### Tennessee Unclassifiable Area Designations for the 2012 Primary Annual PM 2.5 

### Nationa l Ambient Air Quality Standards

Technical Support Document

1.0 Summary

In accordance with section 107(d) of the Clean Air Act (CAA), the EPA must promulgate designations for all areas of the country. In particular, the EPA must identify those areas that are violating a National Ambient Air Quality Standard (NAAQS) or contributing to a violation of the NAAQS in a nearby area. Additionally, through the designation process

, t he EPA identifies areas that are meeting the NAAQS and those areas without sufficient data for the Agency to make a

determination. The EPA use s a designation category of "unclassifiable/attainment" for areas where air quality monitoring dat a indicate attai nment of the NAAQS and for areas that do not have monitors but for which the EPA has reason to believe are likely to be in attainment and are not contributing to nearby violations. The EPA reserve s the category of "unclassifiable" for areas

where the EPA c annot determine based on available information whether the area is meeting or not meeting the NAAQS or where the EPA has not determined that the area contributes to a nearby violation. The EPA must complete th e initial area designation p rocess within 2 yea rs of promulgating a new or revised NAAQS, or may do so within 3 years under certain

circumstances. 1 This Technical Support Document ( TSD ) describes the EPA’s intent to designate

certain areas in Tennessee as unclassifiable for the 2012 primary annual fine particle N AAQS (2012 annual PM 2.5 NAAQS). 2

Under section 107(d), states are required to submit area designation recommendations to the

EPA for the 2012 annual PM 2.5 NAAQS no later than 1 year following p romulgation of the NAAQS, or by December 13, 2013. In December 2013, Tennessee recommended that Knox County be designated “unclassifiable” and all other counties in the State be designated as

“unclassif iable/attainment” for the 2012 a nnual PM 2.5 NAAQS. How ever, a recent EPA

conducted technical systems audit of Tennessee ’s monitoring program revealed data completeness issues for several areas across the State

. 3 Given these data completeness issues, the

1 Section 107(d) of the CAA requires the EPA to complete the initial designation process within 2 years of promulgation of a new or revised NAAQS, unless the Administrator has insufficient information to make initial designation decisions in the 2

- year time frame. In such circumstances, the EPA may take up to 1 additional year to make initial area designation decisions (i.e., no later than 3 years after promulgation of the standard).

2 On December 14, 2012, the EPA promulgated a revised primary annual PM 2.5 NAAQS (78 FR 3086, January 15, 2013). In that action, t he EPA revised the primary annual PM 2.5 standard, strengthening it from 15.0 micrograms per cubic meter (μg/m 3 ) to 12.0 μg/m 3

.

3 Memorandum from Liz Naess, Group Leader, Air Quality Analysis Group, US EPA Office of Air Quality Planning and Standards , to EPA Docket EPA

- HQ

- OAR

- 2012

- 0918

, Air Quality Designations for the 2012 PM 2.52

EPA cannot determine whether the counties with the incom plete monitoring data are meeting or not meeting the NAAQS

. Because the EPA cannot make a final regulatory determination about

whether a violation exists in those counties with incomplete data, in some cases the EPA is also

not able to determine whether counties nearby to those counties with incomplete monitoring data contribute to a nearby violation . Where data completeness issues remain unresolved prior to the EPA Administrator’s final determination on designations for the 2012 PM 2.5 NAAQS, the EPA intends to designate the affected areas as “unclassifiable.”

After considering Tennessee ’s recommendations and based on the EPA’s assessment of available

information as described in this TSD, the EPA intends to designate the areas id entified in Table 1

as unclassifiable for the 2012 annual PM 2.5 NAAQS. Detailed analyses follow for each of the

identified areas.

