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, Berry, & Simms on behalf of Bowater ............ 15

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

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

Appendix P-2: PM2.5 Contribution Assessment, Knoxville, TN 

Appendix P-3: Public Comments 

Appendix P-4: Public Notice Information 

Appendix P-5: Board Order 
3 

Table 1: Comments Submitted by EPA # Section Comment Response 1. NOX

Insignificance 

EPA has evaluated the modeling and technical support that Tennessee has provided in its proposed demonstration that NOx emissions in Tennessee do not significantly contribute to PM2.5 concentrations in the Knoxville PM2.5 nonattainment area. Upon careful 

evaluation, EPA does not believe that the demonstration provided in Tennessee's submission supports a finding that NOx is an insignificant contributor to ambient PM2.5

concentrations in the Knoxville area. The demonstration indicates that the level of impact of NOx emissions to the ambient PM2.5 concentrations for the Tennessee 

nonattainment areas ranges from approximately 0.60 - 0.84 μg/m3. In many instances, contributions to ambient PM2.5 at such a level could alone be the difference between 

attainment and nonattainment, so it is not appropriate to consider such a level of contribution per se “insignificant." Moreover, this level of contribution to ambient PM2.5 levels in a nonattainment area is 

well above the 0.2 μg/m3 level of contribution that EPA has previously determined was appropriate 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 the benefit of downwind states. The contribution threshold of CAIR is based upon Clean Air Act section 110(a)(2)(D) and the facts of that rule, and is therefore not a bright line test of what constitutes "significant" contribution for purposes of 40 CFR section 51.1002(c)(2). Nevertheless, we consider it inappropriate for a downwind state with a 

nonattainment area to treat local sources of NOx emissions as an insignificant contributor to local nonattainment, and thereby decline to address NOx emissions in its SIP, when the level of contribution is well above the threshold which obligated upwind states to restrict NOx emissions because of impacts on downwind nonattainment areas through interstate transport. After evaluating all of the evidence presented in your demonstration, we believe that this level of impact on PM2.5 concentrations from NOx emissions is significant and therefore 

that NOx should be treated as an attainment plan precursor for PM2.5 in the Tennessee 

nonattainment area. 

Tennessee will incthe NOX addendu

following languagSection 3.0. “EPA has indiccontinues to have 

insignificance deminformation presemay not be supresumption of NOprecursor pollutincorporate the Attachment Q (

enforceable part oobtains sufficient overturn the 

significance in thwill be submitted will submit an arequest removal provisions.” 
4 

Table 1: Comments Submitted by EPA # Section Comment Response 2. General 

Comments 

a. 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 was applied for the Knoxville annual PM2.5 SIP. We attempt to offer 

recommendations and suggestions for additional data and analyses that should be discussed and submitted. 

b. Adding subsection numbers to the SIP is recommended. 

(a) Specific comm(b) Subsection nufinal version. 

3. General 

Comments 

Section 1.0 of the SIP Narrative states that EPA designated the area as nonattainment for the annual PM2.5 National Ambient Air Quality Standard (NAAQS). Those 

designations, however, did not specify whether they were for the annual or daily standard. Section 51.1007(a) of the PM2.5 Implementation Rule requires that “[f]or any 

area designated as nonattainment for the PM2.5 NAAQS, the State must submit an 

attainment demonstration showing that the area will attain the annual and 24-hour 

standards as expeditiously as practicable.” [emphasis added] Although Tennessee has no nonattainment areas for the 1997 24-hour PM2.5 NAAQS, this standard should be 

addressed as well in order to meet the requirement of the rule. We recommend adding a table similar to Table 1-1 showing the 24-hour design values for the same periods and adding a statement regarding the compliance status of these areas with the 1997 24-hour PM2.5 NAAQS and the fact that measures for achieving attainment with the annual 

standard have a co-benefit for the 24-hour standard. 

