# Attachment P

Public Participation

# Table of Contents for Attachment P

Table 1: Comments Submitted by EPA ............................................................................. 3

Table 2: Comments Submitted by the Tennessee Environmental Council ...................... 12

Table 3: Comments Submitted by Bass, Berr y, & Simms on behalf of Bowater ............ 15

Table 4: Comments submitted by TDEC-APC ................................................................ 16

Appendix P-1: Air Quality Monito ring Data for 24-Hour PM2.5 NAAQS

Appendix P-2: PM 2.5 

# Contribution Assessment, Knoxville, TN

Appendix P-3: Public Comments

Appendix P-4: Public Notice Information

Appendix P-5: Board Order3Table 1: Comments Submitted by EPA#SectionCommentResponse1. NOXInsignificanceEPA has evaluated the modeling and technical support that Tennessee has provided in itsproposed demonstration that NOx emissions in Tennessee do not significantly contributeto PM2.5concentrations in the Knoxville PM2.5nonattainment area. Upon carefulevaluation, EPA does not believe that the demonstration provided in Tennessee'ssubmission supports a finding that NOx is an insignificant contributor to ambient PM2.5concentrations in the Knoxville area. Thedemonstration indicates that the level ofimpact of NOx emissions to the ambient PM2.5concentrations for the Tennesseenonattainment areas ranges from approximately 0.60 - 0.84 μg/m3. In many instances,contributions to ambient PM2.5at such a level could alone be the difference betweenattainment and nonattainment, so it is notappropriate to consider such a level ofcontribution per se “insignificant."Moreover, this level of contribution to ambient PM2.5levels in a nonattainment area iswell above the 0.2 μg/m3 level of contribution that EPA has previously determined wasappropriate to require inclusion of an upwind state in the Clean Air Interstate Rule(CAIR), and thereby require control of NOx emissions in such upwind state for thebenefit of downwind states. The contribution threshold of CAIR is based upon CleanAir Act section 110(a)(2)(D) and the facts of that rule, and is therefore not a bright linetest of what constitutes "significant" contribution for purposes of 40 CFR section51.1002(c)(2). Nevertheless, we considerit inappropriate for a downwind state with anonattainment area to treat local sources of NOx emissions as an insignificantcontributor to local nonattainment, and thereby decline to address NOx emissions in itsSIP, when the level of contribution is well above the threshold which obligated upwindstates to restrict NOx emissions becauseof impacts on downwind nonattainment areasthrough interstate transport.After evaluating all of the evidence presentedin your demonstration, we believe that thislevel of impact on PM2.5concentrations from NOx emissions is significant and thereforethat NOx should be treated as anattainment plan precursor for PM2.5in the Tennesseenonattainment area.Tennessee will incorporate the provisions ofthe NOXaddendum into the final SIP. Thefollowing language was added to the end ofSection 3.0.“EPA has indicated that the Agencycontinues to have concerns regarding NOXinsignificance demonstrations, and that theinformation presented within this sectionmay not be sufficient to overturn thepresumption of NOXsignificance as a PM2.5precursor pollutant. Tennessee willincorporate the measures indicated inAttachment Q (NOXAddendum) as anenforceable part of thisSIP. If Tennesseeobtains sufficient additional information tooverturn the presumption of NOXsignificance in the future, that informationwill be submitted to EPA, and Tennesseewill submit an amendment to the SIP torequest removal of applicable NOXprovisions.”4Table 1: Comments Submitted by EPA#SectionCommentResponse2. GeneralCommentsa.Throughout, the SIP does a good job in summarizing EPA policy and guidance.However, it does not, in several areas, discuss or document how guidance wasapplied for the Knoxville annual PM2.5SIP. We attempt to offerrecommendations and suggestions for additional data and analyses that shouldbe discussed and submitted.b.Adding subsection numbers to the SIP is recommended.(a) Specific comments are addressed below.(b) Subsection numbers were added to thefinal version.3. GeneralCommentsSection 1.0 of the SIP Narrative states that EPA designated the area as nonattainment forthe annual PM2.5National Ambient Air Quality Standard (NAAQS). Thosedesignations, however, did not specify whether they were for the annual or dailystandard. Section 51.1007(a) of the PM2.5Implementation Rule requires that “[f]or anyarea designated as nonattainment for the PM2.5NAAQS, the State must submit anattainment demonstration showing that the area will attain the annualand 24-hourstandardsas expeditiously as practicable.” [emphasis added] Although Tennessee hasno nonattainment areas for the 1997 24-hour PM2.5NAAQS, this standard should beaddressed as well in order to meet the requirement of the rule. We recommend adding atable similar to Table 1-1 showing the 24-hour design values for the same periods andadding a statement regarding the compliance status of these areas with the 1997 24-hourPM2.5NAAQS and the fact that measures for achieving attainment with the annualstandard have a co-benefit for the 24-hour standard.Monitoring data for the 24-hour PM2.5NAAQS are presented inAppendix P-1 ofthis attachment. Appendix A demonstratesthat all monitors in the Knoxvillenonattainment are currently attaining the 24-hour PM2.5NAAQS.4. GeneralCommentsPlease correct the typographical error, at thebottom of Page 1 of Attachment I, stating“Error! Reference source not found.”Corrected5. SpeciatedModeledAttainmentTest (SMAT)a.There is no discussion on how the base or current design values used in themodeled attainment test were developed. We recommend expanding thediscussion on page 101 and adding a table that contains the observed meanquarterly PM2.5baseline concentrations for the monitors that were used in theSpeciated Monitor Attainment Test (SMAT). The text would also discuss howthese data were developed. This would complement the data in Table 8-6 andaid in the discussion of how Table 8-6 data were developed.b.The fractions would be applied to the observed quarterly mean PM2.5valuespresented in the table we suggested tobe added in the above comment todetermine the quarterly component specific concentrations in Table 8-6.Items (a), through (g) were corrected byincorporating extensive revisions to Section8.0. See section 8.12 of the revised SIP foradditional details.Additional comments on item (f): Monitor47-093-1013 was addressed in the revisedSIP by noting that the monitor was operatedfrom April 2002 to February 2004 and shutdown