Proposed Revisions 

to the 

Alabama State Implementation 

Plan 

- Jackson County- 1997 Annual PM 2.5 

Redesignation Request 

- Nitrogen Dioxide (N02) and Sulfur Dioxide 

(S02) Infrastructure SIP 

Post-Adoption Submittal 
fl 
• 

Part APart BPart CPart D -

PartEPart FTABLE OF CONTENTS 

Resolutions Signed by the Director of the Alabama Department of 

Environmental Management 

1. Jackson County- 1997 Atmual PM 2.5 Redesignation Request 

2. Nitrogen Dioxide (N02) and Sulfur Dioxide (S02) Infrastructure SIP 

Legal Notice 

Proof of Publication of Legal Notice 

Reconciliation Statements 

1. Jackson County- 1997 Annual PM 2.5 Redesignation Request 

2. Nitrogen Dioxide (N02) and Sulfur Dioxide (S02) Infrastructure SIP 

Legal Authority 

Final Jackson County PM2.5 Redesignation Request 

Final N02 and S02 Infrastructure SIP 

Part AResolutions Signed by the Director of the Alabama Department of Environmental 

Management 

ALABAMA DEPARTMENT OF ENVIRONMF:NTAL MANAGEMENT 

RESOLUTION 

WHEREAS, on February 24, 2013, the Alabama Department of Environmental Management gave 

notice of the opportunity for a public hearing and comment on documents that propose to certify that the 

State of Alabama's State hnph;:mentation Plan meets all Section IIO(a)( I) and II O(a)(2) provisions of the 

Clean Air Act (CAA) that address the requirements for the 20 l 0 nitrogen dioxide (N02) and sulfur dioxide 

(S02) NAAQS; and 

WHEREAS, no requests for a public hearing were received and therefore no public hearing was 

held; and 

WHEREAS, the Alabama Department of Environmental Management has reviewed the written 

submissions introduced into the record, and has prepared a concise statement of the response to comments 

received; and 

WHEREAS, written comments were received from one party, the USEPA; and 

WHEREAS, minor changes have been made to the proposed documents to address EPA's 

comments. 

NOW THEREFORE, as Director of the Department, I hereby adopt the proposed revision to 

the State of Alabama's State Implementation Plan to certify that the State of Alabama's State Implementation 

Plan meets all Section II O(a)( l) and II O(a)(2) provisions of the Clean Air Act (CAA) that address the 

requirements for the 20 l 0 nitrogen dioxide (N02) and sulfur dioxide (S02) NAAQS, and I hereby further 

state that this revision shall become effective immediately on the date indicated below. 

IN WITNESS WHEREOF, I have affixed by signature below on this 2s-~ay of 

---~-~~~1 a"--'-~=-<-;{ __ , 20 13. 

I 

f)ia~t~ t!t~ Lance R. l';efleur 

Director 

ALABAMA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

RESOLUTION 

WHEREAS, on February 24, 2013, the Alabama Department of Environmental 

Management gave notice of the opportunity for a public hearing and comment on the proposed 

revision to the State of Alabama's State Implementation Plan (SIP), and said proposal would 

redesignate the Jackson County portion of the Chattanooga Nonattainment Area to attainment for 

the 1997 Annual National Ambient Air Quality Standard (NAAQS) tor fine particulate matter 

(PM2.5); and 

WHEREAS, no requests for a public hearing were received and therefore no public hearing 

was held; and 

WHEREAS, the Alabama Department of Environmental Management has reviewed the 

written submissions introduced into the record, and has prepared a concise statement of the response 

to comments received; and 

WHEREAS, minor changes have been made to the proposed revision to the State 

Implementation Plan pursuant to comments. 

NOW THEREFORE, as Director of the Department, I hereby adopt the proposed revision to 

the State of Alabama's State Implementation Plan to redesignate the Jackson County portion of the 

Chattanooga Nonattainment Area to attainment for the 1997 NAAQS for tine particulate matter, 

and I hereby turther state that this revision shall become effective immediately on the date indicated 

below. 

IN WITNESS WHEREOF, I have at11xed by signature below on this 2t;tlrday of 

ap:rUA . 2013. 

1/li«lyr tlltr 

Lance R. leFleur 

Director 

Part BLegal Notice 

Proof of Publication of Legal Notice 

ALABAMA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

350 - NOTICE OF PUBLIC HEARING 

REGARDING THE ALABAMA STATE IMPLEMENTATION PLAN (SIP) 

1

( t- H -) t r--'- ·-J 

:2) ')_L( 

Notice is hereby qiven that the Alabama Department of Environmental Mclnaqement of the State 

<Jf Alabama IS prov1dinq the opportuntty for interested persons to comment on proposed revisions to the 

Alabama State Implementation Plan (SIP). Interested parties may request that a public heanng be 

held. 

lf a hearing is held, it w1ll be held on March 28, 2013, at 10:00 a.m. tn the Main Heanng Room 

.Jt the ADEM- Central Office location at 1400 Coliseum Blvd. 

Those requesting a hearing should call (334) 271-7909. The deadline to submit a request for a 

hearing IS 5:00 p.m. on March 26, 2013. If no hearing is to be held, a Notice of Cancellation of the 

hearing wtll be posted on March 27, 2013, on the Department's website 

located at www.adem.state.al.us/PubHearings/PubHearinqs.htm. Interested persons may also call (334) 

271-7909 to determine if a public hearing Will be held. 

rhe proposed revisions to the Alabama SIP concern the redesignation of the Jackson County 

portion of the Chattanooga Nonattainment Area ("Chattanooga NAA") for the 1997 Annual National 

Ambient Air Quality Standard (NAAQS) for fine particulate matter (PM2.5). The Jackson County portion 

of the Chattanooga NAA, located in Northeast Alabama, is geographically comprised of a single census 

block group in Jackson County, Alabama. On May 31, 2011, EPA promulgated its determination that the 

Chattanooga nonattainment area had attained the 1997 annual average PM2.5 NAAQS. This 

determination was based upon quality-assured and certified ambient air monitoring data for the 2007-

2009 period, which showed all monitors have attained the Annual PM2.5 NAAQS of 15 1Jg/m3

. This final 

rule became effective on June 30, 2011. Monitoring data through 2011 indicates that the area continues 

to meet the annual PM2.5 NAAQS. Based on this monitoring data, the Department is requesting 

redesignation of the Jackson County portion of the NAA to attainment status for the1997 Annual PM2.5 

NAAQS. 

Notice is also given for interested persons to comment on documents that propose to certify that 

Alabama's existing State Implementation Plan (SIP) meets Section 110(a)(1) and 110(a)(2) provisions of 

the Clean Air Act (CAA) that address the requirements for the 2010 nttrogen dioxide (N02) and sulfur 

dioxide (S02) NAAQS. 

Copies of the proposed SIP are available at a cost of 30 cents per page at each of the ADEM office 

locations listed below or on the Internet at: www.adem.state.al.us/PubHearings/PubHearings.htm at no 

cost. 

ADEM, Office of General Counsel 

Attn: Molly Tatum 

1400 Coliseum Boulevard 

(P. 0. Box 301463, Zip code 36130-1463) 

Montgomery, AL 36110-2059 

( 334) 394-4360 

ADEM, Birmingham Field Office 

i'\ttn: Mary Taylor 

110 Vulcan Road 

Birmingham, AL 35209-4702 

(205) 942-6168 

;\OEM, Decatur Field Office 

Attn: Jan Childers 

2715 Sandlin Road, SW 

IX>eJtur, AL 35603-1333 

(256) 353-1713 

ADEM, Mobile Field Office 

Attn: Jenika Monroe 

2204 Perimeter Road 

~'labile, AL 36615-1131 

(251) 450-3400 

Southeast Alabama Regional Planning & 

Development Commission 

}62 North Oates, 4th Floor 

Dothan, AL 36303 

Alabama- fombigbee Rivers Planning & 

Development Commission 

Courthouse Annex 

t07 Broad Street 

Camden, AL 36726 

East Alabama Regional Planning & 

Development Commission 

1130 S Quintard Avenue 

Anniston, AL 36201 

(2) 

rf the Department holds a hearing, it will be held to receive data, views, and arguments from 

interested persons regarding the document. Attendance at the hearing is not necessary to present such 

data, views, arguments, or comments as the same may be submitted in writing, but must be received by 

Ronald W. Gore prior to 5:00p.m. on March 29, 2013. 

Written submissions and other inquires should be directed to: Mr. Ronald W. Gore, Chief, Air 

Division, Alabama Department of Environmental Management, P.O. Box 301463, Montgomery, AL 36130-

1463 (street address: 1400 Coliseum Boulevard, Montgomery, AL 36110-2059) or by e-mail at 

rwg@adem.state.al.us. 

Any person wishing to participate in this hearing who needs special accommodations should 

contact the Department's Permits and Services Division at (334) 271-7714 at least five working days 

prior to the hearing. 

This notice is hereby given this February 24, 2013, by authority of ADEM. 

j ·, ..,~l.,!.~.,..... 

Lance R. Lefleur 

Director 

I 
J 
I 

l'rtnt-Friendly J>:t~c.: of Search l~c.-;ults- ,\L com 

E·,.,rythinq Ala~ma BEST LOCAL CLASSIFIEDS 

.ttl fElT 

Environmental Notices 

.\LABAMA DEPARTMENT OF ENVIRONMEN~L MANAGEMENT 350 - NOTICE Of 

PUBLIC HE EGARDING THE ALA fE IMPLEMENTATION PLAN 

otice IS hereby g1ven a e Alabama Department of Environmen a 

,. anagement of the State of Alabama is providing the opportunity for mterested 

persons to comment on proposed rev1s1ons to the Alabama State 

Implementation Plan (SIP). Interested parties may request thnt a public 

heanng be held. If n hearing IS held, 1t will be held on March 28, 2013, at 

10:00 a.m. 1n the Main Hearing Room at the ADEM- Central Office location at 

l-lOO Coliseum Blvd. Those requesting a hearing should call (334) 271-7909. 

rhe deadline to subm1t a request for a hearing is 5:00 p.m. on March 26, 2013. 

If no hearing is to be held, a Notice of Cancellation of the hearing will be posted 

.m March 27, 2013, on the Department's webs1te located at 

.vww. adem. state.al. us/PubHearings/PubHeanngs. htm. Interested persons may 

Jlso call ( 334) 271-7909 to determine 1f a public hearing w1ll be held. The 

proposed revisions to the Alabama SIP concern the redesignation of the 

lJckson County portion of the Chattanooga Nonattamment Area 

(.'xquot;Chattanooga NAA") for the 1997 Annual National Ambient Air 

<~uality Standard (NAAQS) for fine particulate matter (PM2.5). The Jackson 

County portion of the Chattanooga NAA, located in Northeast Alabama, IS 

•Jeographically comprised of a single census block group 1n Jackson County, 

,\labama. On May 31, 2011, EPA promulgated its determmation that the 

<:hattanooga nonattamment area had attained the 1997 annual average PM2.5 

~JAAQS. This determination was based upon quality-assured and certified 

,Jrnbient a1r mon1tonng data for the 2007-2009 period, which showed all 

mon1tors have attained the Annual PM2.5 NAAQS of 15 µg/m3. This final 

rule became effective on June 30, 2011. Monitoring data through 2011 

1ndicates that the area continues to meet the annual PM2.5 NAAQS. Based on 

this monitoring data, the Department is requesting redesignation of the 

Jackson County portion of the NAA to attainment status for the 1997 Annual 

f)M2. 5 NAAQS. Notice is also g1ven for interested persons to comment on 

documents that propose to certify that Alabama's existing State 

Implementation Plan (SIP) meets Section 110( a)( 1) and 110(a )( 2) provisions 

•Jf the Clean Air Act (CAA) that address the requirements for the 2010 nitrogen 

dioxide (N02) and sulfur dioxide (S02) NAAQS. Copies of the proposed SIP are 

JVallable at a cost of 30 cents per page at each of the ADEM office locations 

listed below or on the Internet at: 

www.adem.state.al.us/PubHearings/PubHearings.htm at no cost. ADEM, Office 

of General Counsel Attn: Molly Tatum 1400 Coliseum Boulevard (P. 0. Box 

301463, Zip code 36130-1463) Montgomery, AL 36110-2059 (334) 394-4360 

,1\DEM, Birmingham Field Office Attn: Mary Taylor 110 Vulcan Road 

Birmingham, AL 35209-4702 (205) 942-6168 ADEM, Decatur Field Office Attn: 

Jan Childers 2715 Sandlin Road, SW Decatur, AL 35603-1333 (256) 353-1713 

ADEM, Mobile Field Office Attn: Jen1ka Monroe 2204 Perimeter Road Mobile, AL 

36615-1131 (251) 450-3400 Southeast Alabama Regional Planning & 

Development Commission 462 North Oates, 4th Floor Dothan, AL 36303 

Alabama - Tombigbee Rivers Planning & Development Commission Courthouse 

Annex 107 Broad Street Camden, AL 36726 East Alabama Regional Planning & 

Development Commission 1130 S Quintard Avenue Anniston, AL 36201 If the 

Department holds a hearing, it will be held to receive data, views, and 

arguments from interested persons regarding the document. Attendance at the 

hearing 1s not necessary to present such data, v1ews, arguments, or comments 

'JS the same may be submitted in writing, but must be received by Ronald W. 

