# Appendix D.2a Point Source Emissions Inventory Documentation

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasTABLE OF CONTENTS
1. INTRODUCTION ...................................................................................................................... 4
2. 2002 POINT SOURCE I NVENTORY DEVELOPMENT ........................................................ 4 2.1 Development of 2002 Actual Point Source Inventory .................................................... 4 2.1.1 Consolidated Emissions Reporting Rule .................................................................... 5 2.1.2 Initial Data Evaluation ................................................................................................ 5 2.1.3 PM Augmentation ....................................................................................................... 7 2.1.4 EGU Analysis ............................................................................................................. 9 2.1.5 Emission Inventory QA Review ............................................................................... 10 2.1.6 Summary of the 2002 Actual Inventory .................................................................... 11 2.2 Development of Typical Year EGU Inventory ............................................................. 11
3. 2018 POINT SOURCE EMISSIONS INVENTORY DEVELOPMENT ................................ 13 3.1 EGU Emission Projections ........................................................................................... 13 3.1.1 Chronology of the Development of EGU Projections .............................................. 14 3.1.2 VISTAS/MRPO IPM runs for EGU sources ............................................................ 16 3.1.3 Post-Processing of IPM Parsed Files ........................................................................ 16 3.1.4 Eliminating Double Counting of EGU Units ............................................................ 18 3.1.5 Quality Assurance steps ............................................................................................ 19 3.1.6 S/L Adjustments to IPM Modeling Results .............................................................. 20 3.2 Non-EGU Emission Projections ................................................................................... 21 3.2.1 Growth assumptions for non-EGU sources .............................................................. 22 3.2.2 Control Programs applied to non-EGU sources ........................................................ 24 3.2.3 Quality Assurance steps ............................................................................................ 25 4. Emission Inventory Summaries ................................................................................................ 26 4.1 Summary of EGU Point Source Inventories ................................................................. 27 4.2 Summary of non-EGU Poin t Source Inventories .......................................................... 31

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasLIST OF TABLES Table 2.1.6-1 2002 Actual Point Source Inventory for Tennessee .............................................. 11 Table 2.2-1 NO x Emissions Comparison for EGUs ..................................................................... 13 Table 3.1.6-1 TDEC-APC Adjustments to IPM Results for the 2009 and 2018 EGU Inventories

............................................................................................................................... ................ 21 Table 4.1-1 EGU Point Source SO 2 Emission Comparison ........................................................ 28 Table 41.7-2 EGU Point Source NO x Emission Comparison ...................................................... 28 Table 4.1-3 EGU Point Sour ce VOC Emission Comparison ...................................................... 29 Table 4.1-4 EGU Point Source CO Emission Comparison ......................................................... 29 Table 4.1-5 EGU Point Source PM 10 -PRI Emission Comparison ............................................... 30 Table 4.1-6 EGU Point Source PM 2.5 -PRI Emission Comparison ............................................. 30 Table 4.1-7 EGU Point Source NH 3 Emission Comparison ........................................................ 31 Table 4.2-1 Non-EGU Point Source SO 2 Emission Comparison ................................................ 31 Table 4.2-2 Non-EGU Point Source NO x Emission Comparison ................................................ 32 Table 4.2-3 Non-EGU Point S ource VOC Emission Comparison .............................................. 32 Table 4.2-4 Non-EGU Point S ource CO Emission Comparison ................................................. 33 Table 4.2-5 Non-EGU Point Source PM 10 -PRI Emission Comparison ....................................... 33 Table 4.2-6 Non-EGU Point Sour ce PM25-PRI Emission Comparison ..................................... 34 Table 4.2-7 Non-EGU Point Source NH 3 Emission Comparison ................................................ 34

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I Areas

### 1. INTRODUCTION The regional haze modeling was performed by th e Southeast Regional Planning Organization, Visibility Improvement State and Tribal Associ ation of the Southeast (VISTAS) and is run by the ten Southeast states (Alabama, Florida, Ge orgia, Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, Virginia and West Virginia) and the local programs and tribal agencies located within these states. The re gional haze modeling uses annual simulations and includes an intermediate year. VISTAS deve loped emission estimates for all pollutants of concern for regional haze.


### 2. 2002 POINT SOURCE INVENTORY DEVELOPMENT This section details the development of the 2002 base year inventory for point sources. There were two major components to the development of the point source sector of the inventory. The first component was the incorporation of data s ubmitted by State and Local (S/L) agencies to the United States Environmental Protection Agency (U SEPA) as part of the Consolidated Emissions Reporting Rule (CERR) requirements. Work on incorporating the CERR data into the revised base year involved: 1) obtaini ng the data from the USEPA or th e S/L agencies, 2) evaluating the emissions and pollutants reported in the CERR submittals, 3) augmenting CERR data with annual emission estimates for primary coarse particulate matter (PM 10 -PRI) and primary fine particulate matter (PM 2.5 -PRI); 4) evaluating the emissions from electric generating units, 5) completing quality assurance reviews for eachcomponent of the point source inventory, and 6) updating the database with corrections or ne w information from S/L agencies based on their review of the 2002 inventory. The processes used to pe rform the emission inventory development are described in the first portion of this section. The second component was the development of a “typical” year inventory for electric generating units (EGUs). The VISTAS states determined th at a typical year EGU inventory was necessary to smooth out any anomalies in emissions from the EGU sector due to meteorology, economic, and outage factors in 2002. The typical year EGU i nventory is intended to represent the five-year (2000-2004) period that will be usedto determine the regional baseline and to determine the regional haze reasonable progress goals. Th e second part of this section discusses the development of the typical year EGU inventory.
2.1 Development of 2002 Actual Point Source Inventory VISTAS/ASIP contracted with MACTEC to develop the 2002 emission inventory. The Tennessee Department of Environment and Cons ervation – Air Pollution Control (TDEC-APC) submitted the most updated statewide emission invent ory to the contractor with the exception of the emissions from the four local programs. For the four local programs, Davidson, Hamilton,
Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasKnox, and Shelby Counties, the CERR submittal fr om the USEPA was used. Once all of the files were obtained, MACTEC ran the files through the USEPA’s National Emissions Inventory (NEI) Input Format (NIF) Basic Format and Conten t checking tool to ensure that the files were submitted in standard NIF format and that there were no referential integrity issues with the files. The primary task in preparing the 2002 base year point source inventory wa s the incorporation of corrections and new information as submitted by the S/L agencies based on their review of the previous draft versions of the inventory. The following subsections document the data sources for the inventory, the checks made on the CE RR submittals, the evaluation of EGU emissions, and other quality assurance/quality control (QA/ QC) checks. The final subsection summarizes the 2002 point source inventory by sector (EGU and non-EGU). Throughout the development of the point source emissions inventory, th e TDEC-APC completed detailed reviews of the inventories prepared by the VISTAS contractor and provided comments and data corrections when needed.
2.1.1 Consolidated Emissions Reporting Rule The CERR was published in the Federal Register on June 10, 2002 (67 Federal Register 39602). This brief summary is provided as a quick intr oduction to the CERR and covers the major items in the rule. The purpose of the CERR is to simplify reporting, offer options for data collection and exchange, and unify reporting dates for various categories of criteria pollutant emission inventories. The rule applies to S/L agencies. Previous reporting requirements ha ve, at times, forced reporting agencies into inefficient collecting and reporting activities. This rule consolidates the emission inventory reporting requirements found in various parts of the Clean Air Act (CAA). Consolidation of reporting requirements will enable S/L agencies to better explain to program managers and the public the necessity for a consistent inventory program, increases the efficiency of the emission i nventory program, and provide more consistent and uniform data. States are required to prepare a comprehensive st atewide inventory every th ree years. The first inventory was for the year 2002 and was due J une 1, 2004. This CERR inventory was used for the VISTAS 2002 base year.

