## Appendix A

– Nonattainment Area Emissions Inventory Development

The Nassau County SO 2 

### nonattain ment area emission inventory consists of four source categories: point, onroad mobile, area/nonpoint, and nonroad mobile

. The data and methods used

to estimate these source categories as described below are sufficient for the creation of comprehensive, a ccurate, and current base year (2011) and future attainment year (2018 ) emissions inventories as required by CAA Section 172(c)(3).

1. Point Sources

The only point source of SO 2 

### in the nonattainment area is the Rayonier facility which account s
for over 99% of the SO 2 

### emissions in the nonattainment area . The emissions from Rayonier and the nearby RockTenn facility were quantified using the facilities’ Annual Operatin g Reports,
AOR, that contain actual emissions measurements and calculations

. These are summarized in

Table 1 and Table 2 below.

Table 1

Summary of Rayonier's 2011 AOR

Emission Unit Number Unit Description SO 2 EMISSIONS (tons)

EU005 Vent Gas Scrubber 10.42

EU006 Recovery Boiler 521.85

EU022 No. 6 Power Boiler 29.70
Total 2011 Rayonier SO 2 Stack Emissions 561.97



### Table 2

Summary of RockTenn’s 2011 AOR

Emission Unit Number Unit Description SO 2 EMISSIONS (tons)

EU006 No. 5 Power Boiler 237.74

EU007 No. 4 Recovery Boiler 113.09

EU011 No. 5 Recovery Boiler 104.37

EU013 No. 4 Smelt Dissolving Tank 1.47

EU014 No. 5 Smelt Dissolving Tank 1.50

EU015 No. 7 Power Boiler 3,160.74

EU021 No. 4 Lime Kiln 97.76

Total 2011 RockTenn SO 2 Stack Emissions 3,716.67



### DEP calculated e stimated attainment year 2018 actual emissions from these sources by 

### multiplying each facility’s 2018 allowable emissions for all units that will be operating in 2018 by the ratio of

their 2011 actual to allowable emissions for all units that had SO 2 

### limits in 2011

. These

calculations are summarize in Table 3 below.

### Table 3

Nassau SO 2 

### Nonattainment Area Point Source 2018 Emissions Estimates (tons)

Source 2011 Allowable 2011 Actual Ratio 2018 Allowable 2018 Actual Estimate

Rayonier 3,663.87 561.97 15.34% 2,200.07 337.45

RockTenn 7,823.07 * 3,499.21 * 44.73% 6,793.77 3,038.81

Total 2018 Point Source Estimated SO 2 Emissions 3,376.26

*Does not include recovery boilers as these units had no SO 2 limit in 2011.



### 2. Onroad Mobile Sources

The onroad mobile source category was estimated by utilizing the most recent version of EPA’s

Mo tor Vehicle Emission Simulator (MOVES), MOVES2014. MOVES2014 is a state

- of

- the

science emission modeling system that estimates emissions for mobile sources at the national, county, and project level for criteria pollutants, greenhouse gases, and air toxics. The model was run in inventory mode at the county level for 20 11 and 2018. Characterization data input to the

model consisted of a mix of MOVES2014 default data and local data. The local data used are

described in Table 4 below. Road type and a ge distribution data from Duval County in 2010 are sufficiently representa tive of 2011 conditions in Nassau County as these factors do not change appreciably from year to year or from county to county within the same core

- based statistical
area (CBSA) . Annual vehicle miles t raveled (VMT) data from 2010 and source t yp e p opulation data from 2007 were adjusted proportionately by population increase to 2011 and 2018 . This was the most recently available data and is considered to be sufficient for this analysis given the

small relative size of the mobile emissions of SO 2 

### in the nonattainment area.

Table 4

Description of Local Characterization Data Inputs to MOVES2014 Model

Year Annual Vehicle Miles Traveled Road Type

Distribution Source Type Population Age

Distribution

2011 2010 Nassau County d ata adjusted by 2010

- 11 population change 2010 Duval County d ata 2007 Nassau County d ata adjusted by 2007

