carolina
Department
of
Environment
and
Natural
Resources
to
improve
air
quality
in
the
Charlotte
region.

To
ensure
air
quality
goals
are
considered
in
all
transportation
plans,
programs
and
projects,
the
Department
is
working
closely
with
Federal
Highways,
EPA
Region
4,
South
Carolina
Department
of
Transportation
and
local
Metropolitan
Planning
Organizations.
While
this
effort,
referred
to
as
"
Smart
Highways,"
is
not
a
strategy
that
will
result
in
emission
reductions,
it
will
provide
the
citizens
of
South
Carolina
the
assurance
that
air
quality
goals
are
considered
in
transportation
improvements.

The
Department
anticipates
having
plans
in
place
by
April
2005
for
statewide
compliance
with
8­
hour
ozone
standards,
well
before
EPA's
deadline
of
April
2007
with
attainment
for
some
marginal
and
moderate
areas
in
2007
and
2009,
and
until
2024
for
areas
with
the
worst
air
quality.

Enclosed
you
will
also
find
the
local
Early
Action
Plans
completed
by
participating
counties
and
a
progress
report
update
of
emission
reduction
strategies
for
the
Department.
This
information
will
be
available
on
our
website
as
soon
as
possible.
Enclosure
2
includes
the
updated
progress
report
for
the
Department
and
Enclosure
3
includes
the
final
local
Early
Action
Plan
for
each
participating
county,
grouped
by
the
following
areas:
Letter
to
Mr.
Palmer
March
31,
2004
Page
3
Appalachian:
Anderson,
Cherokee,
Greenville,
Oconee,
Pickens,
Spartanburg
Catawba:
Chester,
Lancaster,
Union,
York
Pee
Dee:
Chesterfield,
Darlington,
Dillon,
Florence,
Marion,
Marlboro
Waccamaw:
Georgetown,
Horry,
Williamsburg
Santee
Lynches:
Clarendon,
Kershaw,
Lee,
Sumter
Berkeley­
Charleston­
Dorchester:
Berkeley,
Charleston,
Dorchester
Low
Country:
Beaufort,
Colleton,
Hampton,
Jasper
Lower
Savannah:
Aiken,
Allendale,
Bamberg,
Barnwell,
Calhoun,
Orangeburg
Central
Midlands:
Fairfield,
Lexington,
Newberry,
Richland
Upper
Savannah:
Abbeville,
Edgefield,
Greenwood,
Laurens,
Saluda
Local
stakeholder
groups
continue
to
meet
and
upon
request,
the
Department
attends
as
many
of
these
meetings
as
possible
to
offer
technical
assistance
and
updates
regarding
the
8­
hour
ozone
standard
and
the
early
action
process.

To
date,
the
early
action
process
has
been
a
positive
experience
for
South
Carolina.
The
awareness
of
air
quality
issues
has
reached
an
all­
time
high
and
is
expected
to
increase
as
the
local
areas
implement
education
and
outreach
initiatives.
Thank
you
for
the
assistance
and
support
EPA
has
provided
in
this
process.
We
look
forward
to
continuing
to
work
with
EPA
as
we
implement
measures
to
achieve
cleaner
air
sooner
for
our
citizens.
Should
you
have
questions
or
desire
additional
information,
please
do
not
hesitate
to
contact
me
at
(
803)
896­
8940
or
Henry
Phillips,
of
my
staff
at
(
803)
898­
3260.

Sincerely,

Robert
W.
King,
Jr.,
P.
E.
Deputy
Commissioner
Environmental
Quality
Control
Enclosures:
1.
DRAFT
8­
hour
Ozone
Modeling
Analysis
and
Attainment
Demonstration
for
South
Carolina's
Early
Action
Compact,
Technical
Support
Document,
March
2004
2.
South
Carolina's
March
2004
Progress
Report
Update
3.
Local
Early
Action
Plans
for
Participating
Areas
cc:
Kay
Prince,
EPA
Region
4
County
Officials
(
no
attachments*)
Ron
Methier,
GA
Dept.
of
Natural
Resources
(
no
attachments*)
Keith
Overcash,
NC
Dept.
of
Environmental
and
Natural
Resources
(
no
attachments*)
EQC
District
Directors
(
no
attachments*)
Henry
Phillips
(
no
attachments*)

*
All
those
not
receiving
attachments
will
be
notified
when
materials
are
placed
on
website.
