1 

BEFORE THE ADMINISTRATOR 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

In the Matter of: ) 

 ) 

FINAL RULE, ) 

AIR QUALITY DESIGNATIONS ) EPA-HQ-OAR-2008-0476; 

FOR THE 2008 OZONE NATIONAL ) FRL-9668-2, RIN 2060-AP37 

AMBIENT AIR QUALITY STANDARDS, ) 

77 FED. REG. 30,088 (MAY 21, 2012) ) 

 ) 

 ) 

ANDERSON COUNTY, TENNESSEE, ) 

BLOUNT COUNTY, TENNESSEE, and ) 

KNOX COUNTY, TENNESSEE ) 

 ) 

Petitioners. ) 

 

SUPPLEMENTAL PETITION FOR RECONSIDERATION 

 On July 20, 2012, pursuant to Section 307 of the Clean Air Act (“CAA”), 42 U.S.C. § 7607, 

Anderson County, Tennessee (“Anderson County”), Blount County, Tennessee 

(“Blount County”), and Knox County, Tennessee (“Knox County”) (collectively, “Counties”) 

filed a Petition for Reconsideration of the Final Rule entitled “Air Quality Designations for 

the 2008 Ozone National Ambient Air Quality Standards,” 77 Fed. Reg. 30,088 (May 21, 2012) 

(the “Final Rule”). The Counties, through the undersigned counsel, now file this Supplemental 

Petition for Reconsideration (the “Supplemental Petition”), which provides further technical 

analysis in support of the legal and technical arguments set forth in the Counties’ Petition for 

Reconsideration. 

INTRODUCTION

 EPA based its nonattainment designation for the Knoxville Combined Statistical Area 

(“Knoxville CSA” or “CSA”) on the violating Look Rock monitor in Blount County. EPA 
2 

Technical Support Document, Knoxville, Tennessee Area Designations for the 2008 Ozone 

National Ambient Air Quality Standards 16 (“TSD”). Look Rock is one of the most highly 

instrumented and studied ozone monitoring stations in the southeastern United States. Numerous 

researchers have studied Look Rock data measured as a part of the CASTNET and NCore 

monitoring programs, as well as other specialized measurements made from time to time. In 

addition to ozone, the CASTNET monitoring program measures an array of meteorological 

parameters,1 and the NCore monitoring program measures several gaseous and particulate air 

components.2 These researchers have reported extensively on their studies. In spite of this 

wealth of information, EPA took a simplistic approach to determining which counties in the 

Knoxville CSA to designate nonattainment and ignored much of what is known about the air 

quality of this very complex site. Consequently, the rationale undergirding EPA’s designations 

is seriously flawed. 

 EPA performed a number of analyses based on Look Rock CASTNET data, including 

analyses that it concluded demonstrated that Look Rock ozone levels are influenced by both 

valley and regional precursor emissions – conditions totally anomalous and not representative of 

the vast majority of the Knoxville CSA. See TSD at 13 (noting that, unlike two other 

Knox County sites and a high elevation site in North Carolina, Look Rock shows a “combination 

of . . . two signals”: “a typical urban pattern of ozone events in the afternoon” and “a typical high 

elevation site pattern ozone overnight.”). However, despite EPA’s conclusion that ozone levels at 

Look Rock are the result of these totally anomalous conditions, it used the 2009-2011 Look Rock 

design value exceedance of the NAAQS to designate the entirety of two counties and a portion of 

a third as nonattainment. 

                                                            

1 See http://epa.gov/castnet/javaweb/index.html for a description of the CASTNET program. 2 See http://www.epa.gov/ttnamti1/ncore/index.html for a description of the NCore program.
3 

 Because EPA was unaware of, or disregarded, the wealth of information that exists 

regarding air quality and meteorological conditions at Look Rock, it attributed the influences it 

identified as “valley” impacts to Knoxville. This misconception led EPA to conclude 

erroneously that Knox County and northern Blount County contribute meaningfully to 

the exceedance of the NAAQS at Look Rock. 

 In addition, EPA made the nonattainment designation despite its belief that (1) without 

designating any of the twelve counties in the Knoxville CSA nonattainment and burdening them 

with specific additional local emission reductions, NOX and VOC emissions in the Knoxville CSA 

are projected to decrease significantly due to national and regional emission-reducing rules 

already in place; and (2) these national and regional emission reductions will result in 

all monitors in the Knoxville CSA being well below the ozone NAAQS by 2015. 