until March 2007. We believe that itwould not be helpful to include this monitor5Table 1: Comments Submitted by EPA#SectionCommentResponsec.The SMAT section could contain a tablewith the quarterly species fractionsand the degree of sulfate neutralization (DON) data to show how this part of theattainment test was developed. It would contain the data needed to generate thedata in Table 8-6).d.There is no discussion on how the FRM monitors were speciated. The SIPNarrative (see bottom of page 101) mentions how this should be accomplishedaccording to the guidance, but it does not discuss specifically how this wasaccomplished for the Knoxvillenonattainment area.e.We recommend that discussions and tables on the following be added to the SIPNarrative on the SMAT documentation before the discussion on Table 8-9.Having the following tables and the additional ones mentioned above shouldcomplete in greater detail how the SMAT was applied in the Knoxville NAA.i.Quarterly PM2.5component RRFs.ii.Quarterly mean PM2.5mass estimates for 2009iii.Estimated annual mean 2009 PM2.5mass compared to the baselinedesign values and provide the 2009 non-blank mass, blank value and2009 annual design value.f.Table 8-9:iv.The 2009 projected DV for the 47145004 FRM monitor is slightlydifferent in Table 8-9 on page 105 and Table 4-10 of Attachment G.v.It appears that the 2009 projected DV for the 470931013 FRM monitorshould be added to this table since it has a projected DV presented inAttachment G. Maybe, caveats on the completeness of the data could beadded as a footnote using language similar to that provided inAttachment E.g.The “Defining RRFs Based on Modeling Results “Near” the Monitor” sectionand the second sentence in section 4.6 state how EPA guidance defines “near”the monitor. However, these sections donot clearly stated how data from a gridof nine cells from the 12km CMAQ modeling was used to determine the baseas part of the attainment demonstration, dueto the lack of baseline data for this site.6Table 1: Comments Submitted by EPA#SectionCommentResponseand future concentrations in the relative reduction factor analysis.6. Weight ofEvidencea. Table 9.4 states that air quality has shown a downward trend since 1999 to 2006,however, the data in Table 1-1 shows the design value at the controllingviolating Vermont Avenue monitor to consistently hover around 15.6 μg/m3.Several other monitors also have shown consistent NAAQS violations, but thetrend is not downward. Therefore, it is important for the weight of evidenceanalysis to document the specific emission reductions that will occur in the nexttwo ozone seasons that will achieve the 0.9 μg/m3improvement in air qualityfor attainment.b. The change or improvement in PM2.5impact that an emission reduction wouldcause could be added to the information in Table 9.4c. The Loudon monitor was not used in the attainment test but it has recent annualPM2.5NAAQS violations. However, we believe that the existing modeling datacould still be used to address the Loudon County. A RRF could be developedfrom the modeling similar to that performed at the other FRM monitors. TheRRF could be used to show if comparablelevels of reductions are expected atthe Loudon FRM site.d. The State appears to relyheavily on sulfur dioxide (SO2) reductions that areexpected to occur by 2009 at two Tennessee Valley Authority (TVA) powerplants to help achieve attainment. Since the recent air quality has not shown adownward and if the 2005-2007 design values are above the PM2.5NAAQS, weencourage the State to highlight those mandatory and voluntary controls andreductions that are expected to occurin 2008 and by late spring/early summermonths of the 2009 season.(a) We believe that the statement in Table9-4 is correct: monitoring data for theKnoxville area does indicate a downwardtrend in ambient PM2.5levels from 1999 to2006. We note in this table that the designvalue at the controlling monitor decreasedby about 25% between 1999-2001 and 2004-2006. This trend is clearly visible in Figure2-6 of the SIP. Although some PM2.5concentrations have trended upward over thelast 2-3 years, we also noted that historicalchanges in utility SO2emissions did notuniformly decline during this period (seeTables 5-1 and 5-2 and accompanyingnarrative). The most important differencebetween monitored PM2.5concentrationsfrom 2004-2007 and projectedconcentrations in 2009 is that another sharpdecline in utility SO2emissions is expectedas coal-fired boilers install controls forCAIR compliance.See Table 9-8 of the final SIP for specificreductions at TVA Bull Run and Kingston.Tennessee can provide additionaldocumentation in the form of IntegratedPlanning Model predictions anddocumentation of add-on controlsundergoing engineering or construction, ifnecessary to provide additional evidence offuture attainment.7Table 1: Comments Submitted by EPA#SectionCommentResponse(b) Emissions sensitivity results are includedin Appendix P-2 of this attachment. Theemission sensitivities provide an estimate ofthe impact of SO2and NOXreductions fromvarious source categories in Tennessee andneighboring States. Estimation of theimpact of control measures at specificfacilities would likely require additionalmodeling work.(c) See Section 9.0 of revised SIP foradditional information on Loudon Countymonitor.(d) See revisions to Table 9-4 forinstallation date and estimated reductions atTVA Bull Run.7. SIP NarrativeTable of Contents- We recommend that the descriptivename be added to the attachmentfile names. For instance, “AttachmentG Final” would become “Attachment G –Attainment demonstration.” This would helpthe reader to locate anattachment file toreview without having to look at the Table of Contents to see what it contained oraddressed.File names will be updated in the final SIP.8. SIP NarrativeTable 1-1 on page 2 lists the design values (DV) for five of the six Federal ReferenceMethod (FRM) monitors in the Knoxville annual PM2.5nonattainment area (PM2.5NAA). We encourage the state to add this data for the remaining FRM NAA monitor(i.e., Loudon County (ID# 471050108). Even though the Loudon County monitor didnot become operational until 2003, its data still could be included in the table. Themonitor will have to be used to determine attainment whenever the State requestsredesignation to attainment and because themonitor’s design 2004-2006 DV is at 15.3μg/m3.The monitor was removed from Table 1-1to avoid confusion, because inclusion ofdesign values in this table suggested that themonitor would need to be included in theattainment test. The Loudon Countymonitor is addressed in revisions to Section9.0 (Weight of Evidence).9. EmissionInventories –Chapter 4.0a.With the exception for Roane