Gore pnor to 5:00p.m. on March 29, 2013. Written submissions and other 

./ 

Prtnt-hicndly l':tge ut Search l{cstdts- .\L.cum 

lllflUires should be Ll1rected to: Mr. Konilld W. Gore, Chtef, Atr Divt~;ion, 

i\lilbilma Department ot EnvtronmentLJI Management, P.O. f3ox JOH63, 

i·lontqomery, AL 36130- l ,~63 (street ,Jddress: 1·WO Coliseum Boulevard, 

rl!ontqomery, AL 36110-2059) or by e-rnatl ilt rwqli.,llildem.st.:Jte.al.us. Any 

person w1shinq to partlctpate m thts heannq who needs speetal 

1ccommodattons should contact the Department's Permtts .:1nd Servtces 

Diviston Jt ( J 34) 2 71· 7714 Jt least five working days pnor to the heannq. rhis 

nottce IS hereby qtven thts Februury 24, 2013, by authonty of ADEM. LJnce R. 

I.<.! Fleur Dtrector 1-'RESS f<EGIS fER FEB. 2·l, 2013 

IZelated Categones: Notices .:md Announcements· Legal 

Notice 

l'ublished 1n The Press·Reqister!Mi>slssippi Press 2/24. Updated 2/24. 

'~, flo <J s d t <.:> k n o w 

montf{Oitfit&~vcrtiscr rnqntqomervo<jver trser com 

TO: ADEM Permits & Services 

PO Box 301463 

Montgomery, AL 36130 

.\ftidavit of Publication of Legal Notice 

State of Alabama 

,\lontgomery County 

1<:-Vcrify# DHS72l79 

, \d Number: IJ732-t7 

l3ctore me. a notary public in and for the county and state above listed. personally appeared 

Shalawn Williams, who, by me duly sworn, deposes and says that: 

--My name is Shalawn Williams. I am the Legal Clerk ofThe Montgomery Advertiser 

(''Newspaper''). !'he Newspaper is printed in the English language, has a general cin.:ulation and 

its principal editorial oftice in the county above listed and has been maikd under a publication 

class mailing privilege of the United States Postal Service from the post office where it is 

published at least 51 weeks of a year. 

The Montgomery Advertiser published the attached legal notice in the issues of: 2/2-t/20 13 

.\copy of each issue in which the advertisement appeared was mailed to the person or olticial 

placing this advertisement and another copy was mailed to the person to whom the notice was 

directed, if the address was provided by the person or orticial placing the advertisement. 

!'he sum charged lor these publications was $_.82.-'0. 

rhc sum charged by the Montgomery Advertiser for said publication does not exceed the 

lowest classified rate paid by commercial customers for an advertisement of similar size 

and frequency in the same newspaper(s) in which the public notice appeared. 

rhere are no agreements between the Montgomery Advertiser and the ofticer or attorney charged 

with the duty of placing the attached legal advertising notices whereby any advantage, gain or 

protit accrued to said ofticer or attorney . 

. \FFlANT 

NOTARY 

KAYE V'IJAIGHT 

Notary Public, .1\labama State At Large 

\ly Commission Exwes July 3, 2016 

Sworn and subscribed this lstday of March 2013. 

\I ~HAMA I ;I ~J,\H! f,.1f, N I (IF ' 

1 }.;!H:( .l~JMf- NT AL 

\1AN~lN'frfr------..-

/50 NOTICE IJF f'lll~ 

liF.{IRING 

~)FCAHOlNr; f I JE ,\1,\i~t\MA ~ 

,fA IE Mf'l fM~NfAfiiJN 

r

1 L1\N (SIP) 

'-~tt;'lt 

tt1e /\labarna u.,parlmllnt Jt 

L- rw1ronmenldl M<lfhJqeme-nt ,Jf 

rhe ()tate l)f i\f,Jbama 1') 

i-JfOV!dlnq ihft fJ~purtlHlJty l•Jr 

.nterested por fona to r~omrT'ent 

;n proposed r •N1<sK1fl:!l 10 th$ 

1.fabama ')!c~te !rrlp!emen1a11on 

rlfgn (SIP) rtii!Jrastad p.1ltlut 

. nay 1 ~quust ! ~ldl .J pubhc 

rearmg be held 

If a heannq ~~ htJ!d, rt Ntll t)tt 

'""'.afd on March •. '8. ~:013 Jl 1 0 00 a m 1n ttle Ma1n Heannq 

f~oom dt th8 ;\UEM CtH1trat 

UH1ce tocat1on <:~t \400 Cuh~eum 

Blvd 

! hose r rH~utJshr~ c;~ neanng 

'jt\oufd call LU4l .. U~ ,l1J09 rr'e Jaadhne to submit cJ ruqua-Jt for 

J heanng IS 5 c)O p m on March 

26. 2013 !f 110 t~eanng 1S to btt 

nefd. a Not1Cd of C anceflatlon of 

the hear1nq Ndl be posted on 

March Ll, .'01"1, 'Jn tna 

D>1partmenf1 wt1bS1te located at 

.vww adem state al uSJPubHean 

nqs/PubHeanngs him. 

interested per "Sons may also call 

1 334) 271- ~t:)09to determ1na 1t a 

pubhc heannq NJU tJa neld 

fhe proposed rev1'l10fl! to rne 

i\!abama '"liP :oncarn !t111 

1 o:!destgnatton •Jt thG Jackson 

1;uunty portion r)t the 

Chattanooqa Nonatta1nment 

,\rea ( "Chaltan-ooqa NAA") tor 

the 1997 Annual Nat1onat 

Ambtent A1r lJu~lhty Standard 

NAAQS) tor tw:e particulate 

natter (PM2 5) fha Jackson 

(;ounty port1on of \he 

Ct'"1attanooga NAA. located 1n 

Nonheast /l!abama. 15 

Jeographlcally compnsed of a 

.;1ngle census block group 1n 

Jdckson County Alabama On 

May J1 .'011, EPA 

promulgated rl' determlnauon 

;hat the r.:hattanooga 

•1onatta1nment area t1ad attamed 

'he 1997 .'Jnnual average PM2 5 

NAAOS 1 h1s determ1natton 

.vas based upon quahty~assured 

~nd '~ertlflad Jmb1ent ,·=ur 

,non110nng data for the 2007~ 

.2009 penod. whtch showed all 

fY\Onttor! have .1ttatned 'he 

Mnual PM2 5 NAA!JS of 15 

..J<.J/m3 f hts ftnal rule became 

::Hacttve un June 30, 2011 

Montlonnq data through 2011 

'ndtcates that the area conttnues 

to ,neat tha dnnual PM2 5 

NAAQS Hased on thts 

lilonttonng data. the Oepanrnent 

·5 .equesllng redestgnatlon of 

i1e Jackson County ponton of 

1t1e NAA to dttatnment status for 

'h81997 Annual PM2 5 NMOS 

Notice rs dlso q1ven for 

r 11erested persons to comment 

'Jn Jocuments that propose to 

(.erttfy that Alabama's ex1shng 

State lmplementatton Plan (SIP) 

,rBets Sectton 110(a){1) and 

! 10(a)(2} PfOVISIOnS of !he 

C!aan Air Act (CAA) that 

.:Jddress the reqUirements for 

the 2010 nitrogen diOXide (N02) 

=md sulfur d1oxtde (S02) 

NAAQS 

1:::optes of the proposed SIP 3re 

iYd!lable at 3 cost of m cents 

ut3'r page at each of !he ADEM 

urt1ce locations listed below or 

_Jn +he Internet .:~t 

v NW adem slate al uSJPubHean 

'·qs/PubHeanngs htm at no 

rJSt 

l\lJEM Off1ce of General 

\,uun~el 

;.ttn Molly fatum 

~ ti}O Cohseum Boulevard 

Y 0 Box 301463. Zip code 

.•;130·1463) 

Montgomery, AL 36110-2059 

i A) 3 94-4360 

\f!n M.tfy I l'p'I•Jf 

• ••\ ;r1h ,Jn p,,,.,J 

I'I'Tt"ff\,un ,\1. ~·,._tJ'J 4/fll. 

,,'l) I·U l}lrji:J 

l'l ·:.m<lhn Hu.td, ·)w I •("i!LI(,,\l ',',003·1\iJ 

'.li) lo l-1 I I I 

·IlL M MtJblle 1-••J!d l)tf!C8 

,\tin ;HrHka Monroe 

. 0--1 f

1unm6ter HnJd 

',1obll-e 1\l Jt-1615·1131 

51) ·l'lO· '!400 

:0HJ!Ilt1rH1l 1\l<ib.una 1-.'o•)!Ofl~ 

1\ 1 1r1f11ng & 

I l•Jvi:!k)pment Cornmt'i510n 

i~-)2 NOfth Oates. ·ilh Floor 

rloth:ln, AL }fjJQ3 

)' 1nnmq d. 

lhwttlopment Comml5!11on 

1_ uwthouse Anna)( 

l!Jl !!road Street 

r __ Jmden AL Jtj 726 

1 ·•~t t\I,Jb.tma H8<qtonaJ 

i'lo:~nntnq & 

l)tJv!1topmenl Cornmt'istOn 

I I lO S Uuullard A11enue 

/\nrH5ton AL 16201 

If ihe O•-,partment t1o1d11 d 

"•~annq, 11 'Nifl be held lo reottvtt 

J.Jta, VIBWI, md drquments 

rrom ,ntarested ~arsons 

, ·'l)dfdlnQ 1ha .locurnent 

·\lh:mdance at the t1eannq ~~not 

r I• •cessarv 'O present 'jUCh data. 

<I>JW!, .JrgLunents, or comment! 

-.HI tna s-dm8 may be submuted 

n tvr1ttnq, but must be recetved 

t.1y Honald W ( Jora pnor to 5 00 

p m on March 29. 2013 

'Nnlfan submiSSIOns .:~nd ,.Jther 

,nqu1ras should be 1j1rected to 

Mr ~~onald 'N Gore. Ch1ef. A1r 

D1v1S10n, Alabama Department 

'Jf Environmental Management. 

I' 0 flax 101463. Montqornery, 

AL J6130-1463 1 <tree! address 

1-100 Coliseum 13oulevard, 

Montqomsry. AL 36110·2059) 

ur by a~rnatl <:~l 

l'tvqi~adem state al us 

Any fJOrson w1shtng :o 

pdrtKtpate 1n thl! heanng who 

11eeds special accommodations 

·,hOuld contact the Department'! 

Perm1IS and Sorvtces DIVISion at 

/334) 271·7714 at least five 

c..-orktnq days pnor to ttle 

t1canng 

~s 

/~ Fo;,bruary 24. 2013. oy 

( 

iuthonly of ADEM 

L.:mce R leF!eur 

Dr rector 

Mont Adv 2/24113 

)73247 . .__ 

'JJte: 

Newspaper: 

County: 

Legal 

., ,.\IJAM,\ 1 J! fJ 1\ t) r \IF·~ r 1) F 1: v t~<J~1~.tHJ L·\.L .'.1ANA.GLi ·A HJ r :~ ,J ""' 1 1 '', t': r ;r: I'' Jilt 1c : 11- ,, ,,, 1 ~ 1\ ; "f-'_1 ;;\ 1, u 1 !\j( ; 

. ' ' 1-: \l _~ lL\MA ') f /\lrc !t·.1PI •·MI:'Nfr\ l' li ; n jJ! . •. ,\J t>)lfJ Nntlr;e 1$ ·~l· hy 'JIVte fl cfL!Illl P. Ai.Jb am:l D··ip;utmPnt •l l 

" 'JI [OIH1H':I1t:'tl f'Jl:JI1.1'J<;tnent .,t th e ·; t;;l e <Jt ;\i, Jb:un:J ,,; >Jf'lVt<111 '<J tile •jpp•Jttuntt'{ !or lr lter•!st<::d ~i~ rs ons ro .:onu n t:nl 'Jrl 

n <Jposed r·~V St• ms ro thP. ·' l. tt),mn '.) Lite ltnplement:ltt01 11Ji;1n t. )II·J) lntP.res ted o. Jitles 111.1y r"!'Ju est ltlctl :1 punltc; rwa nrHJ IJ>j 

:,:ld. If .1 he:Htn'] IS 1>e ld . 1t -.v1il 118 IV!Id 011 M:m:n 2o , 201 l . ,It Ill !)() d rn rn tiH~ M.11n l·~artnq rl oorn 1t th t'J ;\IJEM - 1; cntnl 

· : lfice location :1t I ·1 00 Colr seurn lcllvd 1'11Qse I eqU>JStlnq d 11edrtf'lq should CJII t.l34) 2 71 -/')09 f he d•!adliill-! to submtt a 

·'•1uest f0r a 11eartnq 1S :5 00 p rn. •Jn M:·u ch . t:O I :3 . If no t1~ an nq 1s to oe held :.1 Notice of C.m cc;IICJtron •Jt the ~e annq will 

P. posted on ;,~ rch 2 7. 201 3. <l ll tt1 e D~pa1tment's webs1te located at 

··;ww Jdem state alt iS/PrrtJH eann' JS/PubHeannfJS htm. Interested pmsons rnay ~lso cJ il (:.l34) 2.7 1 -/')09 to detertnme rf a 

,;11bhc heannq w tll IJe t1~1<1 l'he p1c posed re,11srons to the ;\labama SIP concern the re<leslrJrFltron nt il1e Ja<:kson C c';unty 

· .ortron ot the Chattanooqa Nonattatnment .A. rea t"CI1attanooqa NAA") for the 1997 Annual Nation al Arnb1ent A.rr ')udtrty 

)tandard rNAAOS) for rin e particulate matter tPM2 5) rl1 e .J3cl<.son l>Junty portron of the ChattanOOfJ3 NAA nca erj Ill 

lo11heast J\l;rbama . rs 'Jeoqr'lpiltcally <:1J mp11sed of :l ~;r n<Jie cen sus otock 'JriJup rn .Jackson C01m ty. Alctbatnrt t )n ~;hy ) 1 

'tJ 1t . l'Pfl.. prornui'JJied 1ts d8terrnrn:Hron !hat the CI':Jtt3nonga nonattarnment ared n.Jd J!tained the J~Jl .lflnrr;l l :wer:1qe 

, '~.112 5 NAAO~; rl11s .J ,~te rrntn tron wa'i based upon l" llrty ss ured .111<J ·~ertt d :Jmbrent .Jir morlltr)(lnq nat<J tor me 200 7. 

