### _________________________________________________________________________________________________________



# Redesignation Request

and Maintenance Plan

For



## The Tennessee Portion of the Chattanooga, Tennessee

- Georgia

, PM 2.5 

## Nonattainment Area

_________________________________________________________________________________________________________

Prepared by:

Chattanooga

- Hamilton County Air Pollution Control Bureau 6125 Preservation Drive, Suite 140 Chattanooga, Tennessee 37416

- 3740

July 1 , 201 4Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page i EXECUTIVE SUMMARY

T h e Chattanooga

- Hamilton County Air Pollution Control Bureau (the Bureau) requests, by way of this document, that the United States Environmental Protection Agency (U.S. EPA) redesignate the Tennessee portion (Hamilton County) of the Chattanooga, Tennessee

- Georgia

, PM 2.5 (fine particulate matter) n onattainment a rea to attainment as a ―maintenance area.‖ This

req uest is warranted because air monitoring data for the three

- year period from 2007 through

2009 was granted a ―clean data determination‖ by the U.S. EPA for demonstrating attainment

with the 1997 annual n ational a mbient a ir q uality s tandard for PM 2.5

. Furthermore, evidence is presented in this document that attainment of the standard is attributable to permanent,

enforceable reductions in emissions of PM 2.5 and its significant precursors.

This document also include s the Bureau’s plan for maint aining at tainment with the standard through at least the year 2025 . Th e plan includ es contingency measures to be taken if the

standard is either e xceeded or at risk of being e xceeded as indicated by ambient air monitoring

or emission s inventory trends

. This maintenance plan is supported by projections through 2025

that show decreases in emissions of PM 2.5 and its significant precursors , nitrogen oxides (NO X ) and sulfur dioxide (SO 2 ), with in Hamilton County

. In addition, motor vehicle emissions budget s, in ac cordance with the U.S. EPA’s transportation ―conformity‖ rule, are presented for emissions

of PM 2.5 and NO X within Hamilton County

.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page ii TABLE OF CONTENTS

Executive Summary

................................ ................................ ................................ ..................... i

List of Tables

................................ ................................ ................................ ............................. i ii List of Figures

................................ ................................ ................................ ............................ i v List of Appendices

................................ ................................ ................................ ....................... v

1.0 Introduction

................................ ................................ ................................ ......................... 1

1.1 Fine Particulate Matter (PM 2.5 )

................................ ................................ .................... 1

1.2 PM 2.5 National Ambient Air Quality Standard s

................................ ............................. 2

1.3 PM 2.5 Federal Reference Method Monitor s

................................ ................................ . 2

1. 4 Chattanooga, Tennessee

- Georgia

, PM 2.5 Nonattainment Area

................................ ... 4

1. 5 Redesignation Request Requirements

................................ ................................ ........ 5

1. 6 Maintenance Plan Requirements

................................ ................................ ................ 6

2.0 Redesignation Request

................................ ................................ ................................ ....... 7

2.1 Attainment of the Annual PM 2.5 NAAQS

................................ ................................ ...... 7

2

. 2 Emissions Reduction Measures

................................ ................................ .................. 8

2

. 2.1 S peciated Ambient PM 2.5 C oncentrations

................................ ........................ 8

2 .2 .2 Source Apportionment of Ambient PM 2.5 C oncentrations

................................ . 8

2.2 .3 Industrial Source Emission s Reduction Measures

................................ ......... 10

2.2. 4 Mobile Source Emission s Reduction Measures

................................ ............. 1 3

2.2 .5 PM 2.5 and Ozone Transport Rules

................................ ................................ . 1 4

2.2

. 6 Other Emissions Reduction Measures

................................ ........................... 1 5

2.3 Requirements of Title I, Part A, Section 110 and Title I, Part D of the Clean Air Act

.. 1 5

3 .0 Maintenance Plan

................................ ................................ ................................ ............. 1 7

3.1 Maintenance Demonstration

................................ ................................ ..................... 1 7

3 .1 .1 Attainment Year Emissions Inventory

................................ ............................ 1 7

3.1

. 2 Projected Emissions Inventory

................................ ................................ ...... 20

3.1 .3 Safety Margins

................................ ................................ .............................. 2 3

3.1 .4 Regulatory Programs

................................ ................................ .................... 2 4

3.2 Verification of Continued Attainment

................................ ................................ ......... 2 6

3.3 Contingency Measures

................................ ................................ ............................. 2 6

3.3 .1 Contingency Measure Triggers

................................ ................................ ...... 2 7

3.3 .2 Procedures for Adoption and Implementation of Contingency Measures

....... 2 7

4 .0 Motor Vehicle Emissions Budget s

................................ ................................ ..................... 2 9

4 .1 Applicable Pollutants

................................ ................................ ................................ . 2 9

4 .2 Motor Veh icle Emissions Budgets Determination

................................ ...................... 30

4

. 3 Safety M argin Allotment s

................................ ................................ .......................... 3 1

5 .0 Conclusion

................................ ................................ ................................ ........................ 3 3Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page iii L IST OF TABLES

Table 1

- 1 Annual PM 2.5 Design Values

................................ ................................ ..................... 4

Table 2

- 1 Monitored Annual Mean PM 2.5 Concentrations

................................ ......................... 7

Table 2

- 2 Monitored Annual Mean Concentrations of Speciated PM 2.5 Components

................ 8

Table 2

- 3 Annual Industrial Point

- Source Emissions of SO 2

................................ ................... 10

Table 2

- 4 Annual Industrial Point

- Source Emissions of NO X

................................ ................... 1 0

Table 3

- 1 Attainment Year Emissions from Sources in Hamilton County

................................ 20

Table 3

- 2 Projected Annual Emissions of PM 2.5 from Sources in Hamilton County

................. 2 1

Table 3

- 3 Projected Annual Emissions of NO X from Sources in Hamilton County

................... 2 2

Table 3

- 4 Projected Annual Emissions of SO 2 from Sources in Hamilton County

................... 2 2

Table 3

- 5 Projected Annual Emissions of VOCs and Ammonia from Sources in Hamilton

County

................................ ................................ ................................ .................... 2 3

Table 3

- 6 Projected Annual Emissions from Combined Sources in Hamilton County

............. 23

Table 3

- 7 Projected Annual Emissions from Combined Sources in the Chattanooga

Maintenance Area

................................ ................................ ................................ .. 2 4

Table 4

- 1 Projected Annual Emissions from Onroad Source s in Hamilton County

.................. 3 1

Table 4

- 2 Safety Margin Allotments to Proposed Motor Vehicle Emissions Budgets for

Onroad Sources in Hamilton County

................................ ................................ ....... 3 2Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page iv LIST OF FIGURES

Figure 1

- 1 Locations of PM 2.5 Federal Reference Method Monitors

................................ .......... 3 Figure 1

- 2 Chattanooga, Tennessee

- Georgia, PM 2.5 Nonattainment Area

................................ 5 Figure 2

- 1 2002

– 2006 Average Contributions to Ambient PM 2.5 C oncentrations

...................... 9 Figure 2

- 2 Annual SO 2 Emissions and Energy Production from Combined Bowen and

Hammond Plants

................................ ................................ ................................ ... 1 2 Figure 2

- 3 Annual NO X Emissions and Energy Production from Combined Bowen and

Hammond Plants

................................ ................................ ................................ ... 12Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page v L IST OF APPENDICES

Appendix A ―Georgia’s Redesignation Request and Maintenance Plan for the Chattano oga

Nonattainment Area for the 1997 PM 2.5 NAAQS for Catoosa and Walker Counties‖ (narrative)
Ap pendix B ― Redesignation Request and Maintenance Demonstration

— Jackson County,

Alabama

— Chattanooga Annual P M 2.5 Nonattainment Area‖ (narrative)
Appendix C Annual PM 2.5 Design Values and Annual Mean P M 2.5 C oncent r a tions

Applicable Portions of PM 2

. 5 Design Value Reports from www.epa.gov/airtrends/values.

h tml and www.epa.gov/airtrends/values _previous

. h tml Appendix D ―Source Apportionment of PM 2.5 in Georgia‖
Appendix E Power Plant Emissions Data

Facility Emissions Trends Reports from the U.S. EPA Clean Air Markets Division for Widows Creek, Bowen, and Hammond Power Plants Appendix F Point Source Emissions Data

Chattanooga

- Hamilton County Air Pollution Control Bureau 2003, 2004, 2005, 2006, 2008, 2009, and 2010 Emissions Inventory System Reports Appendix G 2007 Point Source Emissions Data

2005 National Emissions Inventory (NEI) Download for Hamilton County, Tennessee

– Updat ed to 2007 Appendix H Point Source Emission Calculation Spreadsheets
Appendix I 2007 Area Source Emissions Data

2005 National Emissions Inventory (NEI) Download for Hamilton County, Tennessee

– Updat ed to 2007 Appendix J 2005 Aircraft, Marine, and Railroad Source Emissions Data

2005 National Emissions Inventory (NEI) Download for Ham ilton County, Tennessee Appendix K Area Source Emission Calculation Spreadsheets
Appendix L Onroad Source Input Data

MOVES2010b (Motor Vehicle Emission Simulator) In put Data for Hamilton County,

Tennessee (provided electronically under folder names: 2007 MOVES Inputs

, 2025 w.o. IM MOVES Inputs

, 2025 Worst Case w.o. IM MOVES Inputs

, 2040 w.o. IM MOVES Inputs , and 2040 Worst Case w.o. IM MOVES Inputs ) Appendix M Onroad Source Emissions Data

MOVES2010b (Motor Vehicle Emission Simulator) Output for Hamilton County,

Tennessee Appendix N Onroad Source Emission Calculation Spreadsheets
Appendix O Nonroad Source Emissions Data

NONROAD2008a Emission Inventory Model Output for Hamilton County, TennesseeRedesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page vi LIST OF APPENDICES (Continued)

Appendix P VOC and Ammonia Emissions Data

Applicable Portion of the Particulate Matter (PM) NAAQS Final Rule Regulatory Impact

Assessment from ftp .epa.gov/ EmisInventory

/ 2007v5 (filename: 2007platform_county_ sector_emissions_2007re_2020re.zip ) Appendix Q Point Source Emission Growth Factors

Economic Growth Analysis System (EGAS) Version 5.0 Output by North American Industry Classification System (NAICS) Codes for Hamilton County, Tennessee

– 2007

Base Year Appendix R Area Source Emission Growth Factors

Economic Growth Analysis System (EGAS) Version 5.0 Output by Source Classification Codes (SCC) for Hamilton County, Tennessee

– 2007 Base YearRedesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 1 of 33 1.0 INTRODUCTION

This document contains technical support for the request by the Chattanooga

- Hamilton County Air Pollution Control Bureau (the Bureau) that the Tennessee portion (Hamilton County) of the Chattanooga, Tennessee

- Georgia, PM 2.5 nonattainment area be redesignated as an area that is

in attainment with the 1997 annual PM 2.5 national ambient air quality standard (NAAQS)

, pursuant to Title I, Part A, §107(d) (3) (D) and (E) of the Clean Air Act

. A plan for maint aining

attainment with the standard is also included in this document

. The redesignation request and maintenance plan were prepared in accordance with a September 4, 1992, guidance

memorandum from the United States Environmental Protection Agency (U.S. EPA) entitled ―Procedures for Processing Requests to Redesignate Areas to Attainment

. ‖ Furthermore, this document includes motor vehicle emissions budgets that are being proposed in accordance with
the U.S. EPA’s tran sportation ―conformity‖ rule.

