# Redesignation Demonstration and Maintenance Plan for the Hickory (Catawba County) and Greensboro/Winston-Salem/High Point (Davidson and Guilford Counties) Fine Particulate Matter Nonattainment Areas

Prepared by North Carolina Department of Environment and Natural Resources Division of Air Quality

December 18, 2009 Revised December 22, 2010(This page intentionally left blank)Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 i Redesignation Demonstration and Ma intenance Plan December 18, 2009 

### Preface: This document contains the technical s upport for North Carolina’s Division of Air Quality to request the Hickory and Greensboro/ Winston-Salem/High Point fine particulate matter nonattainment areas be redesignated as atta inment for the annual fine particulate matter national ambient air quality standa rd pursuant to §§107(d)(3)(D) and (E) of the Clean Air Act, as amended.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 ii Redesignation Demonstration and Ma intenance Plan December 18, 2009 

## EXECUTIVE SUMMARY

Introduction Fine particulate matter, also known as fine particles and PM 2.5 , refers to airborne particles less than or equal to 2.5 micrometers in diameter. Fine particles are treated as though they are a single pollutant, but they come from many different sources and are composed of many different compounds. PM 2.5 exposure adversely affects human h ealth, especially respiratory and cardiovascular systems. Individu als particularly sensitive to PM 2.5 exposure include children, people with heart and lung di sease, and older adults.

A variety of meteorological and geographic factors influence the concentration levels of fine particles, including both the regi onal and local distribution of urbanized areas, primary and precursor emissions sources, and natural features such as oceans and forests. PM 2.5 concentrations can also be high and exceed the national ambient air quality standards (NAAQSs) for fine particulate matter at any time of the y ear. Therefore, the United States Environmental Protection Agency (USEPA) mandate s the year round monitoring of PM 2.5 concentrations throughout the country.

Nonattainment Designation The nonattainment designation was an action ta ken by the USEPA under Section 107(d) of the Clean Air Act (CAA). The CAA requires that so me areas be designated as nonattainment if a monitor is found to be in violation of a NA AQS. The USEPA took designation action in 2005 based on the ambient data from 2001-2003. At that time, the design value for Hickory area (Catawba County) was 15.6 micrograms per cubic meter (μg/m 3 ) and the design value for the Greensboro/Winston-Salem/High Point area (Davids on and Guilford Counties, referred to as the Triad area) was 15.9 μg/m 3

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Current Air Quality The most recent three years of fine particulat e monitoring data (2006-2008) for both the Hickory and Triad PM 2.5 nonattainment areas demonstrate complia nce with the annual fine particulate matter NAAQS. The three year design valu e at the Hickory monitor is 14.2 μg/m 3 . In the Triad nonattainment area, the three year design va lue at the Lexingt on monitor is 14.5 μg/m 3 and the three year design value at th e Mendenhall monitor is 12.9 μg/m 3 . Additionally, the annual design values at all three sites are trending downward.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 iii Redesignation Demonstration and Ma intenance Plan December 18, 2009 Maintenance Plan Requirements

The State of North Carolina has implemented pe rmanent and enforceable reductions in sulfur dioxide (SO 2 ) and nitrogen oxide (NO x ) emissions, which are precursor s to fine particulates. These actions include implementing the on-board diagnostic vehicle inspection and maintenance program that began on July 1, 2002, and an open bur ning ban during air quality action days. In addition, there have been several State rules that have resulted in reductions in emissions within and surrounding the nonattainment area. These State actions include the NO x State Implementation Plan (SIP) Call, the Clean Smokes tacks Act legislation, a nd heavy-duty engine stop-gap rule for model years 2005 and 2006. Finall y, several actions at the Federal level by the USEPA have resulted in lower emissions through out the eastern portion of the country. These Federal actions include the Tier 2 engine standards for light and medium duty vehicles, heavyduty engine standards, the low sulfur gasoline and diesel requ irements, and off-road engine standards.

This combination of State and Federal acti ons has resulted in cleaner air in the PM 2.5 nonattainment areas, and the anticipated future benefits from these programs are expected to result in continued maintenance of the 1997 annual PM2.5 NAAQS in this region. A baseline year emissions inventory for NO x , SO 2 , and direct PM 2.5 was developed for 2008, since the design value for the 2006-2008 period showed a ttainment of the 1997 annual PM2.5 NAAQS. Future year emissions inventories were al so developed for the interim years 2011, 2014, 2017, and a final year emission inventory was develo ped for 2021. The future year emissions were lower than the 2008 emissions in all cas es. This demonstrates that the PM 2.5 nonattainment areas are expected to main tain the 1997 annual PM 2.5 NAAQS through 2021, since in no future year are the emissions expected to be greater than they were in the ba seline year. The areas are also in compliance with Section 110 and Pa rt D requirements of the CAA.

Conclusion and Request for Redesignation
Based on the information above and criteria esta blished in Section 107(d )(3)(E) of the CAA, North Carolina is requesting that the USEPA re designate the Hickory an d Greensboro/WinstonSalem/High Point fine particulate matter nonattainme nt areas to attainment. The monitoring data clearly shows that the region has attained the annual fine part iculate matter standard, and the maintenance demonstration shows that the future emission inventories are expected to be lower than the attainment year inventory through the implementation of the va rious control measures listed above.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 iv Redesignation Demonstration and Ma intenance Plan December 18, 2009 TABLE OF CONTENTS
EXECUTIVE SUMMARY ............................................................................................................ ii
1.0 INTRODUCTION .............................................................................................................. ... 1-1 1.1 WHAT IS FINE PA RTICULATE MATTER? ................................................................. 1-1 1.2 CLEAN AIR ACT OF 1990 .............................................................................................. 1-2 1.3 AIR QUALITY HISTORY ............................................................................................... 1-2 1.4 CLEAN AIR ACT REDESIGNATION CRITERIA ........................................................ 1-3 2.0 AIR QUALITY ............................................................................................................... ....... 2-1 2.1 HISTORIC AIR QUALITY (1999 – 2007) ...................................................................... 2-1 2.2 RECENT AIR QUALITY VALUES (2006 –2008) ......................................................... 2-3 2.3 PERMANENT AND ENFORCEAB LE EMISSIONS REDUCTIONS ........................... 2-4
3.0 MAINTENANCE PLAN ....................................................................................................... 3- 1 3.1 CONCEPT OF NORTH CAROLINA 'S MAINTENANCE PLAN ................................. 3-1 3.2 FOUNDATION CONTROL PROGRAM ........................................................................ 3-2 3.2.1 Federal Control Measures .......................................................................................... 3-2 3.2.2 State Control Measures .............................................................................................. 3- 5 3.2.3 Additional Programs Supporting Maintenance .......................................................... 3-9 3.3 EMISSIONS INVENTORIES AND MA INTENANCE DEMONSTRATION ............. 3-10 3.3.1 Theory of Approach ................................................................................................. 3-1 0 3.3.2 Emission Inventories ................................................................................................ 3- 11 3.3.3 Summary of Emissions ............................................................................................ 3-15 3.3.4 Maintenance Demonstration .................................................................................... 3-16 3.4 CONTINGENCY PLAN ................................................................................................. 3-17 3.4.1 Overview ............................................................................................................... ... 3-17 3.4.2 Primary and Secondary Triggers ............................................................................. 3-18 3.4.3 Action Resulting From Trigger Activation .............................................................. 3-19 3.4.4 Tracking Program for Ongoing Maintenance .......................................................... 3-20
4.0 MOTOR VEHICLE EMISSIONS BU DGET FOR CONFORMITY ................................... 4-1 4.1 TRANSPORTATION CONFORMITY ............................................................................ 4-1 4.2 POLLUTANTS TO BE CONSIDERED ........................................................................... 4-1 4.2.1 Precursor Pollutants NO x , VOC, and Ammonia ........................................................ 4-2 4.2.2 Reentrained Road Dust .............................................................................................. 4-2 4.2.3 Precursor Pollutant SO 2 ............................................................................................. 4-3 4.2.4 Direct PM 2.5 Emissions .............................................................................................. 4-5 4.3 SAFETY MARGIN ........................................................................................................... 4-7 4.4 MOTOR VEHICLE EMISSION BUDGETS ................................................................... 4-7Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 v Redesignation Demonstration and Ma intenance Plan December 18, 2009 4.5 NEW SAFETY MARGINS ............................................................................................ 4-10
5.0 STATE IMPLEMENTATION PLAN APPROVAL ............................................................. 5-1 5.1 INTRODUCTION ............................................................................................................. 5-1 5.2 EVIDENCE OF COMPLIANCE ...................................................................................... 5-1
6.0 STATE COMPLIANCE WITH CLEA N AIR ACT REQUI REMENTS.............................. 6-1
7.0 CONCLUSION ................................................................................................................ ...... 7-1Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 vi Redesignation Demonstration and Ma intenance Plan December 18, 2009 LIST OF APPENDICES
APPENDIX A: CORRESPONDENCE AND GUIDANCE DOCUMENTS
APPENDIX B: STAKEHOLDER CORRESPO NDENCE REGARDING MOTOR VEHICLE EMISSION BUDGETS
APPENDIX C.1: POINT SOURCE EM ISSION INVENTORY DOCUMENTATION
APPENDIX C.2: AREA SOURCE EM ISSION INVENTORY DOCUMENTATION APPENDIX C.3: ON-ROAD MOBILE SOURCE EMISSION INVENTORY DOCUMENTATION
APPENDIX C.4: NONROAD MOBILE SOURCE EMISSION INVENTORY DOCUMENTATION
APPENDIX D: MENDENHALL DATA REPLACEMENT DOCUMENTATION
APPENDIX E: PUBLIC NOTICE REPORT , COMMENTS RECEIVED AND RESPONSES

LIST OF TABLES Table 2-1 Historic PM 2.5 Annual Averages (1999-2007) ............................................................ 2-2 Table 2-2 Historic PM 2.5 Design Values (2000 – 2007) .............................................................. 2-3 Table 2-3 Current PM 2.5 Data (2006 -2008) ................................................................................ 2-4 Table 2-4. Annual Emissions from NC Sources in USEPA Acid Rain Database ....................... 2-7 Table 2-5. Annual SO 2 Emissions for Utilities Near the PM 2.5 Nonattainment areas (tons/year) 2-9 Table 3-1 OBDII Phase-in Effective Dates ................................................................................. 3-6 Table 3-2 I/M NO x Benefits by County ....................................................................................... 3-6 Table 3-3 Estimated Emission Reductions from Open Burning Regulation ............................... 3-8 Table 3-4. Point Source NO x Emissions (tons per year) ............................................................ 3-11 Table 3-5 Point Source SO 2 Emissions (tons per year) ............................................................. 3-12 Table 3-6. Point Source PM 2.5 Emissions (tons per year) .......................................................... 3-12 Table 3-7. Area Source NO x Emissions (tons per year) ............................................................ 3-12 Table 3-8. Area Source SO 2 Emissions (tons per year) ............................................................. 3-13 Table 3-9. Area Source PM 2.5 Emissions (tons per year) .......................................................... 3-13 Table 3-10. On-road Mobile Source NO x Emissions (tons per year) ........................................ 3-13 Table 3-11. On-road Mobile Source SO 2 Emissions (tons per year) ......................................... 3-14 Table 3-12. On-road Mobile Source PM 2.5 Emissions (tons per year) ...................................... 3-14 Table 3-13. Nonroad Mobile Source NO x Emissions (tons per year) ........................................ 3-14 Table 3-14. Nonroad Mobile Source SO 2 Emissions (tons per year) ........................................ 3-15Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 vii Redesignation Demonstration and Ma intenance Plan December 18, 2009 Table 3-15. Nonroad Mobile Source PM 2.5 Emissions (tons per year) ...................................... 3-15 Table 3-16. Total Man-Made NO x Emissions (tons per year) ................................................... 3-15 Table 3-17. Total Man-Made SO 2 Emissions (tons per year) .................................................... 3-15 Table 3-18. Total Man-Made PM 2.5 Emissions (tons per year) ................................................. 3-16 Table 3-19 Maintenance De monstration for Hickory PM 2.5 Nonattainment Area ................... 3-16 Table 3-20 Maintenance De monstration for Triad PM 2.5 Nonattainment Area ........................ 3-16 Table 3-21 Safety Margin for Hickory PM 2.5 Nonattainment Area .......................................... 3-17 Table 3-22 Safety Margin for Triad PM 2.5 Nonattainment Area ............................................... 3-17 Table 4-1. On-Road Mobile Source PM 2.5 Emissions ................................................................ 4-8 Table 4-2. On-Road Mobile Source NO x Emissions .................................................................. 4-9 Table 4-3 Catawba County MVEB ............................................................................................. 4- 9 Table 4-4 Davidson County MVEB ........................................................................................... 4-9 Table 4-5 Guilford County MVEB ........................................................................................... 4-1 0 Table 4-6 New Safety Margins for the Hickory PM 2.5 nonattainment area .............................. 4-10 Table 4-7 New Safety Margins for the Triad PM 2.5 nonattainment area .................................. 4-11

