# MIDDLE TENNESSEE

110(a)(1) MAINTENANCE PLAN

Ju ly , 2010



# Pre

- Hearing Draft

Prepared by:

Metro Nashville/Davidson County

Pollution Control Division Office

Lentz Public Health Center

Room 208

311 23rd Avenue North

Nashville

, TN 37203

and

Tennessee Department of Environment and Conservation

Division of Air Pollution Control

9 th Floor L&C Annex

401 Church Street
Nashville, TN 37243MIDDLE TENNESSEE 110(a)(1) MAINTENANCE PLAN Page i TABLE OF CONTENTS

1.0 Background

................................ ................................ ................................ ........... 1

2.0 Attainment Inventory

................................ ................................ .............................. 2

3.0 Maintenance Demonstration

................................ ................................ .................. 2

3.1 Point Source Emissions

................................ ................................ ......................... 3

3.2 Ar ea Source Emissions

................................ ................................ ......................... 4

3.3 Onroad Mobile Source Emissions

................................ ................................ ......... 5

3.4 Nonroad Source Emissions

................................ ................................ ................... 6

4.0 Ambient Air Quality Monitoring

................................ ................................ .............. 9

5.0 Contingency Plan

................................ ................................ ................................ 10

6.0 Verification of Continued Attainment

................................ ................................ ... 11

7.0 Conclusion

................................ ................................ ................................ ........... 12MIDDLE TENNESSEE 110(a)(1) MAINTENANCE PLAN Page ii LIST OF APPENDICES

Appendix A: Point Source Emissions Inventory

Appendix B: Area Source NO

x and VOC Emissions for Davidson, Rutherford, Sumner,

Williamson and Wilson Counties

Appendix C: Onroad Mobile Source NO

x and VOC Emissions for Davidson, Rutherford, Sumner, Williamson and Wil son Counties

Appendix D: Nonroad Source NO

x and VOC Emissions for Davidson, Rutherford, Sumner, Williamson and Wilson Counties

Appendix E: P ublic Notice

Appendix F: Comments Received110(a)(1) MAINTENANCE PLAN

FOR THE 1997 8

- HOUR OZONE NAAQS FOR THE

MIDDLE TENNESSEE 8

- HOUR OZONE MAINTENANCE AREA

1.0 Background

This document contains the 110(a)(1) maintenance plan for the 1997 Middle Tennessee Early Action Compact (EAC) maintenance area. This maintenance plan is being

submitted in accordance with , and to satisfy, the requirements of the EPA guidance

document Maintenance Plan Guidance Document for Certain 8

- Hour Ozone Areas

Under Section 110(a

)( 1) of the Clean Air Act , May 20, 2005 1

.

On July 18, 1997, the U.S. Environmental Protection Agency (EPA) revised the National Ambient Air Quality Standard (NAAQS) for ground

- level ozone from a 0.12 ppm (parts per million) 1

- hour standard to a 0.08 5 ppm 8

- hour average standard. The Middle

Tennessee area was not attaining the more stringent standard on April 15, 2004

, therefore, the Greater Nashville Area was faced with a pending designation of

nonattainment

.

The EPA offered a new option of reaching attainment earlier than would be required by

the Clean Air Act ’s (CAA) conventional nonattainment route . C ertain areas were allowed to opt into a voluntary program called a n Early Action Compact (EAC) . The

EPA offered to defer the effective date of air quality nonattainment desig nations for these areas if they met the qualifications to participate in the EAC. Specifically, the area had to develop a plan to bring the area’s ozone design value to an attaining level by

2007. This plan had to contain a modeling demonstration that the area’s projected emissions inventory in 2007 would lead to attaining the 8

- hour Ozone NAAQS

. Davidson

, Rutherford

, Sumner

, Williamson and Wilson Counties chose to participate in

the E arly A ction C ompact. Through the region’s efforts to proactively address ozone air quality, a demonstration was made that the area was expected to attain the new standard by 2007. As a result of the proactive effort , t he Middle Tennessee area met the EAC requirements, demonstrat ing attainment with the 8

- hour NAAQS of 0.085 ppm.

The primary intent of this 110(a)(1) maintenance plan submittal is to demonstrate that the projected emissions through 2018 do not exc eed those of the attainment year, 2007. If this demonstration can be made, it can then be concluded that the region should be

able to maintain the 1997 8

- hour ozone NAAQS through the maintenance period.