A r edesignation request and maintenance plan for the Georgia portion (Catoosa and Walker Counties) of the Chattanooga nonattainment area was prepared by the Air Protection Branch of the Environmental Protection Division (EPD) of the Georgia Department of Natural Resources. The narrative of this document is provided in Appendix A. Similarly, the Air Division of the Alabama Department of Environmental Management (DEM) prepared a r edesignation request and maintenance plan , the narrative of which is provided in Appendix B, for the Alabama portion (part of Jackson County) of the nonattainment area.

1.1 Fine Particulate Matter (PM 2.5 )

PM 2.5 , or fine particulate matter, refers to airborne particles tha t have a n aerodynamic diameter

of 2.5 micro meters ( μ m ) or less

. These particles are treated as a single air pollutant, but they are composed of various compounds and come from many different sources

. Inhalation of

PM 2.5 can result i n adverse respiratory and cardiovascular h ealth effects

. Children, older adults, and people with a chronic d isease of the lungs or heart are particularly sensitive to PM 2.5 exposure.

PM 2.5 can be a solid, liquid, or solid core surrounded by liquid. Primary PM 2.5 is directly emitted to the atmosphere and retain s the same chemical composition a fter i t is released

. Secondary

PM 2.5 i s formed through chemical reactions in the atmosphere involving precursors such as sulfur dioxide (SO 2 ), nitrogen oxides ( NO X ), ammonia, and volatile organic compounds (VOCs)

from biogenic or anthropogenic sources

. PM 2.5 c onstituents includ e :

 Sulfates ;

 Nitrates ;

 Ammonium i on ;

 Elemental c arbon ;Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 2 of 33  Primary organic compounds ( generally from combustion ) ;

 Secondary organic aerosols (SOA); and

 Inorganic c rustal m aterial ( e.g., dust, metals, and sea salt )

.

C oal

- fired power plants , other fuel combustion sources, motor vehicles, and industrial processes are among t he most significant source s of emissions of PM 2.5 and its precursors

. PM 2.5 can also

be emitted into the air as windblown dust

. These emissions are often transported over long

distances. PM 2.5 concentration levels in the ambient air are influenced by both m eteorological

conditions and geographic factors

.

1. 2 PM 2.5 National Ambient Air Quality Standards

T he U.S. EPA promulgated both 24

- hour and annual N AAQS for PM 2.5 on July 18, 1997 ( Federal Register Vol . 62 , N o. 138

, p p

. 38652

– 38760 )

. T he 24

- hour standard was set at 65 micrograms per cubic meter (μg/m 3 ) and t h e annual standard was set at 15 .0 μg/m 3

. Th e
24

- hour PM 2.5 NAAQS was subsequently re vised to 35 μg/m 3 o n October 17, 2006 ( Federal Register Vol . 71 , N o. 200

, p p

. 61144

– 61233 )

. The 2006 24

- hour standard is met when the 98th percentile d aily PM 2.5 monitored concentration (the value below which 98 % of the values in a calendar year fall), as averaged over three consecutive years , is less than or equal to 35 μg/m 3

. T he U.S. EPA designated Hamilton County as being in attainment with this 24

- hour standard o n Nove mber 13, 200 9 ( Federal Register Vol . 74 , N o. 218

, p p

. 58688

– 58781 )

. The 1997 annual

standard is met when the annual mean of daily PM 2.5 monitored concentrations (average of quarterly

- average values in a calendar year), as averaged over three consecutive y ears , is less than or equal to 15 .0 μg/m 3

.

1. 3 PM 2.5 Federal Reference Method Monitor s

D aily concentrations of PM 2.5 in the ambient air , which are used in determin ing attainment with

the 24

- hour and annual PM 2.5 NAAQS , ar e obtained from data that is collected by F ederal

R eference M ethod (FRM) monitors

. The Bureau operates three PM 2.5 FRM m onitors in Hamilton County

, Tennessee . A PM 2.5 FRM m onitor i n nearby Walker County

, Georg ia , is operated by the Georgia EPD

. The locations of the se four monitors are mapped in Figure 1

- 1,
which follows. (The Hamilton County monitor that is identified in the figure as being on Maxwell Road in East Ridge was relocated a distance of less than one mile to Tombras Avenue in East Ridge in 200 7 .)Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 3 of 33

Figure 1- 1. Locations of PM 2.5 Federal Reference Method Monitors \ 

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# •Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 4 of 33 1. 4 Chattanooga, Tennessee

- Georgia, PM 2.5 Nonattainment Area

The annual mean PM 2.5 concentration (average of quarterly

- average concentrations) , based on quality

- assured and certified data from an FRM monitor as averaged over three consecutive calendar years, is referred to as th e monitor’s annual PM 2.5 ―design value‖ for that three

- year period. Annual design values for each PM 2.5 FRM monitor are given below in Table 1

- 1.
Exceedances of the 1997 annual PM 2.5 NAAQS of 15.0 μg/m 3 are demarcated in bold font in

this table. T he design values in th e table are from PM 2.5 d esign value r eports that are available
at the U.S. EPA website s www.epa.gov/airtrend s /values.html and www. epa.gov/airtrends/

values _previous .html

. A pplicable portions of these reports are p rovided in Appendix C

.

Table 1

- 1. Annual PM 2.5 Design Values

Annual PM 2.5 Design Value ( μg/m 3 )

PM 2.5 Federal Reference
Method Monitor 2001

– 2003 2002

– 2004 2003

– 2005 2004

– 2006 2005

– 2007 2006

– 2008 2007

– 2009 2008

– 2010 2009

– 2011 2010

– 2012

Siskin Drive ( UTC ) (ID #470654002) 15.2 14.7 15.0 15.0 15.2 14.3 12.7 11.6 11.1 10.9

Tombras Avenue

, East Ridge (ID #470650031) 16.1 15.7 16.1 15.3 15.1 13.8 12.6 11.6 11.2 11.1

Soddy

- Daisy High School (ID #470651011) 14.1 13.8 13.8 13.4 13.7 12.9 11.7 11.4 11.0 11.2

Maple Street, Rossville , GA (ID #132950002) 15.5 15.2 15.8 15.2 14.9 * 13.5 * 12.3 * 10.6 10.1 * 10.0 *

* D ata from the Rossville, Georgia, monitor for 2007 and 2011 d id not meet completeness criteria

Data from t h r e e of the four PM 2.5 FRM monitors in the Chattanooga area for the period from

2001 through 2003 showed an exceed a nce of the 1997 annual PM 2.5 NAAQS. Based on the

2001

– 2003 monitoring data

, t he U.S. EPA designated the Chattanooga, Tennessee

- Georgia

,
a rea as being in nonattainment with the annual standard on January 5, 2005 ( Federal Register

Vol

. 7 0 , N o. 3

, p p

. 944

– 1019 )

. The U.S. EPA re addressed this designation on April 14, 2005 ( Federal Register Vol

. 7 0 , N o. 71

, p p

. 19846 and 19847 ) , but made no change to it. Th e Chattanooga nonattainment area consists of Hamilton County in Tennessee, Catoosa and Walker Counties in Georgia, and an interior portion of Jackson County in Alabama that is
described as U.S. Census 2000 B lock G roup I dentifier 01

- 071

- 9503

- 1. Th e nonattainment area

is depicted in Figure 1

- 2, which follows. ( PM 2.5 FRM monitor locations that are shown in this figure are approximate and are less precise than those indicated in the preceding Figure 1

- 1.)Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 5 of 33

Figure 1

- 2

. Chattanooga, Tennessee

- Georgia, PM 2.5 Nonattainment Area

1. 5 Redesignation Request Requirements

Title I, Part A, §107(d) (3)(E) of the Clean Air Act requires that the following conditions be met i n order for the Tennessee portion of the Chattanooga nonattainment area to be redesignated as

an area in attainment with the 1997 annual PM 2.5 NAAQS :Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 6 of 33  A determination by t he U

. S

. EPA that the annual PM 2.5 NAAQS ha s been attained ;

 A determination by t he U

. S

. EPA that the improvement in air quality that resulted in

attainment of the standard is due to permanent and enforceable reductions in emissions ;

 Full approval by the U.S. EPA of t he state implementation plan (SIP) for the Tennessee portion of the nonattainment area under Title I, Part A, § 110(k) of the C lean Air Act ;

 Attainment of all applicable requirements for the Tennessee portion of the nonattainment

area under Title I, Part A, § 1 10 and Title I, Part D of the C lean Air Act ; and

 Full approval by t he U

. S

. EPA of a maintenance plan, including contingency measures
, for the Tennessee portion of the nonattainment area as required by Title I, Part D, § 175A
of the C lean Air Act

.

1. 6 Maint enance Plan Requirements

The required m aintenance p lan must provide for the continued attainment of the 1997 annual

PM 2.5 NAAQS for a period of at least ten years after the U.S. EPA has formally redesignated the Tennessee portion of the Chattanooga nonattainment area to attainment as a ― maintenance

area

. ‖ The plan must demonstrate that future attainment of the standard is expected to continue, it must indicate how continued attainment of the standard will be ver ified, and it must include contingency measures to be implemented if the standard is either exceeded or determined to be at risk of being exceeded.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 7 of 33 2.0 REDESIGNATION REQUEST

The Bureau formally requests that the U.S. EPA redesignate the Tennessee portion of the Chattanooga, Tennessee

- Georgia, PM 2.5 nonattainment area to a maintenance area in

attainment with the 1997 annual PM 2.5 NAAQS , pursuant to Title I, Part A, §107(d) (3) (D) and (E)
of the Clean Air Act. T echnical support for th e request is provided in this section of the

document , including demonstrations that the standard has been met as a result of permanent and enforceable emissions reductions and that applicable requirements of the Clean Air Act have been complied with.

2. 1 Attainment of the Annual PM 2.5 NAAQS

Annual mean PM 2.5 concentrations (averages of quarterly

- average concentrations) for each

PM 2.5 FRM monitor , based on quality

- assured and certified data, are given below in Table 2

- 1.