LIST OF FIGURES Figure 1-1. USEPA De signated Annual PM 2.5 Nonattainment Areas in North Carolina ........... 1-3 Figure 2-1. PM 2.5 Monitor Locations in the PM 2.5 Nonattainment Areas................................... 2-1 Figure 2-3. Location of Power Plan ts in the Vicinity of the PM 2.5 Nonattainment Areas .......... 2-8 Figure 3-1. North Carolina’s Inspection & Maintenance (I/M) Ph ase-In Map .......................... 3-5 Figure 4-1. Speciated Data for the Hickory area (left) and the Tr iad area (right) ....................... 4-3 Figure 4-2. North Carolina’s 2009 Statewide SO 2 Emissions .................................................... 4-4 Figure 4-3. Hickory Area 2009 Primary PM 2.5 Emissions ........................................................... 4-6Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 viii Redesignation Demonstration and Ma intenance Plan December 18, 2009 LIST OF ACRONYMS Acronym Definition oF Degrees Fahrenheit CAA Clean Air Act CAAA Clean Air Act Amendments of 1990 CERR Consolidated Emissions Reporting Rule CFR Code of Federal Regulations CO Carbon Monoxide E-GAS 5.0 Economic Growth Analysis System version 5.0 FR Federal Register FRM Federal Reference Method GUAMPO Greensboro Urban Area Metropolitan Planning Organization HC Hydrocarbons I/M Inspection and Maintenance MVEB Motor Vehicle Emission Budget NAAQS National Ambient Air Quality Standard NCCSA North Carolina Clean Smokestacks Act NCDAQ North Carolina Division of Air Quality NCDENR North Carolina Depart ment of Natural Resources NCDOT North Carolina Depart ment of Transportation NO x Nitrogen Oxides PM Particulate Matter PM 2.5 Fine Particulate Matter ppm Parts per million QA Quality Assure SAFETY-LU Safe, Accountable, Flexible, Efficien t Transportation Equity Act: A Legacy for Users SIP State Implementation Plan SO 2 Sulfur Dioxide SO x Sulfur Oxides SUV Sports Utility Vehicle TIP Transportation Improvement Program TPD Tons per Day TSP Total Suspended Particulates USEPA U.S. Environmental Protection Agency VMT Vehicle Miles Traveled VOC Volatile Organic Compounds μg/m 3 Micrograms per cubic meter μm MicrometerHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 1-1 Redesignation Demonstration and Ma intenance Plan December 18, 2009 

### 1.0 INTRODUCTION

1.1 WHAT IS FINE PARTICULATE MATTER?
Fine particulate matter, also known as fine particles and PM 2.5 , refers to airborne particles less than or equal to 2.5 micrometers (μm) in diameter . Fine particles are tr eated as though they are a single pollutant, but they come from many different sources and are composed of many different compounds. PM 2.5 exposure adversely affects human h ealth, especially respiratory and cardiovascular systems. Individu als particularly sensitive to PM 2.5 exposure include children, people with heart and lung di sease, and older adults.

PM 2.5 can be liquid, solid, or can have a solid core surrounded by liquid. PM 2.5 can include material produced by combustion, photochemical reactions, and can contain salt from sea spray and soil-like particles. Partic les are distinguished based on th e method of formation. Primary particles are particles directly emitted into th e atmosphere and retain the same chemical composition as when they were released. Second ary particles are those formed through chemical reactions involving atmospheric oxygen, water vapor, hydroxyl radi cal, nitrates, sulfur dioxide (SO 2 ), oxides of nitrogen (NO x ), and organic gases from natu ral and anthropogenic sources. PM 2.5 can therefore be composed of varying am ounts of different spec ies, including:

• Sulfates

• Nitrates (usually found in the form of ammonium nitrate)

• Ammonium

• Hydrogen ion

• Particle bound water

• Elemental carbon

• Organic compounds

o Primary organic species (from cooking and combustion)

o Secondary organic compounds

• Crustal material (includes calcium, aluminum, silicon, magnesium, and iron)

• Sea salt (generally only found at coastal monitoring sites)

• Transitional metals

• Potassium (generally from wood burning or cooking)Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 1-2 Redesignation Demonstration and Ma intenance Plan December 18, 2009 The most significant sources of PM 2.5 and its precursors are coal-f ired power plants, industrial boilers and other combustion sources. Thes e emissions are often transported over large distances. Other sources of PM 2.5 emissions include mobile sources, area sources, fires, windblown dust, and biogenic, i.e ., naturally occurring emissions su ch as sea salt from oceans and organics from trees.

A variety of meteorological and geographic factors influence the concentration levels of fine particles, including both the regi onal and local distribution of urbanized areas, primary and precursor emissions sources, and natural features such as oceans and forests. PM 2.5 concentrations can also be high and exceed the national ambient air quality standards (NAAQSs) for fine particulate matter at any time of the y ear. Therefore, the United States Environmental Protection Agency (USEPA) mandate s in the Code of Federal Re gulations (CFR) the year round monitoring of PM 2.5 concentrations throughout the country (40 CFR 58.App. D, 4.7).

In 1997, the USEPA promulgated the primary (health) and secondary (welfare) NAAQSs for PM 2.5 (40 CFR 50.7), setting the standard at a 15.0 micrograms per cubic meter (μg/m 3 ) annual average and at a 65 μg/m 3 daily or 24-hour average. A violation of the annual PM 2.5 NAAQS occurs when the annual average PM 2.5 concentration averaged over a three consecutive year period is equal to or greater than 15.1 μg/m 3 . A violation of the daily PM 2.5 NAAQS occurs when the annual 98 th percentile of daily PM 2.5 concentration averaged over a three consecutive year period is equal to or greater than 66 μg/m 3 . The annual or daily PM 2.5 design value for a nonattainment area is the highest design value for any monitor in that area.

1.2 CLEAN AIR ACT OF 1990

Since the 1977 amendments to the Clean Air Ac t (CAA), areas of the country that had not attained the ambient standard for a particul ar pollutant were formally designated as nonattainment for that pollutant. This formal designation concept was retained in the 1990 CAA Amendments (CAAA). With th e implementation of the PM 2.5 standard, areas could be designated under Section 172 of th e CAAA (subpart 1) and have fi ve years from designation to attain the standard.

1.3 AIR QUALITY HISTORY
On January 5, 2005, the USEPA designated the Hickory area (Catawba County) and the Greensboro/Winston-Salem/High Point area (refe rred to as the Triad area and consisting of Davidson and Guilford Counties) as “subpart 1” nonattainment for the annual PM 2.5 standard based on the ambient data from 2001-2003 (Figure 1- 1). At that time, the design values for theHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 1-3 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Hickory and Triad nonattainment areas were 15.6 μg/m 3 and 15.9 μg/m 3 , respectively. The official designation and clas sification was published in the Federal Register (FR) on January 5, 2005 (70 FR 944) and became effectiv e on April 5, 2005. Prior to the implementation of the new PM 2.5 standard, these areas had been in atta inment of the coarse particulate matter (PM 10 ) and total suspended particulat e matter (TSP) standards. All areas of North Carolina met the 1997 daily PM 2.5 standard.

Figure 1-1. USEPA Designated Annual PM 2.5 Nonattainment Areas in North Carolina

All violating monitors we re attaining the annual PM 2.5 standard with the inclusion of the 2008 ambient data. The 2006-2008 design values for th e Hickory and Triad nonattainment areas are 14.2 μg/m 3 and 14.5 μg/m 3 , respectively. Both areas continue to attain the daily PM 2.5 standard.

1.4 CLEAN AIR ACT RE DESIGNATION CRITERIA
Section 107(d) (3) (E) of the CAA, as amended, st ates an area can be redesignated to attainment if the following conditions are met:

1. The USEPA has determined that the NAAQS ha ve been attained. For fine particulate matter, the areas must show that the average of the annual average values from three (3) consecutive calendar years of quality-assure d air quality monitoring data must be 15.0 μg/m 3 or lower.

2. The applicable implementation plan has b een fully approved by the USEPA under section 110(k).Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 1-4 Redesignation Demonstration and Ma intenance Plan December 18, 2009 3. The USEPA has determined that the improvement in air quality is due to permanent and enforceable reductions in emissions. To de monstrate this, the State should estimate the percent reduction (from the y ear used to determine the de sign value for designation and classification) achieved from Fede ral, State, and local measures.

4. The State has met all applicable requirements for the area under Section 110 and Part D.

5. The USEPA has fully approved a maintenance pl an, including a contingency plan, for the areas under section 175A.

In the sections to follow, the North Carolina Department of Environment and Natural Resources, Division of Air Quality (NCDAQ) w ill provide the technical data necessary to show that both the Hickory and Triad nonattainment areas have attain ed and are expected to maintain the annual fine particulate matter standard, and have met th e requirements for redesignation set forth above.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 2-1 Redesignation Demonstration and Ma intenance Plan December 18, 2009 

### 2.0 AIR QUALITY

2.1 HISTORIC AIR QUALITY (1999 – 2007)
The NCDAQ has collected ambient monitoring data for Catawba, Davidson, and Guilford Counties since 1999. At the time of fine particul ate matter designations, there were three Federal Reference Method (FRM) monitors for fine partic ulate matter in the th ree counties; Hickory, Lexington, and Mendenhall (Figure 2-1). In late 2007, another PM 2.5 FRM monitor was installed in Guilford County, located in Colfax which is lo cated just west of Greensboro. These monitors were installed in accordance with the 40 CFR 58.

Figure 2-1. PM 2.5 Monitor Locations in the PM 2.5 Nonattainment Areas

Data from the fourth quarter of 2006 at Mendenhall is incomple te due to construction at the monitoring site and complications in relocating th e site. The NCDAQ had to move the site since the school where the monitoring site is located constructed a two-story field house immediately adjacent to the monitoring site (letter to USEPA Region 4, A ppendix D). The school had not notified the NCDAQ of its intention to build the field house. During a routine site visit, the NCDAQ discovered that construction had started within four meters of the monitoring site. At that point, the monitor no longer met the ambient monitoring siting criteria and had to be shut down and moved.

A new site was promptly found a nd appropriate permits were appl ied for. It took the NCDAQ four months (instead of an estimated 3 weeks) to resolve all the necessary permits and completeHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 2-2 Redesignation Demonstration and Ma intenance Plan December 18, 2009 the relocation of the monitor. This unfortunate circumstance resulted in most of the fourth quarter to go unmonitored.

The USEPA guidance does not address missing m onitoring data for an entire quarter. The NCDAQ decided the best option was to develop regressive analysis between Mendenhall and surrounding monitors. Data from surrounding monito rs was incorporated into the regressive analysis to obtain a best estimate for the four th quarter at Mendenhall. Please see Appendix D for more details.

The Mendenhall monitor has never violated the PM 2.5 standards and has consistently had annual averages that were 1 – 2 μ g/m 3 below the annual PM 2.5 NAAQS. The NCDAQ is confident that had the monitor been operating during the 2006 fourth quarter, th e ambient air quality levels would have been consistent with the estimat ed values the NCDAQ has developed. The USEPA has also proposed to determine that the Gr eensboro/Winston-Salem/High Point nonattainment area has attained the 1997 PM 2.5 NAAQS (74 FR 51249).

Tables 2-1 and 2-2 below show the air qua lity data and corresponding design values, respectively, for the monitors in the both the Hickory and Tr iad nonattainment areas from 1999 to 2006. Table 2-2 indicates that the Hickory and Lexington monito rs were in violation of the PM 2.5 NAAQS for this period, while the Mendenhall monitor was consistently below the annual PM 2.5 standard.