While the aforementioned reductions will result from regional and national emission-reducing 

rules already in place, they will come at a significant cost to the citizens, businesses, and local 

governments in the CSA. Designating the entireties of Knox and Blount Counties and a portion 

of Anderson County as nonattainment will stigmatize the Counties and make it much harder for 

the area to overcome current economic conditions. 

TECHNICAL ANALYSIS 

 I. ADDITIONAL COMMENTS ON EPA’s TECHNICAL ANALYSIS OF 

 THE KNOXVILLE CSA. 

 In its TSD, EPA provided a list of counties in the Knoxville CSA with ozone monitors 

(Sevier, Blount, and Knox Counties have multiple monitors) along with the 2009-2011 design 

values for each of those counties. TSD at 6, Table 3. EPA noted that only one county in 

the CSA has a design value exceeding the ozone NAAQS: Blount County. Without 

acknowledging the fact that Blount County has two monitors -- one attaining the NAAQS (Cades 
4 

Cove with a 2009-2011 design value of 68 ppb) and one exceeding the NAAQS (Look Rock 

with a 2009-2011 design value of 77) -- EPA concluded that “Blount County shows a violation 

of the 2008 ozone NAAQS, therefore this county is included in the nonattainment area.” Id. at 6. 

 In the Meteorology section of the TSD, EPA provided an analysis of back trajectories 

using the National Oceanic and Atmospheric Administration’s Hybrid Single Particle Lagrangian 

Integrated Trajectory Model (“HYSPLIT”) to evaluate the potential contribution from nearby 

areas. The HYSPLIT analysis was done for days that exceeded the NAAQS at the Look Rock 

monitor during the 2009-2011 timeframe. Id. at 10-11, Figure 3. In addition, EPA discussed 

(but did not present) an analysis of the predominant wind directions in the area based on 

an analysis of thirty years’ of ozone season (March through October) National Weather Service 

(“NWS”) data from the Knoxville Airport located just 12.5 miles north-northeast of Look Rock. 

As EPA points out, the predominant wind direction during this period is from the southwest and 

west-southwest with a north-northeast component. Id. at 10. 

 The Counties provided EPA with an analysis of the NWS data for this time period, 

as well as the wind rose summary of that data. Letter from Michael K. Stagg to 

Gwendolyn Keyes-Fleming (April 5, 2012). Based on the Counties’ analysis, disregarding 

the calms (27.25% of the time), the wind is from the northwest, north, northeast, and east 

less than a quarter of the time, while it is from the southeast, south, southwest, and west over 

three quarters of the time. None of the areas EPA chose to designate as nonattainment are in 

the direction from Look Rock from which the winds dominate; therefore, they do not 

meaningfully contribute to the Look Rock monitor exceedance. 

 In the Geography/Topography section of the of the TSD, EPA presented an analysis of 

wind direction data from the CASTNET monitoring site at Look Rock for the days and times 
5 

when the hourly average ozone exceeded 75 ppb. TSD at 13, Figure 6. From this analysis, EPA 

erroneously drew the conclusion that there are “two distinct groups of high ozone events: 

afternoon ozone from the north to northwest (Knoxville) and overnight ozone from the south to 

southeast (regional transport).” Id. at 13. In its analysis, EPA did not mention that the local 

measurements of wind direction at the Look Rock CASTNET monitor have been shown by 

numerous researchers to be influenced by the very localized complex topography surrounding 

the monitoring site and to not be representative of the area-wide wind patterns. EPA also failed 

to mention that the local wind data it used in its analysis does not coincide with the wind 

direction data either from the NWS meteorological station at the Knoxville Airport or 

the HYSPLIT back trajectories it discusses in the Meteorology section of the TSD. Clearly, EPA 

ignored information it had readily available to reach a conclusion that wind directions measured 

at Look Rock indicated that sources in Knox County, northern Blount County, and Anderson 

County were making a “meaningful” contribution to high-ozone events at Look Rock. 

 Also in the Geography/Topography section of the TSD, EPA provided a detailed analysis 

of ozone concentrations at a high elevation monitor in North Carolina, the two monitors in 

Knox County, and the Look Rock monitor. Id. at 13, Figure 5. Based on that analysis, EPA 

concluded, “The Look Rock site . . . is impacted by both downwind afternoon ozone formation 

from Knoxville and high elevation ozone transport. In some cases, these two processes could be 

affecting the Look Rock monitor simultaneously.” Id. at 13. Again, EPA ignored readily 

available information, reached an erroneous conclusion, and used what it considers a totally 

anomalous situation to designate the entireties of Knox and Blount Counties and a portion of 

Anderson County as nonattainment. 
6 

 II. AN ANALYSIS OF HIGH-OZONE EVENTS AT LOOK ROCK BASED 

 ON WHAT IS KNOWN FROM EXTENSIVE MONITORING AND 

 RESEARCH. 