The concentrations in th e table ar e from PM 2.5 design value reports that are available at the U.S.

EPA website s www.epa.gov/airtrends/values.html and www.epa.gov/airtrends/values _previous

. html . A pplicable portions of these reports are provided in Appendix C

.

Table 2

- 1. Monitored Annual Mean PM 2.5 Concentrations

PM 2.5 Federal Reference
Method Monitor Annual Mean PM 2.5 Concentration ( μg/m 3 )

200 6 200 7 200 8 2009 2010 2011 201 2

Siskin Drive ( UTC ) ( ID # 470654002) 15 .039 15.046 12.707 10. 471 11.7 26 11. 073 10.010

Tombras Avenue , East Ridge ( ID # 470650031) 1 4

. 2 5 8 14.933 12.289 10. 475 12.0 25 11. 056 10.073

Soddy

- Daisy High School ( ID # 470651011) 13

. 081 14.222 11.388 9.5 20 13. 290 10. 290 9.992

Maple Street, Rossville, G A ( ID # 132950002) 1 4

. 453 13.689 * 12.482 10.7 04 8. 690 10. 772 * 10.5 41

* D ata from the Rossville, Georgia, monitor for 2007 and 2011 d id not meet completeness criteria

The annual mean PM 2.5 concentration, as rounded to one decimal place, from any of the four

monitor s in the Chattanooga area has been no greater than 15.0 μg/m 3 from 2006 onwards

. Furthermore, the annual PM 2.5 design value for each monitor and for each three

- year period

, beginning with 2006

– 2008

, has been below the annual PM 2.5 NAAQS of 15.0 μg/m 3 , as shown in the preceding Table 1

- 1. Accordingly, the U.S. EPA granted a ―clean data determination‖ to

the ambient air m onitoring data from the four PM 2.5 FRM monitors for the period from 2007

th rough 2009 and determin ed , as of the publication date of May 31, 2011 ( Federal Register Vol

.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 8 of 33 7 6 , N o. 104

, p p

. 31239

– 31241 )

, that the Chattanooga nonattainment area has attained the 1997

annual PM 2.5 NAAQS

.

2.2 E missions R eduction M easures

I n order for the Chattanooga nonattainment area to be redesignated to attainment, the decrease

in monitored ambient PM 2.5 concentrations through 2009 , which resulted in a clean data

determination for monitoring data for the th r e e

- year period ending in 2009, must be

demonstrated to be due to permanent and enforceable reductions in emissions of PM 2.5 and/or its significant precursors . These reductions are required to have resulted from measures implemented after 200 3 since the no nattainment designation was based upon monitoring data

for the three

- year period that continued through 2 00 3

.

2.2 .1 S peciated Ambient PM 2.5 C oncentrations

P M 2.5 constituents include many compo nents from varying sources. A PM 2.5 speciation monitor

is located adjacent to the PM 2.5 FRM monitor at the Siskin Drive ( UTC ) site in Hamilton County

and is a part of the U.S. EPA speciation trends network (STN) . It provides ambient air

concentrations of sulfates, nitrates, ammonium ion , potassium, sodium, elemental carbon, organic carbon, and specific metals , all of which are speciated PM 2.5 components

. Annual

mean concentrations of m ajor components of PM 2.5 from th e STN monitor are from U.S. EPA Air Quality System raw data reports and are given below in Table 2

- 2

.

Table 2

- 2

. Monitored Annual Mean Concentrations of Speciated PM 2.5 Components

Speciated PM 2.5 Component Annual Mean Concentration ( μg/m 3 )

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Sulfates 5.2 5.2 4.9 5.4 4.0 4.8 4.0 2.4 3.1 2.8 2.1

Nitrates 1.0 1.2 1.0 1.0 1.0 1.1 0.8 0.7 0.9 0.5 0.7

Ammonium Ion 1.7 1.8 1.6 1.9 1.5 1.9 1.5 0.9 1.1 0.8 0.6

2.2 .2 S ource Apportionment of Ambient P M 2.5 C oncentrations

The Georgia EP D conducted a source apportionment analysis of speciated PM 2.5 component concentrations that were obtained from the Hamilton County PM 2.5 STN monitor from 2002 through 2006 . The analysis was conducted using EPA

- PMF1.1 (P ositive M atrix F actorization ),
which is the U.S. EPA’s model for distinguish ing correlation patterns among speciated PM 2.5 concentrations in a given location. T he results of the analysis are included in a documentRedesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 9 of 33 entitled ―Source Apportionment of PM 2.5 i n Georgia

, ‖ which is provided in Appendix D , and are diagrammed below in Figure 2

- 1

.

Figure 2

- 1 . 2002

– 2006 Average Contributions to Ambient PM 2.5 Concentrations ( μ /m 3 )

According to the source apportionment analysis, t he greatest contribution to ambient PM 2.5 concentrations in the Chattanooga area is from secondary sulfate s
, which are formed from atmospheric reactions with SO 2

. Three coal (f ossil fuel)

- fired electric power plants are the largest industrial point

- sources of SO 2 emissions that sign ificantly impact the area. These three plants also result in considerable emissions of NO X . One of these plants, the Tennessee Valley Authority (TVA) Widows Creek power plant, is located in the Alabama portion of the Chattanooga nonattainment area in Jac kson County. The other two facilities are located nearby in Northwest Georgia

— Georgia Power’s Bowen power plant in Bartow County and Hammond power plant in Floyd County. Bartow County is a part of the extensive Atlanta PM 2.5 nonattainment area, and Flo yd County comprises a separate PM 2.5 nonattainment area.

S econdary organic aerosols are shown to be the second largest contributor to ambient PM 2.5 in

the Chattanooga area, but precursor emissions for these aerosols are considered to mostly

result from biogenic sources and are thus not readily controlled

. P rimary PM 2.5 emissions from

mobile sources and from biomass burning also significantly affect area PM 2.5 concentrations , as indicated by the analysis

. Most i ndustrial sources of primary PM 2.5 emissio ns with in Hamilton County have long been controlled or subject to emission limit ations

. Contributions to PM 2.5 in

the ambient air from all other source categories appear to be of less consequence

.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 10 of 33 2.2 .3 I ndustrial Source Emissions Reduction Measure s

Annual e missions of SO 2 and NO X from each of the Widows Creek, Bowen, and Hammond power plants , along with those from the combined industrial point source s with in Hamilton County

, are given below in Tables 2

- 3 and 2

- 4 , respectively

. The e missions from the three power plants are from U.S. EPA Clean Air Markets Division facility emissions trends reports and are provided in Appendi x E

. The emissions from the combined Hamilton County point sources are from annual reports generated from the Bureau’s E missions Inventory System for all applicable years except 2007. These reports are provided in Appendix F

. P oint source

emissions for 2007 are from the 2005 National Emissions Inventory (NEI) download for Hamilton County, updated to 2007, that is provided in Appendix G , and t hese emissions are tabulated in spreadsheets provided in Appendix H

.

Table 2

- 3

. Annual Industrial Point

- Source Emissions of SO 2

SO 2 Emissions ( tons/year )

Source 2003 2004 2005 2006 2007 2008 2009 2010

Hamilton Count y Point Sources 1,920 1,788 1,779 1,397 919 892 559 788

Widows Creek Plant (Alabama) 44,046 31,396 34,380 33,507 32,723 27,903 12,861 10,982

Bowen Plant (Georgia) 164,884 165,914 186,470 206,442 196,841 148,149 54,811 7,618

Hammond Plant (Georgia) 35,923 37,696 39,548 40,579 47,809 12,465 894 2,427

Table 2

- 4

. Annual Industrial Point

- Source Emissions of NO X

N O X Emissions ( tons/year )

Source 2003 2004 2005 2006 2007 2008 2009 2010

Hamilton County
Point Sources 2,841 2,758 2,748 2,653 2,437 2,140 1,716 1,738

Widows Creek Plant (Alabama) 24,615 19,843 18,154 17,184 17,620 15,100 3,526 2,996

Bowen Plant (Georgia) 24,960 24,770 26,246 28,636 18,478 24,070 6,947 7,257

Hammond Plant (Georgia) 7,437 6,183 6,750 5,783 7,782 6,096 3,164 3,163Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 11 of 33 As shown in the preceding tables, annual emissions of both SO 2 and NO X from each of the three power plants are considerably greater than the respective emissions from all of the industrial point sources in Hamilton County combined prior to 2009. In 2003, emissions from the Widows Creek, Bowen, and Hammond power plants combined were greater than emissions from the combined Hamilton County point sources by factors of 127.5 times for SO 2 and 20.1
times for NO X

. Furthermore, emissions from the three power pla nts combined were reduced from 2003 to 2009 by 72 .0 % for SO 2 and 76

. 1 % for NO X

.

W hile flue

- gas desulfurization scrubbers for each of the eight coal

- fired units at the Widows
Creek power plant were installed prior to 2002, the scrubber controlling SO 2 emissions from Unit 8 was upgraded in 2004. In addition, selective catalytic

- reduction equipment to control NO X emissions was installed in 2003 for Unit 7 and in 2004 for Unit 8 in accordance with F ederal

F acilities C ompliance A greement

, Docket No. CAA

- 0 4

- 2010

- 1760

, b etween the U.S. EPA and

TV A

. This agreement is both permanent and enforceable. Furthermore, Units 1

– 6 at the Widows Creek plant were permanently removed from service as of October 1, 2011, in early compliance with the agreement . Operation of Units 1

– 6 began to be scaled back in 2009

.

T he Bowen and Hammond power plants are both subject to ― Multipollutant Control of Electric Utility Steam Generating Units‖ [ Georgia Rule 391

- 3

- 1

- .02(2)(sss) ], which requires fl ue gas desulfurization to control SO 2 emissions and selective catalytic reduction for the control of NO X emissions. The rule was promulgated in 2007 to reduce mercury deposition and to lower

ambient ozone and PM 2.5 concentrations through the control of precursor emissions. Although

the rule’s compliance date was December 31, 2008, the required controls at both facilities began to be used in the first half of 2008. ―SO 2 Emissions from Electric Utility Steam Generating Units‖ [ Georgia Rule 391

- 3

- 1

- .02(2)( uuu ) ] is a companion rule that requires a 95%

reduction in SO 2 emissions from the majority of Georgia’s coal

- fired power plants . This requirement is being phased in from 2010 through 2016.

