Response to Public Comments

The Shelby County Health Department

- Pollution Control Section (SCHD

- PCS) prepared a draft

Redesignation Request and Maintenance Plan (Plan) for public review and comment prior to

submission for approval to the Tennessee Air Pollution Control Board for subsequent

submission to the United States Environmental Protection Agency (E PA) for their consideration.

The required 30

- day public comment period was formally opened on November 10, 20 15 with a

notice published in the Memphis Daily News. In accordance with the SCHD

- PCS public notice

protocol, electronic notice was sent to a list of interested individuals and local elected bodies. In

addition, electronic notice was sent to local members of the Metropolitan Planning Organization

(MPO).

A public hearing was scheduled and held at the Shelby County Health Department auditorium

on Tues day, December 15 at 5:30 PM.

During the comment period, the SCHD

- PCS received comments from three sources. A

description of those comments and the SCHD

- PCS response in italics follows.

Commenters

1. U.S. Environmental Protection Agency, Region 4 comments dated: December 15, 2015

2. State of Tennessee Department of Environment and Conservation (TDEC), comments dated

December 15, 2015

3. Shelby County Health Department

- Pollution Control Section (SCHD

- PCS)

Summary of Comments Received and Department Responses

Commenter 1

- EPA

EPA Region 4 submitted a letter electronically and later by US mail postmarked December 15.

The letter contained 1 specific comment.

EPA 1. In Section E of the maintenance plan, Shelby County notes that “all existing stationary source controls will remain in force.” Pursuant to Section 175A(d) of the Clean Air Act, please include this requirement in the contingency provisions portion of the ma intenance plan and expand it to require Shelby County to implement all measures with respect to the control of the air pollutant concerned (i.e., ozone) which were contained in the state implementation plan for the nonattainment area before redesignation t o attainment

.

Shelby County Response to EPA1

. We have added a statement in Phase 2 of the contingency measures.Commenter 2

- TDEC

The Tennessee Department of Environmental Conservation submitted a letter electronically on

December 15. The letter contained 1 0 specific comment s.

TDEC 1

.

We recommend Table 1 be revised for clarity as there are a number of rows that indicate a single

year as well as a 3 year design value. We recommend the table be simplified and broken into

t wo tables. Additionally, we recommend explanatory text be included in the document

explaining the tables in a way that is un derstandable for a member of the public who is not

familiar with ozone air quality data or ozone design values. This is a critical s ection as it

encompasses air quality data.

Shelby County Response to TDEC 1

. For clarity, rather than split the table, we simplified it to only reflect design values at each area

monitor over the subject years.

TDEC 2

We recommend including a map showing the locations of the ozone monitors depicted in figure

2.

Shelby County Response to TDEC 2

A map depicting the ozone monitors has been incorporated into the document.

TDEC 3

Werecommend a thorough review to ensure appropriate labeling of tables

. It appears that tables

II through IV are missing, or the tables are not numbered correctly. It also appears there are two

tables labeled VI.

Shelby County Response to TDEC 3

A thorough review of the document was preformed and the table labels have been corrected.

TDEC 4

We r e commend a footnote be added to the bottom of Table V to correspond with the “Effective

Model Year 2 ” in the table header.

S helby County Response to TDEC 4

A footnote has been added to the bottom of what is now Table II to correspond with the

“Effective Model Year 2 ” in the table header.TDEC 5

Table VI indicates a drop in VOC emissions between 2017 and 2020 for Area sources, but it is

not clear what accounts for this drop. It seems to differ from the general trend. We recommend

adding an explanation that discusses the drop.

Shelby County Response to TDEC 5

An error was found in applying growth factors to area sources between the analysis years of

2017 to 2020. This has been corrected and it now shows some increase in emissions between

these two years in what is now Table IV

TDEC 6

On page 14; in section 1 of the Section 182(a) discussion, it is mentioned that resources were

redirected to preparing an “attainment demonstration.” We recommendthe text be modified to

st ate a “red esignation request and maintenance plan” instead.

Shelby County Response to TDEC 6

The text was modified to state “redesignation request and maintenance plan” instead of

“attainment demonstration”.

TDEC 7

We recommend the discussion on the bottom of page 19 regarding motor vehicle emissions

budgets be re v ised to clarify what is not “not necessary” as stated in the sentence beginning

“This is not necessary

... ”

.

Shelby County Response to TDEC7

Changes have been made which should better describe what is being done and why.

TDEC 8

Table VII no longer has MVEBs set for the b ase year, 2012. Did the MPO request MVEBs be

set for 2012 as discussed and agreed to at the August 5 th MATS meeting (we note that a base

year MVEB is optional)?

Shelby County Response to TDEC8

This has been done so that it is now clear the MVEB stays the same across the 10 years of the

maintenance planTDEC 9

Caution should be exercised if the Fuels Wizard was used in MOVES2014; EPA has issued a

notice that the Fuels Wizard does not work properly in MOVES2014 and should not be used.