The basic maintenance plan requirements included in the Maintenance Plan Guidance

Document for Certain 8

- Hour Ozone Areas Under Section 110(a)(1) of the Clean Air Act

are:
1. Development of an attainment inventory ( Section 2) ;
2. Development of a maintenance demonstration ( Section 3) ;

1 US EPA, Lydia Wegman, May 20, 2005. Memorandum and Guidance Document: Maintenance Plan

Guidance Document for Certain 8

- hour Ozone Areas Under Section 110(a)(1) of Clean Air Act

.MIDDLE TENNESS EE 110(a)(1) MAINTENANCE PLAN Page 2

3. Commitment to continue air quality mo nitoring ( Section 4 ) ;
4. Development of a contingency plan ( Section 5 ; and,

5. Verification of continued attainment ( Section 6 )

.

2.0 Attainment Inventory

The attainment inventory should be an inventory for a “typical summer day” for

emissions of oxid es of nitrogen, or NOx and volatile organic compounds, or VOCs. The attainment year was 2007. A comprehensive and up

- to

- date analysis of emissions in

the Middle Tennessee area was conducted for 2007 . Th is analysis included a n upd ate
of the emission inve ntories including updated county

- specific emissions data with the use of the latest EPA tools for estimating onroad mobile and n onroad emissions.

D ata aggregated to the categories of p oint, a rea, onroad

, n onroad and ALM (Aircraft, Locomotive and Commercial Marine) emissions for 2007 are summarized in Table 1

and Table 2 , below.

Table 1

. 2007 NOx Emissions in Middle Tennessee

.

Table 2

. 2007 VOC Emissions in Middle Tennessee.

3.0 Maintenance Demonst r ation

A key element of a maintenance plan is a demonstration of how the area will remain in compliance with the 8

- hour ozone standard for the 10 year period following the effective date of designation as attainment. Emissions for several interim years are estim ated to illustrate the trend between the attainment year and the final year of the maintenance plan. These interim years are illustrated to demonstrate that emissions are not expected to increase, above those for 2007 , before the final year of the mainten anceMIDDLE TENNESS EE 110(a)(1) MAINTENANCE PLAN Page 3

plan. The results for 201 0 and 201 4 show additional reductions in the ozone precursors compared to 2007. T he expected emission reductions (reflecting local and national measures) provide for further improvement in ozone air quality and maintenance of the 0.085 ppm 1997 8

- hour ozone NAAQS in the Middle Tennessee area.

The maintenance demonstration is made for an area when the expected future emissions from all sources in the same geographic area are less or equal throughout the maintenance period as compared to the attainment year (in this case 2007). Each source sector’s emissions are estimated and pro j ected using the latest tools available, and the most current planning assumptions available at the time of the analysis. Each

sector ; point, area

, onroad

, n onroad and ALM are evaluated individually.

3

. 1 Point Source Emissions

The 2007 point source emissions for Rutherford, Sumner, Williamson, and Wilson Counties were developed from the State of Tennessee’s 2007 Annual Emission Inventory. The Annual Emission Inventory is based on information provided by each of the companies as per division rules to supply requested data. Davidson County’s 2007 point source emissions were developed from the SEMAP (Southeastern Modeling, Analysis and Planning) invent ory, which is based on data supplied by the Metropolitan Nashville/Davidson County Public Health Department, Pollution Control Division. Future year growth for the Middle Tennessee point sources was based on the EGAS (Economic Growth Analysis System 5.0) projections where growth potential existed. The EGAS projections were applied at the SCC (Source Code Classification) level for point sources.

Future

- year emissions were projected for 2010, 201 4 and 20 18 , using 2007 emissions and economic growth factors f rom EPA’s Economic Growth and Analysis System (EGAS 5.0). Growth factors were determined using the Default REMI 6.0 SCC Configuration and user

- selected base and future years.

In 2009, E. I. du Pont de Nemours and Company located in Davidson County closed down large parts of the facility. This resulted in decreases in VOC emissions and a large decrease in plant steam requirements. The corresponding reduction in steam production meant it would no longer be efficient for the facility to burn coal in their large boilers. These changes to their method of operation will result in further Davidson County point source actual emission decreases of 4.3 tons of NOx and 0.4 tons of VOC per ozone season day. This additional decrease in emissions further supports th e fact

that the Middle Tennessee area will continue to maintain the 8

- hour ozone NAAQS well

into the future.