County,the overall county point source actualtotals for Anderson, Loudon, Knox and Blount counties in Table 4-5 do notmatch the 2002 actual SO2emission totals for point sources in Table 4-3. It isunclear why this difference exists orif the difference is because the point(a) The point source emission inventoryincluded in Attachment B includes all pointsources, while the summary in Table 4-3includes only point sources with greater than8Table 1: Comments Submitted by EPA#SectionCommentResponsesource cut-off used to develop point sources in Table 4-3 is lower than 100 tonsper year. Also, if the point source cut-off is less than 100 tons per year, pleasediscuss how area sources are determinedfor stationary sources. The tablesshould probably be revised to correct the differences.b.With the exception for Roane and Anderson Counties, the overall county pointsource actual totals for Loudon, Knox and Blount counties in Table 4-6 do notmatch the 2002 actual SO2emission totals for point sources in Table 4-4. Thetables should be revised to correct the differences.c.It is believed that the SO2and PM2.5emissions estimates presented in Tables 4-7 and 4-8, respectively, represent the level of emissions that were modeled inthe annual PM2.5emission control strategy for the Knoxville nonattainment areaand which are needed to achieve attainment in 2009. However, this is notclearly stated in the text preceding these tables. We recommend that the textclearly discuss this comment.d.Since SO2and PM2.5typical and actual emission totals are provided in Tables4-3 and 4-4, respectively, for the EGUemissions, it is unclear if the 2009 EGUemission totals in Table 4-7 and 4-8 represent actual or typical projectedemissions. The text and the table should state which type of totals arepresented. The text above these tables could also refer the reader to the sectionof the SIP Narrative that discusses the controls that were used to develop the2009 emissions.e.We recommend that the facility nameshould accompany the SCC descriptionin Tables 4-5 and 4-6 for point sources. If this is not possible, the SIP couldcontain a list of the point sources with their PM2.5precursor pollutants for thenonattainment counties.100 tons/year of SO2emissions.(b) See response to (a) above.(c) Added a sentence clarifying that theseare the level of emissions modeled todemonstrate attainment in 2009.(d) Added clarifying language in thesetables to indicate that 2009 EGU emissionsinventories were developed from 2002typical emissions inventory for EGUs. Asentence was added to refer to the controlrequirements in Section 5.0.(e) Facility names were added to Tables 4-7and 4-8.10. EmissionInventories –Chapter 4.0We recommend that the State review the data, specifically the point sources and to spotcheck the other source categories, in Tables 4-9, 4-10, 4-11 and 4-12. It appears that thedifference in tons and percentages between the 2002 and 2009 data do not match thatderived from Tables 4-3, 4-4, 4-7 and 4-8.We reviewed the tables referenced in EPA’scomment and found one error in Table 4-9.There were minor discrepancies in numerousother entries, but these are explainable asminor round-off errors (tables were prepared9Table 1: Comments Submitted by EPA#SectionCommentResponseusing Excel spreadsheets, which use, but donot display, all decimal points in thenumbers).11. Initial andBoundaryConditionsDataA reference for more details on the GEOS-CHEM global simulation model that was usedto develop CMAQ boundary conditions should be provided. Attachment C does notprovide very much information.GEOS-CHEM report is added asAttachment L.12. ControlMeasures –Chapter 5.0The SIP Narrative states on page 65 thatwhen the heavy-duty gasoline and dieselhighway vehicle standards are fully implemented, 90 and 95 percent reductions inparticulate matter and NOXemissions. The section does not provide a year when fullimplementation of the program will occur. So it is unclear if full implementation occursin 2009 and these reductions were used in the modeling. Or, if it is fully implementedafter 2009 what percentage was relied upon in the attainment modeling.The SIP was revised to indicate fullimplementation of mobile source reductionsby 2030.13. EpisodeSelection forthe PM2.5AttainmentDemonstrationIt is unclear how days (e.g., number of days per quarter) were chosen to develop therelative reduction factors for the attainment test. At the top of page 149 of this section,the SIP Narrative implies that sufficient days(at least 5 days, preferably more than 15days) should be used in the air quality modeling to develop and attainment strategy. TheEPA modeling guidance on page 149 recommends 15 or more total days per quarter, not15 or more days with monitored data should be used in the modeling and to develop therelative reduction factors. Therefore, in addition to citing what the guidance states, theSIP should discuss specifics on how this guidance was actually used in the SIP modelingfor the Knoxville NAA.The language in the SIP was revised to statethat “Sufficient days should be availablesuch that the modeled attainment testapplied at each monitor violating theNAAQS is based on multiple days.” Airquality modeling was performed for theentire year, but the baseline period waschosen to ensure thatsufficient monitoringdata was available to conduct the modeledattainment test.14. SIP NarrativeAnalyses using the Classification and Regression Tree (CART) and collaborative effortswith other states are mentioned in this section. The analyses were used to assess therepresentativeness of the 2002 episode modeling year. The reference for these analysesor summaries of these efforts should be included or discussed in the SIP Narrative.CART analysis report is added asAttachment K15. ModelPerformanceModel performance for the development of the meteorological files created through theuse of the MM5 model is not addressed in the SIP Narrative or any of the attachments.Model performance for the air quality model is addressed. The SIP should discussmodel performance for the MM5 model and the Knoxville area.MM5 Report is added as Attachment J.10Table 1: Comments Submitted by EPA#SectionCommentResponse16. Data Archivaland Access- On page 106, the SIP states that the largedata files associated with the many steps ofthe modeling process will be archived and maintained by the modeling contractors(ENVIRON and AG). It is unclear how longthese data will be accessible after fundingfor the ASIP grant expires. Also the SIPdoes not provide a primary state contact forassessing any of the SIP data files. In addition, the SIP Narrative references Section 9.1of Attachment C which provides more information but also implies uncertainty in howthis data