Monitoring data NAAQS are presethis attachment. that all monitnonattainment are hour PM2.5 NAAQ

4. General 

Comments 

Please correct the typographical error, at the bottom of Page 1 of Attachment I, stating “Error! Reference source not found.” 

Corrected 

5. Speciated 

Modeled Attainment Test (SMAT) 

a. There is no discussion on how the base or current design values used in the 

modeled attainment test were developed. We recommend expanding the discussion on page 101 and adding a table that contains the observed mean quarterly PM2.5 baseline concentrations for the monitors that were used in the 

Speciated Monitor Attainment Test (SMAT). The text would also discuss how these data were developed. This would complement the data in Table 8-6 and aid in the discussion of how Table 8-6 data were developed. 

b. The fractions would be applied to the observed quarterly mean PM2.5 values 

presented in the table we suggested to be added in the above comment to determine the quarterly component specific concentrations in Table 8-6. 

Items (a), througincorporating exte8.0. See section 8additional details. Additional comme47-093-1013 was SIP by noting that from April 2002 tdown until March would not be help
5 

Table 1: Comments Submitted by EPA # Section Comment Response 

c. The SMAT section could contain a table with the quarterly species fractions 

and the degree of sulfate neutralization (DON) data to show how this part of the attainment test was developed. It would contain the data needed to generate the data in Table 8-6). 

d. There is no discussion on how the FRM monitors were speciated. The SIP 

Narrative (see bottom of page 101) mentions how this should be accomplished according to the guidance, but it does not discuss specifically how this was accomplished for the Knoxville nonattainment area. 

e. We recommend that discussions and tables on the following be added to the SIP 

Narrative on the SMAT documentation before the discussion on Table 8-9. Having the following tables and the additional ones mentioned above should complete in greater detail how the SMAT was applied in the Knoxville NAA. 

i. Quarterly PM2.5 component RRFs. 

ii. Quarterly mean PM2.5 mass estimates for 2009

iii. Estimated annual mean 2009 PM2.5 mass compared to the baseline 

design values and provide the 2009 non-blank mass, blank value and 2009 annual design value. 

f. Table 8-9: 

iv. The 2009 projected DV for the 47145004 FRM monitor is slightly 

different 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 monitor 

should be added to this table since it has a projected DV presented in Attachment G. Maybe, caveats on the completeness of the data could be added as a footnote using language similar to that provided in Attachment E. 

g. The “Defining RRFs Based on Modeling Results “Near” the Monitor” section 

and the second sentence in section 4.6 state how EPA guidance defines “near” the monitor. However, these sections do not clearly stated how data from a grid of nine cells from the 12km CMAQ modeling was used to determine the base 

as part of the attaito the lack of base
6 

Table 1: Comments Submitted by EPA # Section Comment Response 

and future concentrations in the relative reduction factor analysis. 

6. Weight of 

Evidence 

a. 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 controlling violating Vermont Avenue monitor to consistently hover around 15.6 μg/m3. 

Several other monitors also have shown consistent NAAQS violations, but the trend is not downward. Therefore, it is important for the weight of evidence analysis to document the specific emission reductions that will occur in the next two ozone seasons that will achieve the 0.9 μg/m3 improvement in air quality 

for attainment. 

b. The change or improvement in PM2.5 impact that an emission reduction would 

cause could be added to the information in Table 9.4 

c. The Loudon monitor was not used in the attainment test but it has recent annual 

PM2.5 NAAQS violations. However, we believe that the existing modeling data 

could still be used to address the Loudon County. A RRF could be developed from the modeling similar to that performed at the other FRM monitors. The RRF could be used to show if comparable levels of reductions are expected at the Loudon FRM site. 

d. The State appears to rely heavily on sulfur dioxide (SO2) reductions that are 

expected to occur by 2009 at two Tennessee Valley Authority (TVA) power plants to help achieve attainment. Since the recent air quality has not shown a downward and if the 2005-2007 design values are above the PM2.5 NAAQS, we 

encourage the State to highlight those mandatory and voluntary controls and reductions that are expected to occur in 2008 and by late spring/early summer months of the 2009 season. 