- 11 population change 2010 Duval County d ata

2018 2010 Nassau County d ata adjusted by 2010

- 18 population change 2010 Duval County d ata 2007 Nassau County d ata adjusted by 2007

- 18 population change 2010 Duval County d ata



### The p opulation data for 2007, 2010, and 2011 that were used to adjust the input data were
obtained from the US Census Bureau

. 1 

### Population projections for 2018 were developed by the

Florida Bureau of Economic and Business Research

. 2 

### The Nassau County results of the MOVES2014 model runs for 2011 and 2018 were then apportioned to the nonattainment area by

usin g the fraction of the county land area contained within the boundaries of the nonattainment

1 http://www.census.gov/popest/data/historical/index.html

2 Population projections performed by: Florida Demographic Estimating Conference, February 2014 and the University of Florida, Bureau of Economic and Business Research, Florida Population Studies, Bul letin 168, April

2014

. http://edr.state.fl.us/Content/population

- demographics/data/Medium_Projections.pdf

### area ( 13.75 km 2 

### /1673.5 km 2 

### or 0.82% )

. The MOVES2014 results are summarized in Table 5 and

the population data are summarized in Table 6.

Table 5

MOVES2014 Results for Nassau County SO 2 

### Emissions (tons)

Year 2011 2018

County Output 9.73 3.83

Nonattainment Area Apportionment 0.08 0.03



### Table 6

Nassau and Duval County Population Data

2007 2010 2011 2018 2010 Nonattainment Area

Nassau 68,450 73,540 74,192 82,384 6,206

Duval 849,159 865,799 871,803 916,733

-



### 3. Area/Nonpoint and Nonroad Sources

Given the small land area size of the nonattainment area in Nassau County , just 13.75 km 2



### , it is expected that there are very few emissions of SO 2 

### from area/nonpoint and nonroad sources. For
this reason, the 201 1 National Emissions Inventory (NEI) V ersion 2 , which EPA developed, is considered to be a reasonable basis for these categories. The NEI is a comprehensive and

detailed est imate of air emissions of both criteria and h azardous air pollutants from all air emissions sources. The NEI is prep ared every three year s by the EPA based primarily upon emission estimates and emission model inputs provided by State, Local, and Tribal air agencies for sources in their jurisdictions, and suppleme nted by data developed by the EPA. A summary of the EIS source categories from the 2011 NEI is provided in Table 7 below. The county level

emissions were again apportioned to the nonattainment area by usin g the fraction of the county

land area contained within the boundaries of the nonattainment area

. Estimates for 2018 emissions for these categories were calculated by multiplying the 2011 data by the projected increase in p opulation in Nassau County in 2018.

### Table 7

Details of Area/Nonpoint and Nonroad Source Categories (tons)

EIS Emission Sector Nassau County Total 2011 NAA 2018 NAA

Fires

- Agricultural Field Burning 1.85

Fires

- Prescribed Fires 37.64

Fires

- Wildfires 1.78

Miscellaneous Non

- Industrial NEC 0.01

Fuel Comb

- Comm/Institutional

- Biomass 0.00

Fuel Comb

- Comm /Institutional

- Coal 0.03

Fuel Comb

- Comm/Institutional

- Natural Gas 2.18

Fuel Comb

- Comm/Institutional

- Oil 0.00

Fuel Comb

- Comm/Institutional

- Other 0.00

Fuel Comb

- Residential

- Natural Gas 0.24

Fuel Comb

- Residential

- Oil 0.04

Fuel Comb

- Residential

- Other 0.33

Fuel Comb

- Residential

- Wood 3.15

Waste Disposal 0.04

Area/Nonpoint Total 47.31 0.39 0.41

Mobile

- Aircraft 0.40

Mobile

- Commercial Marine Vessels 1.11

Mobile

- Locomotives 8.70

Mobile

- Non

- Road Equipment

- Diesel 0.75

Mobile

- Non

- Road Equipment

- Gasoline 0.30

Mobile

- Non

- Road Equipment

- Other 0.04

Nonroad Mobile Total 11.30 0.09 0.10