Table 2-1 Historic PM 2.5 Annual Averages (1999-2007)
Monitor Fine Particulate Matter Annual Average (μg/m 3 ) 1999 2000 2001 2002 2003 2004 2005 2006 2007 Hickory Nonattainment Area Hickory AIRS ID #37-035-0004 Catawba County 17.42 17.63 15.98 15.36 15.04 15.00 15.95 15.17 14.54

Triad Nonattainment Area Lexington AIRS ID #37-057-0002 Davidson County 17.34 18.04 16.45 15.88 15.17 15.18 15.40 15.13 14.64

Mendenhall AIRS ID #37-081-0013 Guilford County 13.72 13.32 13.97 14.01 14.06* 13.05
*Estimated fourth quarter dataHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 2-3 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Table 2-2 Historic PM 2.5 Design Values (2000 – 2007)

Monitor Design Value (μg/m 3 ) 99-01 00-02 01-03 02-04 03-05 04-06 05-07 Hickory Nonattainment Area Hickory AIRS ID #37-035-0004 Catawba County 17.0 16.3 15.5 15.1 15.3 15.4 15.2

Triad Nonattainment Area Lexington AIRS ID #37-057-0002 Davidson County 17.3 16.8 15.8 15.4 15.3 15.2 15.1

Mendenhall AIRS ID #37-081-0013 Guilford County 13.7 13.8 14.0* 13.7*

Note: Bolded values represent violations of the annual fine particulate matter standard. *Estimated fourth quarter 2006 data used in Design Value calculation.

2.2 RECENT AIR QUALITY VALUES (2006 –2008)
The most recent three years of PM 2.5 monitoring data (2006-2008) for both the Hickory and Triad nonattainment areas demonstrate complian ce with the annual fine particulate matter NAAQS. Table 2-3 is a summary of the annual averages for the monitors located in the nonattainment areas for 2006-2008 and their respective design values . The Colfax monitor only has data for 2008 and therefore does not have su fficient data to calculate a design value. However, the 2008 annual average is significantly below the annual PM 2.5 standard. Therefore, the NCDAQ is confident the area is in compliance of the NAAQS. The 2008 PM 2.5 monitoring data for both the Hickory and the Triad areas have been fully quality assured and were officially submitted to the USEPA on May 9, 2009.

As noted in the previous sect ion, the fourth quarter data fo r 2006 at the Mendenhall monitoring site is incomplete. After an extensive analys is, the NCDAQ is confident that the Mendenhall monitor is not in violation of the PM 2.5 NAAQS (see Appendix D). It should be noted that the Mendenhall monitor has never violated the annual PM 2.5 NAAQS in the history of its operation.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 2-4 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Table 2-3 Current PM 2.5 Data (2006 -2008)
Monitor Year PM 2.5 Annual Average (μg/m 3 ) Design Value (μg/m 3 ) 2006-2008 Hickory Nonattainment Area Hickory AIRS ID #37-035-0004 Catawba County 2006 15.17 14.2 2007 14.54 2008 12.85 Triad Nonattainment Area Lexington AIRS ID #37-057-0002 Davidson County 2006 15.13 14.5 2007 14.64 2008 13.66
Mendenhall AIRS ID #37-081-0013 Guilford County 2006 14.06* 12.9* 2007 13.05 2008 11.45 Colfax AIRS ID #37-081-0141 Guilford County 2006 N/A N/A 2007 N/A 2008 12.21 *Estimated fourth quarter 2006 data used in Design Value calculation.

2.3 PERMANENT AND ENFORCEAB LE EMISSIONS REDUCTIONS

There are several State and Federa l measures that have been en acted in recent years that are resulting in permanent emissions reductions. Most of these emission reductions are due to regulations and thus are enforceable. However, a few measures are non-regulatory but will still result in emission reductions. A list of thos e measures that contributed to the permanent emission reductions are listed below and are more fully described in Section 3.2.

The federal measures that have been implemented include:

• Tier 2 vehicle standard s: In addition to NO x controls, the Tier 2 rule also reduced the sulfur content of gasoline to 30 parts pe r million (ppm) starting in January of 2006. Most gasoline sold in Nort h Carolina prior to January 2006 had a sulfur content of about 300 ppm. These emission reduc tions are federally enforceable.

• Heavy-duty gasoline and diesel highway vehicle standards: Second phase of standards and testing procedures, which began in 2007, will reduce particulate matter from heavy-duty highway engines, and will also reduce highway diesel fuel sulfur content to 15 ppm since the sulfur dama ges emission control devices. The totalHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 2-5 Redesignation Demonstration and Ma intenance Plan December 18, 2009 • program is expected to achieve a 90% reduc tion in particulate matter (PM) emissions. These emission reductions are federally enforceable.

• Nonroad spark-ignition engines and recreati onal engines standards: Tier 1 of this standard was implemented in 2004 and Ti er 2 started in 2007, and will reduce particulate matter emissions. These emissi on reductions are federally enforceable.

• Large nonroad diesel engine standards: Promulgated in 2004, this rule is being phased in between 2008 and 2014. This rule will also reduce sulfur content in nonroad diesel fuel. When fully implemented, this rule will reduce NO x and direct PM 2.5 emissions by over 90%. These emission reductions are federally enforceable.

The state measures that have been implemented include:

• Clean Air Bill: This State legislation expanded the inspection and maintenance (I/M) program from 9 counties to 48. It was phased-in in the Hickory and Triad nonattainment areas from July 1, 2002 through July 1, 2003. This program will reduce NO x and Volatile Organic Compound (VOC s), and Carbon Monoxide (CO). These emission reductions are state enforceable.

• Open burning: This regulation prohibits the burning of man-made materials throughout the State. Additionally, this re gulation prohibits open burning of yard waste in areas that the NCDAQ forecasts an air quality action da y. The open burning regulation will reduce fine particulate matter emissions, as well as NO x , VOCs and CO emissions. These emission re ductions are state enforceable.

• Heavy duty diesel engine gap filling rule: Th is rule requires engine manufacturers to perform the supplemental testing requirem ents for heavy duty diesel engines for model years 2005 and 2006 due to delays in the USEPA’s rule and will reduce PM emissions. These emission reductions are state enforceable.

• Clean Smokestack Act: This rule requires coal-fired power plan ts to reduce annual NO x emissions by 77% by 2009 and to reduce annual sulfur dioxide emissions by 49% by 2009 and 73% by 2013. This legislation sets a cap on NO x and SO 2 emissions, which the public utilities cannot meet by purch asing emission credits. These emission reductions are state enforceable.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 2-6 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 • NO x State Implementation Plan (SIP) Call ru le: This rule was predicted to reduce summertime NO x emissions from power plants and other industries by 68%. These emission reductions are state a nd federally enforceable.

• Diesel Retrofits: As part of the Nort h Carolina Mobile Source Emission Reduction Grants program, a number of cities, counties and school dist ricts have installed Diesel Oxidation Catalysts (DOCs) or Diesel Pa rticulate Filters (DPFs) on their diesel equipment. The vehicles that have been retrofitted include schools buses, as well as county fleet trucks for solid waste pickup. These types of filters are designed to remove particulate matter, and when used with ultra low sulfur diesel fuel, NO x and VOC emissions are also reduced. Even though these emission reductions are voluntary and not enforceable, they are st ill considered permanent reductions.

• Diesel Emissions Reduction Act (DERA): DERA provides new diesel emissions reduction grant authority for the USEPA. Th is funding is used to achieve significant reductions in diesel emissions that improve air quality a nd protect public health. The DERA funds that the NCDAQ have received have been used to retrofit, repower, or replace existing diesel engines from on-road and nonroad mobile source vehicles/equipment. This program will reduce PM, NOx, and VOC emissions. Even though these emission reductions are voluntary and not enfo rceable, they are still considered permanent reductions.

One of the largest components of PM 2.5 in the southeastern United States is sulfate. This is formed through various chemical reactions from the precursor SO 2 . Another component of PM 2.5 is nitrate, which is formed from the precursor NO x . Controls installed on coal-fired power plants over the past few years have significan tly reduced these two pr ecursor pollutants. Table 2-4 presents the annual emissions for the North Carolina sources that are in the USEPA’s Clean Air Markets database. Since 2002, when the NO x controls started coming on-line to meet the NO x SIP Call and later to meet the North Carolina Clean Smokestacks Act (NCCSA), the NO x emissions from subject sources have decrea sed over 84,000 tons per year. To meet the SO 2 emission caps in the NCCSA, the North Caro lina public utilities started installing SO 2 controls late in 2005. Since then, the SO 2 emissions from the utilities in North Carolina have decreased nearly 274,000 tons. The decline in SO 2 emissions has coincided w ith the decline in annual PM 2.5 concentrations across North Carolina.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 2-7 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Table 2-4. Annual Emissions from NC Sour ces in USEPA Acid Rain Database Year Annual SO 2 Emissions (Tons) Annual NO x Emissions (Tons) 2002 462,993 145,706 2003 462,041 135,879 2004 472,320 124,079 2005 500,936 114,300 2006 462,143 108,584 2007 370,827 64,770 2008* 227,030 61,669 *Data from 2008 is considered preliminary.

As mentioned in Section 1.1, PM 2.5 is composed of many species from varying sources. Figure 2-2 presents the North Carolina statewide averaged PM 2.5 speciation data from the speciation trends networ k (STN) monitors for th e year 2004. The figure presents sulfates and organic carbons as the main contributors to PM 2.5 , each with 29% of the total PM 2.5 mass. The “other” portion of the PM 2.5 that accounts for 17% of the mass can be attributed to water, sea salts, and other trace materials cap tured with the STN monitors.

Figure 2-2. North Carolina PM 2.5 Speciation for 2004Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 2-8 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Organic carbon is predominately at tributed to biogenic emission s ources and sulfate is associated with SO 2 emissions. When evaluated across No rth Carolina and al so throughout both nonattainment areas and surrounding regions, the SO 2 is primarily from the point source sector. For this reason, reductions in SO 2 emissions will provide the greatest reductions in PM 2.5 ambient concentrations. Figure 2-3 displays the location of the major power plants located near the PM 2.5 nonattainment areas. Table 2-5 presents the SO 2 emissions from these nine power plants as reported from the USEPA acid rain data base. It is clearly demonstrated that the annual emissions from these facilities have signifi cantly decreased since 2005, with over 250,000 tons of SO 2 emission reduction in the 2008 compared to 2005. This is over a 50% reduction in utility SO 2 emissions that are permanent and enforceable. These reductions have taken place beginning in 2006, which includes the first year of the a ttaining 3-year design va lue. Since the final compliance date for the NCCSA SO 2 emissions caps is 2013, future design values are expected to continue to decline below the 2006-2008 attaining design values.

Figure 2-3. Location of Power Pl ants in the Vicinity of the PM 2.5 Nonattainment AreasHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 2-9 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Table 2-5. Annual SO 2 Emissions for Utilities Near the PM 2.5 Nonattainment areas (tons/year) Facility County 2005 2006 2007 2008 Belews Creek Rockingham 96,813 95,290 86,388 17,252 Buck Rowan 9,582 9,560 10,261 7,353 Cliffside Rutherford 28,209 29,128 27,566 29,421 Dan River Stokes 4,248 7,068 7,672 6,687 Allen Gaston 45,424 45,395 50,550 49,578 Marshall Catawba 100,540 85,050 24,754 6,174 Mayo Person 27,076 24,499 22,811 20,072 Riverbend Gaston 13,964 15,148 15,907 15,942 Roxboro Person 101,444 94,627 65,247 24,436 Total 427,301 405,765 311,155 176,914Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-1 Redesignation Demonstration and Ma intenance Plan December 18, 2009 

### 3.0 MAINTENANCE PLAN

3.1 CONCEPT OF NORTH CARO LINA'S MAINTENANCE PLAN
The State's plan for maintaining compliance with the ambient air quality standard for annual fine particulate matter in the Hickory and Green sboro/Winston-Salem/High Point nonattainment areas consists of three major parts: a foundation control program , a maintenance demonstration, and a contingency plan. The foundation control program consists of the current Federal and State control measures already in effect, as well as the future benefits of the federal cleaner engine programs, and low sulfur gasoline and lo w sulfur diesel fuel programs. Additionally, although the federal Clean Air Interstate Rule (C AIR) has been remanded back to the USEPA, a replacement rule is expected to be promulgated in 2011. This new rule is expected to be as stringent as CAIR.