2.1.2 Initial Data Evaluation MACTEC conducted an initial review of the 2002 point source CERR data. The following evaluations were completed to identify potenti al data quality issues associated with the CERR data:

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I Areas• Compared the number of sites in the CERR su bmittal to the number of sites in the VISTAS draft 2002 inventory; the number of sites in the CERR submittal was less than in the VISTAS draft 2002 inventory, since th e CERR data was limited to major sources, while the VISTAS draft 2002 inventory containe d data for both major and minor sources; verified with S/L contacts that minor s ources not included in the CERR point source inventory were included in th e CERR area source inventory.

• Checked for correct pollutant codes and corrected to make them NIF-compliant.

• Checked for types of particulate matter (PM) codes reported (i.e., PM-FIL, PM-CON, PM-PRI, PM10-PRI, PM10-FIL, PM25-PRI, PM25-FIL); corrected codes with obvious errors (i.e., changed PMPRI to PM-PRI). The PM augmentation process for filling in missing PM pollutants is disc ussed later in Section 2.1.3.

• Converted all emission values that were not in tons to tons to a llow for preparation of emission summaries using consistent units.

• Checked start and end dates in the NIF file s to confirm consistency with the 2002 base year.

• Compared annual and daily emissions when daily emissions were reported; in some cases, the daily value was non-zer o (but very small) but the annual value was zero. This was generally the result of rounding in an S/L agency’s submittal.

• Compared ammonia (NH 3 ) emissions as reported in the CERR submittals and the 2002 Toxics Release Inventory; worked with S/L agencies to resolve any outstanding discrepancies.

• Compared sulfur dioxide (SO 2 ) and nitrogen oxides (NOx) emissions for EGUs to the USEPA’s Clean Air Markets Division (CAM D) continuous emission monitoring (CEM) database to identify any outstanding discre pancies. A full discussion of the EGU emissions analysis is disc ussed later inSection 2.1.4.

• Prepared State-level emission summaries by pollutant for both the EGU and non-EGU sectors to allow S/L agencies to compar e emissions as repo rted in the 1999 NEI Version 2, the VISTAS draft 2002 i nventory, and the CERR submittals.

• Prepared facility-level emissi on summaries by pollutant to al low S/L agencies to review facility level emissions for reasonableness and accuracy.

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasMACTEC communicated the results of these analyses through email/telephone exchanges with the S/L point source contacts as well as through Excel summary spreadsheets. The VISTAS S/L agencies submitted corrections a nd updates as necessary to resolve any QA/QC issues from these checks.
2.1.3 PM Augmentation Particulate matter emissions can be reporte d in many different forms, as follows: PM Category Description PM-PRI Primary PM (include s filterable and condensable) PM-CON Primary PM, condensable por tion only (all less than 1 micron) PM-FIL Primary PM, filterable portion only

PM 10 -PRI Primary PM 10(includes filterable and condensable)

PM 10 -FIL Primary PM 10 , filterable portion only

PM 2.5 -PRI Primary PM 2.5 (includes filterable and condensable)

PM 2.5 -FIL Primary PM 2.5 , filterable portion only Tennessee reports PM-PRI, PM 10 -PRI

, and PM 2.5 –PRI in the CERR. From any one of these pollutants, the USEPA has developed augmen tation procedures to estimate PM10-PRI, PM 10 -FIL, PM 2.5 -PRI, PM 2.5 -FIL, and PM-CON. If not in cluded in a S/L inventory, PM 10 -PRI and PM 2.5 -PRI were calculated by adding PM 10 -FIL and PM-CON or PM 2.5 -FIL and PM-CON, respectively. The procedures for augmenting point source PM emissions are documented in detail in the USEPA’s document Documentation for the Final 1999 Natio nal Emissions Inventory {Version 3} for Criteria Air Pollutants and Ammonia – Point Sources , January 31, 2004. (http://www.epa.gov/ttn/chief/net/ 1999inventory.html). Briefl y, the PM data augmentation procedure includes the following five steps:

• Step 1: Prepare S/L/Tribal PM and PM 10Emissions for Input to the PM Calculator

• Step 2: Develop and Apply Sour ce-Specific Conversion Factors

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I Areas• Step 3: Prepare Factor s from PM Calculator

• Step 4: Develop and Apply Algorithms to Esti mate Emissions from S/L/Tribal Inventory Data

• Step 5: Review Results and Update the NEI with Emission Estimates and Control Information.
Please refer to the USEPA documentation for a co mplete description of the PM augmentation procedures. MACTEC took whatever State/Local provided in the way of PM and filled in gaps to add in PMCON where emissions were missi ng in order to calculate PM 10 -PRI and PM 2.5 -PRI for all processes to get a complete set of particulate data. MAC TEC did not compare any other pollutants besides PM, since for other pollu tants CERR emissions equal VISTAS emissions

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasAfter the PM augmentation process was perfor med, MACTEC executed a series of checks to identify potential inconsistencies in the PM inventory. These checks included:
• PM-PRI less than PM 10 -PRI, PM 2.5 -PRI, PM 10 -FIL, PM 2.5 -FIL, or PM-CON;

• PM-FIL less than PM 10 -FIL or PM 2.5 -FIL;

• PM 10 -PRI less than PM 2.5 -PRI, PM 10 -FIL, PM 2.5 -FIL or PM-CON;

• PM 10 -FIL less than PM 2.5 -FIL;

• PM25-PRI less than PM 2.5 -FIL or PM-CON;