 As mentioned above, air quality at Look Rock has been studied extensively by various 

researchers through the years. These studies have demonstrated that localized wind direction 

measurements at Look Rock do not coincide with area-wide wind patterns. To explain this 

inconsistency, many researchers rely on the localized wind phenomenon identified by 

Roger Tanner and others. Roger L. Tanner, Solomon T. Bairai, Kenneth J. Olszyna, Myra L. 

Valente, and Ralph J. Valente, Diurnal Patterns in PM2.5 Mass and Composition at a 

Background, Complex Terrain Site, 39 Atmospheric Environment 3872 (2005) (hereinafter, 

“Tanner”); see also Kenneth J. Olszyna, Elizabeth M. Bailey, Romualdas Simonaitis, and James 

F. Meagher, O3 and NOy Relationships at a Rural Site, 99 J. of Geophysical Research 14,557 

(1994) (hereinafter, “Olszyna”); Roger L. Tanner, Patricia Brewer, Ivar Tombach, Scott 

Reynolds, Eric Edgerton, Ben Hartsell, and Jim Renfro, Development and Analysis of an Hourly, 

Chemically Speciated Database for PM2.5 Aerosols in the Southeastern US, Journal of Air and 

Waste Management Association (submitted June 18, 2008). Tanner explains that 

as expected, the temperature maxima trail solar radiation by about 2 hours. 

Nocturnal boundary breakup begins in the 0500–0600 (EST) timeframe, and 

boundary layer growth reaches the altitude of the site (about 825m MSL) in the 

0800–1000 (EST) timeframe. In the absence of frontal boundaries, extensive 

cloudiness and/or precipitation, this is nearly always accompanied by a shift in 

wind direction from southerly (down-slope) to the west and north direction 

(up-slope, up-Valley), along with a modest increase in wind velocity. 

On average, the wind direction drifts toward the south and west during the 

afternoon hours and collapses to southerly or southeasterly again around sunset. 

Tanner at 3872. 
7 

 This change in wind direction apparently is due to the orientation of the Look Rock ridge 

and the prevailing valley airflow. As elevation increases above the valley floor toward the tops 

of the ridges that define the sides of the valley, wind direction rotates to align with winds aloft. 

Winds aloft are more likely to have a westerly component which causes the wind direction at 

Look Rock to rotate toward an up-slope configuration. Late in the day, especially in summer, 

the sun angle is such that the west-facing slope of the Look Rock ridge is heated more than 

the opposite side which by that time is in shadow. This differential heating warms the slope and 

the air above it accelerating the up-slope airflow. When the solar heating stops, the western side 

of the slope cools quickly and the atmosphere begins to stabilize. The stable layer cuts off 

Look Rock from the westerly airflow aloft, and the cooling allows for the formation of 

a down-slope wind component. 

 In other words, the local wind direction measurements made at Look Rock are not 

an indication of the direction from which air masses arrive at the Look Rock monitor, but are 

the result of air flow “up-slope, up-Valley” during the daytime and “down-slope” during 

the nighttime. It, therefore, is erroneous for EPA to conclude that “afternoon ozone” is from 

Knoxville when the local CASTNET monitor shows wind direction measurements from 

the north. Rather, these “north” measurements result from a daily localized “up-slope” 

wind direction.

 To cast additional light on this localized wind direction phenomenon described by 

Tanner, the Counties examined data from the CASTNET monitor as well as from the NCore 

monitor, both located at Look Rock. While the CASTNET monitor measures ozone and 

numerous meteorological conditions (wind speed, wind direction, solar radiation, etc.), 
8 

the NCore monitoring system measures the concentration of a number of gaseous and particulate 

air components, including NO, NO2, total oxides of nitrogen (NOY), CO, PM2.5, and 

black carbon. 

 Of the twenty-three events during the 2009-2011 ozone seasons when the maximum 

8-hour average ozone concentration at Look Rock exceeded 75 ppb, practically complete sets of 

both CASTNET and NCore data exist for nine of the events.3

 These nine events should well 

represent the twenty-three total events because they occur in the early, middle, and late parts of 

the ozone season; in each of the three years used to calculate the design value; and on days when 

the HYSPLIT back trajectories were from practically every compass direction. Tables 1 and 2 in 

Appendix 1 provide a tabulation of the pertinent data used in the Counties’ analysis, while 

Appendix 2 contains the back trajectories used. 