 (a) We believe t9-4 is correct: Knoxville area dtrend in ambient P

2006. We note in value at the contby about 25% betw2006. This trend 2-6 of the SIP. 

concentrations havlast 2-3 years, we changes in utility 

uniformly decline Tables 5-1 and narrative). The between monitor

from 2004-20concentrations in decline in utility Sas coal-fired boCAIR complianceSee Table 9-8 of reductions at TVA Tennessee can documentation in Planning Moddocumentation undergoing enginnecessary to provfuture attainment. 
7 

Table 1: Comments Submitted by EPA # Section Comment Response 

(b) Emissions sensin Appendix P-2 emission sensitivitthe impact of SO2 

various source caneighboring Statimpact of contrfacilities would modeling work. (c) See Section additional informmonitor. (d) See revisinstallation date aTVA Bull Run. 

7. SIP Narrative Table of Contents - We recommend that the descriptive name be added to the attachment 

file names. For instance, “Attachment G Final” would become “Attachment G – Attainment demonstration.” This would help the reader to locate an attachment file to 

review without having to look at the Table of Contents to see what it contained or addressed. 

File names will be 

8. SIP Narrative Table 1-1 on page 2 lists the design values (DV) for five of the six Federal Reference 

Method (FRM) monitors in the Knoxville annual PM2.5 nonattainment area (PM2.5

NAA). 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 did not become operational until 2003, its data still could be included in the table. The monitor will have to be used to determine attainment whenever the State requests redesignation to attainment and because the monitor’s design 2004-2006 DV is at 15.3 μg/m3. 

 The monitor was to avoid confusidesign values in thmonitor would neattainment test. monitor is address9.0 (Weight of Ev

9. Emission 

Inventories – Chapter 4.0 

a. With the exception for Roane County, the overall county point source actual 

totals for Anderson, Loudon, Knox and Blount counties in Table 4-5 do not match the 2002 actual SO2 emission totals for point sources in Table 4-3. It is 

unclear why this difference exists or if the difference is because the point 

(a) The point soincluded in Attachsources, while thincludes only poin
8 

Table 1: Comments Submitted by EPA # Section Comment Response 

source cut-off used to develop point sources in Table 4-3 is lower than 100 tons per year. Also, if the point source cut-off is less than 100 tons per year, please discuss how area sources are determined for stationary sources. The tables should probably be revised to correct the differences. 

b. With the exception for Roane and Anderson Counties, the overall county point 

source actual totals for Loudon, Knox and Blount counties in Table 4-6 do not match the 2002 actual SO2 emission totals for point sources in Table 4-4. The 

tables should be revised to correct the differences. 

c. It is believed that the SO2 and PM2.5 emissions estimates presented in Tables 4-

7 and 4-8, respectively, represent the level of emissions that were modeled in the annual PM2.5 emission control strategy for the Knoxville nonattainment area 

and which are needed to achieve attainment in 2009. However, this is not clearly stated in the text preceding these tables. We recommend that the text clearly discuss this comment. 

d. Since SO2 and PM2.5 typical and actual emission totals are provided in Tables 

4-3 and 4-4, respectively, for the EGU emissions, it is unclear if the 2009 EGU emission totals in Table 4-7 and 4-8 represent actual or typical projected emissions. The text and the table should state which type of totals are presented. The text above these tables could also refer the reader to the section of the SIP Narrative that discusses the controls that were used to develop the 2009 emissions. 

e. We recommend that the facility name should accompany the SCC description 

in Tables 4-5 and 4-6 for point sources. If this is not possible, the SIP could contain a list of the point sources with their PM2.5 precursor pollutants for the 

nonattainment counties. 

100 tons/year of S

 (b) See response t (c) Added a senare the level odemonstrate attain (d) Added clartables to indicate inventories were typical emissions sentence was addrequirements in Se(e) Facility names and 4-8. 