Table 1. EPA’s Intended Unclassifiable Areas for the 2012 annual PM 2.5 NAAQS

Area Tennessee ’s

Recommendations EPA’s Intended Unclassifiable
Counties

Clarksville Unclassifiable/Attainment Montgomery and Stewart
Counties

Kingsport Unclassifiable/Attainment Hawkins and Sullivan Counties

Knox County Unclassifiable Unclassifiable

Memphis Unclassifiable/Attainment Shelby, Fayette and Tipton
Counties

Rest of State of
Tennessee Unclassifiable/Attainment Remaining c ounties in the State
of Tennessee with the exception of Hamilton, Marion and Sequatchie C ounties in the Chattanooga Area

However, if future valid air quality data obtained by Tennessee or other relevant states provides adequate basis for determining the air quality status of these areas, in particular if reliable quality assured monitoring data become available that indicate that any of these areas are violatin g the standard, at that time the EPA will may initiate action to resdesignate such areas, including conducting a complete 5

- factor analysis, including consideration of the location and magnitude of the identified violations. As a result of any such future analyses, the boundaries of the

Standards

, titled, “ Initial Area Designations for the 2012 Revised Primary Annual Final Particle National Ambient Air Quality Standard : Tennessee Data Issues

. ”3

nonattainment area will not necessarily be those that EPA uses to define the unclassifiable areas that EPA intends to promulgate now based on incomplete data

.4



### Clarksville TN

- KY Area

Clarksville is located in a b i

- state CBSA that includes four counties : two counties in Tennessee

and two counties in Kentucky . Most of the urbanized portion of Clarksville is contained within Montgomery County, Tennessee . None of the counties in the CBSA have ever been designated

no nattainment for any for the 1997 or 2006 fine particulate matter (PM 2.5 ) national ambient air quality standard (NAAQS ). The Clarksville CBSA and surrounding counties are shown in Figure 1, along with the location of point sources and air quality monitors.

Figure 1. Clarksville CBSA with Point Sources and Air Quality Monitor Locations

There is an attaining monitor in Christian County, Kentucky with a valid design value of 10.3 ug/m3 for the 2011

- 2013 timeframe

. Also, the PM 2.5 air quality in the area has been steadily improving since the early 2000’s as evidenced by the downward trend of PM 2.5 values measured at the monitors in the Clarksville area. This downward trend is shown in Figure 2. The

Mon t gomery County, Tennessee moni tor has an incomplete deign value of 9.6 ug/m 3 for the

2011

- 2013 timeframe.5

Figure 2. Clarksville Area Air Monitor Design Value (DV) Trends

The EPA evaluated PM 2.5 and PM 2.5

- precursor emissions and related data from the counties in
the Clarksville area. Table 2 provides a summary of this data. Montgomery and Stewart Counties have the majority of PM 2.5 and precursor emissions, population and vehicle miles traveled (VMT). Montgomery County has a monitor with invalid data and an urbanized core a round the City of Clarksville. Stewart County has a large point source ( TVA Cumberland Fossil Plant ) with over 2,500 tpy of PM 2.5 emissions and over 7,600 tpy of SO 2 emissions in the upwind direction of the Montgomery County monitor.

In Kentucky, Christian County and Trigg County are outlying areas that are located primarily downwind from the Montgomery County PM 2.5 monitoring site. Christian County has an attaining PM 2.5 monitor, and while the county population is nearly half that of Montgomery County, current growth is only about 3 percent. Trigg County has very low emissions of all pollutants (e.g., 28 tpy of SO 2 and 389 tpy of PM 2.5 ), and the County’s population is rel atively small at about 5 percent for the area. 0 2 4 6 8 10 12 14 16

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 

### Clarksville DVs

Christian Cty, KY Montgomery Cty, TN - 471251009 2012 PM2.5 NAAQS6

Table 2. Summary statistics for the Clarksville, TN

- KY CBSA

Montgomery Stewart Christian Trigg

State Tennessee Tennessee Kentucky Kentucky

Core urbanized county or outlying? Core Outlying Outlying Outlying

SO2 Emissions (tpy) 1

, 529 7

, 740 77 28

PM 2.5 emissions (tpy) 1

, 018 2

, 452 947 389

Population 173,375 13,340 74,138 14,355

Population (% of CBSA) 63% 5% 27% 5%

Population growth (2000

– 2010) 29% 8% 3% 14%

VMT (Millions) 1,467 166 912 218

VMT (% of CBSA) 53% 6% 33% 8%

The EPA also evaluated the meteorology in the area by evaluating wind data collected at the Fort Campbell Airport . Figure 3 provides a wind rose created five years of data from 2009