• The sum of PM 10 -FIL and PM-CON not equal to PM 10 -PRI; and

• The sum of PM 2.5 -FIL and PM-CON not equal to PM 2.5 -PRI.
MACTEC asked S/L agencies to review this information and provide corrections where the inconsistencies were significant. Note that for the inventory, only the PM 10 -PRI and PM 2.5 -PRI emission estimates were retained since they are the only two PM sp ecies that are included in the air quality modeling. Other PM species were removed from the inventory to facilitate emissions modeling.
2.1.4 EGU Analysis MACTEC made a comparison of the annual SO 2 and NO x emissions for EGUs as reported in the S/L agencies CERR submittals and the data from the USEPA’s CAMD CEM database to identify any outstanding discrepancies. Fa cilities report hourly CEM data to the USEPA for units that are subject to CEM reporting requirements of the NO x SIP Call rule and Title IV of the CAA. The USEPA sums the hourly CEM emissions to the annual level, and MACTEC compared these annual CEM emissions to those in the S/L inve ntories. The 2002 CEM inventory containing NOx and SO2 emissions and heat input data we re downloaded from the USEPA CAMD web site ( www.epa.gov/airmarkets ). The data were provided by quarter and emission unit. The first step in the EGU analysis involved prep aring a crosswalk file to match facilities and units in the CAMD inventory to facilities and units in the S/L invent ories. In the CAMD inventory, the Office of Regulat ory Information Systems (ORIS) identification (ID) code identifies unique facilities and the unit ID identifies unique boilers and internal combustion engines (i.e., turbines and reciprocating engi nes). In the Tennessee point source emissions inventories, the state and county code (FIPS code) and State facil ity ID together identify unique facilities and the emission unit ID identifies unique boilers or inte rnal combustion engines. In most cases, there is a one-to- one correspondence between the CA MD identifiers and the S/L identifiers. However, in some of the S/L inve ntories, the emissions for multiple emission units are summed and reported under one emission unit ID. MACTEC created an Excel spreadsheet
Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I Areasthat contained an initial crosswalk with the OR IS ID and unit ID in the CEM inventory matched to the State and county FIPS, State facility ID, and emission unit ID in the emissions inventories. The initial crosswalk contained both the annual emissions summed from the CAMD database, as well as, the S/L emission estimate. The matching at the facility level was nearly complete. In some cases, however, S/L agencies or stakeholders’ assistance was needed to match some of the CEM units to emission units in the S/L inventories. The second step in the EGU analysis was to pr epare an Excel spreadsheet that compared the annual emissions from the hourly CAMD inventor y to the annual emissions reported in the S/L inventory. The facility-level comparison of CEM to emission inventory NO x and SO 2 emissions found that for most facilities, the annual emissi ons from the S/L inventory equaled the CAMD CEM emissions. Minor differences could be explai ned because the facility in the S/L inventory contained additional small or emergency units th at were not included in the CAMD database. The final step in the EGU analysis was to compare the SO 2 and NO x emissions for select Southern Company units in the VISTAS regi on. Southern Company is a super-regional company that owns EGUs in four VISTAS States (Alabama, Florida, Georgia, and Mississippi) and participates in VISTAS as an industry st akeholder. Southern Company independently provided emission estimates for 2002 as part of the development of the preliminary VISTAS 2002 inventory. Emission estimates were reviewed by the States and incorporated into the States CERR submittal. There were no major inconsistencies between the Southern Company data, the CAMD data, and the S/L CERR data. The minor inconsistencies found included small differences in emission estimates (<2 percent difference), exclusion/inclusion of small gas-fired units in the different databases, and grouping of emission units in S/L CERR submittals wher e CAMD listed each unit individually. MACTEC compared SO 2 and NO x emissions on a unit-by-unit basis and did not find any major inconsistencies.
2.1.5 Emission Inventory QA Review Throughout the inventory developm ent process, QA steps were pe rformed to ensure that no double counting of emissions occurred, and to en sure that a full and complete inventory was developed for VISTAS. QA was an important co mponent to the inventory development process and MACTEC performed the following QA steps on the point source component of the VISTAS revised 2002 base year inventory: 1. Facility level emission summaries were prepared and evaluated to ensure that emissions were consistent and th at there were no missing sources.

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I Areas2. State-level EGU and non-E GU comparisons (by pollutant ) were developed between the 2002 base year inventory, the draft VISTAS 2002 inventory, and the 1999 NEI Version 2 inventory. 3. Data product summaries and raw NIF 3.0 data files were provided to the VISTAS Emission Inventory Technical Advisor and to the Point Source, EGU, and non-EGU Special Interest Work Group representative s for review and comment. Changes based on these comments were reviewed and approve d by the S/L point source contact prior to implementing the changes in the files. Version numbering was used for all inventory files developed. The version numbering process used a decimal system to track major and minor changes.
2.1.6 Summary of the 2002 Actual Inventory Tables 2.1.6-1 summarize the final 2002 actual base year inventory for Tennessee. All values are in tons per year. The EGU emissions include the emissions fr om all processes with a Source Classification Code (SCC) of either 1-01-xxx-xx (External Combustion Boilers – Electric Generation) or 2-01-xxx-xx (Inte rnal Combustion Engines – Electric Generation). Emissions for all other SCCs are included in the non-EGU column. Table 2.1.6-1 2002 Actual Point Source Inventory for Tennessee
Pollutant All Point Sources EGUs Non-EGUs SO 2 413,735 334,151 79,584 NO x 221,638 157,307 64,331 VOC 78,230 926 77,304

CO 121,765 7,084 114,681 PM 10 -PRI 49,174 14,640 34,534 PM 2.5 -PRI 39,511 12,166 27,345 NH 3 1,746 204 1,542 VOC = Volatile Organic Compounds CO = Carbon Monoxide
2.2 Development of Typical Year EGU Inventory VISTAS developed a typical y ear 2002 emission inventory for EGUs to avoid anomalies in emissions due to variability in meteorology, eco nomic, and outage factors in 2002. The typical

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I Areasyear inventory represents the five year (2000-20 04) period, which are the y ears used to calculate the regional haze baseline.
Data from the USEPA’s CAMD were used to develop normalization factors for producing a 2002 typical year inventory for EGUs. The VISTAS contractor used the ratio of the 2000-2004 average heat input and the 2002 actual heat input to normalize the 2002 actual emissions. MACTEC obtained data from the USEPA CAMD for utilities regulated by the Acid Rain program. Annual data for the period 2000 to 2004 were obtained from the CAMD web site. The parameters available were the SO2 and NOx emi ssion rates, heat input, and operating hours.
MACTEC used the actual 2002 heat input and the average heat i nput for the 5-year period from 2000-2004 as the normalization factor, as follows:
Normalization Factor: 2000-2004 average heat input 2002 actual heat input If the unit did not operate for all five years, then the 2000-2004 average he at input was calculated for the one or two years in which the unit did operate. The annual actual emissions were multiplied by the normalization factor to dete rmine the typical emissions for 2002, as follows: Typical Emissions = 2002 actual emissions x Normalization Factor After applying the normalization factor, some adjustments were needed for special circumstances. For example, a unit may not have operated in 2002 and thus have zero emissions. If the unit had been permanently retired prior to 2002, then MACTEC used zero emissions for the typical year. If the unit ha d not been permanently retired and would normally operate in a typical year, then MACTEC used the 2001 (or 2000) heat input and emission rate to calculate the typical year emissions. The final step was to replace the 2002 actual emi ssions with the 2002 typical year data described above. MACTEC provided the raw data and resu lts of the typical y ear calculations in a spreadsheet for S/L agency to review and commen t. Any comments made were incorporated into the typical 2002 inventory.
Table 2.2-1 summarizes emissions by State and pollutant for the actual 2002 EGU inventory and the typical year EGU inventory. For the entire VISTAS region, actual 2002 NOx emissions were about 0.1 percent lower than the typical year emissions. Tennessee’s actual 2002 NOx emissions were 3.3 percent higher than the typical year emissions.

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasTable 2.2-1 NO xEmissions Comparison for EGUs NO xEmissions (tons/year) State Actual 2002 Typical 2002 Percentage Difference AL 161,038 154,704 3.9 FL 257,677 282,507 -9.6 GA 147,517 148,126 -0.4 KY 198,817 201,928 -1.6 MS 43,135 40,433 6.3 NC 151,854 148,812 2.0 SC 88,241 88,528 -0.3 TN 157,307 152,137 3.3 VA 86,886 85,081 2.1 WV 230,977 222,437 3.7



### 3. 2018 POINT SOURCE EMI SSIONS INVENTORY DEVELOPMENT Different approaches were used for different sectors of the point s ource inventory. For the EGUs, VISTAS relied primarily onthe Integrated Planning Model ® (IPM), version 2.1.9, to project future generation, as well as, to calculate the impact of future emission control programs. The IPM results were adjusted based on S/L agen cy knowledge of planned emission controls at specific EGUs. For non-EGUs, VISTAS used recently updated growth and control data consistent with the data used in the USEPA’s Clean Air Interstate Rule (CAIR) analyses, and supplemented these data with available S/L agen cy input and updated fuel use forecast data for the United States Department of Energy. For both sectors, VISTAS generated 2018 inventory with control scenarios that account for post2002 emission reductions from promulgated and proposedFederal, State, Local, and site-specific control programs as of July 1, 2004. Secti on 3.1 discusses the EGU projection inventory development, while Section 3.2 discusses the non-EGU projection inve ntory development.
3.1 EGU Emission Projections The following subsections discuss the aspects of the development of the EGU projections.