10. Emission 

Inventories – Chapter 4.0 

We recommend that the State review the data, specifically the point sources and to spot check the other source categories, in Tables 4-9, 4-10, 4-11 and 4-12. It appears that the difference in tons and percentages between the 2002 and 2009 data do not match that derived from Tables 4-3, 4-4, 4-7 and 4-8. 

We reviewed the tcomment and fouThere were minor other entries, but minor round-off er
9 

Table 1: Comments Submitted by EPA # Section Comment Response 

using Excel spreanot display, all numbers). 

11. Initial and 

Boundary Conditions Data 

A reference for more details on the GEOS-CHEM global simulation model that was used to develop CMAQ boundary conditions should be provided. Attachment C does not provide very much information. 

 GEOS-CHEM Attachment L.

12. Control 

Measures – Chapter 5.0 

The SIP Narrative states on page 65 that when the heavy-duty gasoline and diesel highway vehicle standards are fully implemented, 90 and 95 percent reductions in particulate matter and NOX emissions. The section does not provide a year when full 

implementation of the program will occur. So it is unclear if full implementation occurs in 2009 and these reductions were used in the modeling. Or, if it is fully implemented after 2009 what percentage was relied upon in the attainment modeling. 

The SIP was rimplementation of by 2030. 

13. Episode 

Selection for the PM2.5

Attainment Demonstration 

It is unclear how days (e.g., number of days per quarter) were chosen to develop the 

relative 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 15 days) should be used in the air quality modeling to develop and attainment strategy. The EPA modeling guidance on page 149 recommends 15 or more total days per quarter, not 15 or more days with monitored data should be used in the modeling and to develop the relative reduction factors. Therefore, in addition to citing what the guidance states, the SIP should discuss specifics on how this guidance was actually used in the SIP modeling for the Knoxville NAA. 

The language in ththat “Sufficient dsuch that the applied at each NAAQS is based quality modeling entire year, but chosen to ensure data was availablattainment test. 

14. SIP Narrative Analyses using the Classification and Regression Tree (CART) and collaborative efforts 

with other states are mentioned in this section. The analyses were used to assess the representativeness of the 2002 episode modeling year. The reference for these analyses or summaries of these efforts should be included or discussed in the SIP Narrative. 

 CART analysis Attachment K 

15. Model 

Performance 

Model performance for the development of the meteorological files created through the use 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 discuss model performance for the MM5 model and the Knoxville area. 

MM5 Report is ad
10 

Table 1: Comments Submitted by EPA # Section Comment Response 16. Data Archival 

and Access 

- On page 106, the SIP states that the large data files associated with the many steps of the modeling process will be archived and maintained by the modeling contractors (ENVIRON and AG). It is unclear how long these data will be accessible after funding for the ASIP grant expires. Also the SIP does not provide a primary state contact for 

assessing any of the SIP data files. In addition, the SIP Narrative references Section 9.1 of Attachment C which provides more information but also implies uncertainty in how this data will be archived. It states that decisions on how to store this data (either on a Visibility Improvement – State and Tribal Association of the Southeast (VISTAS) or ASIP website) had yet to be determined. Finally, it is unclear how data files associated with the development of the MM5 meteorological modeling will be archived, maintained and accessed. The archival, maintenance and access of this data is not addressed. It is our understanding that this part of the attainment modeling was performed outside of the ASIP process by another contractor (i.e., not ENVIRON or AG). 

The language in updated to indicgroup is archiving SMOKE, and CMand will send an ewith all the suppoprimary contact Revised SIP. 

17. Footnotes 

a. It appears that a lack of a 2002-2004 DV prevents the state from adding the 

Loudon County monitor data to Table 1-1. It is not clear why this would present a problem since the data was used in the attainment test and results presented in Attachment G. 

b. Footnote 3 states that Section 9 would discuss attainment at the 47-105-0108 

Loudon County and 47-093-1013 Knox County monitors in the weight of evidence. However, this discussion does not appear to be in section 9.0. 