The NCDAQ has implemented programs that will remain enforceable and are hereby submitted as the plan to ensure that maintenance of th e annual fine particulate matter standard will continue. Sources are prohibited from reducing emission controls (anti-backsliding) following the redesignation of the area unless such a chan ge is first approved by the USEPA as a revision to the North Carolina SIP that is consistent with Section 110(l) of the Clean Air Act.

For the maintenance demonstration, the base year of 2008 was chosen since it is a year that falls within the attaining design va lue period of 2006-2008 and some em issions inventory data was already developed for this year. The interi m years chosen were: 2011, 2014, and 2017 since the USEPA recommends three-year increments for inte rim years. The final year of the maintenance demonstration is 2021, since the CAA requires maintenance for at least ten years after redesignation. The maintenan ce demonstration consists of a comparison between the 2008 baseline emissions inventory and the projected emissions inventories (for 2011, 2014, 2017, and 2021), which consider economic and population grow th as well as expected controls. The comparison shows that the total emissions in each of the interim years and the final year will be lower than in the base year, which de monstrates maintenance of the annual PM 2.5 standard. The reductions in emissions are due to the foundation control programs outlined below.

The North Carolina contingency plan involves tracking and trigge ring mechanisms to determine when contingency measures are needed and a process of implementing appropriate control measures. The primary trigger of the contingenc y plan will be a violation of the ambient air quality standard for annual PM 2.5 . The secondary trigger will be a monitored air quality pattern that suggests an actual annual PM 2.5 NAAQS violation may be im minent, such as repeated exceedances of the daily fine pa rticulate matter standard.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-2 Redesignation Demonstration and Ma intenance Plan December 18, 2009 3.2 FOUNDATION CONTROL PROGRAM
The main element of the maintenance plan is the foundation control program. The foundation control program contains the controls necessary to maintain the ambient air quality standards. The purpose of the foundation control program is to prevent the ambient air quality standards from being violated and thereby eliminate the n eed for more costly controls being imposed on industry and the general public. Each component of the State's foundation control program is essential in demonstrating maintenan ce of the air quality standards.

The foundation control program consists of Federa l and State measures. The Federal measures include the cleaner fuel programs and the federa l highway motor vehicle and off-road equipment control program and controls on power plants. State measures include the I/M program, the NO x SIP Call rule, the NCCSA, and open burning and idle reduction regulations. The state measures also include additional programs th at support maintenance of the PM 2.5 standard. Most of these emission reductions are due to regulations and th us are enforceable. However, a few measures are non-regulatory but will still result in emission reductions. All of these programs have already been implemented or are in the process of being implemented.

3.2.1 Federal Control Measures
Tier 2 Vehicle Standards Federal Tier 2 vehicle standards require all passenger vehicles in a manufacturer’s fleet, including light-duty trucks and Sport Utility Vehi cles (SUVs), to meet an average standard of 0.07 grams of NO x per mile. Implementation began in 2004, with full compliance required by 2007. The Tier 2 standards also cover passeng er vehicles over 8,500 pounds gross vehicle weight rating (the larger pi ckup trucks and SUVs), which are not covered by the Tier 1 regulations. For these vehicles, the standa rds were phased in beginning in 2008, with full compliance required by 2009. The new standards requi re vehicles to be 77% to 95% cleaner. The Tier 2 rule also reduced the sulfur content of gasoline to 30 ppm starting in January of 2006. Most gasoline sold in North Carolina prior to Ja nuary 2006 had a sulfur content of about 300 ppm. Sulfur occurs natura lly in gasoline and interferes with the operation of catalytic converters on vehicles, which results in higher NO x emissions. Lower-sulfur gasoline is necessary to achieve the Tier 2 vehicle emissi on standards. These emission reductions are federally enforceable.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-3 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Heavy-Duty Gasoline and Diesel Highway Vehicles Standards The USEPA standards designed to reduce NO x and VOC emissions from heavy-duty gasoline and diesel highway vehicles bega n to take effect in 2004. The se cond phase of the standards and testing procedures began in 2007 and will reduc e particulate matter from heavy-duty highway engines, and reduces highway di esel fuel sulfur content to 15 ppm since the sulfur damages emission control devices. The total program is expected to achieve a 90% reduction in PM emissions and a 95% reduction in NO x emissions for the new engines using low sulfur diesel, compared to engines using higher- content sulfur diesel. These emission reductions are federally enforceable.

Large Nonroad Diesel Engines Rule In May 2004, the USEPA promulgated new rules for large nonroad diesel engines, such as those used in construction, agricultur al, and industrial equipment, to be phased in between 2008 and 2014. The nonroad diesel rules also reduce the al lowable sulfur in nonroad diesel fuel by over 99%. Prior to the fuel standard change, nonroa d diesel fuel averaged about 3,400 ppm sulfur. The rule limits nonroad diesel sulfur conten t to 500 ppm by 2006 a nd 15 ppm by 2010. The combined engine and fuel rules is expected to reduce NO x and PM emissions from large nonroad diesel engines by over 90%, compared to curr ent nonroad engines using higher-content sulfur diesel. These emission reductions are federally enforceable.

Nonroad Spark-Ignition Engines an d Recreational Engines Standard The nonroad spark-ignition and recreational engine standards, effective in July 2003, regulates NO x , hydrocarbons (HC) and CO for groups of previ ously unregulated nonroad engines. These engine standards apply to all new engines sold in the United States and imported after these standards began and applies to la rge spark-ignition engines (fork lifts and airpor t ground service equipment), recreational vehicles (off-highway motorcycles and all- terrain-vehicles), and recreational marine diesel engines. The regul ation varies based upon the type of engine or vehicle.

The large spark-ignition engines co ntribute to ozone formation and ambient CO and PM levels in urban areas. Tier 1 of this standard was impl emented in 2004 and Tier 2 started in 2007. Like the large spark-ignition, recreationa l vehicles contribute to ozone formation and ambient CO and PM levels. For the off-highway motorcycles an d all-terrain-vehicles, the exhaust emissions standard was phased-in. Fifty pe rcent of model year 2006 engines had to meet the standard and for model years 2007 and later, all engines must m eet the standard. Recreational marine diesel engines over 37 kilowatts are used in yachts, cr uisers, and other types of pleasure craft.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-4 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Recreational marine engines contribu te to ozone formation and PM levels, especially in marinas. Depending on the size of the engine, the standard began phasing-in in 2006.

When all of the nonroad spark-i gnition and recreational engine st andards are fully implemented, an overall 72% reduction in HC, 80% reduction in NO x , and 56% reduction in CO emissions are expected by 2020. These controls will help redu ce ambient concentrations of ozone, CO, and PM 2.5 . These emission reductions are federally enforceable.

NO x SIP Call in Surrounding States In October 1998, the USEPA made a fi nding of significant contribution of NO x emissions from certain states and published a rule that set ozone season (May to September) NO x budgets for the purpose of reducing regional transport of ozone (63 FR 57356). This rule, referred to as the NO x SIP Call, required ozone season controls to be put on utility and industr ial boilers, as well as internal combustion engines, in 22 states in the Eastern United States. A NO x emissions budget was set for each state and the states were requir ed to develop rules that would assure that each state met its budget. A NO x trading program was established, allowing sources to buy credits to meet their NO x budget as opposed to actually installing controls. Th e emission budgets were to be met by the beginning of 2004. Even with the trading program, the amount of ozone season NO x emissions has decreased si gnificantly in and around Nort h Carolina. These emission reductions are federally enforceable.

Clean Air Interstate Rule On May 12, 2005, the USEPA promulgated the “Rule To Reduce Interstate Transport of Fine Particulate Matter and Ozone (C lean Air Interstate Rule); Revisions to Acid Rain Program; Revisions to the NO x SIP Call”, referred to as CAIR. This rule established the requirement for States to adopt rules limiting the emissions of NO x and SO 2 and a model rule for the states to use in developing their rules. The purpose of the CAIR is to reduce interstate transport of precursors of fine particulate and ozone.

This rule provides annual state caps for NO x and SO 2 for large fossil-fuel-fired electric generating units in two phases, with the Phase I caps for NO x and SO 2 starting in 2009 and 2010, respectively. Phase II caps become effective in 2015. The USEPA is allowing the caps to be met through a cap and trade program if a state so chooses to participate in the program. These emission reductions are federally enforceable.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-5 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Due to court challenges of CAIR in 2008, the US EPA will be making changes to the program by 2011. However, the existing CAIR rules will re main in place until the USEPA promulgates changes to the program. Additionally, the revisions to the CAIR program are expected to be as stringent as the existing program.

3.2.2 State Control Measures North Carolina has adopted a number of regulatio ns, legislation, and vol untary programs to address pollution issues across the Stat e. These are summarized below.

Clean Air Bill The 1999 Clean Air Bill expanded the vehicle emissions I/M progr am in North Carolina from 9 counties to 48 counties, between July 1, 2002 th rough January 1, 2006 (Figure 3-1). Vehicles are tested using the onboard diagnostic system (O BDII), an improved method of testing, which ensures proper emission system operation for vehi cles and light trucks during their lifetime by monitoring emission-related components and system s for malfunction and/or deterioration. An important aspect of OBDII is its ability to notify the driver of malfunction and/or deterioration by illuminating the "check engine light". If the vehicle is taken to a repair shop in a timely fashion, it can be properly repaired before any significant and prolonged emission increase occurs. The previously used tailpipe te st (i.e., idle test) did not measure NO x emissions; it only tested for VOC and CO emissions. By utilizing the OBDII test method, the NO x emissions as well as other pollutants from motor vehicles are reduced. The eff ective dates for the counties in the PM 2.5 nonattainment area are listed below.

Figure 3-1. North Carolina’s Inspectio n & Maintenance (I/M) Phase-In MapHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-6 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 3-1 OBDII Phase-in Effective Dates County Date Catawba July 1, 2003 Davidson July 1, 2003 Guildford July 1, 2002
These emission reductions are state enforceable. The expected NO x benefits for the maintenance years are listed in Table 3-2 below.

Table 3-2 I/M NO x Benefits by County NO x I/M Benefit (Tons/year) 2008 2011 2014 2017 2021 Catawba County 171 136 132 122 111 Davidson County 180 166 139 129 114 Guilford County 541 505 403 358 318

NO x SIP Call Rule/CAIR In response to the USEPA’s NO x SIP call, North Carolina adopted rules to control the emissions of NO x from large stationary combustion sources. These rules cover (1) fossil fuel-fired stationary boilers, combustion turbines, and comb ined cycle systems serv ing a generator with a nameplate capacity greater than 25 MW and selli ng any amount of electricity, (2) fossil fuelfired stationary boilers, combustion turbines, and combined cycle systems having a maximum design heat input greater than 250 million Britis h thermal units per hour, and (3) reciprocating stationary internal combustion en gines rated at equal to or great er than 2400 brake horsepower (3000 brake horsepower for diesel engines and 4400 brake horsepow er for dual fuel engines). As part of the NO x SIP Call, the USEPA rules established a NO x budget for sources in North Carolina and other states. North Carolina has a Phase II budget (i.e., em ission allowance) of 165,022 tons NO x per ozone season.

Besides amending existing NO x rules and adopting new NO x rules specifically to address the USEPA NO x SIP Call, the North Carolina rules also re quire new sources to control emissions of NO x . The objective of this requiremen t is (1) to aid in meeting the NO x budget for North Carolina for minor sources and (2) to aid in a ttaining and maintaining the ambient air quality standard for ozone in North Carolina. North Carolina’s NO x SIP Call rule was predicted to reduce summertime NO x emissions from power plants a nd other industries by 68% by 2006. In October 2000, the North Carolina Environmen tal Management Commission (EMC) adopted rules requiring the reductions.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-7 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 In 2009, the NO x SIP Call program was replaced with th e CAIR, a cap-and-trade program that will achieve reductions of emissions of SO 2 and NO x in the eastern United States. NO x sources that were regulated under the NO x SIP Call are now regulated under the CAIR program. North Carolina adopted the CAIR rule s in 2006 (amended in 2008). North Carolina’s CAIR rules set annual SO 2 allowances as well as bo th ozone season and annual NO x allowances for coal-fired electric generating units and ot her large combustion sources. Th ese regulations are due to a Federal program and thus are both State and Federally enforceable.

Due to the Court challenges of CAIR in 2008, the USEPA will be making changes to this program soon. However, the existing CAIR rules will remain in place until the USEPA promulgates changes to the program.