_:)():} pertor1. •;Jfl iLh ;,llfJ\Ved all rnr)f)I(OI S h.ive Jtt:Jined the Ani11L'I PM;z .5 ~JAAI JS lif 15 ;i. ~'J/ITI ::I rt: is lin <11 rul~ IJ8C:ll fle 

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,r t ccner<JI Counsel Attn : Molly r . .tum 1400 r_:: olrseum l-3oulevard tP 0 f3ox 3014o3. Lip code 361 30-1463) Montqo merv. ~\L 

ci 110-2059 (3'34) 3')4-4360 ADEM. Birmlllqham Field Utfice .LI.ttn Mary f aylo r 110 Vulcan Road Blrmln'Jham. i\L "J'3 2U9-

>702 (205) 042-6 tr)8 ADEM . Decatur Field Office Attn : JJn Chrlders 2 7 15 Sandlin Road . SW Decatur. AL 35603-1333 l25f3) 

:sJ- 1 71 J ADEM . Mob1le Field l)ffi ce Attn Jen1ka Monroe 2204 Penmeter Road Mobtle. r'I.L 36615- 1131 (251) 450-3400 

:out11east Alabama Reg ion al PI::Jnnrnq ,'I, Development Cornrnrss1on 462 North Oates . 4th Floor Dothan. AL ::6303 Alilbarna 

romb1gbee Rrvers Plann1ng .">. Development Comrnrssron \~o urth e Annex 107 Broad Street C.1rnrJen . AL 67~8 East 

,\ labarna l~e qr on01 ~' I;:JnnlnlJ & Development C omrnrssro n 11 JO S Ou1ntard Av enue Ann1ston. AL J6201 If the Department 

lds a ne::mnq, 11 wrll be held to rP. r-:e 1ve data. •11 ews. et nd arguments from interes tefJ persons regardinq rhe docutnent . 

. ··ttendim ce dl the heC~ rrng 1S not necessary to pre 5ent such data. vt ews . arguments . or comments as the same rnay he 

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::1rJ other ,nqu1res should te drrected to Mr. l"cnald 'N Core . Ct11 ef. ,'l,rr Oivtston . Alabama l)epartrnent of Envrronment.1l 

.l.inJty:•ment. 1-' 0 f)o x 011t:3:l . ~.l ntq >ery . AL :f31:l0-l -h3lr.street audress: 1400 Colr seurn t3 oulevm1 . Hontqorne1y, ;\l. 

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:_:rector F':!b 24. 201 3 

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Search 

Air Program 

Date 

March 20, 2013 

March 8, 2013 

March 5. 2013 

February 28, 

2013 

February 24, 

2013 

Description 

Coastal Program 

Date Description 

Waste/Remediation Program 

Date 

March 27, 2013 

March 27, 2013 

March 20, 2013 

March 14, 2013 

March 8, 2013 

March 7, 2013 

March 1, 2013 

Description 

f'·,'" r~RO IJSTB l.LC 

r:CZ :)erve 11441<3 

i<erth :irr11th 

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County Permit 

Dale Proposed Atr Permtt 

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Chtlton Proposed Atr Permtt 

(PSD) 

Talladega fitle V 

Clarke Proposed Air Permtts 

Statewide Alabama State 

Implementation Plan 

County Permit 

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Jefferson Proposed Voluntary 

Cleanup Plan 

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Mobile Solid Waste Landfill 

Permtt 

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Morgan UST 

Madtson UIC 

Proposed Renewal of a 

Clarke Solid Waste Landfill 

Permit 

Colbert UIC 

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1\labama I kpartrncnt ol Fnvironmcntal :Vlanagcmcnt 

PtJblic Hearings 

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Date 

Apnl 3, 2013 

March 28, 2013 

March 19, 2013 

March 14, 2013 

February 6, 2013 

January 22, 2013 

January 17, 2013 

January 16, 2013 

December 13, 2012 

December 13, 2012 

June 28, 2012 

May 24, 2012 

Time Location 

10 OOam Matn Heanng Hoom, 

ADEM Central Office 

1000am Matn Heanng Room, 

ADEM Central Office 

10 OOam Main Hearmg Room, 

ADEM Central Office 

6 OOpm Shelby Building, Dauphrn 

Island Sea Lab 

1000am Main Hearing Room, 

ADEM Central Office 

600pm Madison County 

Elementary School, 

Gurley, Alabama 

6 OOpm Madison County 

Elementary School 

10 OOam Main Heanng Room, 

ADEM Central Office 

1 OOpm Matn Hearing Room, 

ADEM Central Office 

1000am Main Heanng Room, 

ADEM Central Office 

600pm Tom Bev1ll Building 

Exh1bit Hall, 101 State 

Street, Sumiton 

6.00pm Town Hall, Cordova, 

Alabama 

Part CReconciliation Statements 

Reconciliation of Comments Received on the Proposed Revisions to 

ADEM's 1997 Annual PM2.

5 State Implementation Plan- .Jackson 

County 

The USEP A was the only commenter. A summary of their comments follows. 

EPA Comment #1: 

In the narrative section- pgs 3-4 and 3-6 Section 3.2.1.2.1.4 /Table 3.2.1.1.2.1.4-1 and 

Section 3.2.1.2.2.4/Table 3.2.1.2.2.4-1 Historical and Future Projections- ADEM should 

update the historical and future NOx and PM2.s projections referenced in the 2030 LRTP 

Conformity Determination with the NOx and PM2 5 projections from the 2035 LRTP 

Conformity Determination since it is the most recent. 

ADEM Response: The SIP has been revised as suggested. 

EPA Comment #2: 

The narrative lists the Clean Air Interstate Rule (CAIR) as a federal program that has led 

to actual, enforceable PM2 5 and PM2.5 precursor emission reductions in the Area. The 

EPA notes that CAIR is currently being implemented and administered consistent with 

the August 21, 2012, D.C. Circuit court order that vacated the Cross State Air Pollution 

Rule (CSAPR). CSAPR was the EPA's response to the deficiencies noted by the court in 

an earlier ruling that had remanded CAIR. The EPA petitioned for rehearing on CSAPR 

en bane, which the court denied on January 24, 2013. The United States is still 

considering whether to submit a petition for certiorari to the Supreme Court, which would 

be due on or before April 24, 2013. In its CSAPR ruling, the court ordered the EPA to 

use CAIR in the interim while the Agency develops a replacement rule for CSAPR. On 

November 19, 2012, the EPA's Assistant Administrator for the Office of Air and 

Radiation issued a Memorandum entitled, "Next Steps for Pending Redesignation 

Requests and State Implementation Plan Actions Affected by the Recent Court Decision 

Vacating the 2011 Cross-State Air Pollution Rule." In that Memorandum (which has 

been challenged by environmental groups in the D.C. Circuit Court), the EPA explained 

that it is appropriate to rely on CAIR emission reductions as "permanent and 

enforceable" for certain actions, including redesignations. 

ADEM Response: No re!>ponse necessary. 

- 1 -

Reconciliation of Comments Received on Alabama's 2010 Nitrogen 

Dioxide (N02) and Sulfur Dioxide (S02) Infrastructure SIP 

The USEP A was the only commenter. A summary of their comments follows. 

EPA Comment #1: 

§ll0(a)(2)(B) 

With regards to 110(a)(2)(B), it is suggested that Alabama include the following 

statement regarding the state's N02 monitoring strategy: "As of the date of this 

infrastructure submittal the development of the N02 monitoring network is ongoing; 

therefore Alab<:una's N02 monitoring strategy will be established per the requirements set 

forth in the 2012 and any subsequent Annual Monitoring Network plan relevant to the 

development of the State's N02 monitoring network". 

ADEM Respollse: The N02 infrastructure SIP submittal has been revised to 

include the suggested language. 

EPA Comment #2: 

§110(a)(2)(D) 

Prongs 1 and 2 of 11 O(a)(2)(D)(i)-The D.C. Circuit Court's recent opinion in EME Homer 

City Generation v. EPA, 696 F.3d 7, 31 (D.C. Cir. 2012), concluded that a 

11 O(a)(2)(D)(i)(I) SIP submission cannot be considered a "required" SIP submission until 

EPA has defined a state's obligations pursuant to that section. See EME Homer City, 696 

F.3d at 32 ("A SIP logically cannot be deemed to lack a 'required submission' or deemed 

to be deficient for failure to meet the good neighbor obligation before EPA quantifies the 

good neighbor obligation, therefore citing to CAIR to meet this requirement may not be 

appropriate either. Please see EPA's January 15,2013 (78 FR 2882) rulemaking. 

ADEM Respo!lse: Per EME Homer City Generation v. EPA, 696 F.3d 7, 31 

(D.C. Cir. 2012), I JO(a)(2)(D)(i)(l) has not been addressed for either S02 or N02 

EPA Comment #3: 

§ 11 0( a )(2)(E)(iii) 

The EPA has recently disapproved AL's PM2.5 I-SIP for this element on 10/15/2013 in 

77 FR 62449. At this time, there are not provisions approved into the SIP to adequately 

address 110(a)(2)(E)(ii). Until the state requests incorporation of such provisions into the 

- 1 -

SIP, the EPA will not be able to take favorable action to approve this section of 

Alabama's SIP revision . 

.-fDEM Response: No revision to the injrastructure SIP submittals were made as 

a result olthis comment. 

EPA Comment #4: 

§llO(a)(2)(J) 

For l10(a)(2)(C), (D)(i) and (J) it is suggested that Alabama remain consistent when 

addressing compliance of prevention of significant deterioration and visibility 

components of these elements including documentation of relevant regulations, statues 

and statements 

ADEM Response: The infrastructure SIP submission has been revised as 

suggested. 

- 2 -

Part DLegal Authority 

I ( I ~ I 

[·Jr-. r:Jr~er Tlj• .. ;~ll 

?egional Administrat~r 

~ rt ~J 1 , n 'l , -. r r 11 f1" 

t'·1 au:: h l 2 , l 9 J l 

fJ. S. En·;ironmental Protection Aqencj' 

Pegicn ['/ 

J~S Courtland Street, ti E" 

Atlanta, Georgia J036S 

Dear Mr. Tidwell: 

This letter is to notify you that I have designated the 

)\labama Department of Environmental r·Yanagement (the Department) 

as the lead state agency for the purposes of Alabama's 

responsibilities under the Federal Clean Air Act. The Department 

is authorized to take all actions necessary and appropriate to 

secure to the state the benefits of sald federal act under the 

Alabama En•Iironmental t·1anagement Act, Code of Alabama 1975, 

Section 22-22A-4(n), and by implicatioi1 through the Alabama Air 

Pollution Control Act, Code of Alabama 1975, Section 22-28-11(131 

'?'"ld ( 11)' 

This action that I am taking will help facilitate the 

implementation of the new Clean Air Act Amendments in Alabama. I 

am sure the Department and your office will continue to cooperate 

in managing Alabama's environmental resources" 

GH:ch 

cc: Mr. Leigh Pegues 

Sincerely, 

L\,,, 5 !In,, r 

Guy Hunt 

Governor 
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01vision tJf Air Po11Ytion Control· 

A l.abama A 1 r Po 111Jt 1 on Centro 1 Cammi ss ion 

645 South McDonough St~t 

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':.Jith <:his ! r!~i" L ,~f.te i"Onm& 1 4\etnowij ~~ger.:ent r<Jf .1f!J'Ilr authority. 