will be archived. It states that decisions on how to store this data (either on aVisibility Improvement – State and Tribal Association of the Southeast (VISTAS) orASIP website) had yet to be determined. Finally, it is unclear how data files associatedwith the development of the MM5 meteorological modeling will be archived, maintainedand accessed. The archival, maintenance and accessof this data is not addressed. It isour understanding that this part of the attainment modeling was performed outside of theASIP process by another contractor (i.e., not ENVIRON or AG).The language in the draft SIP will beupdated to indicate that the ASIP workgroup is archiving all modeling files, MM5,SMOKE, and CMAQ on external drives,and will send an external drive to each Statewith all the supporting modeling data. Aprimary contact will be provided in theRevised SIP.17. Footnotesa.It appears that a lack of a 2002-2004DV prevents the state from adding theLoudon County monitor data to Table 1-1. It is not clear why this would present aproblem since the data was used in the attainment test and results presented inAttachment G.b.Footnote 3 states that Section 9 would discuss attainment at the 47-105-0108Loudon County and 47-093-1013 Knox County monitors in the weight ofevidence. However, this discussion does not appear to be in section 9.0.(a) The monitor was removed from Table1-1 to avoid confusion, because inclusion ofdesign values in this table suggested that themonitor would need to be included in theattainment test. As EPA notes elsewhere,this monitor should be included in theweight of evidence discussion. The revisedSection 9.0 of the SIP provides additionaldetails about this monitor.(b) Discussion for 47-105-0108 will beadded as indicated in the previouscomments. The statement that 47-105-0108will be discussed in Section 9.0 is an error.As the revised footnote indicates, thismonitor collected less than three years ofdata and was not operational between 2004and 2007.18. Attachment B“Attachment B – Final” provides detailed information on the emissions inventory forammonia, direct primary, sulfur dioxide and nitrogen oxide emissions, especially for theFacility names are provided in revisions toTables 4-5 and 4-6 of the SIP.11Table 1: Comments Submitted by EPA#SectionCommentResponsepoint sources. We recommend that in addition to the SCC description that is provided,the name of the stationary point source be added to these charts. At a minimum, thiscould be provided for the counties in the Knoxville nonattainment areas.19. Attachment G There are no monitor names for the Tennessee data in Figure 4-11. We recommend thatthe monitor names be added to the data in this figure.Figure 4-11 was corrected to show themonitor names.20. Attachment G Section 4.4 describes the steps used to apply the speciated model attainment test(SMAT). It does not provide any data used in the development of this test for the FRMmonitors.SMAT data is included in Attachment O(2009 Base G4a PM2.5Projections).12Table 2: Comments Submitted bythe Tennessee Environmental Council#SectionCommentResponse1. SIP NarrativeThe proposed State Implementation Plandoes not adequately protect thehealth of the residents of Anderson, Blount, Knox, and Loudon Countiesalong with a portion of Roane County.The proposed SIP demonstrates attainment bythe federally mandated attainment date.2. SIP NarrativeWe challenge the assessment that the NOXemissions from inside the stateof Tennessee are not significantly contributing to the PM2.5nonattainmentin the Knoxville area and request EPA require TDEC to submit anaddendum to the PM2.5SIP.See response to EPA comment #1.3. SIP NarrativeEPA’s projections in 2006 expected the Knoxville area to be innonattainment in 2010 for PM2.5, even after all federal measures(CAIR/CAMR/CAVR) were put in place.We do not see a basis thatTDEC assumes that things will differ from the EPA projections.EPA’s projections under the CAIR modelingprojected a design value for 2010 of 16.16μg/m3, while the current design value for 2004-2006 for the controlling monitor in Knoxville isalready below that level at 15.6 μg/m3.4. SIP NarrativeWe disagree with the proposed assertion in Option 1 that “NOXemissionsfrom sources in the State do not significantly contribute to PM2.5nonattainment in the Knoxville area.” There are major sources of NOXremaining in the state.Tennessee does not assert that there are notlarge sources of NOXin the State. Sensitivitymodeling and sample speciation demonstratethese sources do not have a large impact on theformation of PM2.5.5. SIP NarrativeTVA’s coal-fired power plants, while much more NOX-controlled thanksto the SIP call, still produce significant tons of NOXannually because ofseasonal use of SCRs.In order to meet the requirements of CAIR,TVA will operate many SCRs year-roundbeginning in 2009.6. SIP NarrativeTennessee has taken some steps to address the existing fleet, but moreneeds to be done with this clearly in-state source.The projected inventory indicates all onroadmobile sources will contribute approximately2.5% of the directly emitted PM2.5in 2009. Inaddition, Tennessee has a Diesel WorkingGroup and an Alternative Fuels Working Groupestablished to help address this concern.7. SIP NarrativeWe believe that Tennessee should implement additional controls for thefollowing reasons:•Meeting the PM2.5standard will not protect the health ofour citizens with an adequate margin of safety. TheClean Air Scientific Advisory Committee (CASAC)EPA established the NAAQS for PM2.5at 15μg/m3to protect the public’s health; whichTennessee is required to meet. AttainmentDemonstration modeling and weight ofevidence projects Tennessee will attain theNAAQS for PM2.5as required by EPA.13Table 2: Comments Submitted bythe Tennessee Environmental Council#SectionCommentResponsestated “there is clear and convincing evidence thatsignificant adverse human-health effects occur inresponse to short term and chronic particulate matterexposures at and below 15 micrograms per cubic meter,the level of the current annual PM2.5standard”. CASACstrongly recommended that the standard be reduced to13 to 14 micrograms per cubic meter,•CASAC’s position was fully supported by the AmericanMedical Association, the American Thoracic Society,the American Lung Association, the AmericanAcademy of Pediatrics, the American College ofCardiology, the American Heart Association, theAmerican Cancer Society, the American Public HealthAssociation, and the National Association of LocalBoards of Health.•The EPA states that “Numerous scientific studies havelinked particle pollution exposure to a variety ofproblems including: increased respiratory symptoms,such as irritation of the airways, coughing, difficultybreathing, decreased lung function, aggravated asthma,development of chronic bronchitis, irregular heartbeat,nonfatal heart attacks, andpremature death in peoplewith heart or lung disease.