# 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 Submittalfl

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Part APart BPart CPart D -PartEPart F

### TABLE OF CONTENTS Resolutions Signed by the Director ofthe 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 ProofofPublication ofLegal 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 SIPIfPart A

### Resolutions Signed by the Director ofthe 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 ofthe Clean Air Act (CAA) that address the requirements for the 20 l0 nitrogen dioxide (N02) and sulfur dioxide (S0 2) 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 ofthe 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 ofthe Department, I hereby adopt the proposed revision to the State ofAlabama's State Implementation Plan to certify that the State ofAlabama's State Implementation Plan meets all Section II O(a)( l) and II O(a)(2) provisions ofthe 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

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# f)ia~t~**t!t~** Lance R. l';efleur DirectorALABAMA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT RESOLUTION WHEREAS, on February 24, 2013, the Alabama Department of Environmental Management gave notice ofthe 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 ofthe 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 ofEnvironmental Management has reviewed the written submissions introduced into the record, and has prepared a concise statement ofthe 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 ofthe Department, I hereby adopt the proposed revision to the State ofAlabama's State Implementation Plan to redesignate the Jackson County portion ofthe 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



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# tlltr Lance R. leFleur DirectorPart BLegal Notice ProofofPublication ofLegal NoticeALABAMA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 350 - NOTICE OF PUBLIC HEARING REGARDING THE ALABAMA STATE IMPLEMENTATION PLAN (SIP)

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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/m 3

. 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 (N0 2) 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.

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## 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) 271· 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 

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# 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 ofa year. The Montgomery Advertiser published the attached legal notice in the issues of: 2/2-t/20 13 .\copy ofeach 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** r1 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 Canceflatlon 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 1o:!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 1h1s 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 r11erested persons to comment 'Jn Jocuments that propose to (.erttfy that Alabama's ex1shng State lmplementatton Plan (SIP) ,rBets Sectton 110(a){1) and ! 1 0(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) 394-4360 \f!n M.tfy I l'p'I•Jf • ••\ ;r1h ,Jn p,,,.,J

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,·'l)dfdlnQ 1 ha .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

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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, AlabamaPart CReconciliation Statements

### Reconciliation of Comments Received on the Proposed Revisions to ADEM's 1997Annual PM2.5 

### State Implementation Plan- .Jackson County The USEPA was the only commenter. A summary oftheir 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.
ADEMResponse: 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 ofAir 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.

ADEMResponse: No re!>ponse necessary.
- 1 -

### Reconciliation of Comments Received on Alabama's 2010 

### Nitrogen Dioxide (N02) 

### and Sulfur Dioxide (S02) 

### Infrastructure SIP The USEPA was the only commenter. A summary oftheir 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 ofthe 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 S02or 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 AuthorityI ( I**~** I

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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
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## 197**~**PartEFinal Jackson County PM2.5 Redesignation Request

# REDESIGNATION REQUEST AND MAINTENANCE DEMONSTRATION

Jackson County, Alabama Chattanooga AnnualPM 2. 5

## NonattainmentArea

Prepared 

### by:



### Alabama Department ofEnvironmental Management Air Division

### DRAFTJackson CountyAnnual PM2.5 

### Nonattainment Area Requestfor Redesignation toAttainment 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 ofJackson County, Alabama, in the Chattanooga nonattainment area because they concluded that the Tennessee Valley Authority (TVA) 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 ofambient 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 ofEnvironmental 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 eachjurisdiction. 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 ofthis work, coordination and consultation took place between the three agencies concerning emissions, monitoring data and the expectations ofmaintenance for the entire area. The emissions and monitoring data gathered as a result ofthis 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 ofGeorgia'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

### DRAFTJackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor 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 FullyApprovedSIP, Section 110 andPart 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 Nonattainment 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 ofmotor vehicle NOx emissions in the Jackson County portion ofthe Chattanooga nonattainment area........................................................................, ..................3-2 3.2.1.2.1.2 The current state ofthe air quality in Jackson County
......................................3-3 3.2.1.2.1.3 The absence ofSIP motor vehicle controls for the area...................................3-4 3.2.1.2.1.4 Historical trends and future projections ofthe growth ofmotor vehicle emissions.
..........................................................................................................................3-4 3.2.1.2.2 Direct PM2.5 .............................................................................................................3-4 3.2.1.2.2.1 Analysis ofmotor vehicle PM25 emissions in the Jackson County portion ofthe 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 ofSIP motor vehicle controls for the area...................................3-6 3.2.1.2.2.4 Historical trends and future projections ofthe growth ofmotor vehicle emissions.
..........................................................................................................................3-6 4.0 Maintenance Plan
................................................................-........................................................4-1 4.1 Maintenance Demonstration
....................................................................................................4-1

11

### DRAFTJackson CountyAnnual PM2.5 

### Nonattainment Area Requestfor 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 ofContinued Attainment
................................................................................ 4-12 4.5.2 Contingency Plan
............................................................................................................... 4-12 5. 0 Conclusion
...................................................................................................................................5-1 TABLES Table 2.1.1-1 Annual and Three-yearAverageAmbient PM25 Concentrations
................................. 2-2 Table 3.2.1.2.1.1-1 2007, 2017, 2025 NOx (TPY) Emissions in the Nonattainmentportion of Jackson County by Source Type
.................................................................................................................... 3-3 Table 3.2.1.2.1.1-2 2007, 2017, 2025 NOx (TPY) On-roadMobile Source Emissions in the

Nonattainment Portion of Jackson County Compared to Total On-roadMobile Source Emissions in the entire Chattanooga NAA
... .............................................................................................................. 3-3 Table 3.2.1.2.1.4-1 Historical andFuture Projections ofNOxemissionsfrom On-RoadMobile Sources

in Jackson County
........................................................................................................................... 3-4 Table 3.2.1.2.2.1-1 2007, 2017, 2025 Direct PM 2.5 (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 PM 25 (TPY) On-roadMobile Source Emissions in the Nonattainment Portion of Jackson County Compared to Total On-roadMobile Source Emissions in the Entire Chattanooga NAA
.. .............................................................................................................. 3-5 Table 3.2.1.2.2.4-1 Historical andFuture Projections of PM2.5 emissions from On-RoadMobile 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 Emissionsfor 2007 (TPY)
............................. 4-3 Table 4.2.4-1 2007 NonroadMobile Source Emissions (tons).
.......................................................... 4-5 Table 4.3.4-1 ProjectedNonroadMobile Source Emissions (tons peryear)
..................................... 4-8

ill

### DRAFTJackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor Redesignation to Attainment Table 4. 4-1 Jackson County, ALportion of the ChattanoogaAnnualPM25AttainmentArea 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 ChattanoogaAnnualPM 25NAA
..................... 1-2 Figure 2.1.1-1 Locations of PM25Monitors in the Chattanooga NAA
.............................................. 2-3

IV

### DRAFTJackson CountyAnnualPM2.s 

### Nonattainment Area Requestfor Redesignation to Attainment APPENDICES GA Maintenance Plan andRedesignation Request
............................................................................... A Insignificance Determinationfor Transportation Conformity Under PM 2.5 NAAQSfor Jackson County, AL
........................................................................................................................................................... B Emissions Inventory Documentation
..................................................................................................... C Development ofthe Point Source Emissions Inventory for 2007 in the SESARM Region (Version 1.10a), January 18, 2012
................................................................................................................ C-1 Area andNonroad 2007 Base Year Inventories, RevisedFinal Report, Jan 2012
......................... C-2 Onroad andNonroad 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 QualityAssurance Project Plan.
......................................... C-5 E.H Feehan andAssociates, July 29, 2009. Quality Assurance Project Planfor Non- road andArea Source Base Year andFuture 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, TNDRAFTMaintenance Plan andRedesignation Request- Narrative Only
................ E

v

### DRAFTJackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor Redesignation to Attainment 

### Listof Acronyms Acronym Meaning Acronym Meaning

ADEM Alabama Department of FR Federal Register Environmental Management
AERR Annual Emissions Reporting FRM Federal Reference Monitor Requirements
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 NEI National Emissions Inventory Rule
CFR Code ofFederal 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