Annual emissions of SO 2 and NO X from the Bowen and Hammond power plants combined, along with th e annual quantity of electrical energy generated from the two combined plants, are graphically presented in the following Figures 2

- 2 and 2

- 3, respectively. The energy produc tion

data w as furnished by the Georgia EPD

.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 12 of 33 F ig ure 2

- 2

. Annual SO 2 Emissions and Energy Production from Combined Bowen and

Hammond Plants

Figure 2

- 3

. Annual NO X Emissions and Energy Production from Combined Bowen and

Ham mond PlantsRedesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 13 of 33 The preceding figures indicate that annual e nergy generation from the Bowen and Hammond

power plants combined was stable . In fact, electrical energy production from the combined plants was 26.7 megawatt hours (MWh) in 2003 and 26.6 MWh in 2009, which is relatively unchanged. This demonstrates that the reductions in SO 2 and NO X emissions from the two plants are due to the implementation of permanent and enforceable regulations rather than to

any decrease in energy output.

2.2 .4 M obile Source Emissions Reduction Measure s

―Control of Emissions from New and In

- Use Highway Vehicles and Engines‖ (the Tier 2

s tandards, Title 40 Code of Federal Regulations Part 86 ) w as initiated in 2004 and were mostly phased in by 2007. For passenger vehicles with a gross weight of over 8,500 pounds, the Tier

2 standards were phased i n beginning in 2008 with full compliance in 2009. The standards require all passenger vehicles in a manufacturer’s fleet, including light

- duty trucks and sport utility vehicles, to emit no more than 0.07 grams of NO X per mile , on average

. The standards

a lso require that subject vehicles emit at least 77% less NO X than passenger vehicles in operation prior to the standards adoption. A second phase of these standards, which began to be implemented in 2007, resulted in an estimated 90% reduction in particul ate matter emissions from heavy

- duty engines used in highway vehicles.

In addition, t he Tier 2 standards required a lowering of the sulfur content of gasoline to 30 parts per million (ppm) , beginning in January of 2006. Prior to this, the typical sulfur content of gasoline available in the Chattanooga area was about 340 ppm. Furthermore, ―Regulation of

Fuels and Fuel Additives‖ (Title 40 Code of Federal Regulations Part 80 ) became effective in 2004. This rule required sulfur content reduction s to 15 ppm for onroad diesel fuel, 500 ppm for nonroad diesel fuel by 2006, and 15 ppm for nonroad diesel fuel by 2010. Nonroad diesel fuel in the area had an average sulfur content of about 3,400 ppm before 2006. Sulfur , which occurs naturally in gasoline and die sel fuel

, interferes with the operation of catalytic converters that are

used on vehicles t o control NO X emissions

. Reducing the content of sulfur in these fuels also

serve d to proportionally decrease motor vehicle emissions of SO 2

.

―Control of Emissions from New and In

- Use Nonroad Compression

- Ignition Engines‖ ( Title 40 Code of Federal Regulations Part 1039 ) was promulgated in 2004 with a phase

- in period from

2008 to 2014. This r egulation appl ies to emissions of particulate matter and NO X from engines used in construction, agricultural, and industrial equipment. Full implementation of th e rule is anticipated to reduce particulate matter emissions from large nonroad diesel

- fuel engines by

over 90%.

―Control of Emissions from New, Large Nonroad Spark

- Ignition Engines

, ‖ ( Title 40 Code of Federal Regulations Part 1048 ) regulates NO X and other pollutants emitted from engines that

are used in vehicles such as forklift truck s and airport ground service equipment . The firstRedesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 14 of 33 phase of this rule was impl emented in 2004 and the second phase commenced in 2007.
―Control of Emissions from Recreational Engines and Vehicles ‖ (Title 40 Code of Federal Regulations Part 10 51) pertains to emissions of NO X and other pollutants from such sources as

off

- highway motorcycles, all

- terrain

- vehicles, and recreational motor boats , and phase

- in of this

rule commenced in 2006

. It is estimated that th e se two rule s will result in an 80% overall

reduction in NO X emissions from subject sources when fully impleme nted

.

2.2

. 5 PM 2.5 and Ozone T ransport Rule s

In October 1998, the U.S. EPA made a finding of significant contribution to ozone formation due

to NO X emissions from certain states and published the ― NO X Budget Trading Program for State Implementation Plans‖ (the NO X SIP Call, Title 40 Code of Federal Regulations Part 96

, Subparts A

– I), which set ozone

- season NO X emission budgets for the purpose of reducing regional transport of ozone. This rule called for NO X emission budgets to be established for twenty

- tw o eastern states (and the District of Columbia), including Tennessee, Georgia, and Alabama. Each subject state was required to develop rules requiring the control of NO X emissions from utility and industrial boilers that would allow the state to meet its budget by 2004. Furthermore, a NO X emission trading program was established that allows sources to buy credits to meet the applicable budget as opposed to installing NO X emission control equipment.

T he U.S. EPA promulgated the ― Rule to Reduce Interstate Transport of Fine Particulate Matter
and Ozone [ Clean Air Interstate Rule (CAIR) ] ‖ on May 12, 2005 ( Federal Register Vol

. 70, N o. 91, p p . 25162

– 25405) . This rule established a requirement for s tates to regulate emissions of
NO X and SO 2 from fossil

- fuel fired electric generation units with capacities in excess of 25 megawatts. Annual limits on state

- wide emissions of NO X and SO 2 were to be set in phases beginning in 2009 and continuing t hrough 2015.

On July 11, 2008, the U.S. Court of Appeals for t he District of Columbia Circuit vacated CAIR

and remanded it to the U.S. EPA. A rehearing of the Court’s decision was requested and granted. On December 23, 2008, the Court remanded CAIR to the U.S. EPA without vacatur (i.e., the rule was still in place)

. The U.S. EPA was directed to correct the deficiencies in CAIR

that were identified in the Court’s decision.

To replace CAIR, the U.S. EPA promulgated the ― Transport Rule‖ [ Cross

- State Air Pollution Rule (CSAPR) ] on August 8, 2011 ( Federal Register Vol

. 76, No. 152, p p . 4820 8

– 48 483 ) . Th is

rule was to impose restrictions on emissions of NO X and SO 2 from states identified as having significant impacts on ozone and/or PM 2.5 NAAQS attainment or as interfering with maintenance

of these standards in downwind states. The requirements of CSAPR were to become effective in 2012 and 2014. However, the U.S. Court of Appeals for the D istrict of Columbia Circuit

issued respective ruling s on December 30, 2011, and August 21, 2012, at first to stay CSAPR,Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 15 of 33 pending judicial review , and then to vacate it . Regardless of the timing of any transition from
CAIR to a replacement transport rule , emissions of NO X and SO 2 affecting the Chattanooga nonattainment area have declined significantly and are expected to continue to decrease due , in large part, to the continuation of the Federal F acilities C ompliance A greement b etween the U.S.

EPA and TV A and Georgia R ules 391

- 3

- 1

- .02(2)(sss) and (uuu) that apply to coal

- fired electric power plants

.

2.2

. 6 O ther Emissions Reduction Measure s

I n 2005, a seasonal open

- burning ban was instituted in Hamilton County. Furthermore, t he City of Chattanooga no longer operates an air

- curtain destructor for brush burning, with the exception of operation to dispose of debris from major storms

. Permits issued for open burning in Hamilton County numbered 7,131 in calendar year 1994 and 5,510 during the open burning season from October 1, 2006, through April 30, 2007, a decrease of 22.7%

. Emissions from open burning include elemental carbon, or ganic carbon, and direct PM 2.5

.

― P ollution Solution ‖ is a public outreach and education program of the Bureau. The goal of the program is to reduce air pollution by voluntary actions. The program is activated on air quality alert days when the concentra tion of either PM 2.5 or ozone in the ambient air is pr ojected to be above the ―moderate‖ range for health effects . On such days, pertinent info rmation is sent to

select individuals, government employees, hospitals, heal th care facilities, child dayca re

center s, schools, gyms, and emergency responders , in addition to television, radio, and print

media outlets.

2

. 3 Requirements of Title I, Part A, S ection 110 and Title I, P art D of the Clean Air Act

Title I, Part A, §110 of the Clean Air Act contains r e quirements for SIP s that provid e for the implementation, maintenance, and enforcement of applicable NAAQS . Title I, Part D, Subpart 1 (§171

– 179) of the C lean Air Act contains general requirements for areas that have been designated as nonattainment for a NAAQS

. Following designation by the U.S. EPA of t he Chattanooga area as being in n onattainment with the 1997 annual PM 2.5 NAAQS in 2005 , t he

B ureau submitted a PM 2.5 NAAQS SIP for the Tennessee portion of the Chattanooga

nonattainment area in accor dance with Part D.

With the determination by the U.S. EPA in 2011 that the Chattanooga nonattainment area has

attained the 1997 annual PM 2.5 NAAQS , the area is no longer subject to nonattainment requirements of Part A

, §110 and Part D

. Accordingly, the f ollowing was published on May 31, 2011 ( Federal Register Vol

. 7 6 , N o. 104

, p. 31241 ) :

―EPA has determined, as of May 31, 2011, the Chattanooga, Tennessee, nonattainment area has attaining data for the 1997 annual PM 2.5 NAAQS. This determination, inRedesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 16 of 33 accordance with 40 CFR 52.1004(c), suspends the requirements for this area to submit an attainment demonstration, associated reasonably available control measures, a reasonable further progress plan, contingency measures, and other planning SIPs

related to attainment of the standard for as long as this area continues to meet the 1997

annual PM 2.5 NAAQS.‖

All other requirements of Part A, §110 and Part D pertaining to the Chattanooga area have previously been approved or are currently subject to approval by the U.S. EPA.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 17 of 33 3 .0 M AINTENANCE PLAN

The Bureau’s plan for maintaining attainment with the 1997 annual PM 2.5 NAAQS within the Tennessee portion of the Chattanooga, Tennessee

- Georgia, PM 2.5 maintenance area is detailed

in this section of the document. Th e maintenance plan demonstrates continued attainment of

the standard and in cludes procedures for verification of future attainment

. In addition, this plan

i nc orporates contingency measures to be implemented if the verification procedures indicate

that the standard is no longer being attained or close to not being attained

.

3

. 1 M aintenance Demonstration

The Bureau is demonstrating maintenance of the 1997 annual PM 2.5 NAAQS by showing that

future annual emissions of PM 2.5 , its significant precursors of NO X and SO 2 , and its precursors
of VOCs and ammonia from all sources combined within the Tennessee portion (Hamilton County) of the Chattanooga m aintenance a rea will not exceed the respective emissions for the ―attainment year.‖ M aintenance of the annual PM 2 .5 NAAQS has been similarly demonstrated

for the Georgia portion (Catoosa and Walker Counties) of the maintenance area by the Georgia EPD and for the Alabama portion (part of Jackson County) of the maintenance area by the

Alabama DEM

. These respective demonstrations are included in redesignation request and maintenance plan document s that were prepared by the Georgia EPD and by the Alabama DEM, the narratives of which are provided in Appendices A and B , correspondingly

.