Table 3 illustrates point source emissions by county proj ected through 2018 for both

NOx and VOC.MIDDLE TENNESS EE 110(a)(1) MAINTENANCE PLAN Page 4

Table 3

. Point Source Emissions for Middle Tennessee

3

. 2 Area Source Emissions

The 2007 State of Tennessee area source emissions estimates for Rutherford, Sumner, Williamson, and Wilson Counties were largely based on published or locally available energy or fuel consumption data for 2007. The area source emission inventory was developed using EPA Nonpoint files located on EPA’s CHIEF Emission Inventory website for the 2008 NEI and from Appendix A of the documentation for the Final 2002 Nonpoint Sector (February 2006 version) National Emission Inventory for Criteria and

Hazardous Air Pollutants

. Davidson County area source emissions estimates were developed from the SEMAP (Southeastern Modeling, A nalysis, and Planning) inventory, which is based on data supplied by the Metr opolitan Nashville/Davidson County Public Health Department, Pollution Control Division

.

Future

- year emissions were projected for 2010, 2014, and 2018 using 2007 emissions

and EGAS growth factors. Growth factors obtained from EGAS were multiplied by the 2007 emission values to calculate emissions for future years

.

It should be noted that Davidson County has historically used a very low cutpoint to distinguish point sources fro m area (nonpoint) sources. Davidson County routinely permits sources with permitted emissions at or below one ton per year. For these sources, actual emissions are often lower. For this reason Davidson County includes many sources in the point source em issions inventory that might otherwise be include in an area (nonpoint) source inventory.

Table 4 illustrates area source emissions projected through 2018 for NOx and VOCs for

the Middle Tennessee Maintenance Area.MIDDLE TENNESS EE 110(a)(1) MAINTENANCE PLAN Page 5

Table 4

. Area Source Emissions for Middle Tennes see.

3

. 3 Onroad Mobile Source Emissions

The onroad mobile source emissions were prepared using MOBILE6.2. The Tennessee Department of Transportation provided 2007 county

- level daily V ehicle M iles T raveled (VMT) by functional classes. Vehicle Miles Traveled for 2018 w ere p rovided by the Nashville Metropo litan Planning Organization. VMT for 2010 and 2014 were interpolated by functional class between 2007 and 2018. More detailed information on

how onroad emissions were estim a ted is contained in Appendix C

.

Seaso nal adjustment factors (contained in Appendix C ) were applied to daily average vehicle miles traveled to estimate summer season travel activity. Appendix C contains the seasonally adjusted daily vehicle miles travelled for 2007 and 2018.

The most current version of the MOBILE model (MOBILE6.2) was used with locally specific inputs in order to generate an onroad mobile emission inventory for Middle

Tennessee. VMT mix fractions used in the model runs were provided by the Tennessee Department o f Transportat ion for each roadway type. Average speed by facility type

w as provided by the Nashville Metropolitan Planning Organization. S easonal summer adjustment factor s were used to adjust the Annual DVMT (Daily Vehicle Miles Traveled)

to summer DVMT as illustrate d in Table 5

. Local inspection and maintenance program inputs are used to represent the effects of the local Motor Vehicle Inspection Program.

Table 5

. 2007 Seasonally Adjusted Daily Vehicle Miles Traveled.MIDDLE TENNESS EE 110(a)(1) MAINTENANCE PLAN Page 6

Table 6 illustrates a drastic decrease in onroad emissions for both NOx and VOCs from the five county Middle Tennessee M aintenance A rea. Oxides of nit rogen (NOx) are expected to decrease nearly seventy percent from 2007 through 2018 , while volatile organic compounds (VOCs) are expected to decrease over fifty percent during the same period.

Table 6

. Onroad Emissions for Middle Tennessee.

3

. 4 N onroad Source Emissions

Middle Tennessee county

- level emission estimates for the majority of n onroad mobile source emissions were developed using EPA’s NONROAD200 8 model

. Emissions from Aircraft, Locomotives and Commercial Marine (ALM) sources were obtained from E. H. Pechan & Associates, Inc., the contractor for the Southeastern Modeling, Analysis, and Planning (SEMAP) project. Future year ALM sources were developed by growing the base year 2007 emissions by the appropriate EGAS growth factors

.

Table 7 contains the projected inventory for nonroad mobile sources including construction, agriculture , pleasure marine and lawn care equipment

. Both NOx and VOCs are expected to decrease nearly fifty percent fr om 2007 through 2018 as projected by EPA’s Nonroad emissions model.

Table 7

. Nonroad Emission for the Middle Tennessee.

Table 8 contains estimates for the more commercial and industrial nonroad mobile types of equipment including all aircraft, locomotives and commercial marine vessels. Slight increases are potentiall y expected from these sources, although they are a relatively small component of the overall inventory.MIDDLE TENNESS EE 110(a)(1) MAINTENANCE PLAN Page 7

Table 8

. Aircraft, Locomotive and Commercial Marine (ALM) Emissions for Middle Tennessee.