- 2013 . The predominant winds blow from the southwest and south directions. These predominant wind directions do not support contribution of emissions from the Kentucky counties to the PM 2.5 air quality in the Tennessee areas.7

Figure 3. Wind Rose Data for the Clarksville TN

- KY Area8

Clarksville Area Conclusion :

As a result of our technical analysis of the Clarksville CBSA

, the EPA is preliminarily
determinin g that the Tennessee counties of Montgomery and Stewart be designated unclassifiable along with most of the State of Tennessee d ue to the ambient monitoring data quality issues , including an invalid 2013 design value at the Montgomery County monitor. The
EPA is agreeing with the recommendation from Kentucky and are preliminarily recommending that Christian and Trigg Counties be de sig nated attainment/unclassifiable. As discussed above, any potential violation at the Montgomery County monitor would be strongly influenced by the point sources in Stewart County, Tennessee.9



### Kingsport

- Bristol
, TN

- VA Area

Kingsport

- Bristol is located in a bi

- state CBSA that includes four counties and a city: two counties in Tennessee and two counties in Virginia, along with Bristol City which straddles the Tennessee and Virginia state line. Most of the urbanized portion of Kingsport

- Bristol is
contained within Sullivan and Hawkins Counties in Tennessee. None of the counties in the CBSA have ever been designated nonattainment for any for the 1997 or 2006 fine particulate matter (PM 2.5 ) national ambient air quality standards (NAAQS ). The Kingsport

- Bristol CBSA and surrounding counties are shown in Figure 4 , along with the location of point sources and air quality monitors.

Figure 4

. Kingsport

- Bristol CBSA with Point Sources and Air Quality Monitor Locations

There is an attaining monitor in Bristol City on the Virginia side of the state line with a valid design value of 9.0 ug/m 3 for the 2011

- 2013 timeframe. Also, the PM 2.5 air quality in the area has been steadily improving since the early 2000’s as evidenced by the downward trend of PM 2.510

v alues measured at the monitors in the Kingsport

- Bristol area. This downward trend is shown in Figure 5

. The Sullivan County, Tennessee monitor has an incomplete deign value of 9. 3 ug/m 3

for the 2011

- 2013 timeframe.

Figure 5

. Kingsport

- Bristol Area Air Monitor Design Value (DV) Trends

The EPA evaluated PM 2.5 and PM 2.5

- precursor emissions and related data from the counties in the Kingsport

- Bristol area. Table 3 provides a summary of this data. Sullivan and Hawkins Counties have the majority of PM 2.5 and precursor emissions, population and VMT. Hawkins County also has four large point sources in the upwind direction of the Sullivan County monitor, two of which, TVA John Sevier Fossil Plant and Holston Army Ammunition Plant , have significant SO 2 emissions of over 15,000 tpy and over 1,500 tpy, respectively.

In Virginia, Scott and Washington Counties and Bristol City have low emissions, population and
VMT relative to Sullivan and Hawkins Counties. These are outlying areas that are located in the primarily downwind direction from the Sullivan County PM 2.5 monitoring site. Bristol City has an attaining PM 2.5 monitor and low population and population growth of about 3 percent. Scott County has very low SO 2 emissions of about 40 tpy and relatively low PM 2.5 emissions of 306 tpy. Although Scott County has 18 percent of the area’s population, the recent growth trend is negative. Washington County has very low emissions of all pollutants (e.g., 88 tpy of SO 2 an d 104 tpy of PM 2.5 ), and the County’s population is relatively small at about 6 percent for the area. 0 2 4 6 8 10 12 14 16