3.1 .1 Attainment Year Emissions Inventory

A mbient a ir monitoring data from all four FRM monitors in the Chattanooga area indicated

attainment with the 1997 annual PM 2.5 NAAQS for the three

- year period from 2007 through

2009

, and this data was accordingly granted a clean data determination by the U.S. EPA. Furthermore, the annual mean PM 2.5 concentration (average of quarterly

- average concentrations) , rounded to one decimal place, from each monitor was no greater than 15.0 μg/m 3 for each of the three years in this period, based on quality

- assured and certified monitoring data . These concentrations were previously given in Table 2

- 1

. T he Bureau has

therefore chosen to use 2007, t he first year of th e three

- year attainment period, as the

attai nment, or base, year for Hamilton County

. 2007 was also selected as the attainment year by the Georgia EPD for the Georgia portion of the m aintenance a rea and by the Alabama DEM for the Alabama portion of the maintenance area

.

Emissions of PM 2.5 , its sig nificant precursors of NO X and SO 2 , and its precursors of VOCs and

ammonia occur from point, area, onroad mobile, and nonroad mobile sources within Hamilton County. E missions of these pollutants that occurred during 2007 from the combined s ources within Hamilton County represent emission levels that are consistent with attainment of the

sta n dard

.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 18 of 33 Point sources are certain industrial

, commercial , and institutional stationary sources. A ttainment

year emissions of PM 2.5 , NO X , and SO 2 from poi nt sources were obt a in e d from the 2005 NEI download for Hamilton County, updated to 2007, that is provided in Appendix G

. These

emissions are tabulated in spreadsheets provided in Appendix H . The original source for most
of these emissions is the Bureau’s Emissions Inventory System, which is a database wherein annual emissions from sources that are permitted by the Bureau are recorded. The se emissions were determine d from direct measurement, calculate d using material balanc e s,
estimate d using emission factors from sources such the U.S. EPA’s Compilation of Air Pollutant

Emission Factors (

AP

- 42 )

, or estimated by other methods. The PM 2.5 emissions include any condensable portion that could be determined

. The Emissions Invent ory System is updated continually and archived for each calendar year. The up dated emissions , predominately from

industrial fuel

- combustion sources, were obtained from the Emissions Inventory System for

2007 and are either higher or lower than what was reported in the 2005 NEI.

Area (nonpoint) sources are residential stationary sources and those industrial, commercial, and

institutional stationary sources that are not classified as point sources

. Emissions from area

sources are estimated for entire source categories (e.g., residential natural

- gas combustion)

rather than for individual emission points. A ttainment year emissions of PM 2.5 , NO X , and SO 2 from area sources were obtained from the 2005 NEI download for Hamilton County, updated to 2007, that is provided in Appendix I

. E missions were updated by subtracting out emissions from

certain fuel

- combustion source categories that were found either to not actually be performed

with in Hamilton County or to a lso be included in the NEI as point sources.

A ttainment year e missions of PM 2.5 , NO X , and SO 2 from aircraft, marine vessels, and railroads are also being listed as area source emissions . These emissions were determined by the U.S.

EPA and were obtained from the 2005 NEI download for Hamilton County that is provided in Appendix J

. Emissions from aircraft were based on airport

- specific landing and take

- off data provided by the Federal Aviation Administration of the U.S. Department of Transpor t ation (U.S. DOT)

. Emissions from marine vessels are given for both ―port‖ and ―underway‖ categories

. E missions from marine vessels while in port were based on cargo tonnage handled at specific

river port facilities

, and emissions from vessels while underway were based on cargo tonnage transported along lengths of waterway segments as established by the U.S. Army Corps of Engineers

. Emissions from railroads are given for both ―yard‖ and ―line haul‖ categories.

Emissions from both switchyard and line haul locomoti ves were based on fuel use data from the Energy Information Administration of the U.S. Department of Energy and on Geographic Information System rail tonnage data provided by the Bureau of Transportation Statistics of the
U.S. DOT

. No updates were made to these emissions, which are more conservative than what was reported in the 2008 NEI

. An economic downturn that was ongoing in 2008 makes the 2005 data more appropriate to use. All of t he area source emissions are tabulated in spreadsheets provided in Appendix K

.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 19 of 33 Onroad mobile sources include passenger cars and trucks, commercial trucks, buses, motorcycles, and motor homes. A ttainment year emissions of PM 2.5 , NO X , and SO 2 f r o m onroad

sources within H amilton County were determined by using MOVES2010b (Motor Vehicle Emission Simulator), dated March 2012, which is the U.S. EPA’s current model for estimating

emissions from onroad sources

. The model was run in ―inventory‖ mode, and the hourly ―time

aggreg ation level‖ was used in order to obtain the greatest precision. Input data for the model

include s the number of vehicles of each type, ―vehicle miles travelled‖ by vehicle type and hour of day, vehicle age distribution, and road type distribution. In addition, since the Tennessee Automobile Inspection and Maintenance (I/M) Program has been in effect in Hamilton County since April 1, 2005, the model input option for an I/M program was selected. The model input

data w as supplied by t he Chattanooga Metropolitan Planning Organization ( MPO ) as ten spreadsheets. The input spreadsheet files and the ―run specification‖ file (.mrs extension) that

was used to set up the model run are provided electronically in Appendix L under the folder
name ―2007 MOVES I nputs

. ‖ The resulting emissions from th e model are provided in Appendix

M and are tabulated in spreadsheets provided in Appendix N

.

Nonroad mobile s ources include construction equipment, agricultural equipment, and lawn care equipment. A ttainment year e missions of PM 2.5 , NO X , and SO 2 f rom nonroad sources within Hamilton County were determined by using N ONROAD 2008 a, dated 2009, which is the U.S.

EPA’s current model for estimating emissions from nonroad sources

. Input data for this model was supplied by t he U.S. EPA. The resulting emissions from th e model are provided in Appendix O

.

A ttainment year emissions of VOCs and ammonia from point, area, onroad mobile , and nonroad

mobile sources within Hamilton County were obtained from a county

- level emissions summary that is a part of the Particulate Matter (PM) NAAQS Final Rule Regulatory Impact Assessment

. I t is available from the U.S. EPA Emissions Modeling Clearinghouse at the website ftp.epa.gov/ EmisInventory/2007v5 (filename: 2007platform_cou nty_sector_emissions_2007re_2020re.zip ). The applicable portion of the emissions summary is provided in Appendix P

.

The emissions of PM 2.5 , NO X , SO 2 , VOCs, and ammonia from the various source types within Hamilton County during the attainment year are gi ven in Table 3

- 1 , which follows

.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 20 of 33

Table 3

- 1

. Attainment Year Emissions from Sources in Hamilton County

2007 Emissions ( tons/year )
Source Type PM 2.5 NO X SO 2 VOCs Am m onia

Point 160.2 2,437.2 919.2 1,047.0 12.5

Area 875.4 3,415.1 332.6 5,338.9 194.2

Onroad 395.1 11,465.2 87.6 4,797.5 161.6

Nonroad 153.6 1,792.1 99.3 2,383.3 2.7

Total 1,584.3 19,109.5 1,438.8 13,566.6 370.9

3.1

. 2 Projected Emissions Inventory

Demonstration of future maintenance of the 1997 annual PM 2.5 NAAQS is required for a period of ten years following the presumed date of redesignation, which should end no later than 2025.

T h is demonstration is being made by showing that projected emissions of PM 2.5 and its significant precursors of NO X , and SO 2 for each of the years 2010, 2013, 2016, 2019, 2022, and

2025 from all sources combined within Hamilton County will not exceed the respective emissions for the attainment year of 2007

.

P rojected annual emissions of PM 2.5 , NO X , and SO 2 from point sources we re determined by applying Economic Growth Analysis System ( EGAS ) Version 5.0 factors for Hamilton County to
the respective attainment year emissions. These growth factors are for point sources as grouped by North American Industry Classification System (N AICS) codes and are provided in Appendix Q

. The resulting emissions are tabulated in spreadsheets provided in Appendix H

.

T hree coal

- fired boilers at the INVISTA , S. à r.l., LLC, plant in Hamilton County are subject to Consent Decree, Case No. 1:09

- cv

- 00244

- GMS , between the U.S. et al. and INVISTA

. This

consent decree established emission limitations for the combined boilers of at most 194 tons of
NO X per year and 530 tons of SO 2 per year with an effective date of January 28, 2015

. As a

result , t hese maximum emissions are being ascribed to the boilers for years following 2015.

Emissions of PM 2.5 were unaffected by the consent decree. During 2007, the combined boilers resulted in point source emissions of 24.3 tons of PM 2.5 , 280.1 tons of NO X , and 566.8 tons of
SO 2

.

Caraustar Mill Group, Inc., (doing business as Chattanooga Paperboard) previously operated

two residual

- oil

- fired boilers and one natural

- gas

- fired boiler at their plant i n Hamilton County

. All operations at th is plant ceased on July 22, 2008 , and the operating permit for the plant was

withdrawn. N o emissions are therefore being ascribed to the boilers for year s following 2008

.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 21 of 33 During 2007, the combined boilers resulted in point source emissions of 4.6 tons of PM 2.5 , 41.6

tons o f NO X , and 122.5 tons of SO 2

.

P rojected annual emissions of PM 2.5 , NO X , and SO 2 from area sources were determined by applying E GAS Version 5.0 factors for Hamilton County to the respective attainment year emissions. These growth factors are for area sour ces as grouped by s ource c lassification

c odes (SCC) and are provided in Appendix R . The resulting emissions are tabulated in spreadsheets provided in Appendix K

.

P rojected emissions of PM 2.5 , NO X , and SO 2 from onroad mobile sources within Hamilton County for 2025 were determined by using the MOVES2010b model

. The model was run in inventory mode using the hourly time aggregation level. In addition, the model input option for an I/M program was not selected since the future status o f the Tennessee I/M Program cannot
be known

. ( Not selecting the I/M program option for the 2025 model run resulted in 6.0% greater emissions of NO X and no change in the emissions of PM 2.5 and SO 2

. ) Input data for the

model w as supplied by t he Chattanooga MPO as thirteen spreadsheets

. The input spreadsheet files and the run specification file that was used to set up the model run are provided electronically in Appendix L under the folder name ―20 25 w.o. IM MOVES Inputs.‖ The resulting

emission s from the model are provided in Appendix M and are tabulated in spreadsheets provided in Appendix N. Emissions for the years 2010, 2013, 2016, 2019, and 2022 were calculated by linear interpolation between the respective emissions for 2007 and 2025.