• A chronology of the EGU development pr ocess used by MACTEC and discuss key decisions in selecting the final methods for performing the emissions projections.

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I Areas• The development of the final set of IPM runs that are included in the VISTAS 2018 inventory.

• The process of transforming the IPM parsed files into NIF format.

• The process for ensuring that units accountedfor in IPM were not double-counted in the non-EGU inventory.

• The QA/QC checks that were made to ensure that the IPM results were properly incorporated into the VISTAS inventory.

• The changes to the IPM results that S/L ag encies requested to be included in the VISTAS inventory based on new informati on that was not accounted for in the IPM runs.

• Summary of 2002 and 2018 EGU emissions by state
3.1.1 Chronology of the Develo pment of EGU Projections Initially, VISTAS considered three opti ons for developing the 2009 and 2018 projection inventories for EGUs:

• Option 1 – Use the results of IPM modeling conducted in support of the proposed CAIR base and control case analyses as the starting point and refine the projections with readily available inputs from stakeholders; thes e IPM runs were conducted for 2010 and 2015, which VISTAS would use to represen t projected emissions in 2009 and 2018 respectively.

• Option 2 – Use the VISTAS 2002 typical year as the starting point, apply growth factors from the Energy Information Administration, and refine future emission rates with stakeholder input regarding utilization rates, capacity, retirements, and new unit information.

• Option 3 – Use the results of a new round of IPM modeling sponsored by VISTAS and the Midwest Regional Planning Organization (MRPO). These runs incorporated VISTAS specific unit and regul ation modified parameters, an d generate results for 2018 explicitly.
An additional consideration for each of the three options was the inclusion of emission projections developed by the Southern Company specifically for th eir units. Southern Company used their energy budget forecast to project net ge neration and heat input for every existing and future Southern Company EGU for the year 2018.

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasEach of these three options and the Southern Company projections were discussed in a series of conference calls with the VISTAS EGU Special Interest Work Group (SIWG) during the fall of 2004. During a conference call on December 6, 2004, the VISTAS EGU SIWG approved the use of the latest VISTAS/MRPO sponsored IPM runs (Option 3) to represent 2018 EGU forecasts of emissions the future year cases. The Option 3 IPM modeling resulted from a jo int agreement by VISTAS and MRPO to work together to develop future year utility emissions based on IPM modeling. The decision to use IPM modeling was based in part on a study of utility forecast methods by E.H. Pechan and Associates, Inc. (Pechan) for MRPO, whic h recommended IPM as a viable methodology. Although the USEPA used IPM recently to supp ort their rulemaking fo r the CAIR, VISTAS stakeholders felt that certain model inputs need ed to be improved. Thus, VISTAS and MRPO decided to hire contractors to conduct new IPM modeling and to post-process the IPM results. For 2018, Southern Company projections were gene rally less than IPM because of assumptions made by Southern Company on which units would be economical to control and incorrect data in the NEEDS database which feeds IPM. In August 2004, VISTAS contracted with ICF to run IPM to provide u tility forecasts for 2018 under two future scenarios – Base Case and CAIR Case. The Base Case represents the current operation of the power system under currently knownlaws and regulations, including those that come into force in the study horizon. The CAIR Case is the Base Case with the proposed CAIR rule superimposed. The run results were parsed at the unit level for 2018. The IPM output files were delivered by ICF in November, and the post- processed data files we re delivered by Pechan in December 2004.
On March 10, 2005, the USEPA issued the fina l CAIR. VISTAS and MRPO, in conjunction with other regional planning organizations (R POs), conducted another round of IPM modeling, which reflected changes to control assumptions based on the final CAIR as well as additional changes to model inputs based on S/L agency and stakeholder comments. Several conference calls were conducted in the sp ring/summer of 2005 to discuss and provide comments on IPM assumptions related to six main topics: power system operation, generating resources, emission control technologies, set-up parameters and rule, financial assumptions, and fuel assumptions. For the summer 2006 set of IPM runs, ICF genera ted two different parsed files. One file includes all fuel burning units (fossil, biomass, landfill gas), as well as, non-fuel burning units (hydro, wind, etc.). The second file contains just the fossil- fuel burning units (e.g., emissions from biomass and landfill gas are omitted). Th e RPOs decided to use the fossil-only file for modeling to be consistent with the USEPA, since the USEPA used the fossil only results for CAIR analyses. For the 10 VISTAS states, non- fossil fuels accounted for only 0.13 percent of the NOx emissions and 0.04 percent of th e SO2 emissions in the 2018 IPM runs

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasVISTAS asked S/L agencies to review the resu lts of the summer 2006 set of IPM runs, which were incorporated into the VISTAS invent ory. The TDEC-APC primarily reviewed and commented on the IPM results with respect to IPM decisions on NOx post-combustion controls and SO2 scrubbers. The TDEC-APC decided to let the IPM solve the 2018 emissions.

3.1.2 VISTAS/MRPO IPM runs for EGU sources The following summary of the VISTAS/MRPO IPM ® modeling is based on ICF’s documentation Future Year Electricity Generating Sector Emission Inventory Development Using the IPM ® in Support of Fine Particulate Mass and Visibility Modeling in the VISTAS and Midwest RPO Regions , April 2005. The ICF documentation is to be used as an extension to the USEPA's proposed CAIR modeling runs documented in Documentation Supplement for EPA Modeling Applications (V.2.1.6) Using the IPM , EPA 430/R-03-007, July 2003. IPM provides “forecasts of least-cost capacity expansion, el ectricity dispatch, and emission control strategies for meeting energy demand and environmental, transmission, dispatch, and reliability constraints.” The underlying databa se in this modeling is the USEPA’s National Electric Energy Data System (NEEDS) released with the CAIR Notice of Data Availability (NODA). The NEEDS database contains the exis ting and planned/committed unit data in the USEPA modeling applications of IPM. NEED S includes basic geographic, operating, air emissions, and other data on these generating units . VISTAS States and stakeholders provided changes for:

• NO x post-combustion control on existing units

• SO 2 scrubbers on existing units

• SO 2 emission limitations

• PM controls on existing units

• Summer net dependable capacity

• Heat rate for existing units

• SO 2 and NO x control plans based on State ru les or enforcement settlements The years 2009 and 2018 were explicitly modeled in this set of runs. Again, the TDEC-APC decided to let the IPM m odel solve the 2018 emissions.
3.1.3 Post-Processing of IPM Parsed Files The following summary of the VISTAS/MRPO IPM modeling is based on Pechan’s documentation LADCO IPM Model Parsed File Post -Processing Methodology and File