 (a) The monitor 1-1 to avoid confudesign values in thmonitor would neattainment test. this monitor showeight of evidencSection 9.0 of thdetails about this m(b) Discussion added as indiccomments. The swill be discussed As the revised monitor collected data and was not and 2007. 

18. Attachment B “Attachment B – Final” provides detailed information on the emissions inventory for 

ammonia, direct primary, sulfur dioxide and nitrogen oxide emissions, especially for the 

Facility names arTables 4-5 and 4-6 
11 

Table 1: Comments Submitted by EPA # Section Comment Response 

point 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, this could 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 that 

the monitor names be added to the data in this figure. 

Figure 4-11 was monitor 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 FRM monitors. 

SMAT data is in(2009 Base G4a P
12 

Table 2: Comments Submitted by the Tennessee Environmental Council # Section Comment Response 1. SIP Narrative The proposed State Implementation Plan does not adequately protect the 

health of the residents of Anderson, Blount, Knox, and Loudon Counties along with a portion of Roane County.

The proposed SIP dethe federally mandate

2. SIP Narrative We challenge the assessment that the NOX emissions from inside the state 

of Tennessee are not significantly contributing to the PM2.5 nonattainment 

in the Knoxville area and request EPA require TDEC to submit an addendum to the PM2.5 SIP.

See response to EPA 

3. SIP Narrative EPA’s projections in 2006 expected the Knoxville area to be in 

nonattainment in 2010 for PM2.5, even after all federal measures 

(CAIR/CAMR/CAVR) were put in place. We do not see a basis that TDEC assumes that things will differ from the EPA projections. 

EPA’s projections uprojected a design μg/m3, while the curr

2006 for the controllialready below that lev

4. SIP Narrative We disagree with the proposed assertion in Option 1 that “NOX emissions 

from sources in the State do not significantly contribute to PM2.5

nonattainment in the Knoxville area.” There are major sources of NOX

remaining in the state. 

Tennessee does not large sources of NOX 

modeling and sampthese sources do not formation of PM2.5. 

5. SIP Narrative TVA’s coal-fired power plants, while much more NOX-controlled thanks 

to the SIP call, still produce significant tons of NOX annually because of 

seasonal use of SCRs. 

In order to meet thTVA will operate beginning in 2009. 

6. SIP Narrative Tennessee has taken some steps to address the existing fleet, but more 

needs to be done with this clearly in-state source. 

The projected invenmobile sources will 2.5% of the directly 

addition, Tennessee Group and an Alternaestablished to help ad

7. SIP Narrative We believe that Tennessee should implement additional controls for the 

following reasons: 

• Meeting the PM2.5 standard will not protect the health of 

our citizens with an adequate margin of safety. The Clean Air Scientific Advisory Committee (CASAC) 

EPA established the 

μg/m3 to protect th

Tennessee is requireDemonstration modevidence projects TNAAQS for PM2.5 as 
13 

Table 2: Comments Submitted by the Tennessee Environmental Council # Section Comment Response 

stated “there is clear and convincing evidence that significant adverse human-health effects occur in response to short term and chronic particulate matter exposures at and below 15 micrograms per cubic meter, the level of the current annual PM2.5 standard”. CASAC 

strongly recommended that the standard be reduced to 13 to 14 micrograms per cubic meter, 

• CASAC’s position was fully supported by the American 

Medical Association, the American Thoracic Society, the American Lung Association, the American Academy of Pediatrics, the American College of Cardiology, the American Heart Association, the American Cancer Society, the American Public Health Association, and the National Association of Local Boards of Health. 

• The EPA states that “Numerous scientific studies have 

linked particle pollution exposure to a variety of problems including: increased respiratory symptoms, such as irritation of the airways, coughing, difficulty breathing, decreased lung function, aggravated asthma, development of chronic bronchitis, irregular heartbeat, nonfatal heart attacks, and premature death in people with heart or lung disease. 