Clean Smokestacks Act In June 2002, the North Carolina General Assemb ly enacted the NCCSA, which requires coalfired power plants in Nort h Carolina to reduce annual NO x emissions by 77% by 2009. These power plants must also reduce annual SO 2 emissions by 49% by 2009 and 73% by 2013. It is significant to note that this law sets a cap on NO x and SO 2 emissions for the State which the North Carolina public utilities cannot meet by purch asing credits from sour ces outside of North Carolina. With requiring year-round NO x controls and not allowing the purchase of NO x credits to meet the caps, the NCCSA reduces NO x emissions beyond the requirements of the NO x SIP Call Rule. One of the first state laws of its ki nd in the nation, this legislation provides a model for other states in controlling multiple air pollutants from older coal-fired power plants. These emissions reductions are state enforceable.

Prevention of Significant Deterioration All new major sources of SO 2 and NO x will be evaluated under the prevention of significant deterioration program and are required to use best available control technology. These emissions reductions are state enforceable.

Open Burning The North Carolina open burning regulation proh ibits the burning of man-made materials statewide. In June 2004, the EMC approved re visions to the open burning regulation banning open burning of yard waste and land clearing debris on forecasted Code Orange or higher "air quality action days," for those counties that th e NCDAQ or local air programs forecast ozone or fine particulate matter. The following counties in the Hickory area are subject to this rule : Alexander , Catawba , southeastern Burke and southeastern Caldwell. The following counties inHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-8 Redesignation Demonstration and Ma intenance Plan December 18, 2009 the Triad area are subject to this rule : Alamance , Caswell , Davidson , Davie , Forsyth , Guilford , Randolph , Rockingham and Stokes.
The open burning regulation reduces PM, NO x , SO 2 , VOC, and CO emissions and are state enforceable. The estimated emission reductions through the attainment and maintenance period are presented in Table 3-3. For a full expl anation of how these em ission reductions were estimated, please refer to Appendix C.2, the Ar ea Source Emissions Inventory Documentation.

Table 3-3 Estimated Emission Reducti ons from Open Burning Regulation Pollutant/County 2008 2011 2014 2017 2021 NOx Emissions (tons/year) Hickory Area Catawba 56 66 76 85 100

Triad Area Davidson 94 109 126 141 167 Guilford 79 91 105 119 140 Triad Total 173 200 231 260 307 SO 2 Emissions (tons/year) Hickory Area Catawba 10 11 12 14 17

Triad Area Davidson 16 18 21 23 28 Guilford 13 15 17 20 23 Triad Total 29 33 38 43 51 PM 2.5 Emissions (tons/year) Hickory Area Catawba 326 380 438 493 581

Triad Area Davidson 541 632 729 819 965 Guilford 454 530 612 688 809 Triad Total 995 1162 1341 1507 1774
Idle Reduction Regulation
The EMC adopted the Heavy-Duty Vehicle Idling Re strictions rule to reduce unnecessary idling of heavy-duty trucks on July 9, 2009. This rule ha s received several lett ers of objection and will undergo a legislative review in the Spring of 2010 before becoming effective. Once in effect,Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-9 Redesignation Demonstration and Ma intenance Plan December 18, 2009 this rule will be state enforceable and gene rally prevent any person who operates a heavy-duty vehicle to cause, let, permit, suffer or allow id ling for a period of time in excess of 5 consecutive minutes in any 60 minute period. The expected emissions from this regulation were not included in the mobile source emissions estimated for this maintenance plan because of the uncertainty of the regulations.

3.2.3 Additional Programs Supporting Maintenance Air Awareness Program The North Carolina Air Awareness Program is a public outreach and edu cation program of the NCDAQ. The goal of the program is to reduce air pollution t hough voluntary actions by individuals and organizations. Th e program seeks to educate indivi duals about (1) the sources of air pollution; (2) the health effects of air pollution and how these effects can be mitigated by modification of outdoor activities on air quality action days; and (3) simple "action tips", such as carpooling, vehicle maintenance, and energy conservation, that re duce individual contributions to air pollution. One of the major program co mponents is the year round daily air quality forecast. The NCDAQ produces a daily fine pa rticulate matter forecasts and corresponding air quality index for the Hickory forecast area, wh ile the Forsyth County Environmental Affairs Department provides daily fine particulate ma tter forecasts and the corresponding air quality index for the Triad region.

Transportation Conformity The NCDAQ works closely with the North Caro lina Department of Transportation (NCDOT) and local transportation agencies to assure that Transportation Improvement Programs (TIPs) in the nonattainment areas are consis tent with and conform to the State's air quality program, including the SIP, and meet the Federal requirements on tran sportation conformity. This conformity review is performed for all federally funded and all other major projects contained in TIPs, regardless of source of funding. Technical analysis of transportation plans, programs, and projects for conformity are done cooperatively by the Statewide Planning Branch of the NCDOT and the NCDAQ. In the event that the NCDAQ disagrees with the NCDOT on a conformity determination or other conformity related i ssue, the NCDAQ and the NCDOT will present the issue to the Governor for resolution.

The public and interested parties are given an early and reasonable oppo rtunity to comment on transportation plans, programs, projects and propos ed conformity determinations in accordance with procedures adopted by metr opolitan planning organizations pur suant to the requirements ofHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-10 Redesignation Demonstration and Ma intenance Plan December 18, 2009 SAFETY-LU (the Safe, Accountable, Flexible, E fficient Transportation Equity Act: A Legacy for Users) as well as any updated transporta tion legislation and th e CAA as amended.

Mobile Source Emission Reduction Grants

• Diesel Retrofits: As part of the Nort h Carolina Mobile Source Emission Reduction Grants program, a number of cities, counties and school dist ricts have installed Diesel Oxidation Catalysts (DOCs) or Diesel Pa rticulate Filters (DPFs) on their diesel equipment. The vehicles that have been retrofitted include schools buses, as well as county fleet trucks for solid waste pic kup. Although these types of filters are designed to remove fine particulate matter, when used with ultra low sulfur diesel fuel, NO x and VOC emissions are also reduced.

• Diesel Emissions Reduction Act (DERA): DERA provides new diesel emissions reduction grant authority for the USEPA. Th is funding is used to achieve significant reductions in diesel emissions that improve air quality a nd protect public health. In response to DERA, the USEPA created grant and funding programs under the National Clean Diesel Campaign to build on the success of its regulatory and voluntary efforts to reduce emissions from di esel engines. The DERA funds that the NCDAQ have received have been used to retrofit, repower, or replace existing diesel engines from on-road and nonroad m obile source vehicles/equipment.

3.3 EMISSIONS INVENTORIES AN D MAINTENANCE DEMONSTRATION
3.3.1 Theory of Approach There are two basic approaches used to demonstr ate continued maintenance. The first is the comparison of a projected emissions inventory wi th a baseline emissions inventory. The second approach involves complex analysis using grid ded photochemical modeling. The approach used by the NCDAQ is the comparison of emissi ons inventories for the years 2008 and 2021.

For the maintenance demonstration, the base year of 2008 was chosen since it is a year that falls within the attaining design valu e period of 2006-2008 and some emi ssions inventory data was in the process of being developed for this year . The maintenance demonstration is made by comparing the 2008 baseline emissions inventory to the 2021 projected emissions inventory. The baseline emissions inventory represents an emission level for a period when the ambient air quality standard was not violated, 2006-2008. If th e projected emissions remain at or below the baseline emissions, continued maintenance is dem onstrated and it then follows, if the projected emissions remain at or below the baseline emissi ons, then the ambient ai r quality standard shoulHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-11 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 not be violated in the future. In addition to comp aring the final year of th e plan, all of the interim years are compared to the 2008 baseline to demons trate that these years are also expected to show continued maintenance of the a nnual fine particulate matter standard.

The emissions inventories are comprised of four major types of sources: point, area, on-road mobile and nonroad mobile. The projected emi ssions inventories have been estimated using projected rates of growth in population, traffic, economic activity, expected control programs, and other parameters. Naturally occurring, or biogenic, emissions are not included in the emissions inventory comparison, as these emission s are outside the State’s span of control.

3.3.2 Emission Inventories
There are four different man-made emission inventory source classi fications: (1) st ationary point, (2) area, (3) on-road mobile and (4) nonroad mobile sources.

Point sources are those stationary sources that require an Air Permit to operate. In general, these sources have a potential to emit more than 5 tons per year of CO, NO x , PM, SO 2 and/or VOC from a single facility. The source emissions are tabulated from data coll ected by direct on-site measurements of emissions or mass balance cal culations utilizing emission factors from the USEPA’s AP-42. There are usually several emissi on sources for each facility. Emission data is collected for each point source at a facility and the data is entered into an in-house database system. For the projected year's inventory, point sources are adjusted by growth factors based on Standard Industrial Classification codes. The growth factors are gene rated using the USEPA’s Economic Growth Analysis System version 5.0 (E -GAS 5.0) program or using growth patterns obtained from County Business Patterns. For detailed discussion on how the point sources emission inventory was developed, see Appendix C .1. A summary of the point source emissions are presented in Tables 3-4 to 3-6.

Table 3-4. Point Source NO x Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 13,310 10,549 10,548 10,548 10,548

Davidson 841 865 892 920 961 Guilford 231 231 232 233 237 Triad Total 1,072 1,096 1,124 1,153 1,198Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-12 Errata to Redesigna tion Demonstration and Mainte nance Plan December 22, 2010 Table 3-5 Point Source SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 6,189 6,187 6,186 6,184 6,183

Davidson 286 289 292 295 299 Guilford 449 451 453 455 458 Triad Total 735 740 745 750 757

Table 3-6. Point Source PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 6,976 6,975 6,975 6,973 6,971

Davidson 179 178 177 176 175 Guilford 62 62 62 63 63 Triad Total 241 240 239 239 238

Area sources are those stationary sources whose emissions are relatively small but due to the large number of these sources, the collective emi ssions could be significan t (i.e., dry cleaners, service stations, etc.). For area sources, emissions are estimated by multiplying an emission factor by some known indicator of collective activity such as production, number of employees, or population. These types of em issions are estimated on the count y level. For the projected year's inventory, area source emissions are changed by population growth, projected production growth, or when applicable, by E-GAS 5.0 growth factors. For detailed discussion on how the area source emission inventory wa s developed, see Appendix C.2. A summary of the area source emissions are presented in Tables 3-7 to 3-9.

Table 3-7. Area Source NO x Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 662 614 566 520 454

Davidson 583 551 516 486 438 Guilford 1,243 1,210 1,177 1,146 1,099 Triad Total 1,826 1,816 1,693 1,632 1,537Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-13 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 3-8. Area Source SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 2,263 2,037 1,808 1,580 1,277

Davidson 983 838 692 548 353 Guilford 4,129 3,905 3,683 3,460 3,164 Triad Total 5,112 4,743 4,375 4,008 3,517

Table 3-9. Area Source PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 682 658 629 606 559
Davidson 1,071 1,028 979 937 857 Guilford 697 663 623 590 524 Triad Total 1,768 1,691 1,602 1,527 1,381

For mobile sources, the USEPA’s Motor Vehicle Emission Simulator (MOVES) mobile model is run to generate emissions. The MOVES model includes the road class vehicle miles traveled (VMT) as an input file and can directly output the estimated emi ssions. For the projected years’ inventories, the on-road mobile sources emissi ons are calculated by running the MOVES mobile model for the future year with the projected VMT to generate emissions that take into consideration expected Federal ta ilpipe standards, fleet turnover and new fuels. For detailed discussion on how the on-road mobile emission inventory was developed, see Appendix C.3. A summary of the on-road mobile source emissions are presente d in Tables 3-10 to 3-12.

Table 3-10. On-road Mobile Source NO x Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 4,982 4,005 3,240 2,591 2,054
Davidson 5,267 4,095 3,227 2,536 1,974 Guilford 14,499 11,157 8,882 7,143 5,796 Triad Total 19,766 15,252 12,109 9,679 7,770Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-14 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 3-11. On-road Mobile Source SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 35 20 18 19 20

Davidson 36 19 17 18 18 Guilford 111 62 55 59 63 Triad Total 147 81 72 77 81

Table 3-12. On-road Mobile Source PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 166 127 107 89 73

Davidson 169 121 97 77 60 Guilford 465 330 272 221 183 Triad Total 634 451 369 298 243

Nonroad mobile sources are equipment that can move but do not use the roadways, i.e., lawn mowers, construction equipment, railroad locomotiv es, aircraft, etc. The emissions from this category are calculated using the USEPA’s N ONROAD2008a nonroad mobile model, with the exception of the railroad locomotives and aircraft engine. The railroad locomotive and aircraft engine emissions are estimated by taking activit y data, such as landi ngs and takeoffs, and multiply by an emission factor. These emissions ar e also estimated at the county level. For the projected years’ inventories, the emissions are estimated using the USEPA’s NONROAD2008a nonroad mobile model, E-GAS 5.0 growth factor s or projected landing and takeoff data for aircraft. For detailed discussion on how the nonroad mobile emission inventory was developed, see Appendix C.4. A summary of the nonroad mobile source emissions are presented in Tables 3-13 to 3-15.