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasPreparation , February 8, 2005. The essence of the IPM model post-processing methodology is to take an initial IPM model output file and transform it into air quality model input files. ICF via VISTAS/MRPO provided an in itial spreadsheet file contai ning unit-level records of both (1) “existing” units and (2) committed or new generic aggregates.
All records have unit an d fuel type data; exis ting, retrofit (for SO 2 and NO x ), and separate NO x control information; annual SO 2 and NO x emissions and heat input; summer season (MaySeptember) NO x and heat input; July day NO x and heat input; coal heat input by coal type; nameplate capacity (mega-watts), and State FIPS code. Existing units also have county FIPS code, a unique plant identifier (ORISPL) and unit ID (also called boiler ID) (BLRID); generic units do not have these data. The processing includes estimating various types of emissions and adding in control efficiencies, stack paramete rs, latitude-longitude co ordinates, and State identifiers (plant ID, point ID, st ack ID, process ID). Additionall y, the generic units are sited in a county and given appropriate ID s. This processing is descri bed in more detail below. The data are prepared by transforming the generi c aggregates into units similar to the existing units in terms of the available da ta. The generic aggregates are split into smaller generic units based on their unit types and cap acity, are provided a dummy OR IS unique plant and boiler ID, and are given a county FIPS code based on an al gorithm that sites each generic by assigning a sister plant that is in a county based on its a ttainment/nonattainment status. Within a State, plants (in county then ORIS plant code order) in attainment counties are used first as sister sites to generic units, followed by plants in PM2.5 nonattainment counties, followed by plants in 8-hour ozone nonattainment counties. Note th at no LADCO or VISTAS States provided blackout counties that would not be considered whensiting generics, so this process is identical to the one used for the USEPA IPM post-processing. SCCs were assigned for all units ; unit/fuel/firing/bottom type data were used for existing units’ assignments, while only unit and fuel type were used for generic units’ assignments. Latitudelongitude coordinates were assi gned, first using the USEPA-provide d data files, secondly using the September 17, 2004 Pechan in-house latitude -longitude file, and lastly using county centroids. These data were only used when th e data were not provide d in the 2002 NIF files. Stack parameters were attached, first using the USEPA-provided data files, secondly using a March 9, 2004 Pechan in-house stack parameter file based on previous Energy Information Adminitration form 767 (EIA- 767) data, and lastly using an the USEPA June 2003 SCC-based default stack parameter file. These data were on ly used when the data were not provided in the 2002 NIF files. Additional data were required for estimating VOC, CO, filterable primary PM 10and PM2.5, PM condensable, and NH 3 emissions for all units. Thus, ash and sulfur contents were assigned by first using 2002 EIA-767 values for existing units or SCC-based defaults; filterable PM10 and

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasPM2.5 efficiencies were obtai ned from the 2002 EGU NEI that were based on 2002 EIA-767 control data and the PM Calculat or program (a default of 99.2 percent is used for coal units if necessary); fuel use was back calculated from th e given heat input and a default SCC-based heat content; and emission factors were obtained from an USEPA-approved October 7, 2004 Pechan emission factor file based on the USEPA’s AP-42 emi ssion factors. Note that this updated file is not the one used for estimating emissions for previous USEPA post-processed IPM files. Emissions for 28 temporal-pollutant combinations were estimated since there are seven pollutants (VOC, CO, primary PM 10and PM 2.5 , NH 3 , SO 2 and NO x ) and four temporal periods (annual, summer season, winter season, July day). The next step was to match the IPM unit IDs wi th the identifiers in VISTAS 2002 inventory. A crosswalk file was used to obtain FIPS State an d county, plant ID (within State and county), and point ID. If the FIPS State and county, plant ID and point ID are in the 2002 VISTAS NIF tables, then the process ID and st ack ID are obtained from the NIF; otherwise, defaults, described above, were used. Pechan provided the post-processe d files in NIF 3.0 format. Two sets of tables were developed: “NIF files” for IPM units that have a crosswalk match and ar e in the 2002 VISTAS inventory, and “NoNIF files” for IPM units that are notin the 2002 VISTAS inventory (which includes existing units with or without a crossw alk match as well as generic units).
3.1.4 Eliminating Double Counting of EGU Units The following procedures were used to avoi d double counting of EGU emissions in the 2018 point source inventory. The 2002 VISTAS point source emission i nventory contai ns both EGUs and non-EGUs. Since this file contains both EGUs and non-EGU point sources, and EGU emissions are projected using the IPM, it was ne cessary to split the 2002 poi nt source file into two components. The first component contains those emission units acco unted for in the IPM forecasts. The second component contains all other point sources not accounted for in IPM. As described in the previous section, Pechan developed 2018 NIF files for EGUs from the IPM parsed files. All IPM matched units were initia lly removed from the 2018 point source inventory to create the non-EGU inventor y (which was projected to 2018 using the non-EGU growth and control factors described in Section 3.2.1). This was done on a unit-by-unit basis based on a cross-reference table that matches IPM emission unit identifiers (ORISPL plant code and BLRID emission unit code) to VISTAS NIF emission uni t identifiers (FIPSST state code, FIPSCNTY county code, State Plant ID, State Point ID). When there was a match between the IPM ORISPL/BLRID and the VISTAS emission unit ID, the unit was assigned to the EGU inventory; all other emission units were assi gned to the non-EGU inventory.

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasIf an emission unit was contained in the NIF f iles created by Pechan fr om the IPM output, the corresponding unit was removed from the in itial 2018 point source inventory. The NIF 2018 EGU files from the IPM parsed files were then merged with the non-EGU 2018 files to create the 2018 point source files. Next, MACTEC prepared several ad-hoc QA/QC queries to verify that there was no doublecounting of emissions in the EGU and non-EGU inventories:

• MACTEC reviewed the IPM parsed files to identify EGUs accounted for in IPM. MACTEC compared this list of emission uni ts to the non-EGU inve ntory derived from the VISTAS cross-reference table to verify that units accounted for in IPM were not double-counted in the non-E GU inventory. As a result of this comparison, MACTEC made a few adjustments in the cross-reference table to add emission units for four plants to ensure these units accounted for in IPM were moved to the EGU inventory.

• MACTEC reviewed the non-EGU inventory to identify remaining emission units with a Standard Industrial Classification (SIC) code of “4911 Electrical Serv ices” or SCC of “1- 01-xxx-xx External Combustion Bo iler, Electric Generation”.

• MACTEC compared the list of sources meeting these selection criteria to the IPM parsed file to ensure that these units were not double-counted. MACTEC asked S/L agencies to review the 2018 point source inventory to verify whether there was any double counting of EGU emissions.
3.1.5 Quality Assurance steps Quality assurance was an important component to the inventory development process and MACTEC performed the following QA steps on th e EGU component of the VISTAS revised 2009 and 2018 EGU inventories: 1. Provided parsed files (i.e., Ex cel spreadsheets that provide unit-level results derived from the model plant projections obtained by the IP M) to the VISTAS EGU SIWG for review and comment. 2. Provided facility level emission summarie s for 2018 for both the base case and CAIR case to the VISTAS EGU SIWG to ensure that emissions were consis tent and that there were no missing sources.