• Due to increased temperatures and drought, TVA 

provided record peak levels of electricity last summer, depending on coal fired power plants which are the primary source of particulate matter in Tennessee air. Models used to predict future levels of PM2.5, may not 

fully reflect the possibility of continued warming and its effect on electrical demand. 

8. Attachment I: Limited 

RACT Analysis 

To protect the health and quality of life of its citizens, Tennessee should go beyond the “do nothing” response in its PM2.5 State Implementation 

Tennessee acknowledto attain the NAAQS 
14 

Table 2: Comments Submitted by the Tennessee Environmental Council # Section Comment Response 

Plan. The measures identified in Attachment I or equivalent should be implemented. By setting a goal of 12 micrograms per cubic meter as recommended by the American Lung Association, Tennessee can take a leadership position for public health. 

but we disagree thanothing approach 

Specifically, we nadopted the Federal Csome of the largest eState or Federal regulTennessee is requireAvailable Control TReasonably Availa(RACM), as listed in and to adopt RACT/would advance the analysis of these rulemeasures listed in implemented sufficieattainment date. To meet the requireOzone NAAQS, and 

NAAQS review, theslooked at again in tadditional reductions attainment for the new 
15 

Table 3: Comments Submitted by Bass, Berry, & Simms on behalf of Bowater # Section Comment Response 1. Attachment I Attachment I of the PM2.5 SIP contains language which indicates that 

modeling is proceeding with a source that appears to be Bowater. There is no reference to this in the main body of the SIP. If modeling is not proceeding, this language should be deleted. If modeling is proceeding, Bowater has significant concerns that have not been addressed. 

The referenced langnote the following: was not conducted, including Tennesanalyses for poinnonattainment areaswere conducted for source. The resultshowing a maximuμg/m3, are noted in t
16 

Table 4: Comments submitted by TDEC-APC # Section Comment Response 1. Section 2.0 In Section 2.0, “non attainment” is written as two separate words in the first 

paragraph. We will change this to “nonattainment” (one word). 

Corrected 

2. Section 10.0, NOX

Addendum, other portions of SIP referencing add-on controls at TVA Kingston 

Section 10.0 states that Tennessee is claiming SO2 reductions from units 1 

through 4 at the TVA Kingston Fossil Plant as contingency measures for PM2.5 attainment in the Knoxville area, based on the installation and startup 

of a wet scrubber at these units by December 2009. These statements should read that Tennessee is claiming SO2 reductions from TVA Kingston 

units 6 through 9 as contingency measures. All references in this section to units 1 through 4 at TVA Kingston will be replaced with language referencing the correct units at this facility. Since the level of emissions from units 6 through 9 is not the same as emissions from units 1 through 4, we will recalculate the amount of SO2 reductions available for contingency 

measures. These changes will not affect our determination that SO2

reductions from Kingston fossil plant are adequate for contingency planning purposes. The NOX addendum to the PM2.5 SIP contains additional language on 

contingency measures, and that section contains the same error referenced above. If we find that it is necessary to adopt the NOX addendum as part of 

the SIP, we will correct all references to TVA Kingston Units 1 through 4, as noted above, as well as all calculations developed for contingency planning purposes. 

Corrected 

3. Attachment D Notes from the most recent Interagency Consultation (IAC) call were added 

to Attachment D of the SIP. This call was held subsequent to the public hearing version of the SIP documentation. 