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PartEFinal Jackson County PM2.5 Redesignation Request 

REDESIGNATION REQUEST 

AND 

MAINTENANCE DEMONSTRATION 

Jackson County, Alabama 

Chattanooga 

Annual PM2.5 Nonattainment Area 

Prepared by: 

Alabama Department of Environmental Management 

Air Division 

DRAFT Jackson County Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

Executive SUilllllal)' 

This document contains Alabama's demonstration under the federal Clean Air Act (CAA) 

Amendments of 1990 that the Jackson County portion of the Chattanooga Annual PM2.s 

Nonattainment Area (NAA) should be redesignated from nonattainment to attainment with 

respect to the National Ambient Air Quality Standard (NAAQS) for annual fine particle 

pollution. This area consists of Hamilton County in Tennessee, Catoosa and Walker Counties 

in Georgia, and the portion of Jackson County in Alabama that is described as U.S. Census 

2000 block group identifier 01-071-9503-1. There are no PM2.s monitors located in the 

Jackson County, Alabama, portion of the nonattainment area; however, the air quality 

monitoring data for 2001-2003 from monitors located in the Georgia and Tennessee portions of 

the nonattainment area indicated that the annual average PM2.s concentrations (design values) 

exceeded the 15.0 micrograms per cubic meter (Jlg/m3

)NAAQS. The U.S. Environmental 

Protection Agency (EPA) included the above-mentioned portion of Jackson County, Alabama, 

in the Chattanooga nonattainment area because they concluded that the Tennessee Valley 

Authority (TV A) Widows Creek Fossil Plant located in the county contributes to the 

nonattainment situation in the Chattanooga NAA. 

This redesignation request is based on three years of ambient monitoring data, 2007 to 2009, at 

all four PM2.5 monitors in the Chattanooga NAA showing no violation of the annual PM2.s 

standard, the implementation of permanent and enforceable reductions in PM2.5 and precursor 

emissions, compliance with Section 110 and Part D requirements of the CAA, and the 

Chattanooga Maintenance Plan with projections demonstrating that the 2007 emission levels in 

this nonattainment area will not be exceeded through at least the year 2025. 

The Alabama Department of Environmental Management (ADEM), the Chattanooga-Hamilton 

County Air Pollution Control Bureau, the Tennessee Division of Air Pollution Control and the 

Georgia Air Protection Branch collaborated to develop a PM2.s NAAQS State Implementation 

Plan (SIP) for each jurisdiction. 

On May 31, 2011, EPA promulgated its determination (76 FR 31239) that the Chattanooga 

nonattainment area had attained the 1997 annual average PM2.s NAAQS. This determination 

was based upon quality-assured and certified ambient air monitoring data for the 2007-2009 

period, which showed a design value of 12.7 Jlg/m3• This final rule became effective on June 

30, 2011. Upon EPA's determination that the area had, in fact, attained the standard, Alabama, 

Georgia and Chattanooga began work on redesignation requests for their respective portions of 

the nonattainment area. As part of this work, coordination and consultation took place between 

the three agencies concerning emissions, monitoring data and the expectations of maintenance 

for the entire area. The emissions and monitoring data gathered as a result of this consultation 

is reflected in this request. 

This document contains the redesignation request for the Jackson County, Alabama, portion of 

the nonattainment area, which demonstrates maintenance of the annual PM2.s NAAQS, 

promulgated in 1997, in the Chattanooga NAA thru 2025. The State of Georgia's redesignation 

request and maintenance plan is located in Appendix A, and the Chattanooga-Hamilton County 

Air Pollution Control Bureau's draft redesignation request and maintenance plan is located in 

Appendix E. 

1 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

TABLE OF CONTENTS 

1. 0 Introduction .................................................................................................................................. 1-1 

1.1 Purpose ..................................................................................................................................... 1-1 

1.2 Historic Background ................................................................................................................ 1-1 

1.3 Formation ofPM2.

5 ................................................................................................................... 1-3 

1.4 Criteria for Redesignation ........................................................................................................ 1-4 

2. 0 Attainment Demonstration ........................................................................................................... 2-1 

2.1 Demonstration that the NAAQS Has Been Attained ............................................................... 2-1 

2.1.1 PM2.

5 Monitoring Network .................................................................................................. 2-1 

2.2 Permanent and Enforceable Reductions in Emissions ............................................................. 2-4 

3. 0 Fully Approved SIP, Section 110 and Part D Requirements ........................................................ 3-1 

3.1 Section 110 Implementation Plans ........................................................................................... 3-1 

3.2 Part D Plan Requirements for Nonattainment Areas ............................................................... 3-1 

3 .2 .1 N onattainment Areas in General .......................................................................................... 3-1 

3.2.1.1 Section 172(c)-........................................................................................................... 3-1 

3.2.1.2 Section 176(c)-........................................................................................................... 3-l 

3.2.1.2.1 Nitrogen Oxides (NOx) ........................................................................................... 3-2 

3.2.1.2.1.1 Analysis of motor vehicle NOx emissions in the Jackson County portion of the 

Chattanooga nonattainment area ........................................................................ , .................. 3-2 

3.2.1.2.1.2 The current state of the air quality in Jackson County ...................................... 3-3 

3 .2.1.2.1.3 The absence of SIP motor vehicle controls for the area ................................... 3-4 

3 .2.1.2.1.4 Historical trends and future projections of the growth of motor vehicle 

emissions. . ......................................................................................................................... 3-4 

3 .2.1.2.2 Direct PM2.

5 ............................................................................................................. 3-4 

3 .2.1.2.2.1 Analysis of motor vehicle PM25 emissions in the Jackson County portion of the 

Chattanooga nonattainment area .......................................................................................... 3-4 

3.2.1.2.2.2 The current state ofthe air quality in Jackson County ...................................... 3-6 

3 .2.1.2.2.3 The absence of SIP motor vehicle controls for the area .................................. .3-6 

3 .2.1.2.2.4 Historical trends and future projections of the growth of motor vehicle 

emissions. . ......................................................................................................................... 3-6 

4.0 Maintenance Plan ............................................................... .-........................................................ 4-1 

4.1 Maintenance Demonstration .................................................................................................... 4-1 

11 
DRAFT Jackson County Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

4.2 Attainment Inventory ............................................................................................................... 4-1 

4.2.1 Point Sources ....................................................................................................................... 4-2 

4.2.2 Nonpoint Sources ................................................................................................................. 4-2 

4.2.3 On-road Mobile Sources ...................................................................................................... 4-4 

4.2.4 Nonroad Mobile Sources ..................................................................................................... 4-5 

4.3 Projected Emissions Inventory ................................................................................................ 4-5 

4.3.1 Point Sources ....................................................................................................................... 4-6 

4.3.2 Nonpoint Sources ................................................................................................................. 4-6 

4.3.3 Onroad Mobile Sources ....................................................................................................... 4-6 

4.3.4 Nonroad Mobile Sources ..................................................................................................... 4-7 

4.4 Maintenance Plan Inventory .................................................................................................... 4-9 

4. 5 PIan to Maintain Air Quality .................................................................................................. 4-11 

4.5 .1 Verification of Continued Attainment ................................................................................ 4-12 

4.5.2 Contingency Plan ............................................................................................................... 4-12 

5. 0 Conclusion ................................................................................................................................... 5-1 

TABLES 

Table 2.1.1-1 Annual and Three-year Average Ambient P M25 Concentrations ................................. 2-2 

Table 3.2.1.2.1.1-1 2007, 2017, 2025 NOx (TPY) Emissions in the Nonattainment portion of Jackson 

County by Source Type .................................................................................................................... 3-3 

Table 3.2.1.2.1.1-2 2007, 2017, 2025 NOx (TPY) On-road Mobile Source Emissions in the 

Nonattainment Portion of Jackson County Compared to Total On-road Mobile Source Emissions in the 

entire Chattanooga NAA ................................................................................................................. 3-3 

Table 3.2.1.2.1.4-1 Historical and Future Projections ofNOxemissionsfrom On-Road Mobile Sources 

in Jackson County ........................................................................................................................... 3-4 

Table 3.2.1.2.2.1-1 2007, 2017, 2025 Direct PM2.

5 (TPY) Emissions in the Nonattainment Portion of 

Jackson County by Source Type ...................................................................................................... 3-5 

Table 3.2.1.2.2.1-2 2007, 2017, 2025 Direct PM25 (TPY) On-road Mobile Source Emissions in the 

Nonattainment Portion of Jackson County Compared to Total On-road Mobile Source Emissions in the 

Entire Chattanooga NAA ................................................................................................................ 3-5 

Table 3.2.1.2.2.4-1 Historical and Future Projections of P M2.5 emissions from On-Road Mobile Sources 

in Jackson County ........................................................................................................................... 3-6 

Table 4.2.1-1 2007 Point Emissions (TPY) ........................................................................................ 4-2 

Table 4.2.2-1 Jackson County NAA Nonpoint Source Emissions for 2007 (TPY) ............................. 4-3 

Table 4.2.4-1 2007 Nonroad Mobile Source Emissions (tons). .......................................................... 4-5 

Table 4.3.4-1 Projected Nonroad Mobile Source Emissions (tons per year) ..................................... 4-8 

ill 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

Table 4. 4-1 Jackson County, AL portion of the Chattanooga Annual P M25 Attainment Area Maintenance 

Plan Emissions (Tons per Year) ...................................................................................................... 4-9 

Table 4.4-2 Maintenance Inventory for the Chattanooga NAA (TPY) ............................................. 4-10 

Table 4.5.2-1 Schedule for Permit Revisions or Rule Revisions for Contingency Measures ........... 4-13 

FIGURES 

Figure 1.2-1 The Jackson County, ALportion ofthe Chattanooga Annual PM25NAA ..................... 1-2 

Figure 2.1.1-1 Locations of P M25 Monitors in the Chattanooga NAA .............................................. 2-3 

IV 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

APPENDICES 

GA Maintenance Plan and Redesignation Request ............................................................................... A 

Insignificance Determination for Transportation Conformity Under PM2.5 NAAQS for Jackson County, 

AL ........................................................................................................................................................... B 

Emissions Inventory Documentation ..................................................................................................... C 

Development of the Point Source Emissions Inventory for 2007 in the SESARM Region (Version 

1.10a), January 18, 2012 ................................................................................................................ C-1 

Area and Nonroad 2007 Base Year Inventories, Revised Final Report, Jan 2012 ......................... C-2 

Onroad and Nonroad Emissions Modeling Data ........................................................................... C-3 

Growth Factors, Control Factors, and Emission Summaries for Emission Inventory (includes 

memorandum from K. Thesing) ...................................................................................................... C-4 

MACTEC, August 2009. Point Source, On-road, and Fire Base Year, Future Year, and Control 

Strategy Emissions Inventories Draft Quality Assurance Project Plan. ......................................... C-5 

E.H Feehan and Associates, July 29, 2009. Quality Assurance Project Plan for Non- road and Area 

Source Base Year and Future Year Emissions Inventories .............................................................. C-6 

The Federal Facilities Compliance Agreement Between EPA and the Tennessee Valley Authority, Docket 

No. CAA-04-2010-1760 ......................................................................................................................... D 

Chattanooga, TN DRAFT Maintenance Plan and Redesignation Request- Narrative Only ................ E 

v 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

List of Acronyms 

Acronym Meaning Acronym Meaning 

ADEM Alabama Department of FR Federal Register Environmental Management 

AERR 

Annual Emissions Reporting 

Requirements FRM Federal Reference Monitor 

Aerometric Information Retrieval Industrial and 

AIRS System ICI Commercial/Institutional 

ALDOT Alabama Department of LRTP Long Range Transportation Plan Transportation 

AQS Air Quality Subsystem MOVES Motor Vehicle Emissions Simulator 

CAA Clean Air Act NAA Nonattainment Area 

CAIR Clean Air Interstate Rule NAAQS 

National Ambient Air Quality 

Standard 

CERR 

Consolidated Emissions Reporting 

Rule NEI National Emissions Inventory 

CFR Code of Federal Regulations NESHAP National Emissions Standards for 

Hazardous Air Pollutants 

CMV Commercial Marine Vessels NMIM National Mobile Inventory Model 

EGAS Economic Growth Analysis System NSR New Source Review 

EGU Electric Generating Unit NOx Nitrogen Oxides 

EIA Energy Information Administration PM Particulate Matter 

EPA U.S. Environmental Protection 

PM2.s Fine Particulate Matter Agency 

FGD Flue Gas Desulfurization PPM parts per million 

Vl 
DRAFT Jackson County Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

Acronym Meaning Acronym Meaning 

PSD Prevention of Significant Deterioration SIP State Implementation Plan 

RACM Reasonably Available Control Measures S02 Sulfur Dioxide 

RACT Reasonably Available Control 

Technology TIP Transportation Improvement Plan 

RFP Reasonable Further Progress TPY tons per year 

RVP Reid Vapor Pressure TVA Tennessee Valley Authority 

SAFETEA- Safe, Accountable, Flexible, Efficient 

LU Transportation Equity Act- A Legacy ULSD Ultra-Low Sulfur Diesel 

for Users 

Visibility Improvement- State 

sec Source Classification Code VISTAS and Tribal Association of the 

Southeast 

SCR Selective Catalytic Reduction VMT Vehicle Miles Traveled 

SEMAP Southeastern Modeling Analysis Plan 

Vll 

DRAFT Jackson County Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

1.0 Introduction 

1.1 Purpose 

This document contains the technical support necessary for the ADEM request that the Jackson 

County, Alabama, portion of the Chattanooga annual PM2.

5 NAA be redesignated as an area 

attaining the annual PM2.s NAAQS pursuant to §§107(d)(3)(D) and (E) of the CAA, as 

amended. 

1.2 Historic Background 

On January 5, 2005, the EPA designated a portion of Jackson County, Alabama, as a part of the 

Chattanooga NAA for the annual PM2.5 standard. The official designations and classifications 

were printed in the Federal Register on January 5, 2005 (70FR944), and were amended on April 

5, 2005 (70FR19844). Figure 1.2-1 shows the boundaries ofthe Jackson County portion ofthe 

NAA. 