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I Areas3. Compared State-level emissions from the IP M parsed files with the post-processed NIF files to verify that the post-processed NIF files were consistent with the IPM parsed file results. VISTAS requested S/L review of these files – th e changes specified by Tennessee as a result of this review are documented in the following subsection.
3.1.6 S/L Adjustments to IPM Modeling Results After the S/L agency review of the final set of IPM runs, S/L agencies specified a number of changes to the IPM results to better reflect current information on when and where future controls would occur. These changes to the IP M results primarily invol ved S/L agency addition or subtraction of future emission controls based on the best available data from state rules, enforcement agreements, compliance plans, permits, and discussions/commitments from individual companies. Some S/L agencies specified changes to the c ontrols assigned by IPM to reflect their best estimates of emission controls. The VISTAS contra ctors used a scrubber control efficiency of 90 percent when adding or removing SO 2 scrubber controls, used a control efficiency of 90 percent when adding or removing NO x SCR controls at coal-fired pl ants, 80 percent when adding or removing NO x SCR controls at gas-fired plants, a nd 35 percent when adding or removing NO x SNCR controls. The specific changes from the TDEC-APC to the IPM results are also summarized in Table 3.1.6-1. S/L agencies provided informati on and/or comment on changes in stack parameters from the 2002 inventory for the 2009 and 2018 inventories. Ch anges to stack parameters were also made in cases where new controls are scheduled to be installed. In cases where an emission unit projected to have a SO 2 scrubber in either 2009 or 2018, some st ates were able to provide revised stack parameters for some units based on design f eatures for the new control system. Other units projected to install scrubbers by 2009 or 2018 ar e not far enough along in the design process to have specific design details. For those un its, the VISTAS EGU SI WG made the following assumptions: 1) the scrubber is a wet scrubber; 2) keep the current stack height the same; 3) keep the current flow rate the same, and 4) change the stack exit temperature to 169 °F (this is the virtual temperature derived from a wet temperatur e of 130 °F). VISTAS determined that exit temperature (wet) of 130 °F +/- 5 °F is represen tative of different size units and wet scrubber technology. A final table of the 2009 and 2018 NO x and SO 2 controls that will be or are assumed to be applied to specific EGU emission units throughout the VISTAS states is presented in Appendix H.

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasTable 3.1.6-1 Tennessee Adjustments to IPM Results for the 2009 and 2018 EGU Inventories
Plant Name and ID Unit Nature of Update/Correction Department of Energy (DOE) (47001-0020-002) Y-12 Boilers 1-4 will be shut down in 2010.

Eastman Chemicals (47163-0003-021520)

B-253-1 This source will install scrubb ers as a result of BART. SO2 emissions will be reduced by 90%. Changed 2018 EM emissions for B-253-1: SO2 from 16,728.78 to 1,672.88 tpy. Added SO2 to CE table with 90 % efficiency. Changed stack temperature in ER table to 169 to reflect addition of scrubber per VISTAS Guidance.

Eastman Chemicals (47163-0003-020101) B-83-1 Boilers 11-17 have been removed from service. Emissions from this source should be reduced by 26.64%.

3.2 Non-EGU Emission Projections The general approach for assembling future year data was to use recently updated growth and control data consistent with the data used in the USEPA’s CAIR analyses , supplement these data with available stakeholder input, and provide the results for stakeholder review to ensure credibility. The VISTAS contra ctor used the 2002 VISTAS base year inventory, based on the 2002 CERR submittals as the starting point fo r the non-EGU projection inventory. The 2002 VISTAS/ASIP point source emissi on inventory contains both EGUs and non-EGUs. Since this file contains both EGUs and non-EGU point sour ces, and EGU emissions are projected using the IPM, it was necessary to split the 2002 point so urce file into two components. The first component contains those emission units accoun ted for in the IPM forecasts. The second component contains all other point sources notaccounted for in IPM and constitutes the nonEGU emissions inventory. MACTEC performed the following activities to apply growth a nd control factors to the 2002 non-EGU emissions inventory to generate the 2009 and 2018 projection inventories:

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I Areas• Obtained, reviewed, and applied the most current growth factors developed by the USEPA, based on forecasts from an update d Regional Economic Models, Inc. (REMI) model (version 5.5) and the latest Annual Energy Outlook published by the Department of Energy (DOE);

• Obtained, reviewed, and applied any State-sp ecific or sector-specific growth factors submitted by stakeholders;

• Obtained and incorporated information regard ing sources that have shut down after 2002 and set the emissions to zero in the projection inventories;

• Obtained, reviewed, and app lied control assumptions;

• Provided data files in NIF3.0 format and emission summaries in EXCEL format for review and comment; and

• Updated the database with corrections or ne w information from S/L agencies based on their review of the 2009 and 2018 inventories. The following sections discu ss each of these steps.
3.2.1 Growth assumptions for non-EGU sources The growth factor data used in developing th e emission inventory were consistent with the USEPA’s analyses for the CAIR rulemaking. Thes e growth factors are fu lly documented in the USEPA’s reports entitled Development of Growth Factors for Future Year Modeling Inventories (dated April 30, 2004) and CAIR Emission Inventory Overview (dated July 23, 2004). Three sources of data were used in developing th e growth factors for the 2009 and 2018 emissions inventories:

• State-specific growth rates from the Re gional Economic Model, Inc. (REMI) Policy Insight ® model, version 5.5 (being used in the development of the EGAS Version 5.0). The REMI socioeconomic data (output by indus try sector, population, farm sector value added, and gasoline and oil expenditures) ar e available by 4-digit SIC code at the State level.

• Energy consumption data from the Department of Energy, Energy Information Administration’s (EIA) Annual Energy Outlook 2004, w ith Projections through 2025for use in generating growth factors for non-E GU fuel combustion sources. These data include regional or national fuel-use forecast data that were mapped to specific SCCs for the non-EGU fuel use sectors (e.g., commercial coal, industrial natu ral gas). Growth
Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I Areasfactors for the residential natural gas co mbustion category, for example, are based on residential natural gas consumption forecasts that are reported at the Census division level. These Census divisions represent a group of States (e.g., the South Atlantic division includes eight southeas tern States and the Districtof Columbia). Although one would expect different growth rates in each of these States due to unique demographic and socioeconomic trends, all St ates within each division rece ived the same growth rate.

• Specific changes for sectors (e.g., plastics, synthetic rubber, carbon black, cement manufacturing, primary metals, fabricated me tals, motor vehicles and equipment) where the REMI-based rates were unrealistic or hi ghly uncertain. Growth projections for these sectors were based on industry group forecas ts, Bureau of Labor Statistics (BLS) projections and Bureau of Ec onomic Analysis (BEA) histor ical growth from 1987-2002. In addition to the growth data described above, VISTAS received two sets of growth projections from stakeholders. The American Forest a nd Paper Association (A F&PA) supplied growth projections for the pulp and paper sector, wh ich were applied to SIC 26xx Paper and Allied Products, for growth from 2002 to 2009 and 2002 to 2018. The AF&PA projection factors (1.067 and 1.169, respectively) are for the United States industry and apply to all States equally. The number come from the 15-year forecast fo r world pulp and recove red paper prepared by Resource Information Systems Inc. (RISI). Th e VISTAS contractor used the above AF&PA growth factors by SIC instead of the factors obtained from the USEPA’s CAIR analysis for the 2009 and 2018 emission inventories.
For the 2009 and 2018 inventories, the VISTAS/ASIP contractor ma de one additional change to the growth factors. The A nnual Energy Outlook (AEO) 2004 data was replaced with the more recent AEO2006 forecasts (released in February 2006) to reflect changes in the energy market and to improve the emissions growth factors pr oduced. The VISTAS co ntractor obtained the corresponding AEO2006 projection tables from DOE. VISTAS de veloped tables comparing the growth factors based on AEO2004 and AEO2006 a nd these comparison tables were reviewed by the S/L agencies. Based on this review, the VI STAS states decided to use the AEO2006 growth factors for fuel burning SCCs.