Pr o jected annual emissions of PM 2.5 , NO X , and SO 2 from nonroad mobile sources within Hamilton County were determined by using the NONROAD 2008 a model

. Input data for this model was supplied by the U.S. EPA. The resulting emissions from th e model are provided in Appendix O

.

The p rojected annual e missions of PM 2.5 , NO X , and SO 2 from the various source types within Hamilton County are given in the following T ables 3

- 2

, 3

- 3 , and 3

- 4 , respectively

.

Table 3

- 2 . Projected Annual Emissions of PM 2.5 from Sources in Hamilton County

PM 2 .5 Emissions ( tons/year )
Source Type 2007 2010 2013 2016 2019 2022 2025

Point 160.2 156.3 158.2 169.2 180.7 193.1 205.8

Area 875.4 916.6 955.8 1,001.2 1,042.6 1,083.6 1,121.9

Onroad 395.1 342.0 288.9 235.8 182.7 129.6 76.5

Nonroad 153.6 141.6 123.7 101.0 82.4 70.4 63.5

Total 1,584.3 1,556.5 1,526.6 1,507.3 1,488.4 1,476.7 1,467.8Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 22 of 33 Table 3

- 3 . Projected Annual Emissions of NO X from Sources in Hamilton County

NO X Emissions ( tons/year )
Source Type 2007 2010 2013 2016 2019 2022 2025

Point 2,437.2 2,484.1 2,575.6 2,650.6 2,811.6 2,982.2 3,154.6

Area 3,415.1 3,638.0 3,835.2 4,089.8 4,348.5 4,609.0 4,880.6

Onroad 11,465.2 9,9 72

. 4 8,4 79

. 7 6,9 86

. 9 5, 494

. 2 4

, 001

. 5 2, 508

. 7

Nonroad 1,792.1 1,562.6 1,264.3 1,003.4 833.6 730.8 675.2

Total 19,109.5 17,6 57

. 2 16,1 54

. 7 14, 730

. 8 13, 487

. 9 12, 323

. 4 11, 219

. 1

Table 3

- 4 . Projected Annual Emissions of S O 2 from Sources i n Hamilton County

SO 2 Emissions ( tons/year )
Source Type 2007 2010 2013 2016 2019 2022 2025

Point 919.2 797.5 808.1 798.0 819.4 842.1 865.6

Area 332.6 346.7 363.2 382.9 401.1 420.6 441.1

Onroad 87.6 77.1 66.5 56.0 45.5 34.9 24.4

Nonroad 99.3 25.9 15.2 14.2 14.7 15.3 15.9

Total 1,438.8 1,247.2 1,253.2 1,251.1 1,280.7 1,312.9 1,346.9

On January 4, 2013, the U.S. Court of Appeals for the District of Columbia Circuit remanded to the U.S. EPA both the ―Clean Air Fine Particle Implementation Rule‖ ( Federal Register Vol . 72

, N o. 79

, p p

. 20586

– 20667, April 25, 2007 ) and ―Implementation of the New Source Review (NSR) Program for Particulate Matter Less Than 2.5 Micrometers (PM 2.5 )‖ ( Federal Register Vol

. 73 , N o. 96

, p p

. 28321

– 28350, May 16, 2008 )

. A consequence of this decision is that , in accordance with Title I, Part D, Subpart 4 (§188

– 190) of the Clean Air Ac t, future PM 2.5 precursor emissions of VOCs and ammonia can no longer be presumed to have a limited impact on the maint e n ance of the annual PM 2.5 NAAQS

. The refore, a demonstration is also being made that available future year (2020) emissions of VOCs and ammonia from the combined sources within Hamilton County are below the respective attainment year emissions.

As with the attainment year emissions, emissions of VOCs and ammonia from point, area,

onroad m obile, and nonroad mobile sources within Hamilton County

, projected to 2020

, were
obtained from the county

- level emissions summary that is a part of the Particulate Matter (PM) NAAQS Final Rule Regulatory Impact Assessment and that is available from the U. S. EPA Emissions Modeling Clearinghouse at the website ftp.epa.gov/EmisInventory/2007v5 (filename:Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 23 of 33 2007platform_county_sector_emissions_2007re_2020re.zip ). The applicable portion of the emissions summary is provided in Appendix P

.

The 2020 projected e mis sions of VOCs and ammonia from the various source types within Hamilton County are given below in Table 3

- 5.

Table 3

- 5 . Projected Annual Emissions of VOCs and Ammonia from Sources in Hamilton

County

VOC Emissions ( tons/year ) Ammonia Emissions (tons/year)
Source Type 2007 20 2 0 20 07 202 0

Point 1,047.0 1,038.1 12.5 12.5

Area 5,338.9 5,372.1 194.2 202.0

Onroad 4,797.5 1,541.8 161.6 92.5

Nonroad 2,383.3 1,213.3 2.7 3.1

Total 13,566.6 9,165.4 370.9 310.1

3.1

. 3 Safety Margin s

For PM 2.5 and its significant precursors of NO X and SO 2 , t he ― safety margin ‖ is the difference

between the attainment year (2007) emissions from all source s (i.e., point, area, onroad mobile,

and nonroad mobile ) combined and the respective 2025 projected emissions from the combined

sources. Since projected emissions for PM 2.5 precursors of VOCs and ammonia are only provided for 2020, the difference between the attainment year emissions from the combined sources and the 2020 projected emissions f rom all sources combined is being used as t he safety margin for each of these two pollutant s . The PM 2.5 , NO X , SO 2 , VOC, and ammonia safety margins for Hamilton County are given below in Table 3

- 6

.

Table 3

- 6

. Projected Annual Emissions from Combined Sources in Hamilton County

Emissions ( tons/year

)

Pollutant 2007 2020 202 5 Safety Margin

PM 2.5 1,584.3

-- 1,467.8 116.4

NO X 19,109.5

-- 11, 219

. 1 7

, 890

. 4

SO 2 1,438.8

-- 1,346.9 91.8

VOCs 13,566.6 9,165.4

-- 4,401.2

Ammonia 370.9 310.1

-- 60.9Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 24 of 33 The projected emission decreases from 2007 to 2025 are 7. 4 % for PM 2.5 , 4 1

. 3 % for NO X , and
6.4% for SO 2

. VOC and ammonia emissions are projected to decrease by 32

. 4 % a nd 16

. 4 %

, respectively, from 2007 to 2020

.

The Georgia EPD and Alabama DEM also determined both attainment year emissions and 2025 projected emissions for PM 2.5 and its significant precursors of NO X and SO 2 from point, area, onroad mobile, and nonroad mobile sources combined within the Georgia portion and Alabama
port ion, respectively, of the Chattanooga m aintenance a rea. The resulting PM 2.5 , NO X , and SO 2 safety margins for the entire maintenance area are given below in Table 3

- 7. The emissions

that were used for the Georgia and Alabama portion s of the maintenance area are f r o m narratives of the applicable redesignation request and maintenance plan documents that are provided in Appendices A and B, respectively.

Table 3

- 7

. Projected Annual Emissions from Combined Sources in the Chattanooga

Maintenance Area

PM 2.5 Emissions ( tons/year ) NO X Emissions (tons/year) SO 2 Emissions (tons/year)

Maintenance
Area Portion 2007 2025 Safety Margin 2007 2025 Safety Margin 2007 2025 Safety Margin

Tennessee 1,584 1,468 116 19,10 9 11,219 7,890 1,439 1,347 92

Georgia 1,733 2,056

- 323 5,482 1,806 3,676 404 394 10

Alabama 785 565 220 18,654 3,634 15,020 32,805 10,518 22,287

Total 4,10

2 4,089 1 3 43,24 5 16,659 26,58 6 34,648 12,259 22,389

Significant decrease s from 2007 to 2025 are projected for NO X emissions from the Georgia portion of the maintenance area and for emissions of PM 2.5 , NO X , and SO 2 from the Alabama portion. SO 2 emissions from the Georgia portion are projected to decrease only slightly from

2007 to 2025 , and PM 2.5 emissions from the Georgia portion are projected to show a moderate

increase over this period. The Georgia EPD used PM 2.5 speciation data to show that the projected PM 2.5 emissions increase within the Georgia portion of the maintenance area should

be fully offset by the corresponding large decrease in NO X emissions. This explanation is contained in the redesignation request and maintenance plan for the Georgia portion, th e narrative of which is provided in Appendix A. Overall

, e mission s from the entire Chattanooga

maintenance area are projected to decreas e by 0.3% for PM 2.5 , 61.5% for NO X , and 64.6% for
SO 2 from 2007 to 2025.

3

. 1. 4 Regulatory Programs

The Bureau, the Te nnessee Department of Environment and Conservation, the Georgia EPD

, and the U.S. EPA have previously implemented enforceable requirements that will facilitateRedesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 25 of 33 maintenance of the annual PM 2.5 NAAQS

. R egulatory programs that will remain in place for the Chattanooga maintenance a rea and nearby areas include the following :

 Chattanooga Air Pollution Air Pollution Control Ordinance ;

 Hamilton County Air Pollution Control Regulation ;

 Collegedale Air Pollution Control Ordinance ;

 East Ridge Air Pollution Co ntrol Ordinance ;

 Lakesite Air Pollution Control Ordin an ce ;

 Lookout Mountain Air Pollution Control Ordinance ;

 Red Bank Air Pollution Control Ordinance ;

 Ridgeside Air Pollution Control Ordinance ;

 Signal Mountain Air Pollution Control Ordinance ;

 Soddy

- Daisy Air Pollution Control Ordinance ;

 Walden Air Pollution Control Ordinance ;

 S easonal open burning ban;

 ―Standards of Performance for New Stationary S o u rces ,‖ Title 40 Code of Federal Regulations Part 60;

 ―National Emission Standards for Hazardous Air Pollutan ts,‖ Title 40 Code of Federal Regulations Part 61;

 ―National Emission Standards for Hazardous Air Pollutants for Source Categories,‖ Title

40 Code of Federal Regulations Part 63;

 ―Regulation of Fuels and Fuel Additives

, ‖ Title 40 Code of Federal Regulations Part 80 ;

 ―Control of Emissions from New and In

- Use Highway Vehicles and Engines‖ ( Tier 2

s tandards ), Title 40 Code of Federal Regulations Part 86 ;

 ―NO X Budget Trading Program for State Implementation Plans ‖ ( NO X SIP C all )

, Title 40
Code of Fede ral Regulations Part 96, Subparts A

– I;

 ―Control of Emissions from New and In

- Use Nonroad Compression

- Ignition Engines

, ‖

Title 40 Code of Federal Regulations Part 1039 ;

 ―Control of Emissions from New, Large Nonroad Spark

- Ignition Engines

, ‖ Title 40 Code

of Federal Regulations Part 1048 ;

 ―Control of Emissions from Recreational Engines and Vehicles

, ‖ Title 40 Code of Federal Regulations Part 10 51 ;

 Consent Decree, Case No. 1:09

- cv

- 00244

- GMS, between the U.S. et al. and INVISTA, S.à r.l., LLC

 F ederal F acilities C ompliance A greement

, Docket No. CAA

- 04

- 2010

- 1760

, b etween the
U.S. EPA and TV A;

 ― Multipollutant Control of Electric Utility Steam Generating Units

, ‖ Georgia Rule 391

- 3

- 1

- .02(2)(sss) ; and

 ―SO 2 Emissions from Electric Utility Steam Generating Units

, ‖ Georgi a Rule 391

- 3

- 1

- .02(2)( uuu )

.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 26 of 33 3

. 2 Verification of Continued Attainment

Continued attainment of the Chattanooga maintenance area with the 1997 annual PM 2.5 NAAQS shall be verified through operation of the four existing PM 2.5 FRM monitors in the area and through periodic emissions inventory updates. The three such m onitors in Hamilton C ounty are maintained and operated by the Bureau, and maintenance and operation of the m onitor in Walker County is performed by the Georgia EPD. All of t hese monitors a re o perat ed in

accord ance with applicable provisions of ―Ambient Air Quality Surveillance‖ ( Title 40 C ode of

F ederal R egul

ation s Part 58 )

. R equired data from the four PM 2.5 FRM monitors is submitted quarterly to the U.S. EPA pursuant to §58.16 of P art 58

.