How were the future year fuels with the RVP of 9.0 and 10.0 selected or developed? We

recommend adding text to describe this in the document for the MPO’s use in conformity

de terminations. Details on how future year onroad emissions were developed should also be

included in the document.

Shelby County Response to TDEC9

The future year fuels were selected by exporting the default fuel specifications for Shelby

County, Tennessee from the MOVES2014 fuel input screen panel , making the appropriate RVP

adjustments, and then consulting with the MOVES Team via EPA Region 4 to determine if the

fuels selected and adjustments performed were appropriate. During this process, the MOVES

TEAM advised SCHD

- PCS that the MOVES2014 Fuels Wizard was not working properly.

However, considering the scope of the onroad emission analysis to be performed, which

included adjusting the summertime RVP, it was imperative to have t he refinery analysis

performed. At the request of SCHD

- PCS, the MOVES TEAM performed the refinery analysis

and subsequently conveyed the result s to SCHD

- PCS via email

. Using this data, the summertime

RVP and the corresponding parameters associated with the Fuel Supply, Fuel Formulation, and

Fuel Usage specifications in the MOVES2014 Fuels input w ere adjusted for analysis years 2017,

2020, and 2027.

Finally, text was added to the document to describe the future year fuels with RVP of 9.0 and

10.0 were selec ted or developed

TDEC 10

We recommend including a list of frequently used acronyms at the beginning of the document.

Shelby County Response to TDEC 10

A list of frequently used acronyms has been added to the document.Commenter 3

- SCHD

- PCS

SCHD

- PCS

During the comment period

, SCHD

- PCS staff continued to review the data used to develop the

redesignation request and maintenance plan

. T his internal review identified the following:

oversights :

The 2012 Area source VOC emissions estimate of 44.04 tons/day, which was correctly

stated in the emissions inventory table, was in correctly stated in the MVEB table as

43.99 tons/day

The 2027 Area source NOx emissions estimate of 4.34 tons/day, which was correctly

stated in the MVEB table, was in incorrectly stated in the emissions inventory table as

4.24 tons/day.

Some of the Area source emissions estimates for 2020 and 2027 were project edwith

negative growth values which c aused a slight decrease in the resulting grand totals

The 2017 , 2020, and 202 7 MOVES2014 runs were inadvertently run with the default

Ramp Fraction input value.

The fuels input and the refueling spillage and vapor loss input for the 2012, 2017, 2020,

and 2027 Nonroad Equipment runs were corrected and rerun with MOVES2014.

While thes e oversights were relatively in consequential and d id not a ffect the MVEBs, the y were

corrected

. The following tables illustrate the earlier and the revised calculations for the

emissions inventory.

Summer Season Tons Per Day

Shelby County Volatile Organic Compounds Emission Inventory

Type Year Area Non

- Road On

- Road Point Total

Base Year 2012 44.04 28.31 19.01 9.30 100.6 1

Interim Projection 2017 45.33 21.13 11. 58 6.64 84. 63

Interim Projection 2020 43.16 19.55 9.10 6.22 80. 34

Maintenance Year 2027 46.30 19.09 5.79 6.24 77.42

Shelby County Nitrogen Oxides Emission Inventory

Base Year 2012 4.11 35.88 61.56 13.87 115.42

Interim Projection 2017 4.18 32.05 31. 51 13.45 81.19

Interim Projection 2020 4.2 3 30.53 22.4 6 8.34 65.5 7

Maintenance Year 2027 4.3 3 29.94 12.41 8.43 55.11Summer Season Tons Per Day

Revised Shelby County Volatile Organic Compounds Emission Inventory

Type Year Area Non

- Road On

- Road Point Total

Base Y ear 2012 44.04 28.44 19.01 9.30 100.79

Interim Projection 2017 45.33 21.32 11.22 6.64 84.51

Interim Projection 2020 45.53 19.76 8.75 6.22 80.26

Maintenance Year 2027 46.30 19.33 5.81 6.24 77.69

Shelby County Nitrogen Oxides Emission Inventory

Base Y ear 2012 4.11 35.93 61.56 13.87 115.47

Interim Projection 2017 4.18 32.09 31.30 13.45 81.01

Interim Projection 2020 4.24 30.57 22.42 8.34 65.56

Maintenance Year 2027 4.34 29.77 12.51 8.43 55.05

Likewise, t he following tables illustrate the earlier and the revised calculations for the onroad

emissions budgets

.