3

. 5 Total Projected Emissions

C omparin g the 2007 inventor y and the projected future inventories clearly support s continued maintenance of the 1997 8

- hour ozone standard. Table 9 and Table 10

tabulate the total emissions of NOx and VOCs in Middle Tennessee from 2007 through

2018. Figure 1 and Figure 2 illustrate this trend graphically.

Table 9

. Total Projected NOx Emissions for Middle Tennessee.

Table 10

. Total Projected VOC Emissions for Middle Tennessee.

Through the span of approximately ten years beginning in 2007, reductions in NOx are

expec ted to decrease by nearly half, most of which is expected to come from the onroad mobile sector. Volatile organic compounds are expected to decrease nearly twenty percent during the same period.MIDDLE TENNESS EE 110(a)(1) MAINTENANCE PLAN Page 8

Figure 1

. Projected NOx Emissions for Middle Tennessee.

Figure 2

. Projected VOC Emissions for Middle Tennessee.

Per the EPA section 110(a)(1) guidance document, the key element of a maintenance plan is a demonstration of how the area will remain in compliance with the 8

- hour ozone NAAQS for the 10 year period following the effective date of designation to attainment

. As can be seen f rom the above tables and figures, emissions of both ozone precursors, NOx and VOCs are expected to decrease considerably during the maintenance period. These expected reductions in ozone forming pollutants ensure continued maintenance

of the ozone standar d.

The 110(a)(1) Maintenance Plan Guidance indicates that t he princip al mechanism for demonstrating continued attainment is a projected future inventory. Th is emissions inventory uses the most current information available to develop and project the base

and future

- year emissions inventories. Based on these projections and no direct knowledge to the contrary, emissions of NOx and VOC are projected to decrease significantly between 2007 and 2018 . Oxides of Nitrogen (NOx) is expected to decrease approxima tely fifty percent from 2007 to 2018 for the Middle Tennessee AreaMIDDLE TENNESS EE 110(a)(1) MAINTENANCE PLAN Page 9

(Davidson, Rutherford, Sumner, Williamson and Wilson Counties). Similarly, Volatile Orga n ic Compounds (VOCs) are expected to decrease approximately twenty percent

over the same time frame. The projections of ozone forming precursor pollutant s convincingly demonstrate that the area will likely maintain the 1997 8

– hour ozone
NAAQS.

4 .0 Ambient Air Quality Monitoring

Ambient air quality monitoring has been conducted at several locations throughout the

Middle Tennessee Maintenance Area . Air quality has steadily improved (as indicated by the three year design value

– the official measure of air quality) over time as

ind icated in Table 11

. Since 2007, the three year design value has decreased from 84 parts per billion (ppb) to 78 ppb in 2009.

Table 11

. Mi ddle Tennessee 8

- Hour Ozone Design Value History.

The three year design values in Table 11 are plotted in Figure 3

. Figure 3 illustrates a general downward trend in the ozone design value. If this trend is extrapola ted linearly, a continued downward trend is expected beyond 2018.

Davidson County and the State of Tennessee agree to continue to operate air quality monitors in accordance with 40 CFR 58 to verify maintenance of the 8

- hour ozone
NAAQS in the Middle Tenne ssee Maintenance A rea. Any modification to the ambient air monitoring network will be accomplished through close consultation with EPA.MIDDLE TENNESS EE 110(a)(1) MAINTENANCE PLAN Page 10

Figure 3

. Middle Tennessee 8

- Hour Ozone Design Value Trend.

5 .0 Contingency Plan

Section 110(a)(1) guidance requires the development of a contingency plan that will

ensure a violation of the 8

- hour ozone NAAQS is identified, addressed and corrected in an expeditious a manner as possible.

Triggers for implementation of the contingency plan:

1. Quality assured ambient air quality monitoring data showing a violation of the

1997 8

- hour ozone NAAQS; or,

2. An increase in ozone precursor emissions of at least 10% over the emissions for the attainment year of 2007.

If one of the above triggers occurs, one or more of the following control measures will be adopted to reduce ozone precursor emissions :

1. Expand NOx and/or VOC control strategies in the Middle Tennessee

M aintenance area;

2. In conjunction with the State of Tennessee, i mplement mobile source transportation controls such as r educed speed limits for heavy duty diesel vehicles;

3. Lower major source thresholds;

4. Expand the open burning ban in Davidson County to include homeowners in the General Services area;

5. Implement anti

- idling legislation; and,

6. Any other control measure determ ined to be appropriate at the time a trigger is

exceeded

.MIDDLE TENNESS EE 110(a)(1) MAINTENANCE PLAN Page 11

Davidson County and the State of Tennessee will use one or more of the following parameters to determine the most efficient emissions reduction strateg y:

1. The severity and duration of the violation; or,

2. The cost effectiveness of the controls ; or,
3. The time needed for full implementation; or

4. Any other considerations that may be appropriate at the time.

Davidson County and the State of Tennessee comm it to the adoption and implementation of the necessary control measure(s) as expeditiously as practicable. A ll

reasonable efforts will be made to complete the process in 24 months or less.