•Due to increased temperatures and drought, TVAprovided record peak levels of electricity last summer,depending on coal fired power plants which are theprimary source of particulate matter in Tennessee air.Models used to predict future levels of PM2.5, may notfully reflect the possibility ofcontinued warming and itseffect on electrical demand.8. Attachment I: LimitedRACT AnalysisTo protect the health and quality of life of its citizens, Tennessee shouldgo beyond the “do nothing” response in its PM2.5State ImplementationTennessee acknowledges that our plan proposesto attain the NAAQS based on existing rules,14Table 2: Comments Submitted bythe Tennessee Environmental Council#SectionCommentResponsePlan. The measures identified in Attachment I or equivalent should beimplemented. By setting a goal of 12 micrograms per cubic meter asrecommended by the American LungAssociation, Tennessee can take aleadership position for public health.but we disagree that the SIP proposes a “donothing approach to regulation of PM2.5.Specifically, we note that Tennessee hasadopted the Federal CAIR rules, which requiresome of the largest emissions reductions of anyState or Federal regulations.Tennessee is required to consider ReasonablyAvailable Control Technology (RACT) andReasonably Available Control Measures(RACM), as listed in Attachment I of the SIP,and to adopt RACT/RACM if those measureswould advance the attainment date. Ouranalysis of these rules indicates that none of themeasures listed in Attachment I could beimplemented sufficiently early to advance theattainment date.To meet the requirements of the new 8-HourOzone NAAQS, and EPA’s forthcoming PM2.5NAAQS review, these sources may need to belooked at again in thefuture to determine ifadditional reductions are necessary to achieveattainment for the new standards.15Table 3: Comments Submitted by Bass, Berry, & Simms on behalf of Bowater#SectionCommentResponse1. Attachment IAttachment I of the PM2.5SIP contains language which indicates thatmodeling is proceeding with a source that appears to be Bowater. There isno reference to this in the main body of the SIP. If modeling is notproceeding, this language should be deleted. If modeling is proceeding,Bowater has significant concerns that have not been addressed.The referenced language has been amended tonote the following: 1) additional modelingwas not conducted, but several ASIP States,including Tennessee conducted impactanalyses for point sources adjacent tononattainment areas; and 2) impact analyseswere conducted for more than one Tennesseesource. The results ofthe impact analysis,showing a maximum contribution of 0.08μg/m3, are noted in the Attachment.16Table 4: Comments submitted by TDEC-APC#SectionCommentResponse1. Section 2.0 In Section 2.0, “non attainment” is written as two separate words in the firstparagraph. We will change this to “nonattainment” (one word).Corrected2. Section 10.0, NOXAddendum, other portionsof SIP referencing add-oncontrols at TVA KingstonSection 10.0 states thatTennessee is claiming SO2reductions from units 1through 4 at the TVA Kingston FossilPlant as contingency measures forPM2.5attainment in the Knoxville area, based on the installation and startupof a wet scrubber at these units by December 2009. These statementsshould read that Tennessee is claiming SO2reductions from TVA Kingstonunits 6 through 9 as contingency measures. All references in this section tounits 1 through 4 at TVA Kingstonwill be replaced with languagereferencing the correct units at this facility. Since the level of emissionsfrom units 6 through 9 is not the same as emissions from units 1 through 4,we will recalculate the amount of SO2reductions available for contingencymeasures. These changes will not affect our determination that SO2reductions from Kingston fossil plant are adequate for contingencyplanning purposes.The NOXaddendum to the PM2.5SIP contains additional language oncontingency measures, and that section contains the same error referencedabove. If we find that it is necessary to adopt the NOXaddendum as part ofthe SIP, we will correct all referencesto TVA Kingston Units 1 through 4,as noted above, as well as all calculations developed for contingencyplanning purposes.Corrected3. Attachment D Notes from the most recentInteragency Consultation (IAC) call were addedto Attachment D of the SIP. This call was held subsequent to the publichearing version of the SIP documentation.No further action required.17Table 4: Comments submitted by TDEC-APC#SectionCommentResponse4. Table 4-5 A review of Table 4-5 indicates two errors in the Loudon County pointsource emissions inventory:a.The ASIP emission inventory indicates that SO2emissions fromMonterey Mushroom, a source in Loudon County, were 390 tonsin 2002, with similar emissions in 2009. Review of the permitfiles for this source indicate that from 1996 to 2005, allowable SO2emissions from this facility were 109.9 pounds per hour but only78.6 tons/year due to a Federally enforceable restriction on fuelusage. The most recent operating permit for this source (issued5/18/07) indicates a decrease in allowable SO2emissions to 52.8tons. Allowable emissions for this source appear to be well belowthe value listed in the inventory.b.SO2emissions for Viskase do not appear to have been included inthe ASIP emission inventory. Tennessee’s NEI facility summaryindicates that SO2emissions for this facility were 257 tons/year in2002.In order to avoid potential conflictsbetween the information reported in theSIP and the information contained in theASIP emission inventory Table 4-5 of theSIP was not corrected. Since the twofacilities are located relatively close toeach other (about 4 miles) and becausecombined emissions from the twofacilities are of similar magnitude to theemissions reported for the single sourcein Table 4-5, we believe that theuncertainty that this error introduces intothe modeling results will be minimal.5. NOXAddendum The NOXaddendum indicates that RACT-BACT-LAER (RBLC)determinations are attached. However,an attachment was not provided.The prehearing draft documented RBLCidentification numbers for the applicabledeterminations. RBLC determinations areavailable from EPA’sRBLC Clearinghouse.References to attached copies of thedeterminations will be removed.6. General Comment At U. S. EPA’s request, the public comment period was extended publichearing until March 31, 2008. The extension of the public comment periodwas read into the record at theMarch 25, 2008, public hearing.No response required.