VISTAS used the USEPA’s EGAS model and updated the correspond ing AEO2006 projection tables to create growth factors by SCC. VI STAS applied the updated growth factors to 2002 actual emissions and replaced the 2009 and 2018 emi ssions in NIF EM tables for the affected SCCs.

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I Areas3.2.2 Control Programs applied to non-EGU sources The VISTAS’s contractor developed a control scenario to address the CAA requirements. The control scenario accounts for post-2002 emission reductions from promulgated Federal, State, Local, and site-specific control pr ograms and are listed below.

• Atlanta / Northern Kentucky / Birmingham 1-hour ozone SIPs
• Industrial Boiler/Process Heater/RICE MACT
• NO x RACT in 1-hour NAA SIPs
• NO x SIP Call (Phase I)
• NO x SIP Call (Phase II)
• RFP 3 percent Plans where in place for one hour plans
• VOC 2-, 4-, 7-, and 10-year MACT Standards
• Combustion Turbine MACT The methodologies used to account for the emi ssion reductions associatedwith these emission control programs are discusse d in the following sections.

NO x SIP Call (Phase I) Phase I of the NO x SIP call applies to certain large non-E GUs, including large industrial boilers and turbines, and cement kilns. States in the VISTAS region affected by the NO x SIP call have developed rules for the contro l of NOx emissions that have been approved by the USEPA. VISTAS reviewed the available State rules and guidance documents to de termine the affected sources and ozone season allowances. VISTAS also obtained and reviewed information in the USEPA’s CAMD NOx Allowance Tracking System – Allowances Held Report. Since these controls are to be in effect by the ye ar 2007, VISTAS capped the emissions for NO x SIP call affected sources at 2007 levels and carried forward the capped levels for the 2009 and 2018 future year inventories.

NO x SIP Call (Phase II) The final Phase II NO x SIP call rule was finalized on April 21, 2004. States had until April 21, 2005, to submit SIPs meeting the Phase II NO x budget requirements. The Phase II rule applies to large IC engines, which are primarily used in pipeline transmission service at compressor stations. VISTAS identified affect ed units using the same methodology as was used by the USEPA in the proposed Phase II rule (i.e ., a large IC engine is one that emitted, on average, more than 1 ton per day during 2002). The final rule reflects a control level of 82 percent for natural gas-fired IC engines and 90 pe rcent for diesel or dual fuel categories.

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasIndustrial Boiler/Pr ocess Heater MACT The USEPA anticipates reductions in PM and SO 2 as a result of the Industrial Boiler/Process Heater MACT standard. The methods used to acc ount for these reductions are the same as those used for the CAIR analysis. Reductions were in cluded for existing units firing solid fuel (coal, wood, waste, biomass), which had a design capac ity greater than 10 mmBtu/hr. The USEPA prepared a list of SCCs for solid fuel industrial, commercial/ institutional boilers and process heaters. The VISTAS contractor identified boi lers greater than 10 mmBtu/hr using either the boiler capacity from the VISTAS 2002 inventory, or if the boiler capacity was missing, a default capacity based on a methodology developed by th e USEPA for assigning default capacities based on SCC code. The applied MACT control efficiencies were 4 percent for SO 2 and 40 for percent for PM 10and PM 2.5 . 2, 4, 7, and 10-year MACT Standards Maximum achievable control technology (MACT) requirement s were also applied, as documented in the USEPA’s report entitled Control Packet Development and Data Sources, dated July 14, 2004. The point source MACTs and associated emission reductions were designed from Federal Register notices and di scussions with the USEPA’s Emission Standards Division staff. VISTAS did not apply reductions for MACT st andards with an initial compliance date of 2001 or earlier, assuming that the effects of these controls are already accounted for in the 2002 inventories supplied by the States. Emi ssion reductions were ap plied only for MACT standards with an in itial compliance date of 2002 or greater.

Combustion Turbine MACT The projection inventory does not include the NO x co-benefit effects of the MACT regulations for Gas Turbines or stationary Reciprocating Internal Combustion Engines, which the USEPA estimates to be small compared to the overall inventory.

Clean Air Interstate Rule CAIR does not require or assume additional emission reductions from non-EGU boilers and turbines.
3.2.3 Quality Assurance steps Final QA checks were run on the revised projecti on inventory data set to ensure that all corrections provided by the S/L agencies and stake holders were correctly incorporated into the S/L inventories and that there we re no remaining QA issues that could be addressed during the duration of the project. After exporting the inventory to ASCII text files in NIF 3.0, the USEPA

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasQA program was run on the ASCII files and the QA output was reviewed to verify that all QA issues that could be a ddressed were resolved. Throughout the inventory developm ent process, quality assuran ce steps were performed to ensure that no double counting of emissions occurred, and to ensu re that a full and complete inventory was developed for Tenne ssee. Quality assurance was an important component to the inventory development process and MACTEC performed the following QA steps on the point source component of the VISTAS inventory: 1. Facility level emission summaries were prepared and evaluated to ensure that emissions were consistent and reasonable . The summaries included base year 2002 emissions, 2009/2018 projected emissions accounting only for growth, 2009/2018 projected emissions accounting for both gr owth and emission reductions from CAA controls. 2. State-level non-EGU comparisons (by pollu tant) were developed for the base year 2002 emissions, 2009/2018 projected emi ssions accounting only for growth, 2009/2018 projected emissions accounting fo r both growth and emission reductions from CAA controls. 3. Data product summaries and raw NIF 3.0 data files were provided to the VISTAS Emission Inventory Technical Advisor and to the Point Source, EGU, and non-EGU Special Interest Work Group representati ves for review and comment. Changes based on these comments were reviewed and approved by Tennessee point source contact prior to implementing the changes in the files. 4. Version numbering was used for all inventory files developed. The version numbering process used a decimal system to track major and minor changes. 

### 4. Emission Inventory Summaries The following sections include the emissions inve ntory summaries for the point source for all of the states within the VISTAS region. The first section provides the 2002, 2009 and 2018 emissions for the EGU sources and the second se ction provides the emissions for the non-EGU
sources.

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I Areas4.1 Summary of EGU Point Source Inventories Tables 4.1-1 through 4.1-7 summarize the 2002 base year inventory and 2009 and 2018 projection inventories for the EGU source sector. The 2009 a nd 2018 inventories include the adjustments to the IPM results specified by the S/L agencies in the previous section.