Table 3-13. Nonroad Mobile Source NO x Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 1,173 922 700 551 453
Davidson 1,831 1,632 1,467 1,275 1,115 Guilford 3,864 3,371 2,816 2,350 1,980 Triad Total 5,695 5,003 4,283 3,625 3,095Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-15 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 3-14. Nonroad Mobile Source SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 18 6 4 3 4

Davidson 25 17 2 2 2 Guilford 96 51 42 42 43 Triad Total 121 68 44 44 45

Table 3-15. Nonroad Mobile Source PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 70 67 57 46 38

Davidson 71 67 58 46 40 Guilford 264 252 220 186 157 Triad Total 335 319 278 232 197

3.3.3 Summary of Emissions
The sum total of these man-made emissions for the PM 2.5 nonattainment areas is tabulated in Tables 3-16 though 3-18.

Table 3-16. Total Man-Made NO x Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 20,127 16,090 15,054 14,210 13,509
Davidson 8,522 7,143 6,102 5,217 4,488 Guilford 19,837 15,969 13,107 10,872 9,112 Triad Total 28,359 23,112 19,209 16,089 13,600

Table 3-17. Total Man-Made SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 8,505 8,250 8,016 7,786 7,484
Davidson 1,330 1,163 1,003 863 672 Guilford 4,785 4,469 4,233 4,016 3,728 Triad Total 6,115 5,632 5,236 4,879 4,400Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-16 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 3-18. Total Man-Made PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 7,894 7,827 7,768 7,714 7,641
Davidson 1,490 1,394 1,311 1,236 1,132 Guilford 1,488 1,307 1,177 1,060 927 Triad Total 2,978 2,701 2,488 2,296 2,059

3.3.4 Maintenance Demonstration As discussed above, maintenance is demonstrat ed when the future years total man-made emissions are less than the 2008 baseline emissi ons. The following tables summarized the SO 2 , NO x , and primary PM 2.5 emissions for both the Hickory a nd Triad nonattainment areas. The difference between the base year and the final ye ar of the plan illustrates that the continued maintenance of the annual fine par ticulate matter NAAQS is expected.

Table 3-19 Maintenance Demonstration for Hickory PM 2.5 Nonattainment Area

Year NO x (tons per year) SO 2 (tons per year) PM 2.5 (tons per year) 2008 20,127 8,505 7,894 2011 16,090 8,250 7,827 2014 15,054 8,016 7,768 2017 14,210 7,786 7,714 2021 13,509 7,484 7,641 Difference from 2008 to 2021 -6,618 -1,021 - 253

Table 3-20 Maintenance Demonstration for Triad PM 2.5 Nonattainment Area

Year NO x (tons per year) SO 2 (tons per year) PM 2.5 (tons per year) 2008 28,359 6,115 2,978 2011 23,112 5,632 2,701 2014 19,209 5,236 2,488 2017 16,089 4,879 2,296 2021 13,600 4,400 2,059 Difference from 2008 to 2021 -14,759 -1,715 - 919Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-17 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 The difference between the attainment level of emissions (2008) from all man-made sources and the projected level of emissions from all ma n-made sources in the nonattainment areas are considered the “safety margin”. The safety marg in for each projected year is listed below in Table 3-21 and 3-22.

Table 3-21 Safety Margin for Hickory PM 2.5 Nonattainment Area

Year NO x (tons per year) SO 2 (tons per year) PM 2.5 (tons per year) 2011 -4,037 -255 -67 2014 -5,073 -489 -126 2017 -5,917 -719 -180 2021 -6,618 -1,021 -253

Table 3-22 Safety Margin for Triad PM 2.5 Nonattainment Area

Year NO x (tons per year) SO 2 (tons per year) PM 2.5 (tons per year) 2011 -5,247 -483 -277 2014 -9,150 -879 -490 2017 -12,270 -1,236 -682 2021 -14,759 -1,715 -919

For both nonattainment areas, th ere are significant safety margins from 2011 to 2021. In addition to the above safety margins within the PM 2.5 nonattainment areas, SO 2 emissions from nearby coal-fired power plants will be significantly reduced due to the NCCSA. This effectively gives the PM 2.5 nonattainment areas an even larger safety margin for SO 2 . Table 2-5 shows the SO 2 reductions at nearby coal-fir ed power plants. These reduc tions will benefit both the Triad and Hickory nonattainment areas and will provide large safety margins through 2021.

3.4 CONTINGENCY PLAN

3.4.1 Overview
The two main elements of the North Carolina contingency plan are tracking and triggering mechanisms to determine when contingency meas ures are needed and a process of developing and adopting appropriate control measures. Ther e will be three potential triggers for the contingency plan. The primary trigger of the contingency plan will be a violation of the annual PM 2.5 NAAQS at any of the monitors in either PM 2.5 nonattainment area. Th e secondary triggerHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-18 Redesignation Demonstration and Ma intenance Plan December 18, 2009 will be a rolling 12 quarter aver age that exceeds the annual PM 2.5 NAAQS. The tertiary trigger will be a monitored annual average that exceeds the annual PM 2.5 NAAQS. Upon either the primary or secondary triggers being activ ated, the NCDAQ will commence analyses to determine what additional measures, if any, will be necessary to attain or maintain the annual PM 2.5 standard. If activation of either the primary or secondary triggers occurs, this plan provides a regulatory adoption proc ess for revising emission control strategies. Activation of the tertiary trigger will result in an analysis to understand the cause of the exceedance and to identify voluntary measures if needed.

In addition, there will be a tr acking mechanism that requires a comparison of the actual emissions inventory submitted under the Federa l Consolidated Emissions Reporting Rule (CERR) and Air Emissions Reporting Rule (AE RR) to the projected inventory, and to the attainment year inventory contained in this maintenance plan. The CERR and AERR reporting years coincide with the baseli ne, interim and final years of the emission inventory in this maintenance demonstration.

3.4.2 Primary and Secondary Triggers The primary trigger of the contingency pl an will be a violation of the annual PM 2.5 standard, or when the three-year average of the average a nnual ambient concentration is greater than 15.0 μg/m 3 at any monitor in the PM 2.5 nonattainment areas. The trig ger date will be 60 days from the date that the State observes an annual average concentration that, when averaged with the two previous annual average PM 2.5 concentrations, would result in a three-year average greater than 15.0 μg/m 3

.
The secondary trigger will apply where no actual violation of the annual PM 2.5 standard has occurred, but where the State finds that the rolling 12-quarter average monitored PM 2.5 levels exceed the PM 2.5 NAAQS. A pattern will be deemed to exist when the average PM 2.5 concentrations of any 12 consecutive quarters is greater than 15.0 μg/m 3 at any monitor within the PM 2.5 nonattainment areas. The trigger date will be 60 days from the date that the State observes a rolling 12-quarter average greater than 15.0 μg/m 3 at any monitor.

Similarly, the tertiary trigger will not be an actual violation of the annual PM 2.5 standard. This trigger will be a first alert as to a potential air quality problem on the horizon. The trigger will be activated when a monitor in either of the PM 2.5 nonattainment areas has an annual average greater than 15.0 μg/m 3 , starting the first year after the maintenance plan has been approved. The trigger date will be 60 days from the date that the State observes an annual average greater than 15.0 μg/m 3 at any monitor.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-19 Redesignation Demonstration and Ma intenance Plan December 18, 2009 3.4.3 Action Resulting Fr om Trigger Activation There are a number of programs that are still being implemente d in North Carolina that will continue to reduce fine particulate matter and it s precursors. The NCCSA has a final compliance year of 2013 by which the public utilities in North Carolina must meet their SO 2 emissions caps. It is estimated that an additional 133,320 tons of SO 2 will be reduced from the 2008 emission levels for the sources subject to the NCCSA. Additionally, the NCDAQ is still awarding grants for retrofits, replacement or repowering of diesel engines for on-road and nonroad mobile sources. Since it is possible that the specia tion composition of fine particulate matter may change in the future years, it is important that the NCDAQ identify the pollutant or pollutants for which further reductions are needed in order to maintain the annual PM 2.5 NAAQS.

Once the primary or secondary trigger is acti vated, the Planning Section of the NCDAQ shall commence analyses including trajectory analyses of high PM 2.5 days, and emissions inventory assessment to determine those emission control m easures that will be required for attaining or maintaining the annual PM 2.5 standard. Additionally, the PM 2.5 speciation data from the STN monitors will be reviewed to determine which species are the more pr edominant components for the period where a violation or exce edance of the NAAQS was observed.

If it is determined that the cause of the violation or exceedance of the PM 2.5 NAAQS is due to sources outside of North Caro lina, then the NCDAQ will commen ce discussion with regulatory authorities responsible for upwind sources to de termine additional actions to be implemented. The State of North Carolina has already filed a Section 126 petition in order to ensure that neighboring states reduce their utility emissions in a timely manner. As a result of the recent court decision in the State of North Caro lina vs. Tennessee Valley Authority, additional emissions reductions are anticip ated for upwind TVA sources.

If it is determined that the violation or ex ceedance occurred due to sources within North Carolina, then by November 1 of the year followi ng the year in which the primary or secondary trigger has been activated, North Carolina will comp lete sufficient analyses to begin adoption of necessary rules for ensuring attainme nt and maintenance of the annual PM 2.5 NAAQS. If the rules are still needed, then rules would become State effective by the following July 1, unless legislative review is required. Each adopted rule will include a schedule that will require compliance with the rule no later than 2 years after adoption of the rule.

The measures that will be considered for a doption upon a trigger of the contingency plan include: Reasonably Available Control T echnology on stationary sources in the PM 2.5 nonattainment area counties, diesel inspecti on and maintenance progr am, implementation ofHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-20 Redesignation Demonstration and Ma intenance Plan December 18, 2009 diesel retrofit programs, including incentives fo r performing retrofits, and additional controls in upwind areas.

Once the tertiary trigger is activated, the Pl anning Section of the NCDAQ shall commence analyses including meteorological evalua tion, trajectory analyses of high PM 2.5 days, and emissions inventory assessment to understand wh y an annual exceedance of the standard has occurred. Once the analyses are completed, the NCDAQ will work with the local air awareness program and develop an outreach plan to identify any additional voluntary measures that can be implemented. NCDAQ will work wi th the local air awareness coor dinator to implement the plan for the following summer.

3.4.4 Tracking Program for Ongoing Maintenance In addition to the measures listed above, emissions inventory comparisons will be carried out. The large stationary sources ar e required to submit an emissi ons inventory annually to the NCDAQ. The NCDAQ will commit to review these emissions inventories to determine if an unexpected growth in NO x , SO 2 or primary particulate matter emissions in the PM 2.5 nonattainment areas may endanger th e maintenance of the annual PM 2.5 standard. Additionally, as new VMT data is provided by the North Caro lina Department of Transportation (NCDOT), the NCDAQ commits to review this data and de termine if any unexpected growth in VMT may endanger the maintena nce of the annual PM 2.5 standard.

Additionally, under the CERR and AERR the NCDAQ is required to develop a comprehensive, annual, statewide emissions inventory every three years and is due twelve to eighteen months after the completion of the inve ntory year. The CERR and AERR i nventory years coincide with the baseline, interim and final years of the ma intenance plan. Therefore, the NCDAQ commits to compare these inventories as they are developed with the maintenance plan to determine if additional steps are necessary for co ntinued maintenance of the annual PM 2.5 standard in this

area.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-1 Redesignation Demonstration and Ma intenance Plan December 18, 2009 

### 4.0 MOTOR VEHICLE EMISSIONS BUDGET FOR CONFORMITY

4.1 TRANSPORTATION CONFORMITY
The purpose of transportation conformity is to ensure that Federal transportation actions occurring in nonattainment and maintenance ar eas do not hinder the area from attaining and maintaining the annual fine partic ulate matter standard. This m eans that the level of emissions estimated by the NCDOT or the metropolitan planning organizations for the TIP and Long Range Transportation Plan must not exceed th e motor vehicle emission budgets (MVEBs) as defined in this maintenance plan.