2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 

### Kingsport DVs

Bristol City, VA Sullivan Cty., TN 2012 PM2.5 NAAQS11

Table 3. Summary statistics for the Kingsport

- Bristol, TN

- VA CBSA

Hawkins Sullivan Bristol City Scott Washington

State Tennessee Tennessee Virginia Virginia Virginia

Core urbanized county or outlying? Outlying Core Outlying Outlying Outlying

SO2 Emissions (tpy) 17,819 24,937 26 40 88

PM 2.5 emissions (tpy) 892 3,036 946 306 104

Population 56,842 156,866 17,849 23,111 54,879

Population (% of CBSA) 18% 51% 6% 18% 6%

Population growth (2000

– 2010) 6% 3% 3%

- 1% 7%

VMT (Millions) 537 1,748 225 275 741

VMT (% of CBSA) 15% 50% 6% 21% 8%

The EPA also evaluated the meteorology in the area by evaluating wind data collected at the Tri

Cities Regional Airport . Figure 6 is a wind rose created from five years of data from 2009

- 2013

. The predominant winds blow from the west and southwest directions. These predominant wind directions do not support contribution of emissions from the Virginia areas to the PM 2.5 air quality in the Tennessee areas.12

Figure 6 . Wind Rose Data for the Kingsport

- Bristol TN

- VA Area13

Kingsport

- Bristol Area Conclusion:

As a result of our technical analysis of the Kingsport

- Bristol CBSA

, the EPA is preliminarily determining that the Tennessee counties of Sullivan and Hawkins be designated unclassifiable along with most of the State of Tennessee due to the ambient monitoring data quality issues

, including an invalid 2013 design value at the Sullivan County monitor

. The EPA is agreeing with
the recommendation from Virginia and is preliminarily determinin g that Scott and Washington Counties and Bristol City in Virginia be designated attainment/unclassifiable. As discussed above, any potential violation at the Sulliva n County monitor would be strongly influenced by the point sources in Sullivan and Hawkins County, Tennessee.14



### Memphis TN

- MS

- AR Area

Memphis is located in a tri

- state CBSA that includes nine counties : three counties in Tennessee, five counties in Mississippi

, and one county in Arkansas. Most of the urbanized portion of Memphis is contained within Shelby County, Tennessee, although there are pockets of urbanization that stretch into DeSoto County, Missi ssippi

, and Crittenden County , Arkansas. None of the counties in the CBSA have ever been designated nonattainment for either the 1997

or 2006 PM 2.5 NAAQS

. The Memphis CBSA and surrounding counties are shown in Figure 7

, along with the location of point sources and air quality monitors.

Figure 7

. Memphis TN

- MS

- AR CBSA with Point Sources and Air Quality Monitor Locations15

There are attaining monitors in both DeSoto County and Crittenden County with valid design
values for the 2011

- 2013 timeframe of 9.6 μg/m 3 and 10.6 μg/m 3 , respectively

. Also, the PM 2.5 air quality in the area has been steadily improving since the early 2000’s as evidenced by the

downward trend of PM 2.5 values measured at all of the monitors in the Memphis area, includi ng the monitors in Shelby County prior to the time when data quality issues caused that data to be unreliable for final regulatory determinations (approximately 2008). This downward trend is shown in Figure 8 . The Shelby County, Tennessee monitor has an in complete deign value of 9. 7 ug/m 3 for the 2011

- 2013 timeframe.