Summer Season Tons Per Day

Volatile Organic Compounds On

- Road Emission Budget

Year Area Non

Road On

Road Point Total Safety

Margin On

- Road

Safety

Margin

Allocation On

- Road

Budget Remaining Safety Margin

2012 4 3.99 28.31 19.01 9.30 100.6 1 N/A N/A N/A N/A

2027 46. 24 19.09 5.79 6.24 77. 37 23.2 4 13.22 19.01 10.0 3

Nitrogen Oxides On

- Road Emission Budget

2012 4.11 35.88 61.56 13.87 115.42 N/A N/A N/A N/A

2027 4.34 29.94 12.41 8.43 55.11 60.32 49.15 61.56 11.17

Summer Season Tons Per Day

Revised Volatile Organic Compounds On

- Road Emission Budget

Year Area Non

Road On

Road Point Total Safety

Margin On

- Road

Safety

Margin

Allocation On

- Road

Budget Remaining Safety Margin

2012 44.04 28.44 19.01 9.30 100. 79 N/A N/A 19.01 N/A

2027 46.30 19.33 5.81 6.24 77. 69 23. 10 13.19 19.01 9.91

Nitrogen Oxides On

- Road Emission Budget

2012 4.11 35.93 61.56 13.87 115.47 N/A N/A 61.56 N/A

2027 4.34 29.77 12.51 8.43 55. 05 60. 42 49.04 61.56 11. 38In summary , the revisions to the emissions inventory table are as follows:

VOC revisions

–

F or 201 2

–

the No nroad source VOC emissions estimate was revised from 28.31 to 28.44

tons/day and the Total VOC emissions estimate was revised from 100.61 to 100.7 9

tons/day

.

F or 20 17

– the Nonroad source VOC emissions estimate was revised from 2 1

. 13 to 2 1

. 32

tons/day

, the O nroad source VOC emissions estim ate was revised from 11.58 to 11.22

tons/day

, and the Total VOC emissions estimate was revised from 84.63 to 84. 51 tons/day.

For 2020

– the Area source VOC emissions estimate was revised from 43.16 to 45.53

tons/day, the Nonroad source VOC emissions estimate was revised from 19.55 to 19.76

tons/day, the O nroad VOC emissions estimate was revised from 9.10 to 8.75 tons/day,

and the Total VOC emissions estimate was revised from 80.34 to 80. 26 tons/day.

For 2027

- the Nonroad source VOC emissions estimate was revised from 19.09 to 19.33

tons/day

, the O nroad source VOC emissions estimate was revised from 5.79 to 5.81

tons/day, and the Total VOC emissions estimate was revised from 77.42 to 77. 69

tons/day

NOx revisions

–

For 2012

- the Non road source NOx emissions estimate was revised from 35.88 to 3 5

. 93

tons/day and the Total NOx emissions estimate was revised from 115.42 to 115.47

tons/day.

For 2017

– the Nonroad source NOx emissions estimate was revised from 32.05 to 3 2

. 09

tons/day

, the Onroad source NOx emissions estimate was revised from 31.51 to 31.3 0

tons/day

, and the Total NOx emissions estimate was revised from 8 1

. 19 to 81.01 tons/day.

For 2020

– the Area source NOx emissions estimate was revised from 4 .2 3 to 4 .24

tons/day, the Nonroad source NOx emissions estimate was revised from 3 0

. 53 to 3 0

. 57

tons/day, the Onroad NOx emissions estimate was revised from 22.46 to 22.42 tons/day,

and the Total NOx emissions estimate was revised from 65.57 to 65.5 6 tons/day.

For 2027

- t he Area source NOx emissions estimate was revised from 4.33 to 4.34

tons/day

, the Nonroad source NOx emissions estimate was revised from 29

. 94 to 29

. 7 7

tons/day, the Onroad source NOx emissions estimate was revised from 12.41 to 12.51

tons/day, and the Total NOx emissions estimate was revised from 55.11 to 55. 05

tons/day.

Similarly , the revisions to the emissions budget table are as follows:

VOC revisions

–

F or 201 2

–

the Area source VOC emissions estimate was revised from 43.99 to 44.04

tons/day

, the Nonroad source VOC emissions estimate was revised from 28.31 to 28.44tons/day

, and the Total VOC emissions estimate was revised from 100.61 to 100. 79

tons/day.

For 2027

– the Area source VOC emissions estimate was revised from 46.24 to 46.30

tons/day, the Nonroad source VOC emissions estimate was revised from 19.09 to 19.33

tons/day

, the O nroad source VOC emissions estimate was revised from 5.79 to 5.81

tons/day, the Total VOC emissions estimate was revised from 77. 37 to 77. 69 tons/day,

and the Safety Margin was revised from 23.24 to 23. 10 tons/day.

NOx revisions

–

F or 201 2

–

the Nonroad source NOx emissions estimate was revised from 35.88 to 35.93

tons/day and the Total NOx emissions estimate was revised from 1 15

. 42 to 1 15

. 47

tons/day

For 2027

- the Nonroad source NOx emissions estimate was revised from 29.94 to 29.77

tons/day

, the Onroad source NOx emissions estimate was revised from 12.41 to 12.51

tons/day, the Total NOx emissions estimate was revised from 55.11 to 55. 05 tons/day,

and the Safety Margin was revised from 60.32 to 60. 42 tons/day.