Emissions from industrial , commercial, and institutional point sources that are permitted by the

Bureau are updated continu ally and archived annually in the Bureau’s Emissions Inventory System. The emissions that are tracked in this system include PM 2.5 , NO X , SO 2 , VOCs, and

ammonia

. T he PM 2.5 emissions include any condensable portion that can be determined.

The se emissions f r o m point and nonpoint sources

, as applicable

, are reported to the NEI in

accordance with the submittal schedule outlined in the ― A ir E missions R eporting R equirements (AERR) ‖ [ Title 40 Code of Federal Regulations Part 5 1

, Subpart A (§51.1

– 50)]. In addition,

emissions of area , onroad mobile, and nonroad mobile sources are updated in the NEI every three years as required by th e AERR . The most recent complete emissions inventory was

submitted to the NEI in 2012 for calendar year 2011. The next complete emissions inventory,

which will cover calendar year 2014, is due for submittal to the NEI in 2015.

3

. 3 C ontingency Measures

§1 75A( d) of the Clean Air Act requires that th e maintenance plan include contingency measures

to be implemented , as necessary, to promptly correct any exceedance of the applicable NAAQS that might occur in the maintenance area

. The Bureau has identified the fol lowing possible

means for provid ing further reductions in emissions of PM 2.5 and/or its significant precursors as

co ntingency measure s for emission sources within Hamilton County :

 Reasonably a vailable c ontrol t echnology (RAC T ) for point sources of PM 2.5 emissions not already covered by RACT, b est a vailable c ontrol t echnology (BACT), or reasonable and proper emission limitations;

 Reasonably a vailable c ontrol m easures (RAC M ) for area sources of PM 2.5 emissions;

 RACT for major point

- sources of NO X emission s ;

 RACT for minor point

- sources of NO X emission s;

 RAC M for area sources of NO X emission s;

 RACT for major point

- sources of SO 2 emission s;

 RACT for minor point

- sources of SO 2 emission s;Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 27 of 33  RAC M for area sources of SO 2 emission s; and

 Additional PM 2.5 , NO X , and/or SO 2 emissions reduction measures yet to be identified.

Additional control measures for mobile sources of NO X emissions are not specifically listed as a possible contingency measure because the local agency and its legislative bodies do not have

aut hority to adopt any such additional measures outside of Hamilton County

.

3.3 .1 Contingency Measure Triggers

An exceedance of t he 1997 annual PM 2.5 NAAQS of 15.0 μ g/m 3 at any FRM monitor in the Chattanooga maintenance area, based on quality

- assured and certified monitoring data as averaged over three consecutive calendar years, will ―trigger‖ a comprehensive evaluation by

the Bureau to determine if contingency measures should be implemented. Furthermore, such an evaluation will also be triggered by t he occurrence of any of the following conditions that may forewarn of a potential exceedance of the annual PM 2.5 NAAQS:

 An annual mean PM 2.5 concentration (average of quarterly

- average concentrations) of greater than or equal to 16.5 μg/m 3 for the previous calendar year at any FRM monitor

in the Chattanooga maintenance area , based on quality

- assured and certified monitoring

data ;

 An annual mean PM 2.5 concen tration (average of quarterly

- average concentrations) of greater than or equal to 15.5 μg/m 3 for ea c h of the previous two consecutive calendar

years at any FRM monitor in the Chattanooga maintenance area , based on quality

assured and certified monitoring d ata ;

 T otal emissions of PM 2 .5 in the most recent NEI for Hamilton County of g reater than 2,0 59 tons , which is thirty percent more than the corresponding emissions f or 2007 (the attainment year) ;

 T otal emissions of N O X in the most recent NEI for Hamilton County of greater than 24,84 2 tons , which is thirty percent more than the corresponding emissions for 2007 ; and

 T otal emissions of SO 2 in the most recent NEI for Hamilton County of greater than 1,87 0 tons , which is thirty percent more than the corresponding emissions for 2007

.

3

. 3. 2 Procedures for Adoption and Implementation of Contingency Measures

Upon occurrence of a contingency measure trigger, the required comprehensive evaluation will

be conducted to determine the cause(s) of the elevate d ambient PM 2.5 concentrations or emissions inventory increase

, to determine if an exceedance of the annual PM 2.5 NAAQS is likely to occur or continue , and to determine whether or not the adoption and implementation ofRedesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 28 of 33 appropriate contingency measures is required for the further reduction of emissions of PM 2.5 and/or its significant precursors within Hamilton County . The evaluation will examine:

 S everity of the trigger condition ;

 Potential ly c ontribut ing emissions from sources within Hamilton County ;

 Pot ential ly co ntribut ing emissions resulting from regional or long

- range transport ;

 Potential ly contribut ing meteorological conditions , if applicable;

 Emission trends for all source types;

 F uture emission s reduction s from any adopted or planned regulations or initiatives ;

 C urrent and recently identified emission control technologies applicable to considered contingency measures;

 Emissions reduction potential of considered contingency measures ;

 Technical and economic feasibility of considered contingency measures ;

 Possible g eographic limitations of considered contingency measures ; and

 Implementation timeline of considered contingency measures

.

The comprehensive evaluation will be completed by the Bureau and submitted to the U.S. EPA

as expeditiously as practical

, but no later than nine (9) months after the contingency measure trigger occurs

. Any contingency measures that are needed for reattainment or maintenance of

the annual PM 2.5 NAAQS will be identified through the evaluation

. The Bureau commits to

pursue adopt ion of any rules that are ne cessary for the implementation of such measures within eighteen (18) months following the date on which the trigger condition occurs. Furthermore, the appropriate contingency measures will be imple mented within twenty

- four (24) months after the

occurrence of the trigger condition

. The Bureau will submit a revised implementation schedule
to the U.S. EPA i f it is determined that technical or econ omic considerations warrant a dditional time to fully implement the contingency measures

. Adoption of any rules for the implementation

of cont ingency measures is subject to necessary administrative and legal processes. No such

rule will be adopted without providing an opportunity for full public participati on through the

issuance of public notices , the solicit ation of input from interested and affected persons in the

area , and the holding of a public hearing

.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 29 of 33 4 .0 M OTOR VEHICLE EMISSIONS BUDGET S

―Conformity to State or Federal Implementation Plans of Transportation Plans , Programs, and Projects Developed, Funded or Approved Under Title 23 U.S.C. or the Federal Transit Laws ‖ [t he tr ansportation c onformity r ule

, Title 40 Code of Federal Regulations Part 93 , Su bpart A (§93. 100

– 129 ) ] requires that proposed, non

- exempt highway and transit projects within the maintenance area conform to air quality goals before they can be federally funded. One requirement for a determination of conformity to be made is that , for each applicable pollutant,

a n intended project cannot result in annual emissions in excess of a pertinent motor vehicle emissions budget (MVEB) . The MVEB for each pollutant appli es to the final year covered by the maintenance plan and subsequent years

. The Bureau is proposing MVEBs

, applicable t o 2025 and later, for all onroad mobile sources combined within Hamilton County. Similarly,

MVEB s for the combined onroad mobile sources within Catoosa and Walker Counties ha ve been proposed by the Georgia EP D that also cover years commencing with 2025

. The Alabama DEM was not required to develop MVEBs for onroad mobile sources within the portion of Jackson County that is included in the Chattanooga maintenance area because emissions

from these sources are very minimal and have been determined to not be s ignificant

contributors to PM 2.5 nonattainment.

4 .1 Applicable Po llutants

Pollutants that must be addressed for transportation conformity purposes in PM 2.5 maintenance

areas are identified in §93.119(f)(7) through (10) of the transportation conformity rule. These pollutants are:

 PM 2.5 [§93.119(f)(7)];

 R eentra i ned road dust if the U.S. EPA Regional Administrator or the director of the State air agency has made a finding that emissions from reentrained road dust within the area are a significant contributor to PM 2.5 nonattainment and has so notified the pertinent
MPO and Department of Transportation ( DOT ) [§93.119(f)(8)] ;

 NO X unless the U.S. EPA Regional Administrator and the director of the State air agency have made a finding that emissions of NO X within the area are not a significant

contributor to PM 2.5 nonattainment and have so notified the MPO and DOT [§93.119(f)(9)] ; and

 VOC s
, SO 2 , and/or ammonia if the U.S. EPA Regional Administrator or the director of the State air agency has made a finding that emissions of any such precursor within the area are a significant contributor to PM 2.5 nonattainment and has so notified the MPO

and DOT [§93.119(f)(10)]

.

NO X must be addressed because no finding has been made that emissions of NO X are not a significant contributor to PM 2.5 nonattainment i n the Chattanooga maintenance area.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 30 of 33 Reentrained road dust, VOCs, and ammonia are not required to be addressed because no finding has been made that emissions from reentrained road dust

, emissions of VOC s , or emissions of ammonia are a significant contributor to PM 2.5 nonattainment in the maintenance

area. Although SO 2 is a significant PM 2.5 precursor, it is not required to be addressed because

onroad mobile sources result in only 1.8% (24.4 tons) of the total projected SO 2 emissions for 2025 within Hamilton County.