Figure 8

. Memphis Area Air Monitor Design Value (DV) Trends

The EPA evaluated PM 2.5 and PM 2.5

- precursor emissions and related data from the counties in the Memphis area. Table 4 provides a summary of this data. Shelby County has the majority of

PM 2.5 and precursor emissions, population and VMT. Shelby County also has four large sources just 8

- 12 miles upwind of the Shelby County monitor, including Cargill Corn Milling (330 tpy
PM 2.5 and 3,000 tpy SO 2 ) and Allen Fossil Plant (415 tpy PM 2.5 and 11,000 tpy SO 2 ) as can be seen in the map of the Memphis area provided in Figure 7

. 0 2 4 6 8 10 12 14 16

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 

### Memphis Area Design Values

PM2.5 NAAQS Shelby, TN-0047 (N.V. since 2008)

Shelby, TN-0014 Shelby, TN-0038

Shelby, TN-1004 Crittenden, AR-0004

Crittenden, AR-0005 DeSoto, MS-000216

Table 4. Summary statistics for the Memphis, TN

- MS

- AR CBSA

Fayette Shelby Tipton Benton Desoto Marshall Tate Tunica Cri t tenden

State TN TN TN MS MS MS MS MS AR

Core
urbanized county or outlying? Outlying Core Outlying Outlying Core Outlying Out

lying Outlying Core

SO2
Emissions (tpy) 429 20,010 308 36 52 63 58 107 125

Primary
Sulfate
Emissions (tpy) 10 140 8 10 29 6 6 8 11

PM 2.5 emissions (tpy) 790 4,042 874 475 1,419 1,064 651 1,471 1,854

Population 38,413 928,792 61,160 8,712 161,732 37,098 28,970 10,741 50,952

Population (% of CBSA) 3% 70% 5% 1% 12% 3% 2% 1% 4%

Population growth (2000

– 2010) 33% 4% 19% 9% 51% 6% 14% 16% 0.2%

VMT (Millions) 540 8,562 417 190 1,798 683 365 237 866

VMT (% of CBSA) 4% 63% 3% 1% 13% 5% 3% 2% 6%

The EPA also evaluated the meteorology in the area by evaluating wind data collected at the Memphis International Airport . Figure 9 is a wind rose created from five years of data from
2009

- 2013

. The predominant winds blow from the south and southwesterly directions, with a smaller component of winds blowing from the north to the south. These wind pattern s suggest

t he Shelby County monitor would be strongly be impacted by emissions from these large point

sources in Shelby County

.17

Figure 9 . Wind Rose Data for the Memphis TN

- MS

- AR Area18

In addition, the EPA evaluated speciated PM 2.5 information collected at the Chemical Speciation
Network monitor in the area ( Figure 10 ) . The PM 2.5 speciation data and the derived urban

increment analysis indicate the dominance of different contributing species in each quarter. The peak PM 2.5 concentrations occur during the 3 rd quarter of the calendar year (July

- September) when sulfate and primary organic matter are the major urban increment components of the PM 2.5

mass. Largely responsible for these peak concentrations are the emissions from S helby County, which include 20,010 tpy of SO 2 and 140 tpy direct sulfate. By comparison , the Mississippi and
Arkansas counties of the CBSA have low overall emissions, and in particular they have
emissions of SO 2 and direct sulfate in the range of just 36 t o 125 tpy and 6 to 29 tpy, respectively

.

Figure 1 0 . Quarterly Speciated Monitoring and Urban Increment Data for the Memphis Area

Memphis Area Conclusion:

As a result of our technical analysis of the Memphis CBSA

, the EPA is preliminarily
determini ng that the Tennessee counties of Shelby, Fayette and Tipton be designated unclassifiable along with most of the State of Tennessee due to the ambient monitoring data quality issues , including an invalid 2013 design value at the Shelby County monitor

. The EPA is preliminarily determin ing that Crittenden County, Arkansas, and Benton, DeSoto, Marshall, Tate and Tunica Counties in Mississippi be designated unclassifiable/ attainment, which agrees with the recommendations from Mississippi and represents a slight mo dification to the recommendation from Arkansas of attainment for Crittenden County. As discussed above, any19

potential violation at the Shelby County monitor would be strongly influenced by the point sources within Shelby County, Tennessee , particularly the much higher level of SO 2 and direct
sulfate emission s relative to the rest of the CBSA

.