 A close inspection of the wind direction data from the Look Rock CASTNET monitor 

and the HYSPLIT back trajectory data reveals that during the daytime hours, the wind direction 

measured at the Look Rock CASTNET monitor rarely coincided with the direction from which 

the parcels of air were computed by HYSPLIT to be arriving at Look Rock. For instance, on 

April 15, 2010, the Look Rock CASTNET monitor measured wind directions from the north and 

northwest from 1000 through 1900 EST (a condition consistent with the explanation provided by 

Tanner as well as other researchers), while the back trajectories indicated no air flow to 

the Look Rock area from that direction. Rather, back trajectories all day were from the south 

and southeast. Based on EPA’s analysis (see TSD at 13-15), which relied primarily on the wind 

direction measurements at Look Rock, EPA would have concluded that the high ozone 

concentrations during the daytime hours of April 15, 2010, resulted from emissions in 

                                                            

3

 An “event” often spans two calendar days. 
9 

the Knoxville, north Blount, and Anderson County areas. However, as noted above, the 

afternoon wind direction data at Look Rock actually measures the change in local winds from 

up-slope to down-slope as the day progresses, not the actual direction from which the winds 

arrived. Thus, EPA’s conclusion that emissions came from areas north of Look Rock in this case 

is erroneous. 

 Likewise, on June 25, 2009 (again, consistent with the Tanner description of 

the meteorology of Look Rock), according to the wind direction measurements made at 

Look Rock at 1900 (as solar radiation approached zero), the wind began shifting to the east and 

southeast after having been from the north and northwest since 1000 EST. However, 

an examination of the back trajectories for this day indicates little change in the wind direction 

all day, which was from the north to northeast. This inconsistency again shows that Look Rock’s 

wind direction monitor actually measures the daily cycle of up-slope and down-slope airflows, 

not actual area-wide wind direction. Consequently, the wind direction data at Look Rock cannot 

be relied upon to reach conclusions about the sources of precursor emissions that create high 

ozone events at Look Rock. 

 To further substantiate the view that Tanner and other researchers have of diurnal 

meteorology at Look Rock, the Counties performed an analysis of all the wind direction data 

from the Look Rock CASTNET monitor for the 2009-2011 timeframe. For this analysis, wind 

direction data for each compass quadrant (i.e., east -- 45o

 to 135o, south – 135o to 225o, west 225o

to 315o

, and north 315o to 45o) was correlated with solar radiation. Solar radiation was chosen 

because Tanner and others have observed that wind direction seems to change in the early 

morning as the sun rises and in the late afternoon when the sun sets. Tanner at 3872. Table 3 in 

Appendix 1 summarizes the results of this analysis. 
10 

 This analysis demonstrates that wind directions from the north and west tend to dominate 

during the daylight hours (higher average solar radiation), while wind directions from the east 

and south tend to dominate during nighttime hours (lower average solar radiation). The pattern 

is similar for both the periods of time when the ozone level exceeds 75 ppb and when it does not. 

However, the predominance of north and west in the daytime and east and south in the nighttime 

is much more pronounced when the ozone concentration exceeds 75 ppb. This too is consistent 

with the observation made by Tanner that “in the absence of frontal boundaries, extensive 

cloudiness and/ or precipitation,” which are the ideal conditions for ozone production, “the wind 

shifts direction from southerly (down-slope) to the west and north direction (up-slope, 

up-Valley) as the sun rises and drifts toward the south and west during the afternoon hours and 

changes to southerly or southeasterly around sunset.” Tanner at 3872. EPA’s reliance primarily 

on the CASTNET wind direction data from Look Rock to infer that northern Blount County, 

Knox County, and Tennessee Valley Authority’s (“TVA”) Bull Run Power Plant are meaningful 

sources of Look Rock ozone precursors is seriously flawed.4

 

 The Counties conducted an in-depth analysis of the HYSPLIT back trajectories during 

each of the twenty-three events when the maximum 24-hour ozone concentration exceeded 

75 ppb. These back trajectories are shown in Appendix 2, and the in-depth analysis is 

summarized in Table 4 in Appendix 1. As can be seen by this analysis, during only about a third 

of the episodes (eight out of twenty-three) did the back trajectory pass across the densely 

populated portions of Knox County where emissions of NOX and VOCs from Knox County 

could have made any contribution to ozone concentrations at Look Rock. See TSD at 10, 

Figure 2 (showing the “densely populated portions of Knox County”). 