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasTable 4.1-1 EGU Point Source SO 2Emission Comparison
State 2002 VISTAS 2009 IPM Based with S/L Adjustments 2018 IPM Based with S/L Adjustments AL 447,828 378,052 305,262 FL 453,631 186,055 132,177 GA 514,952 417,449 230,856 KY 484,057 290,193 226,062 MS 67,429 76,579 15,146 NC 477,990 242,286 108,492 SC 206,399 124,608 93,274 TN 334,151 255,410 112,672 VA 241,204 225,653 140,233 WV 516,084 277,489 115,324 Total 3,743,725 2,473,774 1,479,498

Table 4.1-2 EGU Point Source NO xEmission Comparison
State 2002 VISTAS 2009 IPM Based with S/L Adjustments 2018 IPM Based with S/L Adjustments AL 161,038 82,305 64,358 FL 257,677 86,165 73,125 GA 147,517 98,497 75,717 KY 198,817 92,021 64,378 MS 43,135 36,011 10,271 NC 151,854 66,522 62,353 SC 88,241 46,915 51,456 TN 157,307 66,405 31,715 VA 86,886 66,219 75,594 WV 230,977 86,328 51,241 Total 1,523,449 727,388 560,208

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasTable 4.1-3 EGU Point Source VOC Emission Comparison

State 2002 VISTAS 2009 IPM Based with S/L Adjustments 2018IPM Based with S/L Adjustments AL 2,295 2,473 2,952 FL 2,524 1,910 2,376 GA 1,244 2,314 2,841 KY 1,487 1,369 1,426 MS 648 404 1,114 NC 988 954 1,345 SC 470 660 906 TN 926 932 976 VA 754 778 996 WV 1,180 1,361 1,387 Total 12,516 13,155 16,319

Table 4.1-4 EGU Point Source CO Emission Comparison

State 2002 VISTAS 2009 IPM Based with S/L Adjustments 2018 IPM Based with S/L Adjustments AL 11,279 14,986 24,342 FL 57,113 35,928 53,772 GA 9,712 23,721 44,476 KY 12,619 15,812 17,144 MS 5,303 5,051 15,282 NC 13,885 14,942 20,223 SC 6,990 11,135 14,786 TN 7,084 7,214 7,723 VA 6,892 12,509 15,420 WV 10,341 11,493 11,961 Total 141,218 152,790 225,129

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasTable 4.1-5 EGU Point Source PM 10 -PRI Emission Comparison

State 2002 VISTAS 2009 IPM Based with S/L Adjustments 2018 IPM Based with S/L Adjustments AL 7,646 6,969 7,822 FL 21,387 9,007 9,953 GA 11,224 17,891 20,909 KY 4,701 6,463 6,694 MS 1,633 4,957 7,187 NC 22,754 22,152 37,376 SC 21,400 19,395 28,826 TN 14,640 15,608 15,941 VA 3,960 5,508 13,775 WV 4,573 5,657 6,349 Total 113,918 113,607 154,832

Table 4.1-6 EGU Point Source PM 2.5 -PRI Emission Comparison

State 2002 VISTAS 2009 IPM Based with S/L Adjustments 2018 IPM Based with S/L Adjustments AL 4,113 3,921 4,768 FL 15,643 5,910 6,843 GA 4,939 10,907 13,983 KY 2,802 4,279 4,434 MS 1,138 4,777 7,033 NC 16,498 15,949 29,792 SC 17,154 16,042 25,032 TN 12,166 13,092 13,387 VA 2,606 4,067 11,976 WV 2,210 2,940 3,648 Total 79,269 81,884 120,896

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasTable 4.1-7 EGU Point Source NH 3 Emission Comparison

State 2002 VISTAS 2009 IPM Based with S/L Adjustments 2018 IPM Based with S/L Adjustments AL 317 359 1,072 FL 234 1,631 2,976 GA 83 686 1,677 KY 326 400 476 MS 190 333 827 NC 54 445 663 SC 142 343 617 TN 204 227 241 VA 127 694 622 WV 121 330 180 Total 1,798 5,448 9,351 Note: Emission summaries above are based on SCC’s 1-01-xxx-xx and 2-01-xxx-xx
4.2 Summary of non-EGU Point Source Inventories Tables 4.2-1 through 4.2-7 summarize the 2002 base year inventory and the 2009 and 2018 projection inventory for the non-EGU point source sector.
Table 4.2-1 Non-EGU Point Source SO 2Emission Comparison State 2002 2009 2018 AL 96,481 101,246 113,224 FL 65,090 65,511 75,047 GA 53,778 53,987 59,349 KY 34,029 36,418 40,682 MS 35,960 25,564 39,221 NC 44,123 42,536 46,314 SC 53,518 48,324 53,577 TN 79,584 70,678 77,247 VA 63,903 62,560 68,909 WV 54,070 55,973 62,193 Total 580,536 562,797 635,763

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasTable 4.2-2 Non-EGU Point Source NO xEmission Comparison State 2002 2009 2018 AL 83,310 69,409 78,318 FL 45,156 46,020 51,902 GA 49,251 50,353 55,824 KY 38,392 37,758 41,034 MS 61,526 56,397 61,533 NC 44,928 34,767 37,801 SC 42,153 40,019 44,021 TN 64,331 57,883 63,453 VA 60,415 51,046 55,945 WV 46,612 38,031 43,359 Total 536,074 481,683 533,190

Table 4.2-3 Non-EGU Point Sou rce VOC Emission Comparison State 2002 2009 2018

AL 47,037 46,644 54,291 FL 38,471 36,880 42,811 GA 33,709 34,116 40,282 KY 44,834 47,785 55,861 MS 43,204 37,747 45,338 NC 61,182 61,925 70,875 SC 38,458 35,665 43,656 TN 77,304 74,089 93,266 VA 43,152 43,726 53,186 WV 14,595 13,810 16,565 Total 441,946 432,387 516,131

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasTable 4.2-4 Non-EGU Point Sou rce CO Emission Comparison State 2002 2009 2018

AL 174,271 180,369 201,794 FL 81,933 87,037 96,819 GA 130,850 147,427 167,904 KY 109,936 122,024 139,437 MS 54,568 57,748 66,858 NC 50,576 53,744 62,197 SC 56,315 60,473 68,988 TN 114,681 119,039 140,138 VA 63,796 68,346 76,998 WV 89,879 100,045 119,332 Total 926,805 996,252 1,140,465

Table 4.2-5 Non-EGU Point Source PM 10 -PRI Emission Comparison State 2002 2009 2018 AL 25,240 25,421 29,924 FL 35,857 39,872 46,456 GA 21,610 23,103 27,273 KY 16,626 17,174 20,153 MS 19,472 19,245 22,859 NC 13,838 13,910 15,737 SC 14,142 13,370 15,139 TN 34,534 34,145 41,397 VA 13,252 13,048 15,112 WV 17,503 17,090 21,735 Total 212,074 216,378 255,785

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I AreasTable 4.2-6 Non-EGU Point Source PM25-PRI Emission Comparison State 2002 2009 2018 AL 19,178 19,230 22,598 FL 30,504 33,946 39,430 GA 17,462 18,982 22,416 KY 11,372 11,686 13,739 MS 9,906 9,199 10,739 NC 10,500 10,458 11,825 SC 10,245 9,390 11,086 TN 27,345 27,079 33,893 VA 10,165 9,988 11,594 WV 13,313 12,769 16,516 Total 159,990 162,727 193,836

Table 4.2-7 Non-EGU Point Source NH 3 Emission Comparison State 2002 2009 2018 AL 1,883 2,132 2,464 FL 1,423 1,544 1,829 GA 3,613 3,963 4,797 KY 674 760 901 MS 1,169 668 764 NC 1,180 1,285 1,466 SC 1,411 1,578 1,779 TN 1,542 1,764 2,115 VA 3,104 3,049 3,604 WV 332 341 413 Total 16,331 17,084 20,132

Emissions Preparations & Results Appendix D.2a Pre-Hearing Draft November 06, 2007 Regional Haze SIP for TN Class I Areas