On May 31, 2011, EPA promulgated its determination (76 FR 31239) that the Chattanooga 

NAA had attained the 1997 annual average PM2.5 NAAQS. This determination was based 

upon quality-assured and certified ambient air monitoring data for the 2007-2009 period, 

which showed a design value of 12.7 f..1.g/m3. This final rule became effective on June 30, 

2011. 

1-1 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

TVA Wi<bvs Creek () -~- --·.· .,.· 

010719503001 

smurfit-Stone Contaner Enterprises, Inc 0 

Legend 

D PM2_5 Nonattainmenthea 

O c ounty 

o Smurfit-Sione 

o lVA'Mdows Creek 

Figure 1.2-1 The Jackson County, AL portion of the Chattanooga Annual PM2.5 NAA 

1-2 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

1.3 Formation of PM2.s 

Fine particulate matter, also known as fine particles and PM2.5, refers to airborne particles less 

than or equal to 2.5 micrometers (~-tm) in diameter. Fine particles are treated as though they are 

a single pollutant, but they come from many different sources and are composed of many 

different compounds. PM2.s exposure adversely affects human health, especially respiratory 

and cardiovascular systems. Individuals particularly sensitive to PM2.5 exposure include 

children, people with heart and lung disease, and older adults. 

PM2.s can be liquid, solid, or can have a solid core surrounded by liquid. PM2.5 can include 

material produced by combustion, photochemical reactions, and can contain salt from sea spray 

and soil like particles. Particles are distinguished based on the method of formation. Primary 

particles are particles directly emitted into the atmosphere and retain the same chemical 

composition as when they were released. Secondary particles are those formed through 

chemical reactions involving atmospheric oxygen, water vapor, hydroxyl radicals, nitrates, 

sulfur dioxide (S02), nitrogen oxides (NOx), and organic gases from natural and anthropogenic 

sources. PM2.5 can therefore be composed of varying amounts of different species, including: 

• Sulfates 

• Nitrates (usually found in the form of ammonium nitrate) 

• Ammonium 

• Hydrogen ion 

• Particle bound water 

• Elemental carbon 

• Organic compounds 

o Primary organic species (from cooking and combustion) 

o Secondary organic compounds 

• Crustal material (includes calcium, aluminum, silicon, magnesium, and iron) 

• Sea salt (generally only found at coastal monitoring sites) 

• Transitional metals 

• Potassium (generally from wood burning or cooking) 

The most significant sources of PM2.5 and its precursors are coal-fired utilities, industrial 

boilers, and other combustion sources. These emissions are often transported over large 

distances. Other sources of PM2.5 emissions include mobile sources, area sources, biogenic 

sources, fires, windblown dust, and oceans. 

A variety of meteorological and geographic factors influence the concentration levels of fine 

particles, including both the regional and local distribution of urbanized areas, primary and 

precursor emissions sources, and natural features such as oceans and forests. Since PM2.s 

concentrations can exceed the NAAQS at any time of the year, the EPA mandates the year 

round monitoring of the pollutant throughout the country (40 CFR 58, App. D). 

1-3 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

1.4 Criteria for Redesignation 

Section 107(d) of the federal CAA, as amended in 1990, states that an area can be redesignated 

to attainment if the following conditions are met: 

1. The EPA has determined that the NAAQS have been attained. 

2. The applicable implementation plan has been fully approved by EPA under Section 

110(k). 

3. The EPA has determined that the improvement in air quality is due to permanent and 

enforceable reductions in emissions. 

4. The state has met all applicable requirements for the area under Section 110 and Part D. 

5. The EPA has fully approved a maintenance plan, including a contingency plan, for the 

area under Section 175A. 

The first and third of these requirements relate directly to air quality and the reasons for its 

improvement. These requirements are discussed together in Section 2 of this document. 

The second and fourth requirements relate to the implementation plan. All requirements under 

§ 110 and Part D of the Act have been met. These requirements are discussed in Section 3. 

The maintenance plan has two required components under Section 175A. First, the state must 

submit a revision to the SIP, which provides for maintenance of the NAAQS in the area for at 

least ten years after the redesignation. EPA has up to 18 months after submittal of the 

redesignation request to approve or disapprove it. Therefore, EPA is required to make its 

decision by mid-2014 since this document is being submitted in early 2013. Thus, the State 

must demonstrate that the Chattanooga NAA will maintain the standard through at least 2025 

[2015 + 10 = 2025]. The end year of our plan is 2025. Also, the plan revision must incorporate 

a contingency plan outlining commitments by the state to promptly correct any future 

violations. The maintenance demonstration and contingency plan are discussed in Section 4. 

1-4 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

2.0 Attainment Demonstration 

2.1 Demonstration that the NAAQS Has Been Attained 

Compliance with the NAAQS for annual PM2 5 is demonstrated when the three year average of 

the annual arithmetic mean PM2 5 concentrations is less than or equal to 15 J.Lg/m3

. The 

resulting concentration represents an annual PM2.5 design value. A violation of the annual PM2.5 

NAAQS occurs when the design value exceeds 15 J.Lg/m3 at any monitor. 

The three year period of annual PMz.s monitoring data for 2007-2009 for the Chattanooga NAA 

demonstrate compliance with the NAAQS for annual PM2.5, as will be illustrated in the next 

section. 

On May 31, 2011, EPA promulgated its determination (76 FR 31239) that the Chattanooga 

NAA had attained the 1997 annual average PM2.5 NAAQS. This determination was based upon 

quality-assured and certified ambient air monitoring data for the 2007-2009 period, which 

showed a design value of 12.7 J.Lg/m3

. This final rule became effective on June 30, 2011. 

2.1.1 PM2•5 Monitoring Network 

Four PMz.5 federal reference monitors (FRM) are located in the nonattainment area. Three 

monitors are located in Hamilton County, Tennessee, and one monitor is located in Walker 

County, Georgia. FRMs collect samples that are used to determine if an area is in attainment 

with the PMz.5 NAAQS. The FRM located at Soddy-Daisy High School is the most rural site of 

the three Hamilton County FRMs and has always shown attainment. The other three monitors 

showed exceedances of the annual standard for the 2001-2003 averaging period, which is the 

period the EPA used in the designation of the NAA. Table 2.1.1-1 shows the annual average 

PMz.5 concentrations and the associated 3-year average that demonstrate attainment of the 

standard in the Chattanooga nonattainment area. The 2007-2009 three-year design value is 

12.7 J.Lg/m3

, which is below the standard of 15.0 J.Lg/m3

. The table includes annual averages 

from 2003 through 2010, demonstrating the downward trend in the measured ambient PM2.

5 

level in the nonattainment area. The 2008-2010 three-year design value (Monitor ID 

470654002) is 11.6 J.Lg/m3

. This provides continued evidence that the area is meeting the 

standard. Monitor locations are shown in Figure 2.1.1-1. All of the PM2.5 ambient monitoring 

data that was collected during 2007, 2008, and 2009 was collected in accordance with 40 CFR 

58 and has been stored in EPA's Aerometric Information Retrieval System (AIRS) Air Quality 

System (AQS). 

2-1 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

Table 2.1.1-1 Annual and Three-year Average Ambient PM2.5 Concentrations 

Monitor Monitor Monitor 

Year 13-295-0002 47-06S.0031 47-065-1011 

(p.g/m3) (pglm3) (pg/1113) 

2003 15.9 16.5 14.3 

2004 14.9 15.6 13.3 

2005 16.4 16.1 13.8 

2006 14.4 14.3 13.1 

2007 13.7* 14.9 14.2 

2008 12.5 12.3 11.4 

2009 10.7 10.5 9.5 

2010 8.9 12.0 13.3 

201lt 10.8* 11.1 10.3 

2007-2009 12.3* 12.6 11.7 

2008-2010 10.7 11.6 11.4 

2009-2011 10.1 * 11.2 11.0 

*Values subject to data substitution (76 FR 15895) 

t Data obtained from AQS 

2-2 

Monitor 

47-0654002 

(pglm3) 

14.9 

14.5 

15.5 

15.0 

15.0 

12.7 

10.5 

11.7 

11.1 

12.7 

11.6 

11.1 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

PM2.s Monitors 

• FRM (2007) 

• FRM (2002) 

+ Sequatchie 

Marion 

Jackson 

DeKalb 

Hamilton 

TN-Hamilton-0031 

-walker-0002 

Catoosa 

walker 

Chattooga 

Description of Area 

Bradley 

Wh1 1eld Murray 

Gordon 

Figure 2.1.1-1 Locations ofPM2.5 Monitors in the Chattanooga NAA 

2-3 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

2.2 Pennanent and Enforct'able Reductiom in Enmsioos 

Since 2000, there have been several major federal programs enacted that have led to significant 

actual, enforceable PM2.5 and PM2.5 precursor emission reductions. These programs were 

established to provide reductions in emissions from the mobile source and industrial sectors. 

These programs are listed below. 

1. Tier II Motor Vehicle Emissions Standards 

2. Federal Onroad Diesel Engine Standards 

3. Federal Nonroad Diesel Engine Standards 

4. Federal Marine Engine Requirements 

5. Federal Locomotive Requirements 

6. The New Source Performance Standards under Section 111 (42 U.S.C 7411) 

7. The National Emission Standards for Hazardous Air Pollutants under Section 112 ( 4 2 

U.S.C. 7412) 

8. The NOx SIP Call 

9. The Clean Air Interstate Rule 

10. After December 1, 2014, all on-road, non-road, locomotive and marine diesel fuel produced 

and imported will be Ultra-Low Sulfur Diesel (ULSD-15 ppm). 

11. Installation of Selective Catalytic Reduction (SCR) on Unit 7 (2003) and Unit 8 (2004) at 

TVA Widows Creek. SCRs were added as a result of the NOx SIP Call. The Flue-gas 

desulfurization (FGD) on Unit 8 was upgraded in efficiency in 2004. Year round operation 

of the SCRs and FGDs was planned in anticipation of the Clean Air Interstate Rule (CAIR) 

rule, and subsequent replacement rule. 

2-4 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

3.0 Fully Approved SIP, Section 110 and Part D Requirements 

3.1 Section 110 Implementation Plans 

On October 5, 2012, EPA finalized approval of a SIP revision (77 FR 60904) submitted by 

ADEM on October 7, 2009, for the purpose of demonstrating attainment of the 1997 PM2 5 

NAAQS in the Alabama portion of the tri-state Chattanooga PM2.5 NAA. The Chattanooga 

Area is comprised of Catoosa and Walker Counties in Georgia; Hamilton County in Tennessee; 

and a portion of Jackson County in Alabama. The Alabama SIP revision pertains only to the 

Alabama portion of the Chattanooga Area. EPA finalized approval of Alabama's October 7, 

2009, SIP revision regarding reasonably available control technology (RACT) and reasonably 

available control measures (RACM); reasonable further progress (RFP); contingency measures; 

and, for transportation conformity purposes, an insignificance determination for PM2.5 and NOx 

for the mobile source contribution to ambient PM2.s levels for the Alabama portion of the 

Chattanooga Area. This action is being taken in accordance with the CAA and the "Clean Air 

Fine Particle Implementation Rule," issued by EPA on April 25, 2007. EPA also approved the 

base year emissions inventory for the 2009 attainment SIP for the Alabama portion of the 

Chattanooga NAA on February 8, 2012 (77 FR 6469). 

The general elements required in a SIP are listed in §llO(a). These elements include 

procedures for air quality monitoring and modeling; criteria for establishing stationary source 

controls, monitoring and reporting; implementation of permitting programs under Part C 

(Prevention of Significant Deterioration or PSD) and Part D (New Source Review or NSR); and 

provisions for public involvement. Alabama has a fully approved SIP under the authority of 

§110. 

3.2 Part D Plan Requirements for Nonattainment Areas 

3.2.1 Nonattainment Areas in General 

3.2.1.1 Section 172(c)-

In October of 2009, ADEM submitted to EPA the attainment demonstration for the Jackson 

County, Alabama, portion of the Chattanooga annual PM2.s NAA. This plan demonstrates 

attainment of the annual PM2.s NAAQS beginning in 2010 based on implementation of a 

combination of federal measures, other regional controls, and local controls and unit shutdowns 

associated with NAA utilities. Thus, ADEM has met the requirement of Section 172( c). EPA 

also approved the base year emissions inventory for the 2009 attainment SIP for the Alabama 

portion ofthe Chattanooga NAA on February 8, 2012 (77 FR 6469). 

3.2.1.2 Section 176(c)-

The concept of transportation conformity was introduced in the CAA of 1977, but the 

requirements became substantially more rigorous in the Amendments of 1990. The CAA and 

the Safe, Accountable, Flexible, Efficient Transportation Equity Act - A Legacy for Users 

(SAFETEA-LU) define the framework for effective integration of transportation and air quality 

planning. 

3-1 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

Transportation conformity is a process by which it is determined that on-road mobile (highway) 

source emissions evaluated from the Transportation Improvement Program (TIP) and/or Long 

Range Transportation Plan (LRTP) will not adversely impact air quality in a determined area of 

nonattainment. Federal funding and approval are given to transportation activities that are 

consistent with air quality goals. 