# 18 

# Appendix P-1

Air Quality Monitoring Data for 24-Hour

PM 2.5 

# NAAQS19CountyAIRS IDAddressDesign Values for 24-hour PM2.5NAAQS2000-20022001-20032002-20042003-20052004-2006

98th Percentile DV Qtrs >= 11 Samples Qtrs >= 75% Data Rec. 98th Percentile DV Qtrs >= 11 Samples Qtrs >= 75% Data Rec. 98th Percentile DV Qtrs >= 11 Samples Qtrs >= 75% Data Rec. 98th Percentile DV Qtrs >= 11 Samples Qtrs >= 75% Data Rec. 98th Percentile DV Qtrs >= 11 Samples Qtrs >= 75% Data Rec.Blount 47-009-00112007 SequoyahAvenue35 11 933 12 1132 12 1233 12 1230 12 12Knox 47-093-00281000 Francis Road37 12 1234 12 1031 12 1033 12 735 12 7Knox 47-093-10131403 DavannaStreet41 2 236 4 431 4 426 2 219 0 0Knox 47-093-10171613 VermontAvenue39 12 1135 12 1234 12 1234 12 1033 12 10Knox 47-093-10204625 Mildred Drive38 12 1134 12 1132 12 1132 12 1133 12 10Loudon 47-105-0108130 Webb Drive35 2 132 6 533 10 931 12 12Roane 47-145-00041002 N. Roan Street36 12 1230 12 1228 12 1230 12 1230 12 12CountyAIRS IDAddress98th Percentile by Year, 24-hour PM2.52000200120022003200420052006Blount 47-009-00112007 Sequoyah Avenue46 30 30 39 27 33 31Knox 47-093-00281000 Francis Road45 36 29 36 29 34 41Knox 47-093-10131403 Davanna Street41 32 19Knox 47-093-10171613 Vermont Avenue46 37 34 35 31 36 32Knox 47-093-10204625 Mildred Drive43 37 33 32 31 35 32Loudon 47-105-0108130 Webb Drive35 29 34 30Roane 47-145-00041002 N. Roan Street48 34 27 28 28 33 29

