Appendix A – Nonattainment Area Emissions Inventory Development

The Nassau County SO2 nonattainment 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, accurate, 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 SO2 in the nonattainment area is the Rayonier facility which accounts

for over 99% of the SO2 emissions in the nonattainment area. The emissions from Rayonier and 

the nearby RockTenn facility were quantified using the facilities’ Annual Operating 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 SO2 EMISSIONS (tons)

EU005 Vent Gas Scrubber 10.42

EU006 Recovery Boiler 521.85

EU022 No. 6 Power Boiler 29.70

Total 2011 Rayonier SO2 Stack Emissions 561.97

Table 2

Summary of RockTenn’s 2011 AOR

Emission Unit Number Unit Description SO2 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 SO2 Stack Emissions 3,716.67

DEP calculated estimated 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 SO2 limits in 2011. These 

calculations are summarize in Table 3 below.
Table 3

Nassau SO2 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 SO2 Emissions 3,376.26

*Does not include recovery boilers as these units had no SO2 limit in 2011.

2. Onroad Mobile Sources

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

Motor Vehicle Emission Simulator (MOVES), MOVES2014. MOVES2014 is a state-of-thescience 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 2011 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 age distribution data from Duval County in 2010 are 

sufficiently representative 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 traveled (VMT) data from 2010 and source type population

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 SO2 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 data adjusted 

by 2010-11 population change

2010 Duval 

County data

2007 Nassau County data adjusted 

by 2007-11 population change

2010 Duval 

County data

2018 2010 Nassau County data adjusted 

by 2010-18 population change

2010 Duval 

County data

2007 Nassau County data adjusted 

by 2007-18 population change

2010 Duval 

County data

The population 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 

using 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, Bulletin 168, April 

2014. http://edr.state.fl.us/Content/population-demographics/data/Medium_Projections.pdf

 
area (13.75 km2

/1673.5 km2 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 SO2 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 km2

, it is 

expected that there are very few emissions of SO2 from area/nonpoint and nonroad sources. For 

this reason, the 2011 National Emissions Inventory (NEI) Version 2, which EPA developed, is 

considered to be a reasonable basis for these categories. The NEI is a comprehensive and 

detailed estimate of air emissions of both criteria and hazardous air pollutants from all air 

emissions sources. The NEI is prepared every three years 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 supplemented 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 using 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 population 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