As part of the Jackson County attainment demonstration submitted in 2009, ADEM included a 

report entitled "Insignificance Determination for Transportation Conformity Under PM25 

NAAQS for Jackson County, AL". The report, which was approved by EPA in a June 18, 2010, 

Federal Register notice (75 FR 34735), shows that emissions of NOx and direct fine particles 

(PMz.s) from mobile sources in the small portion of Jackson County designated by EPA as 

nonattainment for the annual fine particle NAAQS, are an insignificant contributor to 

nonattainment of the PM2.5 NAAQS. Therefore, the Jackson County portion of the 

Chattanooga annual PM25 nonattainment area is not subject to transportation conformity. The 

analysis performed in the 2009 Insignificance Determination is presented below: 

According to 40 CFR 93.109(f), there are several factors that are used to support a finding of 

insignificance for these transportation-related PMz.s precursor pollutants. The first factor is the 

percentage of motor vehicle emissions in the context of the total SIP inventory. The second 

factor is the current state of the air quality in the area. The third factor is the absence of SIP 

motor vehicle emission control measures. Lastly, historical trends and future projections of the 

growth of motor vehicle emissions are reviewed. These factors are discussed in detail in the 

sections to follow. Each section supports the insignificance ofNOx and direct PM2.5 emissions 

from mobile sources in the Jackson County portion of the nonattainment area under the 

transportation conformity rule for the PM2 5 NAAQS. 

3.2.1.2.1 Nitrogen Oxides (NOx) 

3.2.1.2.1.1 Analysis of motor vehicle NOxemissions in the Jackson County portion of the Chattanooga 

nonattainment area. 

Only a small portion of Jackson County, Alabama, was included in the Chattanooga PM25 

nonattainment area. The small portion of the county designated nonattainment contains a 

limited number of roads. In order to determine the on-road emissions of NOx from motor 

vehicles in that portion of Jackson County, the document titled "Chattanooga Nonattainment 

Area Year 2035 Conformity Determination Report for Particulate Matter (PM2.5)" was used to 

determine how emissions were calculated for Jackson County and the same methodology was 

applied in this analysis. In order to estimate on-road mobile source emissions for the 

nonattainment portion of Jackson County, a ratio of the size of the nonattainment portion of 

Jackson County in square miles to the size of the entire county in square miles was calculated. 

The nonattainment portion of Jackson County was determined to be only about one percent of 

the total area of the entire county. The same ratio was applied to obtain area and non-road 

mobile source emissions for the nonattainment portion of the county. The following table 

shows the small percentage of NOx emissions from on-road mobile sources as compared to 

NOx emissions from all other sources in the Jackson County portion of the nonattainment area. 

Emission data were obtained from the SEMAP 2007 base year emissions inventory. 

3-2 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

Table 3.2.1.2.1.1-12007, 2017,2025 NOx (TPY) Emissions in the Nonattainment portion of 

Jackson County by Source Type 

Source 2007 %of %of %of 

Catee;ory (attainment) total 2017 total 2025 total 

Point 18,591.83 99.668 3,468.44 98.962 3,607.05 99.27 

Area 1.58 0.008 1.55 0.044 1.57 0.043 

Nonroad 37.32 0.2 25.86 0.737 18.95 0.522 

Mobile 23 0.123 9 0.257 6 0.165 

Total 18,653.73 100 3,504.83 100 3,633.57 100 

As the above table demonstrates, NOx emissions from on-road mobile sources in the 

nonattainment portion of Jackson County are 0.123% of the total NOx emissions from all 

source categories in the same area for 2007, 0.257% for 2017, and 0.165% for 2025. 

In the table below, a comparison is made of the mobile source NOx emissions from the 

nonattainment portion of Jackson County to total mobile source NOx emissions for the entire 

Chattanooga nonattainment area. 

Table 3.2.1.2.1.1-2 2007,2017,2025 NOx (TPY) On-road Mobile Source Emissions in the 

Nonattainment Portion of Jackson County Compared to Total On-road Mobile Source Emissions 

in the entire Chattanooga NAA 

2007 Percentage 2017 Percentag 2025 Percentage Area Emissions Emissions Emissions 

(TPY) of Total (TPY) e of Total (TPY) of Total 

Jackson County 23 .18% 9 .11% 6 .16% NAAPortion 

Chattanooga 12,773 8,105 3,827 NAA 

As the table above demonstrates, NOx emissions from on-road mobile sources in the Jackson 

County portion of the nonattainment area are .18% of the total NOx emissions from on-road 

mobile sources in the entire Chattanooga nonattainment area for 2007, .11% for 2017, and .16% 

for 2025. 

3.2.1.2.1.2 The current state of the air quality in Jackson County. 

As stated earlier in this document, the small portion of Jackson County, Alabama, was included 

in the Chattanooga PM2.s nonattainment area due to the fact that a power plant is located in that 

area and it was thought by EPA to contribute to the PM2.5 problem in Chattanooga. There are 

3-3 
DRAFT Jackson County Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

no PM2.s monitors located in Jackson County. Monitors in Alabama near Jackson County have 

monitored values below the annual PM2.5 NAAQS. Other counties surrounding the county are 

either in attainment or unclassifiable. 

3.2.1.2.1.3 The absence of SIP motor vehicle controls for the area. 

There are no SIP motor vehicle controls for Jackson County. 

3.2.1.2.1.4 Historical trends and future projections of the growth of motor vehicle emissions. 

The "Chattanooga Non-Attainment Area Year 2035 Conformity Determination Report for 

Particulate Matter (PM2.s)" was used to obtain past and future projections of the growth in NOx 

emissions from on-road mobile sources. As demonstrated in the table below, future emissions 

ofNOx are expected to decrease. 

Table 3.2.1.2.1.4-1 Historical and Future Projections ofNOx emissions from On-Road 

Mobile Sources in Jackson County 

Year Emissions (TPY) 

2002 21.31 

2009 12.87 

2015 7.17 

2025 4.11 

2035 3.71 

3.2.1.2.2 Direct PM2.5 

3.2.1.2.2.1 Analysis of motor vehicle PM25 emissions in the Jackson County portion of the 

Chattanooga nonattainment area 

Only a small portion of Jackson County, Alabama, was included in the Chattanooga PM2.5 

nonattainment area. The portion designated as nonattainment contains a limited number of 

roads. In order to determine the on-road emissions of PM2.5 from motor vehicles in that portion 

of Jackson County, the document titled "Chattanooga Non-Attainment Area Year 2035 

Conformity Determination Report for Particulate Matter (PM2.5)" was used to determine how 

emissions were calculated for Jackson County and the same methodology was applied in this 

analysis. In order to estimate on-road mobile source emissions for the nonattainment portion of 

Jackson County, a ratio of the size of the nonattainment portion of Jackson County in square 

miles to the size of the entire county in square miles was calculated. The nonattainment portion 

of Jackson County was determined to be only about one percent of the total area of Jackson 

County. The same ratio was applied to obtain area and non-road mobile source emissions for 

the nonattainment portion of the county. The following table shows the small percentage of 

PM2.s emissions from on-road mobile sources as compared to PM2.5 emissions from all other 

3-4 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

sources in the nonattainment portion of Jackson County. Emission data were obtained from the 

SEMAP 2007 base year inventory. 

Table 3.2.1.2.2.1-1 2007, 2017, 2025 Direct PM2•5 (TPY) Emissions in the Nonattainment Portion 

of Jackson County by Source Type 

Source 2007 % of % of % of 

Cate2ory {attainment) total 2017 total 2025 total 

Point 755.49 96.194 534.89 94.79 534.89 94.6_82 

Area 27.11 3.452 28.08 4.976 29. 17 5.164 

Nonroad 2.05 0.261 l.OI 0. 179 0.63 0. 112 

Mobile 0.73 0.093 0.3 1 0.055 0.24 0.042 

Total 785.38 100 564.29 / 00 564.93 / 00 

As the above table demonstrates, direct PM2.5 emissions from on-road mobile sources in the 

nonattainment portion of Jackson County are less than 1% of the total direct PM25 emissions 

from all source categories in the same area. 

In the table below, a comparison is made of the mobile source direct PM2.s emissions from the 

nonattainment portion of Jackson County to total mobile source PM2.5 emissions for the entire 

Chattanooga nonattainment area. 

Table 3.2.1.2.2.1-2 2007,2017,2025 Direct PM2•5 (TPY) On-road Mobile Source Emissions in the 

Nonattainment Portion of Jackson County Compared to Total On-road Mobile Source Emissions 

in the Entire Chattanooga NAA 

2007 Percentage of 2017 Percentage 2025 Percentage Area Emissions Emissions Emissions 

(TPY) Total (TPY) of Total (TPY) of Total 

Jackson 

CountyNAA 0.73 0.2% 0.31 0.2% 0.24 0.2% 

Portion 

Chattanooga 390 197 134 NAA 

As the table above demonstrates, direct PM2.5 emissions from on-road mobile sources in the 

Jackson County portion of the nonattainment area are 0.2% of the total direct PM2.5 emissions 

from on-road mobiles sources in the entire Chattanooga NAA for 2007, 2017, and 2025. 

3-5 
DRAFT Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

3.2.1.2.2.2 The current state of the air quality in Jackson County. 

The small portion of Jackson County, Alabama, was included in the Chattanooga PM2.5 

nonattainment area due to the fact that a power plant is located in that area and it was thought 

by EPA to contribute to the PM2.5 problem in Chattanooga. There are no PM2.5 monitors 

located in Jackson County. Monitors in Alabama near Jackson County have monitored values 

below the annual PM2.5 NAAQS. Other counties surrounding the county are either in 

attainment or unclassifiable. 

3.2.1.2.2.3 The absence of SIP motor vehicle controls for the area. 

There are no SIP motor vehicle controls for Jackson County. 

3.2.1.2.2.4 Historical trends and future projections of the growth of motor vehicle emissions. 

The "Chattanooga Non-Attainment Area Year 2035 Conformity Determination Report for 

Particulate Matter (PM2.5)" was used to obtain past and future projections of the growth in 

direct PM2.5 emissions from on-road mobile sources. As demonstrated in the table below, future 

emissions of direct PM2.s are expected to decrease. 

Table 3.2.1.2.2.4-1 Historical and Future Projections ofPM2.s emissions from On-Road Mobile 

Sources in Jackson County 

Year Emissions (TPY) 

2002 0.413 

2009 0.241 

2015 0.155 

2025 0.130 

2035 0.136 

Each of the factors set forth in 40 CFR 93.109(k) were reviewed for the transportation-related 

PM2.s precursor pollutants NOx, SOx, and direct PM2.s. These reviews support the conclusion 

that mobile source emissions of NOx, SOx, and direct PM2.5 in the Jackson County portion of 

the Chattanooga annual PM2.5 nonattainment area are insignificant under the transportation 

conformity rule for the annual PM2.s NAAQS. 

The report is included in this request as Appendix B. 

3-6 
Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

4.0 Maintenance Plan 

Section 175A of the CAA Amendments of 1990 defines the general framework of a 

maintenance plan. The core provisions include the attainment inventory, the maintenance 

demonstration, the verification of continued attainment, and the contingency plan. 

4.1 Maintenance Demonstration 

The required maintenance plan must become a part of the SIP and provide for maintenance 

of the air quality in the affected area for at least 10 years after designation. Specifically, the 

CAA requirement is that a maintenance plan that is at least 10 years in length (i.e., after 

EPA's expected approval) be submitted with the redesignation request. Subsequently, 8 

years after redesignation and submittal of the initial maintenance plan, the State is required 

to submit an additional maintenance plan that shows maintenance for the remainder of the 

20 year period. Alabama has chosen 2025 as the end year of the initial maintenance plan for 

the Chattanooga NAA. 

The general approach used for the maintenance plan to demonstrate that attainment of the 

annual PM2.5 standard will continue to be maintained is based upon restricting the future 

anthropogenic emissions to a level that is representative of attainment of the standard. If 

these future emissions are no greater than the actual emissions during a year in which 

attainment of the standard was monitored, then it can be assumed that attainment of the 

standard will also be achieved in future years. 

The following sections discuss the attainment year inventory, the projected inventories, and 

verification of continued attainment. Table 4.4-1 shows a calculated safety margin for 

PM2.s, NOx and S02 for each year in the maintenance plan. 

4.2 Attainment Inventory 

2007 was selected as the year for the attainment year emissions inventory. 2007 is one of 

the three years (2007 - 2009) on which the Chattanooga area's clean data determination is 

based. The pollutants inventoried and addressed in this maintenance plan are direct PM2.s, 

S02, and NOx. The following emissions sectors are included in the inventory: 

• Point sources (EGU and non-EGU). 

• Nonpoint sources (including fire), 

• Onroad mobile sources, and 

• Nonroad mobile sources (including marine vessels, aircraft, and rail). 

The 2007 inventory, with the exception of on-road mobile emissions, was prepared for 

Alabama by the contractors for the Southeastern Modeling, Analysis, and Planning 

(SEMAP) project. SEMAP is funded by the same ten states that participated in the Visibility 

Improvement - State and Tribal Association of the Southeast (VISTAS) project. Under the 

SEMAP project, emissions estimates are reported by county and source classification code 

(SCC). The SEMAP emissions inventories were developed using data from a number of 

sources, including state and local agencies and EPA's National Emissions Inventory (NEI). 