4.2 POLLUTANTS TO BE CONSIDERED
40 CFR 93.119(f)(7) through (10) id entifies the pollutants for PM 2.5 that regional emissions analysis needs to be performed for transportatio n conformity purposes. These parts of the rule are listed below:

§119(f)(7) – PM 2.5 in PM 2.5 areas; §119(f)(8) – Reentrained road dust in PM 2.5 areas only if the EPA [Environmental Protection Agency] Regional Administrator or the director of the State air agency has made a finding that emissions from r eentrained road dust within the area are a significant contributor to the PM 2.5 nonattainment problem and has so notified the MPO and DOT [Department of Transportation]; §119(f)(9) – NO x [nitrogen oxides] in PM 2.5 areas, unless the EPA Regional Administrator and the director of the St ate air agency have made a finding that emissions of NO x from within the area are not a significant cont ributor to the PM 2.5 nonattainment problem and has so notified the MPO and DOT; and §119(f)(10) – VOC, SO 2 and/or ammonia in PM 2.5 areas if the EPA Regional Administrator or the director of the St ate air agency has made a finding that any of such precursor emissions from within the area are a significant contributor to the PM 2.5 nonattainment problem and has so notified the MPO and DOT.

Only primary, or direct PM 2.5 , tailpipe emissions must be considered for transportation conformity regional emissions analysis. The othe r precursor pollutants and reentrained road dust only need to be considered if the State air agency and/or the USEPA have deemed the pollutant as a significant contributor to the PM 2.5 nonattainment problem. The following sections discussHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-2 Redesignation Demonstration and Ma intenance Plan December 18, 2009 the significance of the precu rsor pollutants and reentr ained road dust to the PM 2.5 nonattainment problem.

4.2.1 Precursor Pollutants NO x , VOC, and Ammonia
The PM 2.5 precursor NO x is presumed to be a significant contributor to the PM 2.5 nonattainment problem by the USEPA. The NCDAQ has determined that NO x is a relatively minor contributor to the PM 2.5 concentrations in North Carolina. Howe ver, the NCDAQ is not asserting that NO x is an insignificant precursor for the 1997 PM 2.5 standard. Therefore, the NCDAQ will establish county level MVEBs for NO x for all three PM 2.5 nonattainment counties.

For the purpose of this attainment demonstr ation, VOC and ammonia are presumed to be insignificant contributors to the PM 2.5 nonattainment problem by the USEPA. The NCDAQ agrees with the USEPA that both VOC and ammo nia are insignificant contributors to the PM 2.5 nonattainment problem in North Carolina. Since these precursors have been deemed insignificant, no MVEBs are being es tablished for VOC or ammonia.

An affirmative insignificance finding from the USEPA only relieves the transportation partners from a regional emissions analysis for PM 2.5 emissions for these areas and does not relieve them of the other transportation confor mity requirements. The trans portation partners will need to note the VOC and Ammonia insignificance find ing (if found adequate and approved by the USEPA) in future conformity determinations.

4.2.2 Reentrained Road Dust The majority of the roads in North Carolina are paved so there is minimum road dust due to the paved roads. The factor to calcu late reentrained road dust on pave d roads is very small. What dust is generated, has been shown in the literature, Methodology to Estimate the Transportable Fraction (TF) of Fugitive Dust Emissions fo r Regional and Urban Scale Air Quality Analyses, US EPA, August 3, 2005 , to be inconsequential.

This fact is affirmed by the sm all crustal component in the PM 2.5 speciated data which measures only 3% at Hickory monitoring site (Catawba County) in 20 02 and only 2% at Lexington monitoring site (Davidson County) in 2004 (see Figure 4-1 below).Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-3 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Figure 4-1. Speciated Data fo r the Hickory area (left) and the Triad area (right)

Since the reentrained road dust is no t a significant contributor to the PM 2.5 nonattainment problem, the NCDAQ will not be establishing MVEBs for this source category. An affirmative insignificance finding from the USEPA only relieves the transportation partne rs from a regional emissions analysis for reentrained road dust emi ssions for these areas and does not relieve them of the other transportation confor mity requirements. The trans portation partners will need to note the reentrained road dust insignificance finding (if found adequa te and approved by the USEPA) in future conformity determinations.

4.2.3 Precursor Pollutant SO 2 The PM 2.5 precursor SO 2 could not be deemed insignificant to the PM 2.5 nonattainment problem. However, the NCDAQ has determined that SO 2 emitted by the mobile source sector is insignificant. The USEPA in its Federal Register notice for PM 2.5 does not address the mobile sector in its listing of significan t emissions. North Carolina agrees with the following statements addressing SO 2 from on-road mobile emissions as published in the May 6, 2005, Federal Register, (70 FR 24283):

“While speciated air quality dat a show that sulfate is a re latively signific ant component (e.g., ranging from nine to 40 percent) of PM 2.5 mass in all regions of the country, emissions inventory data and projections show that on-road emissions of SO x constitute a ‘‘de minimis’’ (i.e., extremel y small) portion of total SO x emissions. Emissions inventory data for 1999 for the 372 potential PM 2.5 nonattainment counties for PM 2.5 (based on Hickory AIRS Code 370350004 POC 5 (ROUTINE) Date(s): 1/2/2002 - 12/4/2002 Average Concentration (μg/m3)

Nitrate

6%

Sulfate 30%

Ammonium 10% Organic carbon 32% Elemental carbon 4% Crustal component 3% Other 15% (NC) - Lexington AIRS Code 370570002 POC 5 (ROUTINE) Date(s): 1/16/2004 - 2/9/2005 Average Concentration (μg/m3)

Nitrate

7%

Sulfat e 29%

Ammonium 10% Organic carbon 28% Elemental carbon 4% Crustal component 2% Other 20%Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-4 Redesignation Demonstration and Ma intenance Plan December 18, 2009 1999–2001 air quality data) show that on-road s ources were responsible for only two percent of total SO x emissions.

Furthermore, EPA has already adopted tw o regulations that will greatly reduce emissions of SO x from on-road sources by the time such regulations are both in full effect in 2009. First, in 2004 the low sulfur gasoline program began to be phased in and will be fully effective in 2007 (February 10, 2000, 65 FR 6697). This regulation will reduce the sulfur content of gasoline by approximat ely 90 percent when fully effective. Second, in 2006 the low sulfur diesel program will begin to be phased in and will be fully effective by 2009 (January 18, 2001, 66 FR 5001). This regulation will reduce the sulfur content of diesel fuel by approximately 97 percent nationally when fully effective.

Projections of on-r oad emissions of SO 2 in 2020 indicate that on-road sources will be responsible for less than one percent of the total SO 2 emissions in 2020 in the 372 potential PM 2.5 nonattainment counties (based on 1999– 2001 air quality data). These projections confirm that the implementation of the fuel regulations discussed above will ensure that as a general matter of SO 2 emissions from on-road sources remain at insignificant levels in all areas.”

Although sulfate is a signif icant component to the PM 2.5 nonattainment problem in North Carolina, the majority of the SO 2 emissions in 2009 come from the stationary point source sector (see Figure 4-2). The mobile so urce sector only contributes one half of one percent (0.5 %) of the 2009 statewide SO 2 emissions. This is consistent with what the USEPA stated above.

Figure 4-2. North Carolina’s 2009 Statewide SO 2 Emissions Nonroad

0.6% Area 2.1% Mobile 0.5% Point 96.7%Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-5 Redesignation Demonstration and Ma intenance Plan December 18, 2009 Since the mobile source SO 2 contribution is insignificant, the NCDAQ is not establishing MVEBs for this precursor. An affirmative insignificance finding from the USEPA only relieves the transportation partners from a regional emissions analysis for SO 2 emissions for these areas and does not relieve them of the other tran sportation conformity requirements. The transportation partners will need to note the SO 2 insignificance finding (if found adequate and approved by the USEPA) in futu re conformity determinations.

4.2.4 Direct PM 2.5 Emissions 40 CFR 93.109(k) in the Transpor tation Conformity Rule Amendm ents for the new 8-hour ozone and fine particulate matter NAAQSs addresses ar eas with insignificant motor vehicle emissions as follows,

“Notwithstanding the other paragraphs in this section, an area is not required to satisfy a regional emissions analys is for §93.118 and/or §93.119 for a given pollutant/precursor and NAAQS, if EPA finds through the adequacy or approval process that a SIP demonstrates that regional motor vehicle emissions are an insignificant contributor to the air quality problem for that pollutant/precursor and NAAQS. The SIP would have to demonstrate that it would be unreasonable to expect that such an area would experience enough motor vehicle emissions growth in that pollutant/precursor for a NAAQS violation to occur.”

The rule suggests that such a finding would be based on a number of factors, including the percentage of motor vehicle emi ssions in the context of the tota l SIP inventory, the current state of air quality as determined by monitoring data for that NAAQS, the absence of SIP motor vehicle control measures, and historical trends and future projections of the growth of motor vehicle emissions. Although there is an inspection and maintenance program in the nonattainment areas, this control measure does not control primary PM 2.5 , but rather is in place to reduce the ozone precursors.

The NCDAQ believes strongly that the primary PM 2.5 emissions from mobile sources do not contribute significantly to the PM 2.5 nonattainment problem. However, the USEPA has indicated they will not approve a SIP that does not set MVEBs for primary PM 2.5 for the Triad nonattainment area. Therefore, the NCDAQ will establish county level MVEBs for primary PM 2.5 for the Triad area. The sections that follow discuss the insignificance of PM 2.5 emissions.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-6 Redesignation Demonstration and Ma intenance Plan December 18, 2009 The attainment modeling for the Hickory and the Triad PM 2.5 nonattainment areas was submitted to the USEPA on August 21, 2009. In conjunction with that modeling the NCDAQ examined the sources of PM 2.5 emissions and their contribution to PM 2.5 formation in the nonattainment counties. This was accomplished using the 2009 emissions inventories developed for the attainment demonstration modeling. Figure 4-3 provides the percent co ntributions from point, area, nonroad mobile and on-road mobile sour ce sectors for the Hickory nonattainment area.

Figure 4-3. Hickory Area 2009 Primary PM 2.5 Emissions

The 2009 on-road mobile PM 2.5 emissions contributed only 1.6% of the total PM 2.5 emissions for the Hickory area. Therefore, it is demonstrated that the PM 2.5 emissions compared to the total PM 2.5 emissions are insignificant. It s hould be noted that the mobile source PM 2.5 emissions slightly decrease from 2002 to 2009 despite an increase in VMT.

The NCDAQ performed sensitivity modeling in order to address the challenge of Section 93.109(k) in the Transportation Conformity Rule Amendments, “The SIP would have to demonstrate that it would be unreasonable to expect enough motor vehicle emissions growth in that pollutant/precursor for a NAAQS violation to occur”. The sensitivity modeling showed that with a doubling of the mobile source PM 2.5 emissions there was no change in the air quality modeling results. This sensitivity modeling is discussed in more detail in Appendix C.3.

Based on the information discussed above, the NCDAQ believes that the on-road mobile PM 2.5 emissions are insignifican t contributors to the PM 2.5 nonattainment problem. Emission estimates indicate that the on-road mobile PM 2.5 emissions are a small percentage of the total PM 2.5 emissions in the Hickory nonattainment area. On-road mobile PM 2.5 emissions are projected to 1.59%

68.70% 1.49%

28.22%

Mobile Point Area NonroadHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-7 Redesignation Demonstration and Ma intenance Plan December 18, 2009 decrease into the future notwithstanding VMT in creases. Air quality modeling sensitivities show that doubling the mobile source PM 2.5 emissions has very little eff ect on the future design values. The NCDAQ considers it unreasonable to expect that the Hickory PM 2.5 nonattainment area will experience enough motor vehicle PM 2.5 emissions growth for a future PM 2.5 violation to occur due to mobile sources.

Due to above analysis and agreement from the USEPA, budgets for direct PM 2.5 will not be set for the Hickory nonattainment area. An affirm ative insignificance finding from the USEPA only relieves the transportation partners fro m a regional emissions analysis for PM 2.5 emissions for this area and does not relieve them of the othe r transportation conformity requirements. The transportation partners will need to note the PM 2.5 insignificance finding (if found adequate and approved by the USEPA) in futu re conformity determinations.