No further action req
17 

Table 4: Comments submitted by TDEC-APC # Section Comment Response 4. Table 4-5 A review of Table 4-5 indicates two errors in the Loudon County point 

source emissions inventory: 

a. The ASIP emission inventory indicates that SO2 emissions from 

Monterey Mushroom, a source in Loudon County, were 390 tons in 2002, with similar emissions in 2009. Review of the permit files for this source indicate that from 1996 to 2005, allowable SO2

emissions from this facility were 109.9 pounds per hour but only 78.6 tons/year due to a Federally enforceable restriction on fuel usage. The most recent operating permit for this source (issued 5/18/07) indicates a decrease in allowable SO2 emissions to 52.8 

tons. Allowable emissions for this source appear to be well below the value listed in the inventory. 

b. SO2 emissions for Viskase do not appear to have been included in 

the ASIP emission inventory. Tennessee’s NEI facility summary indicates that SO2 emissions for this facility were 257 tons/year in 

2002. 

In order to abetween the inSIP and the infASIP emission SIP was not cfacilities are loeach other (abocombined emfacilities are of emissions reporin Table 4-5uncertainty that the modeling re

5. NOX Addendum The NOX addendum indicates that RACT-BACT-LAER (RBLC) 

determinations are attached. However, an attachment was not provided. 

The prehearing didentification numbdeterminations. Ravailable from EPAReferences to atdeterminations will b

6. General Comment At U. S. EPA’s request, the public comment period was extended public 

hearing until March 31, 2008. The extension of the public comment period was read into the record at the March 25, 2008, public hearing. 

No response require
18 

Appendix P-1 

Air Quality Monitoring Data for 24-Hour 

PM2.5 NAAQS 
19 

County AIRS ID Address

Design Values for 24-hour PM2.5 NAAQS 

2000-2002 2001-2003 2002-2004 2003-2005 

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 

Blount 47-009-0011 

2007 Sequoyah 

Avenue 35 11 9 33 12 11 32 12 12 33 12 1

Knox 47-093-0028 1000 Francis Road 37 12 12 34 12 10 31 12 10 33 12 7 Knox 47-093-1013 

1403 Davanna 

Street 41 2 2 36 4 4 31 4 4 26 2 2 

Knox 47-093-1017 

1613 Vermont 

Avenue 39 12 11 35 12 12 34 12 12 34 12 1

Knox 47-093-1020 4625 Mildred Drive 38 12 11 34 12 11 32 12 11 32 12 1Loudon 47-105-0108 130 Webb Drive 35 2 1 32 6 5 33 10 9 Roane 47-145-0004 1002 N. Roan Street 36 12 12 30 12 12 28 12 12 30 12 1

County AIRS ID Address 

98th Percentile by Year, 24-hour PM2.5

2000 2001 2002 2003 2004 200

Blount 47-009-0011 2007 Sequoyah Avenue 46 30 30 39 27 33 Knox 47-093-0028 1000 Francis Road 45 36 29 36 29 34 Knox 47-093-1013 1403 Davanna Street 41 32 19 Knox 47-093-1017 1613 Vermont Avenue 46 37 34 35 31 36 Knox 47-093-1020 4625 Mildred Drive 43 37 33 32 31 35 Loudon 47-105-0108 130 Webb Drive 35 29 34 Roane 47-145-0004 1002 N. Roan Street 48 34 27 28 28 33 
20 

Appendix P-2 

PM2.5 Contribution Assessment 

Knoxville, TN 
21 

Knoxville, TN PM2.5 Contribution Assessment 

Speciated PM2.5 data from Speciated Trend Network (STN) monitors in the Knoxville 

area indicate that the predominant contributions to PM2.5 mass are organic carbon and 

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

greater than the annual standard for PM2.5 of 15 μg/m3

 (Figure 1, left bar). 

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

source SO2 emissions are the predominant precursors for ammonium sulfate. ASIP 

inventories and air quality modeling indicate that installation of SO2 controls (scrubbers) 

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

reduce PM2.5 levels in the Knoxville area by 2009 (Figure 1, middle and right bars). 