4-1 
Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

ADEM developed the 2007 inventory of on-road mobile emissions. Please see Table 4.4-1 

for a summary of the base year inventory. 

4.2.1 Point Sources 

Point sources captured in the inventory include stationary sources whose actual emissions 

equal or exceed 100 tons per year of S02, NOx, or particulate matter. Emissions from point 

sources have been calculated for EGU and non-EGU sources. 

There are only two point sources in the Jackson County portion of the NAA: TVA Widows 

Creek Plant and Rock-Tenn Mill Company, LLC- Stevenson Mill. 

Table 4.2.1-1 2007 Point Emissions (TPY) 

Facility ·-· Unit NOx PM2.S SOl 

Neutral Sulfite SemiChemical Recovery System 147.17 0.14 0.67 

No. 1 Power Boiler 99.85 34.08 45.78 

Rock-Tenn Mill Company, · No. 2 Power Boiler 51.45 9.44 32.98 LLC - Stevenson Mill 1 No. 1 Wood Waste Boiler 251 .68 42.53 I 1.01 I 

No.2 Wood Waste Boiler 436.68 5.15 6.54 

986.83 91.34 86.98 

Unit 1 1,646.00 20.00 3,550.00 

Unit2 1,706.00 7.04 3,673.00 

Unit 3 1,750.00 111.00 3,766.00 

Unit 4 2,028.00 18.40 4,363.00 

TV A Widows Creek Unit 5 1,316.00 20.40 2,834.00 

Unit 6 1,818.00 2.21 3,911.00 

Unit 7 3,694.00 63 .10 6,519.00 

Unit 8 3,647.00 422.00 4,101.00 

17605.00 664.15 32 717.00 

Facility/Point Emissions Total 18,591.83 755.49 32,803.98 

Emissions estimates for point sources in 2007 were obtained from SEMAP point source 

inventory vl.IO. For more information regarding the SEMAP point inventory, please refer 

to Appendix C-1 . 

4.2.2 Nonpoint Sources 

Nonpoint sources can be defined as those sources and activities that are too small or too 

numerous to be handled individually in a point source inventory. Nonpoint sources captured 

in the inventory include stationary sources whose emissions levels of S02, NOx, and 

particulate matter are each less than 100 tons per year. Emissions from nonpoint sources in 

2007 were obtained from the SEMAP final nonpoint source inventory version 1.1. A default 

2007 nonpoint source inventory was created that includes all of the source categories 

covered by the 2008 nonpoint source NEI. 

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Jackson County Annual PM2.s Nonattainment Area 

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For all source categories, except industrial and commerciaVinstitutional (ICI) fuel 

combustion, emissions data from the 2008 nonpoint source NEI were directly incorporated 

when the NEI emissions were based on 2007 emissions activity data. The NEI emissions 

estimates were recalculated to reflect 2007 activity levels when the NEI emissions reflected 

2006 or 2008 activity levels. Emissions associated with activity reflected in the point source 

inventory were removed from the nonpoint inventory. 

For ICI fuel combustion, the 2008 nonpoint source NEI developed emissions activity 

estimates rather than emission estimates. Because of the potential importance of these 

source categories and the availability of methodological improvements, TranSystems 1 

utilized an emissions estimation method for ICI fuel combustion that incorporates a few 

refinements to the NEI method. These emissions were supplemented with carry-forward 

categories from Alabama's 2005 Consolidated Emissions Reporting Rule (CERR) 

submission grown using EPA's Economic Growth Analysis System 5.0 (EGAS). For more 

information regarding the SEMAP nonpoint inventory, please refer to Appendix C-2. 

Emissions from fires in 2007 were obtained from the SEMAP final "actual" fire emissions 

inventory. This inventory was developed using 2007 burned area data submitted by 

Alabama, as well as updated fuel consumption and emissions factors. The 2007 nonpoint 

source emissions for Jackson County are presented in Table 4.2.2-1. 

Table 4.2.2-1 Jackson County NAA Non point Source Emissions for 2007 (TPY) 

Nonpoint Total Pollutant (excluding Fire Nonpoint fire) 

SOz 0.1455 0.1083 0.2538 

NOx 1.0722 0.5107 1.5829 

PMz.s 25.363 1.7508 27.1138 

The 2007 level of PM2_

5 emissions from nonpoint sources, excluding fire, was 25.363 

tons. This quantity accounted for about 3 percent of total PM2_

5 emissions in Jackson 

County. 

As area sources are largely a function of population, the ratio of the population of the single 

census block to the entire county's population was applied to the county-wide area source 

emissions, as seen below: 

Census Block Population/County Population * County-wide Area Source Emissions = 

Partial County Area Source Emissions 

1 TranSystems is supporting SESARM in the SEMAP project that is funded by the same ten states originally 

involved in the VISTAS project. The SEMAP project addresses the next phase of ozone, fme particle, and 

regional haze assessment obligations of the SESARM member states. The SEMAP project is designed to 

produce technical analyses to aid the participating agencies in developing SIPs required by the CAA. 

In June 2010, TranSystems developed a set of "final" 2007 area and nonroad source base year inventory 

emission estimates. 

4-3 
Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

1,469 I 53,227 * 38.85 TPYNOx = 1.0722 TPYNOx. 

For fire emissions calculations, the ratio of the area of the single census block to the entire 

county's area was applied to the county-wide fire emissions, as seen below: 

Census Block Area/County Area * County-wide Fire Emissions = Partial County Fire 

Emissions 

12.88 sq. miles/1127 sq. miles* 44.6891 TPYNOx = 0.5107 TPYNOx. 

Population data used in calculations was taken from the 201 0 Census. 

4.2.3 On-road Mobile Sources 

The U.S. EPA's MOVES2010b mobile source emissions model was run in inventory mode 

to generate 2007 mobile source emissions for S02, NOx and PM2.s for Jackson County, 

Alabama. Local vehicle miles traveled (VMT) data for Jackson County was developed by 

the Alabama Department of Transportation (ALDOT) for 2007. The VMT data was used to 

make appropriate calculations in the development of the MOVES2010b input files. 

The runspecs for all years modeled were developed using the same format. All were set to 

the county scale with all months, days and hours being modeled. The aggregation level was 

set to hour with the appropriate state and county being selected in the geographic bounds 

section. 

All relevant gasoline and diesel vehicles were chosen as well as all road types. The 

pollutants of concern were NOx, PM2.5 and S02. For those pollutants where the emissions 

calculation is based on prior calculation of another pollutant, the appropriate base pollutants 

were also selected. "Tons" was selected as the emissions unit, and the emissions detail was 

aggregated to "year" in order to retrieve data in tons per year. Input data was then imported 

through the County Data Manager (CDM). 

MOVES2010b default data was exported, reviewed andre-imported for the following CDM 

inputs: Age Distribution, Average Speed Distribution, Fuel Supply, Meteorology and Ramp 

Fraction. Source Type Population, Vehicle Type, VMT, and Road Type Distribution were 

derived from either manual calculation or by using one of the converters provided by EPA. 

For Fuel Formulation, the Reid vapor pressure (RVP) was adjusted to 9.0 for MaySeptember with the default RVP being used for all other months. 

The process of data collection and emissions modeling was conducted in accordance with 

the Technical Guidance on the Use of MOVES2010 for Emission Inventory Preparation in 

State Implementation Plans and Transportation Conformity. The onroad mobile source 

emissions for the portion of Jackson County in the nonattainment area were derived by 

taking 1% of the total for all of Jackson County for each of the pollutants (S02, NOx and 

PM2.5). 1% is based on the ratio of the size of the nonattainment portion of Jackson County 

in square miles to the size of the entire county in square miles. The 2007 onroad mobile 

source emissions totals for the portion of Jackson County in the nonattainment area are 

listed in Table 4.4-1 (Please also see Appendix C-3). 

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Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

4.2.4 Nonroad Mobile Sources 

The nonroad sector is comprised ofnonroad engines included in EPA's NONROAD model, 

such as recreational marine and land-based vehicles, farm, construction and industrial 

machinery, and lawn and garden equipment. This sector also includes engines not modeled 

in NONROAD, specifically aircraft, commercial marine vessels (CMV), and locomotives. 

There are no aircraft emissions sources in the portion of Jackson County that is included in 

the nonattainment area. Nonroad mobile emissions for 2007 for the portion of Jackson 

County in the nonattainment area are presented in detail in Table 4.2.4-1 and summarized in 

Table 4.4-1. 

Emissions from NONROAD model source categories in 2007 were obtained from the 

SEMAP final nonroad mobile sources emissions inventory. These emissions were 

calculated using EPA's latest National Mobile Inventory Model, NMIM2008, which 

incorporates EPA's latest NONROAD model (NONROAD2008) and reflects all of EPA's 

final nonroad standards to date. For more information regarding the SEMAP nonroad 

inventory, please refer to Appendices C-2, C-3 and C-4. Emissions from commercial marine 

vessels and locomotives for 2007 were obtained from the SEMAP final nonroad mobile 

source emissions inventory. For more information regarding the SEMAP marine, aircraft 

and locomotives inventory, please refer to Appendices C-2, C-3 and C4 

Nonroad sources encompass sources that are a function of population as well as sources that 

are more location specific. To develop more conservative nonroad estimates for the partial 

county, a population ratio was applied. The equation is below: 

Census Block Population/County Population * County-wide Emissions = Partial County 

Emissions 

Table 4.2.4-1 2007 Nonroad Mobile Source Emissions (tons) 

PoUutant Total 

(tons) No01-oad* CMV Locomotives Non road 

so2 .55 .08 .28 .91 

NOx 11.40 1.08 24.84 37.32 

PM2.s 1.19 .03 .83 2.05 

*Excludes CMV and Locomotives. 

4.3 Projected Emissions Inventory 

Projected emissions inventories are calculated by applying applicable control and growth 

factors to the 2007 emissions of individual sources or source categories. The pollutants 

whose emissions are projected are S02, NOx, and direct PM2.5. As with the attainment 

inventory, emissions from the following sectors are projected: 

• Point sources (non-EGU). 

• Nonpoint sources (including fire). 

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Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

• Onroad mobile sources. and 

• Nonroad mobile sources (including marine vessels, aircraft, and rail). 

The projected inventories are presented in the following subsections and a summary can be 

found in Table 4.4-1. The methods used to develop the emissions projections are presented 

in more detail in Appendix C-4. 

4.3.1 Point Sources 

To establish 2017 and 2025 projected point emissions, the following issues were taken into 

account: 

• A federal facilities compliance agreement between EPA and the Tennessee Valley 

Authority, Docket No. CAA-04-2010-1760 (Compliance Agreement) requires TV A 

Widows Creek to retire Units 1-6 by July 31,2015 (Please see Appendix D). 

• Power Boilers 1 and 2 at the Stevenson Mill are switching from Grade 6 Residual Oil 

to Natural Gas. The new permit limits are reflected in their Title V. 

Growth rates for Widows Creek Units 1-6 were set to zero to reflect the retirement of those 

units. For Units 7 and 8, an average rate of growth was calculated based on emissions from 

2000-2010 as reflected in the Clean Air Markets Division Database. EGAS 5.0 factors were 

applied to all units at the Stevenson Mill; however, new base estimates were calculated for 

the two power boilers to reflect the switch in fuels. These estimates are based on similar 

units within the State. Please see Appendix C-4 for the projection calculations. 

4.3.2 Nonpoint Sources 

Nonpoint source emissions, excluding fire, in future years 2017 and 2025 were estimated 

using SCC- and county-specific growth factors generated with EGAS 5.0. Appendix C-4 

contains the SCC- specific growth factors for Jackson County. Just as for the base year, the 

emissions were apportioned to the census block group by applying the ratio of block group 

population to county population. No additional future controls can be defined for these 

sources at this time. Emissions from fire in future years 2017 and 2025 were assumed to be 

the same as 2007 emissions. 

4.3.3 Onroad Mobile Sources 

The U.S. EPA's MOVES2010b mobile source emissions model was run in inventory mode 

to generate 2017 and 2025 mobile source emissions for S02, NOx and PM2.s for Jackson 

County, Alabama. Local VMT data for Jackson County was developed by the ALDOT for 

2017 and 2025. The VMT data was used to make appropriate calculations in the 

development of the MOVES2010b input files. 

The same methodologies described in Section 4.2.3 for runspec and input file development 

were used for 2017 and 2025. The process of data collection and emissions modeling was 

conducted in accordance with the Technical Guidance on the Use of MOVES2010 for 

Emission Inventory Preparation in State Implementation Plans and Transportation 

Conformity. The same methodologies described in section 4.2.3 to calculate partial county 

emissions were also used for 2017 and 2025. The projected onroad mobile source emissions 

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Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

totals for the portion of Jackson County in the nonattainment area are listed in Table 4.4-1 

(Please see Appendix C-3). 

4.3.4 Nonroad Mobile Sources 

Projections of nonroad emissions in 2017 and 2025, excluding commercial marine vessels 

and rail sources, were calculated using NMIM2008. Defaults in NMIM2008 were used for 

inputs. 