### DRAFTJackson CountyAnnual PM2.5 

### Nonattainment Area Requestfor Redesignation to Attainment

Acronym Meaning Acronym Meaning
PSD Prevention ofSignificant Deterioration SIP State Implementation Plan
RACM Reasonably Available Control Measures S02 Sulfur Dioxide
RACT Reasonably Available Control TIP Transportation Improvement Plan Technology
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 ofthe Southeast SCR Selective Catalytic Reduction VMT Vehicle Miles Traveled
SEMAP Southeastern Modeling Analysis Plan

Vll

### DRAFTJackson CountyAnnual PM2.5 

### Nonattainment Area Requestfor 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 ofJackson County, Alabama, as a part ofthe 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

### DRAFTJackson CountyAnnual PM2
.s 

### Nonattainment Area Requestfor 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 ofthe Chattanooga Annual PM2.5 NAA

1-2

### DRAFTJackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor Redesignation to Attainment 1.3 Formation ofPM2.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 ofvarying amounts ofdifferent species, including: • Sulfates • Nitrates (usually found in the form ofammonium 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 ofthe pollutant throughout the country (40 CFR 58, App. D). 1-3

### DRAFTJackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor Redesignation to Attainment 1.4 Criteria for Redesignation Section 107(d) ofthe federal CAA, as amended in 1990, states that an area can be redesignated to attainment ifthe 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 ofthis document. The second and fourth requirements relate to the implementation plan. All requirements under §110 and Part D ofthe 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 ofour 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

### DRAFTJackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor Redesignation toAttainment 

### 2.0 AttainmentDemonstration 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 ofthe 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 ofthe 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 ofthe 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

### DRAFTJackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor Redesignation to Attainment Table 2.1.1-1 Annual and Three-yearAverage 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

### DRAFTJackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor Redesignation to Attainment 

### PM2.s Monitors
• FRM (2007) • FRM (2002) 

# + Sequatchie

Marion

Jackson

DeKalb Hamilton

TN-Ham ilton-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

### DRAFTJackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor Redesignation to Attainment 2.2 PennanentandEnforct'ableReductiom inEnmsioos 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 ofthe SCRs and FGDs was planned in anticipation ofthe Clean Air Interstate Rule (CAIR) rule, and subsequent replacement rule.

2-4

### DRAFTJackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor 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 ofSignificant 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 offederal 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 oftransportation and air quality planning.
3-1

### DRAFTJackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor 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 ofthe Jackson County attainment demonstration submitted in 2009, ADEM included a report entitled "Insignificance Determination for Transportation Conformity Under 

### PM 25 

### 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 ofthe 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 Countyportion of the Chattanooga nonattainment area. 

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

### PM 25 

### 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 ofthe entire county in square miles was calculated. The nonattainment portion ofJackson 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 ofthe nonattainment area. Emission data were obtained from the SEMAP 2007 base year emissions inventory.

3-2

### DRAFTJackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor Redesignation toAttainment 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 0.043Nonroad 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 ofJackson 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) ofTotal (TPY) e ofTotal (TPY) ofTotal 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 ofJackson 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

### DRAFTJackson CountyAnnual PM2.5 

### Nonattainment Area Requestfor 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 ofthe 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 PM 25 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 ofPM2.5 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 ofthe 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

### DRAFTJackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor Redesignation to Attainment sources 

### in the nonattainment portion ofJackson 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 ofJackson County by Source Type
Source 