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

contribute to organic carbon mass, including 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 likely due to wood burning 

(from forest fires, prescribed fires, land clearing, agricultural burning, or residential, 

commercial or industrial wood use). Elevated 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 PM2.5 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

18

Blount-0011

Davidson-0023

Dyer-0004

Hamilton-4002

Knox-0028Knox-1017Knox-1020

Maury-2007

McMinn-1002

Montgomery-1009

Putnam-0001

Roane-0004

Shelby-0014Shelby-0038Shelby-0047Shelby-1004

Sullivan-1007

Sumner-0007

Tennessee

ug/m3

PBW

NH4

Crusta

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-06M-06

J-06

J-06

A-06

S-06

O-06

N-06D-06

Mass (μg/m3)

SO4 NH4 NO3 POM LAC Soil Sea Salt

Figure 2: Contributions of PM2.5 Components to Total Measured Mass at 

Knoxville, TN STN Site for 2006. 

Ammonium nitrate is a very small contributor to PM2.5 mass in the warmer months and a 

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

organic carbon and ammonium sulfate. Ground level 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 PM2.5 mass. Fossil fuel combustion and wood burning are the most important 

contributors to elemental carbon. Fine soil might 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 episodes selected in summer (Jun 1-Jul 10) and 

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

reductions in PM2.5 mass would be accomplished by reducing SO2 emissions from 

electric utilities and industrial point sources. SO2 reductions in several southeastern 

states, not just the Knoxville area, would be beneficial in reducing PM2.5 in Knoxville. 
23 

Figure 3: CMAQ Modeled Changes in PM2.5 Mass for Knoxville STN monitor 1020, 

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

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

Figure 4: CMAQ Modeled Changes in PM2.5 Mass for Knoxville STN monitor 1017,

30% 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

SO2_EGU

SO2_nonEGU

NOx_Ground

NOx_Point

NH3

VOCs

Primary Carbon_

Ground

Primary Carbon_

Point

Primary Carbon_

Fires

ΔPM2.5 (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

SO2_EGU

SO2_nonEGU

NOx_Ground

NOx_Point

NH3

VOCs

Primary Carbon_

Ground

Primary Carbon_

Point

Primary Carbon_

Fires

ΔPM2.5 (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_EGU

SO2_nonEGU

NOx_Ground

NOx_Point

NH3

VOCs

Primary Carbon_

Ground

Primary Carbon_

Point

Primary Carbon_

Fires

ΔPM2.5 (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_EGU

SO2_nonEGU

NOx_Ground

NOx_Point

NH3

VOCs

Primary Carbon_

Ground

Primary Carbon_

Point

Primary Carbon_

Fires

ΔPM2.5 (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 PM2.5 mass for Knoxville STN monitor 1020, 

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

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

Figure 6: CMAQ modeled changes in PM2.5 mass for Knoxville STN monitor 1027, 

30% Reduction of 2009 ASIP Base D Emissions 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_Ground

NOx_Point

NH3

VOCs

PC_Ground

PC_Point

PC_Fires

ΔPM2.5 (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_Ground

NOx_Point

NH3

VOCs

PC_Ground

PC_Point

PC_Fires

ΔPM2.5 (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

SO2_EGU

SO2_nonEGU

NOx_Ground

NOx_Point

NH3

VOCs

PC_Ground

PC_Point

PC_Fires

ΔPM2.5 (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

SO2_EGU

SO2_nonEGU

NOx_Ground

NOx_Point

NH3

VOCs

PC_Ground

PC_Point

PC_Fires

ΔPM2.5 (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 the model projects some benefits from reducing local sources 

of primary carbon from ground (on road vehicles, 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 summer 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 ammonium nitrate than reducing nitrogen oxide emissions. 

Finally, the model shows that SO2 emissions from outside the ASIP 12 km modeling 

domain (labeled as “boundary” in Figures 2-5) have a comparable contribution to PM2.5

as local sources of primary carbon. These results demonstrate the regional contribution 

from SO2 point sources located several states away from Knoxville. 

In summary, SO2 reductions from electric utilities and industrial point sources are likely 

to be most effective in reducing PM2.5 in Knoxville. From the mobile sector, reductions 

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

VOC or NOX. 

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