4.3 SAFETY MARGIN
As stated in Section 3.3.4, a safe ty margin is the difference be tween the attain ment level of emissions from all source categories (i.e., poin t, area, on-road mobile and nonroad mobile) and the projected level of emissions from all sour ce categories. The safety margins for both the Hickory and Triad areas are list ed in Table 3-21 and 3-22. The State may choose to allocate some of the safety margin to the MVEB, for tr ansportation conformity purposes, so long as the total level of emissions from all source categ ories remains below the attainment level of emissions.

The NCDAQ has decided to allocate a portion of the safety margin to the MVEB to allow for unanticipated growth in VMT, changes to vehicl e mix assumptions, etc. that will influence the emission estimations. Since NO x is a precursor to ozone, the NCDAQ has decided to limit the amount of the safety margin allocated to the MVEBs. For 2011 and 2021, the NCDAQ has added an additional 10% and 20%, respectively, to the NO x MVEBs. This is consistent with how the NCDAQ has handled NO X MVEBs in ozone maintenance plans.

Since the NCDAQ does not beli eve that mobile source PM 2.5 emissions are a significant contributor to PM 2.5 nonattainment, the 2011 and 2021 MVEBs for the Triad nonattainment area will be set at the 2008 mobile source PM 2.5 emission levels.

4.4 MOTOR VEHICLE EMISSION BUDGETS
As part of the consultation process on se tting MVEBs, the NCDAQ sent out a request for comment on setting the geographic extent of the MV EBs to all of the tran sportation partners. AHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-8 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 copy of the letter can be found in Appendix B. In the letter, the NCDAQ expressed its preference for setting county level budgets and the reasons why the NCDAQ believed county level budgets were appropriate.

The NCDAQ received comments from the Gr eensboro Urban Area Metropolitan Planning Organization (GUAMPO) regarding the geographic extent of th e MVEBs. The GUAMPO was in favor of having county level MVEBs. A co py of the letter received can be found in Appendix B. Therefore, the NCDAQ decided to move forward with setting county-by-county MVEBs.

Additionally, there was discussion through the inte ragency consultation process on the years to set MVEBs for the Hickory and Triad PM 2.5 maintenance plans. According to Section 93.118 of the transportation conformity rule, a maintenance pl an must establish MVEBs for the last year of the maintenance plan (in this case, 2021). Thro ugh the interagency consultation process, it was decided that MVEBs would be set for the year 2011 for both the Hickory and Triad PM 2.5 nonattainment areas.

Although the emissions up to this point have been expressed in terms of tons per year, the MVEBs will be set in terms of kilograms (kg) per y ear. In past conformity exercises, there have been some issues with conversion to tons, as well as concerns with how the MVEBs were rounded to the hundredth place. Setting MVEBs in kilograms will avoid thes e issues in future conformity determinations. Additionally, setting the MVEBs in kilograms was agreed to as part of the interagency c onsultation process.

The table below shows the countie s with their on-road mobile PM 2.5 and NO x emissions expressed in kilograms per year and the corr esponding tons per year values for 2011 and 2021.

Table 4-1. On-Road Mobile Source PM 2.5 Emissions
County Kilograms/year Tons/year 2011 2021 2011 2021 Davidson 109,769 54,431 121 60 Guilford 299,371 166,015 330 183 Triad Total 409,140 220,446 451 243Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-9 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 4-2. On-Road Mobile Source NO x Emissions
County Kilograms/year Tons/year 2011 2021 2011 2021 Catawba 3,633,274 1,863,357 4,005 2,054

Davidson 3,714,921 1,790,782 4,095 1,974 Guilford 10,121,459 5,258,042 11,157 5,796 Triad Total 13,836,380 7,048,824 15,252 7,770

The NCDAQ will set MVEB, for tr ansportation conformity purposes, as county budgets within the Hickory and Triad maintenance areas for 2011 and 2021. Tables 4-3 through 4-5 below list out the MVEBs in kilograms per year, for transportation conformity purposes, by county for the years 2011 and 2021. Upon the USEPA’s affirmativ e adequacy finding for these county level sub-area MVEBs, these MVEBs will become the applicable MVEBs for each county.

Table 4-3 Catawba County MVEB 2011 2021

NO x Emissions (kg/year) Base Emissions 3,633,274 1,863,357 Safety Margin Allocated to MVEB 363,327 372,671 NO x Conformity MVEB 3,996,601 2,236,028

Table 4-4 Davidson County MVEB 2011 2021

NO x Emissions (kg/year) Base Emissions 3,714,921 1,790,782 Safety Margin Allocated to MVEB 371,492 358,156 NO x Conformity MVEB 4,086,413 2,148,938

PM 2.5 Emissions (kg/year) Base Emissions 109,769 54,431 Safety Margin Allocated to MVEB 43,544 98,882 PM 2.5 Conformity MVEB 153,313 153,313Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-10 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 4-5 Guilford County MVEB 2011 2021

NO x Emissions (kg/year) Base Emissions 10,121,459 5,258,042 Safety Margin Allocated to MVEB 1,012,146 1,051,608 NO x Conformity MVEB 11,133,605 6,309,650

PM 2.5 Emissions (kg/year) Base Emissions 299,371 166,015 Safety Margin Allocated to MVEB 122,470 255,826 PM 2.5 Conformity MVEB 421,841 421,841

4.5 NEW SAFETY MARGINS
For the Hickory nonattainment area, a to tal of 363,327 kg/year (400 tons/year) and 372,671 kg/year (411 tons/year) of the 2011 and 2021 NO x safety margins, respectively, were added to the NO X MVEBs.

For the Triad nonattainment area, a to tal of 1,383,638 kg/year (1,525 tons/year) and 1,409,764 kg/year (1,554 tons/year) of the 2011 and 2021 NO x safety margins, respectively, were added to the Triad NO X MVEBs. For PM 2.5 , a total of 166,014 kg/year (183 tons/year) and 354,708 kg/year (391 tons/year) of the 2011 and 2021 PM 2.5 safety margins, respectively, were added to the Triad PM 2.5 MVEBs.

Table 4-6 New Safety Margins for the Hickory PM 2.5 nonattainment area Year NO x (tons/year) PM 2.5 (tons/year) 2011 -3,637 -67 2014 -5,073 -126 2017 -5,917 -180 2021 -6,207 -253Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-11 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 4-7 New Safety Margins for the Triad PM 2.5 nonattainment area Year NO x (tons/year) PM 2.5 (tons/year) 2011 -3,722 -94 2014 -9,150 -490 2017 -12,270 -682 2021 -13,205 -528Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 5-1 Redesignation Demonstration and Ma intenance Plan December 18, 2009 

### 5.0 STATE IMPLEMENTATION PLAN APPROVAL

5.1 INTRODUCTION
For an area to be redesignated and have an approved maintenance plan, the SIP must include evidence of compliance with the rules relied on to show maintenance of the standard. This section provides the evidence of compliance with such rules for the Hickory and Triad PM 2.5 nonattainment area.

5.2 EVIDENCE OF COMPLIANCE
The following rules regulating emissions of SO 2 and/or NO x in PM 2.5 nonattainment area counties have been approved, or have been submitted with a request to be approved, as part of the SIP:

15A NCAC 2D .0530, Prevention of Significant Deterioration 15A NCAC 2D .1000, Motor Vehicle Emission Control Standards 15A NCAC 2D .1200, Control and Em issions from Incinerators 15A NCAC 2D .1409(b), Stationary Internal Combustion Engines 15A NCAC 2D .1416 - .1423, NO x SIP rules 15A NCAC 2D .1600, Ge neral Conformity 15A NCAC 2D .1900, Open Burning 15A NCAC 2D .2000, Transportation Conformity 15A NCAC 2D .2400 Clean Air Interstate Rules

Section 15A NCAC 2D .1000 also regulates emissi ons from motor vehicles in the counties near the Hickory and Triad nonattainme nt area and requires the use of the on board diagnostic system, which will indicate NO x emissions as well as other pollutants.

Section 15A NCAC 2D .1200 regulates the controls a nd emissions from incinera tors. Part of this rule has been submitted as part of the SIP, while .1205, .1206 and .1210 are part of the CAA Section 111(d) plans.

Two rules are conformity related, 15A NCAC 2D .1600 and .2000. General conformity related projects are covered under Sect ion .1600, while transportation conf ormity related projects are covered under Section .2000. Although neither of th ese rules require reduction in emissions, they do ensure that federal acti ons do not hinder atta inment or maintenance of the NAAQS.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 5-2 Redesignation Demonstration and Ma intenance Plan December 18, 2009 North Carolina has adopted an open burning rule, 15A NCAC 2D .1900, which prohibits open burning of vegetative material during Air Qualit y Action Days of Code Orange or higher in forecasted areas of the State. Particle polluti on forecasts are issued for the Hickory and Triad areas year-round; theref ore this area is covered by this rule.

Section 15A NCAC 2D .2400 regul ates nitrogen oxide emissions from electric generating units with a nameplate capacity of 25 megawatts or mo re producing electricity for sale. Section 15A NCAC 2D .2400 also covers industrial boilers that are covered under the NO x SIP Call rules. This Section replaces the NO x SIP Call rules beginning January 1, 2009.

Another important set of rules that may result in control of some par ticulates that are air toxics in North Carolina in these counties is Secti on 15A NCAC 2D .1100, C ontrol of Toxic Air Pollutants. These rules, however, have not been submitted to the USEPA to be approved as part of the SIP.

There are two other rules that control emissions of some particulates in these areas. They are 15A NCAC 2D .0524, New Source Performance Standards. Also, rule 2D.1111, Maximum Achievable Control Technology ap plies to control of emissions of HAP, some of which are particulates. They are not part of the SIP, but the USEPA has delegated the State enforcement authority for standards that have been adopted by the State. (The standards adopted by the State are state-enforceable regardless of the USEPA delegation.)Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 6-1 Redesignation Demonstration and Ma intenance Plan December 18, 2009 

### 6.0 STATE COMPLIANCE WITH CLE AN AIR ACT REQUIREMENTS Section 107(d)(3)(E)(v) of the CAA requires that th e provisions of Sectio n 110 and Part D of the Act be met within the area to be redesignated. This means that North Carolina must meet all requirements, if any, that had come due as of the date of the redesignation request.

The USEPA in its latest guidance on meeting redesignation requirements as contained in a memorandum from John Calcagni, Director, Ai r Quality Management Division, Office of Air Quality Planning and Standards to the USEPA Regional Offices dated September 4, 1992, (See Appendix A), states that "For th e purposes of redesignation, a State must meet all requirements of Section 110 and Part D that were applicable prior to submittal of the complete redesignation request. When evaluating a redesignation request , Regions should not consider whether the State has met requirements that come due under the Ac t after submittal of a complete redesignation request."

Monitoring is one of the requirements of S ection 110. The NCDAQ commits to continue operating the current fine particulate matter m onitors in the Hickory and Triad nonattainment areas, providing sufficient funding is available fo r continued operation. Any monitor shutdowns or relocations will only be made with the approv al of the USEPA. No plans are underway to discontinue operation, relocation or otherwise affect the integr ity of the ambient monitoring network in place. The current monitors are operated consistent with 40 CFR Part 58 and any changes will only be made if they are consistent with 40 CFR Part 58.

NCDAQ believes that North Carolina has met all of the requirements of Section 110 and Part D.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 7-1 Redesignation Demonstration and Ma intenance Plan December 18, 2009 

### 7.0 CONCLUSION The most recent three years of fine particulat e matter monitoring data for the both the Hickory and Greensboro/Winston-Salem/High Point (Triad ) nonattainment areas demonstrate compliance with the NAAQS for annual fine particulate matte r. Since the 1990’s, there have been major programs enacted in North Carolina that have led to significant actual, enforceable emissions reductions, which have led to improvements in th e air quality in both th e Hickory and Triad areas. Additionally, the maintenance plan demonstr ates that the projecte d emissions inventories for 2021, the final year of the maintenance plan and ten years beyond the expected redesignation year, as well as the interim year s, are all less than the base year emissions inventory. Therefore, maintenance of the annual fine particulate matter NAAQS has also been demonstrated.

This redesignation demonstration and maintena nce plan has been prepared to meet the requirements of the 1990 Clean Air Act Amendments.