### 2007 % of % of % of Cate2ory {attainment) 

### total 

### 2017 total 

### 2025 total

Point 755.49 96.1 94 534
.89 9 4.79 534. 89 94.6_82 Area 27
. 11 3
.452 28
.08 4
.9 7 6 29. 17 5
. 16 4Nonroad 2.05 0
.261 l.OI 0. 1 7 9 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 ofthe 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 ofJackson 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) ofTotal (TPY) ofTotal 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

### DRAFTJackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor 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 futureprojections 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 ofdirect 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 ofNOx, 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 CountyAnnual PM2.s

### Nonattainment Area Requestfor 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 ofcontinued attainment, and the contingency plan. 

### 4.1 Maintenance Demonstration The required maintenance plan must become a part ofthe SIP and provide for maintenance ofthe 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 ofthe 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 ofthe 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 ofthe 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 CountyAnnual PM2.s 

### Nonattainment Area Requestfor Redesignation to Attainment ADEM developed the 2007 inventory of on-road mobile emissions. Please see Table 4.4-1 for a summary ofthe 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 Semi

Chemical 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 TVA 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.

4-2

### Jackson CountyAnnual PM2.s

### Nonattainment Area Requestfor Redesignation to Attainment 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 Nonpoint 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 ofpopulation, the ratio ofthe population ofthe 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 CountyAnnual PM2.s 

### Nonattainment Area Requestfor Redesignation toAttainment 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 ofTransportation (ALDOT) for 2007. The VMT data was used to make appropriate calculations in the development ofthe 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 ofanother 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 ofthe size ofthe nonattainment portion ofJackson 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).

4-4

### Jackson County Annual PM2.s

### Nonattainment Area Requestfor 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 ofJackson 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 ofpopulation 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 Nonroad

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).

4-5

### Jackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor 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 TVA 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 ofblock 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 ofthe 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

4-6

### Jackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor 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 ofthese 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 ofthese 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 ofpopulation 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

4-7

### Jackson CountyAnnual PMz.s

### Nonattainment Area Requestfor 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 Nonroad* 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 1 1.9 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.

4-8

### Jackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor Redesignation toAttainment 4.4 Maintenance Plan Inventory Table 4.4-1 Jackson County, AL portion ofthe ChattanoogaAnnual PM2.5 AttainmentArea Maintenance Plan Emissions (Tons perYear) 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

4-9

### Jackson CountyAnnual PMz.5 

### Nonattainment Area Requestfor 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 Nonroad 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 f or TN in the 20 17 column are actually 2016 values.

4-10

### Jackson CountyAnnual PM2.5

### Nonattainment Area Requestfor 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 ofthe annual PM2 .s 

### standard will continue. Sources are prohibited from reducing emission controls ('anti-backsliding') following the redesignation ofthe 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) ofthe 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 NOx SIP Call • The Clean Air Interstate Rule2
• Georgia Rules for Air Quality Control Chapter 391-3-1 Rule (sss) "Multipollutant Control ofElectric 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 ofthe 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 CountyAnnual PM2.5

### Nonattainment Area Requestfor Redesignation toAttainment 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 ofthe ambient fine particulate matter monitor network and the maintenance ofupdating 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 ofthe 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 ofAlabama 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 ofthe 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 ofthese various regulatory programs in determining the need for additional local reductions in emissions ofdirect 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: 4-12

### Jackson CountyAnnual PM2.s 

### Nonattainment Area Requestfor Redesignation to Attainment
• Reasonably Available Control Measures (RACM) for sources ofS02 and PM2.s; • Reasonably Available Control Technology (RACT) for point sources of S02 and PM2.s; • Expansion ofRACMIRACT to area(s) oftransport 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 ofimplementation, and other appropriate factors. A timeline for the development ofNOx, PM2.s and/or S02 regulations or permit conditions follows. This schedule initiates with certification of ambient air quality monitoring data indicating a violation ofthe 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 CountyAnnual PM2.s

### Nonattainment Area Requestfor 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