Category 1 & 2 growth and control factors were applied to the "diesel underway" category 

(SCC2280002200). Growth factors for CMV emissions were calculated based on fuel 

consumption forecasts published by the Energy Information Administration (EIA). Table 67 

of EIA's Annual Energy Outlook, 2010 provides national-level forecasts by domestic and 

international shipping sectors for years out to 2035 (EIA, 2010). Control factors were 

developed based on emission reductions calculated from national base case and control case 

inventories developed for the years 2002 through 2040. Growth and control factors were 

received from TranSystems/Pechan. The development of these growth and control factors is 

discussed in Appendix C-4. 

For Class I and Class II/III line haul and diesel switchyard operations, growth factors were 

calculated based on freight rail sector fuel consumption forecasts, as published by the EIA. 

Similar to CMVs, diesel locomotive engines are subject to revised Federal Tier 0, Tier 1 and 

Tier 2 standards, as well as Tier 3 and 4 standards. Control factors were developed for 

diesel-powered locomotive engine emissions based on EPA's locomotive engine regulatory 

impact analysis and associated emission factor guidance. Growth and control factors were 

received from TranSystems/Pechan. The development of these growth and control factors is 

discussed in Appendix C-4. 

The nonroad mobile source emissions projections for the portion of Jackson County in the 

nonattainment area are presented in detail in Table 4.3.4-1 and summarized in Table 4.4-1. 

Total emissions of all three pollutants trend downward during the maintenance period. For 

more information regarding the nonroad inventory please see Appendices C-2, C-3 and C-4. 

Nonroad sources encompass sources that are a function of population as well as sources that 

are more location specific. To develop more conservative nonroad estimates for the partial 

county, a population ratio was applied. The equation is below: 

Census Block Population/County Population * County-wide Emissions = Partial County 

Emissions 

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Jackson County Annual PMz.s Nonattainment Area 

Request for Redesignation to Attainment 

Table 4.3.4-1 Projected Nonroad Mobile Source Emissions (tons per year) 

Source Type Pollutant 2007 2017 2025 

SOz 0.55 0.02 0.02 

Non road* NOx 11.4 8.16 6.42 

PMz.s 1.19 0.6 0.37 

SOz 0.08 0.08 0.08 

CMV NOx 1.08 0.9 0.66 

PMz.s 0.03 0.02 0.02 

SOz 0.28 0.05 0.05 

Locomotive NOx 24.8 16.8 11.9 

PMz.s 0.83 0.39 0.24 

SOz 0.91 0. 15 0.15 

Total Nonroad NOx 37.3 25.9 19 

PMz.s 2.05 1.01 0.63 

*Excludes CMV and Locomotives. 

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Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

4.4 Maintenance Plan Inventory 

Table 4.4-1 Jackson County, AL portion of the Chattanooga Annual PM2.5 Attainment Area 

Maintenance Plan Emissions (Tons per Year) 

Source Pollutant 2007 %of 2017 %of 2025 % oftotal Category (attainment) total total 

so2 32,803.98 99.996 10,515.63 99.996 10,517.47 99.996 

Point NOx 18,591.83 99.668 3,468.44 98.962 3,607.05 99.270 

PM2.s 755.49 96.194 534.89 94.790 534.89 94.682 

so2 0.25 0.001 0.25 0.002 0.24 0.002 

Area NOx 1.58 0.008 1.55 0.044 1.57 0.043 

PM2.5 27.11 3.452 28.08 4.976 29.17 5.164 

so2 0.91 0.003 0.15 0.001 0.15 0.001 

Non-road NOx 37.32 0.200 25.86 0.737 18.95 0.522 

PM2.s 2.05 0.261 1.01 0.179 0.63 0.112 

so2 0.19 0.001 0.07 0.001 0.07 0.001 

Mobile NOx 23.00 0.123 9.00 0.257 6.00 0.165 

PM2.5 0.73 0.093 0.31 0.055 0.24 0.042 

so2 32,805.33 100.00 10,516.10 100.000 10,517.93 100.000 

Total NOx 18,653.73 100.00 3,504.83 100.000 3,633.57 100.000 

PM2.5 785.38 100.00 564.29 100.000 564.93 100.000 

so2 22,287.40 

Maintenance Plan Decrease from 2007 NOx 15,020.16 

PMz.s 220.45 

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Jackson County Annual PMz.5 Nonattainment Area 

Request for Redesignation to Attainment 

Table 4.4-2 Maintenance Inventory for the Chattanooga NAA (TPY) 

Source NOx 80 2 PM2.5 

Catexory 2007 2017 2025 2007 2017 2025 2007 2017 

Point 

Chattanooga, 

TN 2,437 2,651 3,155 919 798 866 160 169 

Georgia 48 49 52 280 287 295 0 0 

Alabama 18,592 3,468 3,607 32,804 10,516 10,517 755 535 

Point Total 21,077 6,168 6,814 34,003 11,601 11 ,678 915 704 

Nonpoint/Area 

Chattanooga, 

TN 3,415 4,090 4,881 333 383 441 875 1,001 

Georgia 359 414 456 77 82 87 1,548 1,807 

Alabama 2 2 2 0.25 0.25 0.24 27 28 

Nonpoint/ Area 

Total 3,776 4,506 5,339 410 465 528 2,450 2,836 

Non road 

Chattanooga, 

TN 1,792 1,003 675 99 14 16 154 101 

Georgia 633 372 277 27 8 9 51 32 

Alabama 37 26 19 1 0.15 0.15 2 1 

Nonroad Total 2,462 1,401 971 127 22 25 207 134 

Onroad 

Chattanooga, 

TN* 8,308 5,554 2,799 59 43 28 255 117 

Georgia 4,442 2,542 1,022 20 15 ll 134 80 

Alabama 23 9 6 0.19 0.07 0.07 0.73 0.31 

Onroad Total 12,773 8,105 3,827 79 58 39 390 197 

Total 

Chattanooga, 

TN 15,952 13,298 11,510 1,410 1,238 1,351 1,444 1,388 

Georgia 5,482 3,377 1,807 404 392 402 1,733 1,919 

Alabama 18,654 3,505 3,634 32,805 10,516 10,518 785 564 

Total 40,088 20,180 16,951 34,619 12,146 12,271 3,962 3,871 

2025 

206 

0 

535 

741 

1,122 

1,998 

29 

3,149 

64 

22 

0.63 

87 

98 

36 

0.24 

134 

1,490 

2,056 

565 

4,111 

*Emissions for the Chattanooga, TN area are draft. Further, the maintenance demonstration for the Chattanooga, TN 

counties used 2016 as a mid-year rather than 2017. Therefore, the emissions estimates for TN in the 20 17 column are 

actually 2016 values. 

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Jackson County Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

4.5 Plan to Maintain Air Quality 

ADEM has implemented programs that will remain enforceable and are hereby submitted as 

the plan to ensure that maintenance of the annual PM2.s standard will continue. Sources are 

prohibited from reducing emission controls ('anti-backsliding') following the redesignation 

of the area unless such a change is first approved by the EPA as a revision to the Alabama 

SIP that is consistent with Section 11 0(1) of the CAA. 

The following regulatory programs will remain in place in the Chattanooga NAA: 

• Federal Tier II Motor Vehicle Emissions Standards 

• Federal On-road Diesel Engine Standards 

• Federal Non-road Diesel Engine Standards 

• Federal Marine Engine Requirements 

• Federal Locomotive Requirements 

• The Federal New Source Performance Standards under Section Ill (42 U.S.C. 7411) 

• The Federal National Emissions Standards for Hazardous Air Pollutants (NESHAP) 

under Section 112 (42 U.S.C 7412) 

• The Federal N Ox SIP Call 

• The Clean Air Interstate Rule2 

• Georgia Rules for Air Quality Control Chapter 391-3-1 Rule (sss) "Multipollutant 

Control of Electric Steam Generating Units" 

• The federal facilities compliance agreement between EPA and the Tennessee Valley 

Authority, Docket No. CAA-04-2010-1760 requiring TVA Widows Creek to retire 

Units 1-6. The compliance dates for this action are staggered as follows: 

o 2 units by July 31, 2013; 

o 2 units by July 31, 2014; 

o 2 units by July 31,2015. 

The overall expected reductions are 15,111 tons per year ofNOx and 28,192 tons per 

year of S02. The consent decree further required year-round operation of the SCRs 

on Units 7 and 8 (See Appendix D). 

• Rock-Tenn Mill Company, LLC - Stevenson Mill is switching from Grade 6 

Residual Oil to Natural Gas in the power boilers (units ZOOI and X008). The new 

permit limits are reflected in their Title V. 

2 The Cross-State Air Pollution Rule was vacated by the United States Court of Appeals for the District of 

Columbia Circuit on August 21, 2012. The Clean Air Interstate Rule was reinstated until a permanent 

transport rule is put into place; however, EPA's modeling for the Transport Rule demonstrates the Chattanooga 

Area would be able to obtain the 1997 Annual PM2.5 standard even in the absence ofthe Transport Rule. 

4-11 
Jackson County Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

4.5.1 Verification of Continued Attainment 

Verification of continued attainment is monitored through the State of Georgia, the 

Chattanooga-Hamilton County Air Pollution Control Bureau, and the Tennessee Division of 

Air Pollution Control's operation of the ambient fine particulate matter monitor network and 

the maintenance of updating the area's emissions inventory. 

The current four ambient PM2.s monitors that are operating in the annual PM2.s 

nonattainment area will continue to operate unless a change(s) is approved by EPA. No 

plans are underway to discontinue operation, relocate, or otherwise affect the integrity of the 

ambient monitoring network in place. Any change would only be made if it is consistent 

with 40 CFR Part 58. 

The Air Emissions Reporting Requirements (AERR) was promulgated by EPA on 

December 5, 2008. For the purposes of verifying continued attainment based upon the 

emissions inventory, the three main components of the inventory, point, area and mobile, 

will be updated on different schedules. The major point sources of air pollution will 

continue to submit data on their emissions on an annual basis. This has been required under 

40 CFR 51, Subpart Q for many years. For the area source and mobile source portions of 

the inventory, these emissions will continue to be quantified on a three-year cycle. 

4.5.2 Contingency Plan 

Section 175A(d) of the CAA Amendments requires the inclusion of contingency provisions 

that would be implemented by the State to correct any future violation of the NAAQS in 

areas that had been redesignated as an attainment area. Alabama commits to adopt, within 

18 months of certification of a violation of the annual PM2.5 standard, one or more control 

measure(s) (contingency measures) as needed to re-attain the standard. The State of Alabama 

will use actual ambient monitoring data as the indicator or trigger to determine when these 

contingency measures, if deemed necessary, would be implemented. In accordance with 

40 CFR 58, ambient fine particulate matter monitoring data that indicates a future violation 

of the annual PM2.5 NAAQS will begin the process to implement these contingency 

measures. Also, in the event that the annual average PM2.s concentrations in a year at any 

individual monitor in the nonattainment area records a reading of 15 J.tg/m3 or higher, the 

State will evaluate existing control measures to determine whether any further emission 

reduction measures should be implemented at that time. If periodic emission inventory 

updates reveal excessive or unanticipated emissions growth greater than 30%, the State will 

evaluate existing control measures to determine whether any further emission reduction 

measures should be implemented at that time. 

Several factors will be considered in determining the need for additional control measures in 

the event of a future year violation of the annual PM2.s standard. Depending on when such 

future year violation occurs, additional local and regional emissions reductions may still be 

on the way from various regulatory programs. If a future year violation occurs, ADEM will 

consider the air quality impact of these various regulatory programs in determining the need 

for additional local reductions in emissions of direct PM2.5 and/or S02. 

If deemed necessary, contingency measure(s) will be selected from the following types of 

measures or from any other measures deemed appropriate and effective at the time the 

selection is made: 

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Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

• Reasonably Available Control Measures (RACM) for sources of S02 and PM2.s; 

• Reasonably Available Control Technology (RACT) for point sources of S02 and 

PM2.s; 

• Expansion ofRACMIRACT to area(s) of transport within the State; and 

• Additional S02 and/or PM2.s reduction measures yet to be identified. 

Any resulting contingency measure(s) will be based upon cost effectiveness, emtsswn 

reduction potential, economic and social considerations, ease and timing of implementation, 

and other appropriate factors. 

A timeline for the development of NOx, PM2.s and/or S02 regulations or permit conditions 

follows. This schedule initiates with certification of ambient air quality monitoring data 

indicating a violation of the annual PM2.5 NAAQS: 

Table 4.5.2-1 Schedule for Permit Revisions or Rule Revisions for Contingency Measures 

1. Identify and quantify the emissions reductions expected to result in 

the future from existing and future state and federal regulatory 3 months 

programs. 

2. Use the best available air quality modeling to evaluate the air 

quality improvement expected to result in Jackson County from the 6 months 

programs and emissions reductions identified in step 1 above. 

3. Draft any needed permit conditions or SIP regulations. 3 months 

4. Complete rulemaking or permit revision process and submit to 

EPA. 6 months 

Completion no later than: 18 months 

4-13 

Jackson County Annual PM2.s Nonattainment Area 

Request for Redesignation to Attainment 

5.0 Conclusion 

The most recent three years of quality-assured PM2.

5 monitoring data for the Chattanooga 

NAA demonstrate compliance with the NAAQS for annual PM2.5. This redesignation 

request and maintenance demonstration has been prepared to meet the requirements of the 

1990 CAAAmendments. 

5-1 

Part FFinal N02 and S02 Infrastructure SIP