# 20 

# Appendix P-2

PM 2.5 

# Contribution Assessment

Knoxville, TN

# 21 Knoxville, TN PM 2.5 

# Contribution Assessment

Speciated PM 2.5 

# data from Speciated Trend Network (STN) monitors in the Knoxville

area indicate that the predominant contributions to PM 2.5 

# mass are organic carbon and

ammonium sulfate. Three monitors in the Knoxville area have 2002 design values

greater than the annual standard for PM 2.5 

# of 15 μ g/m 3 

# (Figure 1, left bar).

Ammonium sulfate is lowest in the winter a nd highest in the summer (Figure 2). Point

source SO 2 

# emissions are the predominant precurs ors for ammonium sulfate. ASIP

inventories and air quality modeling indicate that installation of SO 2 

# controls (scrubbers)

for electric utilities under EPA’s Clean Air Interstate Rule (CAIR) will significantly

reduce PM 2.5 

# levels in the Knoxville area by 2009 (F igure 1, middle and right bars).

Organic carbon levels vary across the year (Figure 2). A combination of sources

contribute to organic carbon mass, includ ing wood burning, vegetative emissions, and

fossil fuel combustion by industrial point sources, on road vehicles, and non road

engines, and meat cooking. Elevated levels in the winter are lik ely due to wood burning

(from forest fires, prescribed fires, land cl earing, agricultural bur ning, or residential,

commercial or industrial wood use). Elevat ed levels in summer are likely due to

vegetative carbon emissions. Contributions from fossil fuel combustion (gasoline and

diesel) are greater in urban areas such as Knoxville than in rural areas.

Figure 1: 2002 PM 2.5 

# Mass by Species Component from the STN and 2009 CMAQ

Air Quality Model Projections

Tennessee 2002 Design Value (Left) and

2009 base G2 12km projected DVF (Middle) and

2009 base G2 36km projected DVF (Right)

0 2 4 6 8 10 12 14 16 18Blount-0011Davidson-0023Dyer-0004Hamilton-4002Knox-0028Knox-1017Knox-1020Maury-2007McMinn-1002Montgomery-1009Putnam-0001Roane-0004Shelby-0014Shelby-0038Shelby-0047Shelby-1004Sullivan-1007Sumner-0007



# Tennesseeug/m3 

# PBW

NH4

Crust a

EC

OC

NO3

SO4

# 22 Knoxville, TN (47-093-1020)

2006 STN Mass

Ann. Avg. = 12

0 10 20 30 40 50

J

- 06

F - 06 M- 06 A-0 6 M-06

J - 06

J - 06 A-0 6 S- 06 O-06

N - 06

D -06Mass (μg/m3)



# SO4 NH4 NO3 POM LAC Soil Sea Salt



# Figure 2: Contributions of PM 2.5 

# Components to Total Measured Mass at

Knoxville, TN STN Site for 2006.

Ammonium nitrate is a very small contributor to PM 2.5 

# mass in the warmer months and a

somewhat larger contributor in the cooler wi nter months, but always less important than

organic carbon and ammonium sulfate. Ground le vel and point sources of nitrogen oxides

and agricultural emissions of ammonia are the primary precursors for ammonium nitrate.

Elemental carbon (also called light absorbing carbon) and fine soil are minor contributors

to PM 2.5 

# mass. Fossil fuel combustion and wood burning are the most important

contributors to elemental carbon. Fine soil mi ght be from construction or agricultural

activities or windblown dust.

Georgia Tech ran emissions sensitivities in the CMAQ regional air quality model using

the VISTAS 2009 Base D inventory and episode s selected in summer (Jun 1-Jul 10) and

late fall (Nov 19-Dec 19) 2002 (Figures 3-6). Th ese model runs indicate that the greatest

reductions in PM 2.5 

# mass would be accomplished by reducing SO 2 

# emissions from

electric utilities and indu strial point sources. SO 2 

# reductions in seve ral southeastern

states, not just the K noxville area, would be be neficial in reducing PM 2.5 

# in Knoxville.

# 23 Figure 3: CMAQ Modeled Changes in PM 2.5 

# Mass for Knoxville STN monitor 1020,

30% Reduction of 2009 ASIP Base D Em issions for Various Emissions Source

Categories - Summer Modeling Period June 1- July 10, 2002

Figure 4: CMAQ Modeled Changes in PM 2.5 

# Mass for Knoxville STN monitor 1017,

3 0% Reduction of 2009 ASIP Base D Emissions for Various Emissions Source

Categories - Summer Modeling Period June 1- July 10, 2002 

# Knoxville_2, TN (470931017) Summer

-1.20

-1.00

-0.80

-0.60

-0.40

-0.20

0.00

0.20

S

O2 _ EG

U

SO

2_

non E GU NOx_Gr o und

N

Ox

_P

o int N H

3 VOCs Primary Carbon_

G

ro

u nd

P

r ima r y C a rbo n _

P oin

t Pr im

ar

y Ca rb

on _

FiresΔPM2.5(μg/m3) 

# Bio. VOC

Anthro. VOC

Boundary

MRPO

M-VU

CEN

VISTAS

WV

VA

TN

SC

NC

MS

KY

GA

FL

AL 

# Knoxville_2, TN (470931017) Summer

-1.20

-1.00

-0.80

-0.60

-0.40

-0.20

0.00

0.20

S

O2 _ EG

U

SO

2_

non E GU NOx_Gr o und

N

Ox

_P

o int N H

3 VOCs Primary Carbon_

G

ro

u nd

P

r ima r y C a rbo n _

P oin

t Pr im

ar

y Ca rb

on _

FiresΔPM2.5(μg/m3) 

# Bio. VOC

Anthro. VOC

Boundary

MRPO

M-VU

CEN

VISTAS

WV

VA

TN

SC

NC

MS

KY

GA

FL

AL 

# Knoxville_1, TN (470931020) Summer

-1.20

-1.00

-0.80

-0.60

-0.40

-0.20

0.00

0.20

SO2 _ E GU

S

O2 _ n o n EG

U

NOx _ G

ro

u n d

NO

x _

P

o int N H

3

V OC s

P ri

mary C

arbo n _

Gro u n d

Primary Carbon_

P

o in

t Pri ma

ry C a rb

o n _

Fir

e sΔPM2.5(μg/m3) 