Table 12 is a n example schedule the Middle Tennessee area would strive to follow

should additional control measures b e required to continue maintenance of the 1997 8

- hour ozone NAAQS.

Table 12

. Contingency Measure Implementation Schedule.

Action Implementation

Schedule Trigger

– v iolation of the 1997 8

- hour Ozone NAAQS documented by quality assured data or an increase in emissions greater than ten percent over the 2007 projected emissions

Evaluation of available control measures 6 months

Selection of control measures 9 months Begin rulemaking or initiation of control measure 1 2 months Implement new rule or control measure 24 months

6 .0 Verification of Continued Attainment

Davidson County and th e State of Tennessee will track the progress of the Middle

Tennessee M aintenance P lan. Since the maintenance demonstration relied on modeling that was heavily dependent on a comprehensive and accurate ozone precursor emissions inventory, the inventory will be periodically update d

.

Table 11 demonstrates that the Middle Tennessee area attained the 1997 8

- hour ozone NAAQS, and the area’s ozone design value c ontinues to demonstrate maintenance of

the standard. As shown in Figure 1 and Figure 2 , projected levels of VOC and NOx emissions continue to decrease during the maintenance period. As stated above, Davidson County and the State of Tennessee have no knowledge of any emissions occurrence or trend that would indicate any conclusion other than the area will remain in

attainment with the 8

- hour ozone NAAQS to 2018 and for the foreseeable future beyond.

The ozone precursor emissions shown in Table 9 and Table 10 for the interim projection years of 201 0 and 201 4 demonstrate that it is unlikely the area will violate the 1997 8

-MIDDLE TENNESS EE 110(a)(1) MAINTENANCE PLAN Page 12

H our ozone NAAQS due to increases in emissions

. Davidson County and the Sta te of Tennessee will monitor regional emissions through the Consolidate Emissions Reporting Rule’s (CERR) periodic emissions inventory submissions. If the CERR results indicate that the projected emissions in this maintenance plan are significantly

less t han the CERR reveals (more than 10 percent), Davidson County and the State of Tennessee will investigate the differences and develop an appropriate strategy for addressing these differences.

Davidson County and the State of Tennessee believe these addit ional interim year evaluations should provide timely documentation of continued maintenance, and, along with quality assured ambient air quality mo nitor ing data, ample opportunity to correct a

violation of the 1997 8

- hour ozone NAAQS

.

7 .0 Conclusion

In reviewing this maintenance plan, Davidson County and the State of Tennessee request that EPA consider the following:

1. Total projected VOC and NOx emissions demonstrate a continued downward trend from 2007 through 2018;

2. A significant facility (E.I. DuPont) had a major NOx reduction of 4.3 tons per ozone season day in 2009 due to the permanent shutdown of a portion of their facility;

3. The inventory indicates continued maintenance of the 1997 8

- hour ozone
NAAQS. Figure 3 shows the actual and anticipated trend of the Middle

Tennessee Maintenance Area 8

- hour ozone design value through 2018. There are certainly no guarantees that the design value will continue to decline at the rate indicated by the trend line, however, there is ample evidence to indicate the air quality improvements are real and should continue to yield positive results into the foreseeable future;

4. Quality assured ambient air monitoring data pr oves continued attainment of the

1997 8

- hour ozone NAAQS through 2009. Table 11 shows the history of Middle

Tennessee 8

- hour ozone design values demonstrating that t he area attained and

continues to maintain the 8

- hour ozone NAAQS of 0.085 ppm; and,

5. Based on historical and projected data, a downward trend in emissions is expected, resulting in lower emissions in 2018 as compared to 2007.

This information is submitted as documentation that the Middle Tennessee 1997 8

- hour

O zone Maintenance Area is currently attaining the 1997 8

- hour ozone NAAQS and will

continue to maintain that standard based on all available information. Based on the projected ozone concentration tr end shown in Figure 3 , ozone levels in the area will

continue to decrease and monitored ozone air quality data will continue to improve through 2018.