Accordingly , the pollutants for which MVEB s will be established for onroad m obile sources within Hamilton County are PM 2.5 and NO X

. These are also the two pollutants for which MVEBs were proposed by the Georgia EP D for onroad mobile sources within Catoosa and Walker
Counties.

4 .2 Motor Vehicle Emissions Budgets Determination

The MOVES2010b model was run in inventory mode using the hourly time aggregation level in

order to estimate emissions of PM 2.5 and NO X from onroad mobile sources within Hamilton County for 2025 and 2040 using both normal and ―worst case‖ input scenarios. The model input option for an I/M program was not selected for any of these four model runs since the future status of the Tennessee I/M program cannot be known. The worst

- case input assumptions that were employed are:

 A ten percent increase in vehicle m iles traveled for all vehicle types;

 A doubled rate of increase in population (and corresponding number of vehicles) from the population in 2010; and

 A two

- year increase in the age of all vehicles.

Input data was supplied by the Chattanooga MPO as thirtee n spreadsheets for the 2025 model run, thirteen spreadsheets for the 2025 worst case model run, thirteen spreadsheets for the 2040 model run, and thirteen spreadsheets for the 2040 worst case model run. The input spreadsheet files and run specification fi les for the 2025, 2025 worst case, 2040, and 2040 worst case model runs are provided electronically in Appendix L under the folder names ―2025

w.o. IM MOVES Inputs ,‖ ―2025 Worst Case w.o. IM MOVES Inputs,‖ ―2040 w.o. IM MOVES Inputs,‖ and ―2040 Worst Case w.o. IM MOVES Inputs,‖ respectively. The resulting emissions

from the model runs are provided in Appendix M , tabulated in spreadsheets provided in Appendix N

, and summarized in Table 4

- 1 , which follows

. The listed emissions for 2025, using normal input conditions, were previously included in Tables 3

- 2 (for PM 2.5 ) and 3

- 3 (for NO X ).Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 31 of 33 Table 4

- 1

. Projected Annual Emissions from Onroad Sources in Hamilton County

Emissions ( tons/year

)

Pollutant 20 25 2025 Worst Case 20 40 20 40 Worst Case

P M 2.5 76.5 95.8 81.2 97.4

N O X 2, 508

. 7 3

, 1 9 8

. 5 2,3 43

. 4 2, 771

. 1

For 2025, using the worst

- case input scenario rather than the normal input conditions results in emissions that are greater by 19.3 tons/year (25.2% ) for PM 2.5 and 6 89.8 tons/year (2 7

. 5 % ) for
NO X

. T h ese substantial differences between worst case and normal case emissions are much

less than the respective safety margin s , which were previously given in Table 3

- 6

.

T he worst case emissions of PM 2.5 for 2025 are only 1.6 tons/year lower than the worst

- case
PM 2.5 emissions for 2040 and are higher than the corresponding normal

- case emissions for 2040 by 18.0% (14.6 tons/year)

. F or NO X , the 2025 worst case emissions are both higher than

the worst case emissions for 2040 by 1 5

. 4 % ( 427

. 4 tons/year) and considerably higher than the

normal case emissions for 2040 by 3 6

. 5 % ( 855 .1 tons/year). In addition, demonstration of

future maintenance of the annual PM 2.5 NAAQS is required for a period of ten years following

the presumed date of redesignation, which should end no later than 2025. Therefore, the projected 2025 worst case emissions of 100 .0 tons/year for PM 2.5 and 3

, 200 .0 tons/year for
NO X , as rounded to the nearest ―ten‖ with two significant figures then added, are being proposed as MVEBs for onroad mobile sources within Hamilton County

. Incidentally, the projected 2040 worst case emissions for PM 2.5 also round to 100.0 tons/year , with the subsequent addition of s ignificant figures

.

The Chattanooga MPO has conc urred that the proposed MVEBs for onroad mobile sources within Hamilton County of 100.0 tons/year for PM 2.5 and 3,200.0 tons/year for NO X are sufficient and acceptable. For comparison, the Georgia EP D has proposed MVEBs for onroad mobile
sources within Ca toosa and Walker Counties combined of 44.2 tons/year for PM 2.5 and 1,386.5 tons/year for NO X

.

4 .3 Safety Margin Allotment s

The safety margin for each applicable pollutant (PM 2.5 and NO X ) is the quantitative decrease in the combined point, area, onroad mobile , and nonroad mobile source emissions from 2007 (the attainment year) to 2025. For each pollutant, the amount of the proposed MVEB that exceeds the 2025 (normal case) emissions from onroad sources must be provided by the available safety margin. T he p ortion of each safety margin that is being allo ca ted for its respective MVEB

is given i n Table 4

- 2 , which follows

.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 32 of 33 Table 4

- 2

. Safety Margin Allotments to P roposed Motor Vehicle Emissions Budgets for

Onroad Sources in Hamilton County

Proposed
MVEB Safety

Margin Portion of Safety Margin

Allocated for Proposed MVEB
Pollutant tons/year tons/year tons/year percentage

P M 2.5 100 .0 116.4 23

. 5 * 20

. 2 %

NO X 3

, 200 .0 7

, 890

. 4 6 91

. 3 † 8 .8%

* 100.0 tons/year (proposed MVEB)

– 76.5 tons/year ( normal 2025 onroad source emissions) = 23.5 tons/year

† 3 ,200 .0 tons/year (proposed MVEB)

– 2,508.7 tons/year ( normal 2025 onroad source emissions) = 691.3 tons/year

Al l ocating 23

. 5 tons/year of the PM 2.5 safety margin to the proposed MVEB for PM 2.5 emissions

from onroad mob ile sources still leaves 9 2

. 9 tons/year, or 79

. 8 %

, of the safety margin available

to allow for potential PM 2.5 emission increases from other source types. The situation is even
better for NO X , in which designating 6 91

. 3 tons/year of its safety margin to its proposed MVEB

sets 7, 199

. 1 tons/year, or 9 1 .2% , of the NO X safety margin in reserve for potential increases
from other sources of NO X emissions

.Redesignation Request and Maintenance Plan for the

Tennessee Portion of the Chattanooga PM 2.5 Nonattainment Area Page 33 of 33 5. 0 CONCLUSION

This document demonstrates that all requirements have been achieved in order for the Tennessee portion (Hamilton County) of the Chattanooga , Tennessee

- Georgia, PM 2.5 nonattainment area to be redesignated by the U.S. EPA to attainment of the 1997 annual PM 2.5 NAAQS as a maintenance area. T he U.S. EPA determined , as of May 31, 2011, that the Chattanooga area has attained the 1997 annual PM 2.5 NAAQS , b ased on quality

- assured and certified monitoring data for the 2007

– 2009 period

. Ample evidence is given in this document that attainment of the standard is due to permanent and enforceable reductions in emissions of

PM 2.5 and its significant precursors, NO X and SO 2

. The Bureau’s plan for maintaining attainment of the standard within Hamilton County is also presented in the document. This plan uses projected emissions to demonstrate future attainment, and it makes use of ambient air monitoring and emission inventories to verify continued attainment. Included in the plan are

c ontingency measures for emissio n sources within Hamilton County that can be implemented, if necessary, to preclude the maintenance area exceeding the standard or to return the area to

attainment. In addition, motor vehicle emissions budget s
, as required by the U.S. EPA’s transportation conformity rule

, are contained in this document for onroad mobile source emissions of PM 2.5 and NO X within Hamilton County

.

## Appendix A

“ Georgia’s Redesignation Request and Maintenance Plan for the Chattanooga Nonattainment Area for the 1997 PM 2.5 

## NAAQS

for Catoosa and Walker Counties ” (narrative)

## Appendix B

“ Redesignation Request and Maintenance Demonstration

— 

## Jackson County, Alabama

— 

## Chattanooga Annual PM 2.5 

## No n att a inment Area ” (narrative)

## Appendix C

Annual PM 2.5 

## Design Values and Annual Mean PM 2.5 

## Concentrations

Applicable Portions of PM 2.5 

### Design Value Reports
from www.epa.gov/airtrends/values.html
and www.epa.gov/airtrends/values _previous .html

## Appendix D

“Source Apportionment of PM 2.5 

## in Georgia”

## Appendix E

Power Plant Emissions Data

Facility Emissions Trends Reports
from the U.S. EPA Clean Air Markets Division for Widows Creek, Bowen, and Hammond Power Plants

## Appendix F

Point Source Emissions Data

Chattanooga

- Hamilton County Air Pollution Control Bureau 2003, 2004, 2005, 2006, 2008, 2009, and 2010 E missions Inventory System Reports

## Appendix G

2007 Point Source Emissions Data

2005 National Emissions Inventory (NEI) Download for Hamilton County, Tennessee

– Updated to 2007

## Appendix H

Point Source Emission Calculation Spreadsheets

## Appendix I

2007 Area Source Emissions Data

2005 National Emissions Inventory (NEI) Download for Hamilton County, Tennessee

– Updat ed to 2007

## Appendix J

2005 Aircraft, Marine, and Railroad Source Emissions Data

2005 National Emissions Inventory (NEI) Download

for Hamilton County, Tennessee

## Appendix K

Area Source Emission Calculation Spreadsheets

## Appendix L

Onroad Source Input Data

MOVES2010b (Motor Vehicle Emission Simulator) In put Data

for Hamilton County, Tennessee

(provided electronically under folder names:

2007 MOVES Inputs

, 2025 w.o. IM MOVES Inputs

, 2025 Worst Case w.o. IM MOVES Inputs

, 2040 w.o. IM MOVES Inputs

, and 2040 Worst Case w.o. IM MOVES Inputs )

## Appendix M

Onroad Source Emissions Data

MOVES2010b (Motor Vehicle Emission Simulator) Output

for Hamilton County, Tennessee

## Appendix N

Onroad Source Emission Calculation Spreadsheets

## Appendix O

Nonroad Source Emissions Data

NONROAD2008a Emission Inventory Model Output

for Hamilton County, Tennessee

## Appendix P

VOC and A mmoni a Emissio n s D at a

Applicable Portion of the Particulate Matter ( PM ) NAAQS Final Rule

Regulatory Impact Asses s ment from ftp .epa.gov/

EmisInventory

/ 2007v 5 (filename: 2007platform _county_sector_emissions_2007re_2020re.zip )

## Appendix Q

Point Source Emission Growth Factors

Economic Growth Analysis System (EGAS) Version 5.0 Output by North American Industry Classification System (NAICS) Codes for Hamilton County, Tennessee

– 2007 Base Year

## Appendix R

Area Source Emission Growth Factors

Economic Growth Analysis System (EGAS) Version 5.0 Output

by Source Classification Codes (SCC) for Hamilton County, Tennessee

– 2007 Base Year