# Bio. VOC

Anthro. VOC

Boundary

MRPO

MANE-VU

CENRAP

VISTAS

WV

VA

TN

SC

NC

MS

KY

GA

FL

AL 

# Knoxville_1, TN (470931020) Summer

-1.20

-1.00

-0.80

-0.60

-0.40

-0.20

0.00

0.20

SO2 _ E GU

S

O2 _ n o n EG

U

NOx _ G

ro

u n d

NO

x _

P

o int N H

3

V OC s

P ri

mary C

arbo n _

Gro u n d

Primary Carbon_

P

o in

t Pri ma

ry C a rb

o n _

Fir

e sΔPM2.5(μg/m3) 

# Bio. VOC

Anthro. VOC

Boundary

MRPO

MANE-VU

CENRAP

VISTAS

WV

VA

TN

SC

NC

MS

KY

GA

FL

AL

# 24 Figure 5: CMAQ modeled changes in PM 2.5 

# mass for Knoxville STN monitor 1020,

30% Reduction of 2009 ASIP Base D Em issions for Various Emissions Source

Categories - Late Fall Modeling Period November 19-December 19, 2002

Figure 6: CMAQ modeled changes in PM 2.5 

# mass for Knoxville STN monitor 1027,

30% Reduction of 2009 ASIP Base D Em issions for Various Emissions Source

Categories - Late Fall Modeling Period November 19–December 19, 2002. 

# Knoxville_2, TN (470931017) Winter

-1.40

-1.20

-1.00

-0.80

-0.60

-0.40

-0.20

0.00

0.20

SO2_EGU

SO2_ nonEGU

NOx_ Gro un

d

NOx _Po i nt NH3 VOCs PC_Ground PC_Point

P C_Fir esΔPM2.5(μg/m3) 

# Bio. VOC

Anthro. VOC

Boundary

MRPO

M-VU

CEN

VISTAS

WV

VA

TN

SC

NC

MS

KY

GA

FL

AL 

# Knoxville_2, TN (470931017) Winter

-1.40

-1.20

-1.00

-0.80

-0.60

-0.40

-0.20

0.00

0.20

SO2_EGU

SO2_ nonEGU

NOx_ Gro un

d

NOx _Po i nt NH3 VOCs PC_Ground PC_Point

P C_Fir esΔPM2.5(μg/m3) 

# Bio. VOC

Anthro. VOC

Boundary

MRPO

M-VU

CEN

VISTAS

WV

VA

TN

SC

NC

MS

KY

GA

FL

AL 

# Knoxville_1, TN (470931020) Winter

-1.40

-1.20

-1.00

-0.80

-0.60

-0.40

-0.20

0.00

0.20

S

O2 _ E GU

SO

2 _

nonEGU

NOx_ Gro u n d

NO

x _

P

o i nt N H3

V OC s

PC _ Gr

o

u n d PC_Point PC_FiresΔPM2.5(μg/m3) 

# Bio. VOC

Anthro. VOC

Boundary

MRPO

M-VU

CEN

VISTAS

WV

VA

TN

SC

NC

MS

KY

GA

FL

AL 

# Knoxville_1, TN (470931020) Winter

-1.40

-1.20

-1.00

-0.80

-0.60

-0.40

-0.20

0.00

0.20

S

O2 _ E GU

SO

2 _

nonEGU

NOx_ Gro u n d

NO

x _

P

o i nt N H3

V OC s

PC _ Gr

o

u n d PC_Point PC_FiresΔPM2.5(μg/m3) 

# Bio. VOC

Anthro. VOC

Boundary

MRPO

M-VU

CEN

VISTAS

WV

VA

TN

SC

NC

MS

KY

GA

FL

AL

# 25 In both summer and winter th e model projects some benefits from reducing local sources

of primary carbon from ground (on road vehicl es, off road engines, area sources) and

point (industrial and electric utility) sources and from fire emissions. Because biogenic

emissions dominate Volatile Organic Carbon (VOC) emissions, the model indicates little

benefit in winter and no benefit in summe r of reducing anthropogenic VOC emissions.

The model projects very little benefit of reducing emissions of nitrogen oxides from

either ground or point sources in Tennessee. In the southeast, ammonium nitrate levels

are limited by availability of ammonia, so reducing ammonia emissions would be a more

effective strategy to reduce am monium nitrate than reducing nitrogen oxide emissions.

Finally, the model shows that SO 2 

# emissions from outside the ASIP 12 km modeling

domain (labeled as “boundary” in Figures 2-5) have a comparable contribution to PM 2.5 

# as local sources of primary carbon. These re sults demonstrate the regional contribution

from SO 2 

# point sources located several st ates away from Knoxville.

In summary, SO 2 

# reductions from electric utilities a nd industrial point sources are likely

to be most effective in reducing PM 2.5 

# in Knoxville. From the mobile sector, reductions

of primary carbon from local sources would be more effective than reductions of either

VOC or NO X



# .

Prepared August 10, 2007 by

Pat Brewer, Technical Coordinator

# 26 

# Appendix P-3

Public Comments

# 27 

# Appendix P-4

Public Notice Information

# 28 

# Appendix P-5

Board Order