                                                            

4

 As described below, TVA has operated its Bull Run Power Plant with selective catalytic reduction (“SCR”) NOx 

removal technology (with a 90-95% control efficiency) since 2004. 
11 

 In addition to the aforementioned analysis conducted by the Counties, TVA performed 

a detailed statistical analysis of the same twenty-three high ozone events and concluded that 65% 

of the Look Rock high ozone events are not associated with or significantly impacted by 

Knoxville-area emissions. See Stephen F. Mueller, Cluster Analysis of Look Rock High Ozone 

Events and Related Air Parcel Trajectories for 2009-2011 (hereinafter, “Mueller”) (attached as 

Appendix 3).5 The conclusions of TVA and the Counties are consistent and strongly 

demonstrate that Knox County did not contribute in a meaningful way to high ozone events at 

Look Rock during the 2009-2011 time period. 

 III. THE COUNTIES’ ANALYSIS OF EACH HIGH-OZONE EVENT. 

 As noted above, the nine events for which there is complete data from both CASTNET 

and NCore should well represent the twenty-three events in the 2009-2011 timeframe when 

the maximum 8-hour ozone concentration at Look Rock exceeded 75 ppb. Consequently, 

the Counties have conducted an in-depth analysis of these nine events, comparing CASTNET 

and NCore data with several HYSPLIT back trajectories for the period during the event when 

the hourly ozone concentration exceeded 75 ppb. Table 4 in Appendix 1 summarizes this 

detailed analysis. 

For the Counties’ analysis, the photochemical age of the air mass was used to determine 

the distance from which the NOX (NO and NO2) emissions that contributed to the ozone exceedances 

must have come. Photochemical age has been used extensively by researchers to describe 

the average age of NOX in studies of ozone formation from both point and nonpoint sources. 

Menachem Luria, Ralph J. Valente, Solomon Bairai, William J. Parkhurst, and Roger L. Tanner, 

                                                            

5 Available at http://www.tva.com/environment/pdf/Cluster_Analysis.pdf.
12 

Nighttime Chemistry in the Houston Urban Plume, 42 Atmospheric Environment 7544 (2008); 

Menchem Luria, Ralph J. Valente, Solomon Bairai, William J. Parkhurst, and Roger L. Tanner, 

Airborne Study of Ozone Formation over Dallas, Texas, 42 Atmospheric Environment 6951 (2008) 

(hereinafter, “Luria”); J. Dommen, A.S.H. Prevot, A.M. Hering, T. Stafflebach, G.L. Kok, and 

R.D. Schillawski, Photochemical Production and Aging of an Urban Air Mass, 104 Journal of 

Geophysical Research pages 5493 (1999). Photochemical age is computed by dividing 

the concentration of non-NOX (NO + NO2), or more highly oxidized forms of nitrogen in an air 

mass, by the total concentration of all odd-nitrogen oxidized forms. It is normally identified as 

NOZ/NOY. NOZ/NOY varies from 0.0 to 1.0 with the older photochemical ages being nearer 1.0. 

A photochemical age near 0 would indicate that all, or almost all, of the oxidized nitrogen in 

the air mass is present as NOX, while a photochemical age of 1.0, would indicate that none of 

the oxidized nitrogen in the air mass is present as NOX. Olszyna has found that there is little 

additional ozone formation in an air mass with a photochemical age of 0.7 or greater. Olszyna at 

14,561. Further, a lower photochemical age generally implies that nearby sources are more 

influential, while a higher photochemical age generally implies that sources farther away have 

had more impact. See Mueller at 5-6. 

 Therefore, for this analysis, air masses arriving at Look Rock with average 

photochemical ages below 0.5 were considered young, still capable of producing quite a lot of 

ozone, and the sources of NOX in the air mass being nearby; air masses with photochemical ages 

of 0.5 to 0.7 were considered moderately aged, still capable of producing some ozone, and 

the sources of NOX being some distance away; and air masses with photochemical ages above 

0.7 were considered well-aged, no longer producing much ozone, and the sources of NOX being 

a long distance away. 
13 

 In addition to photochemical age, the concentrations of CO from the NCore data set were 

used as indicators of the source of ozone precursor emissions. Emissions from mobile sources 

are relatively high in CO, while emissions from most industrial point sources, certainly electric 

generating units (“EGUs”), are relatively low in CO. Luria at 6598. Therefore, an air mass 

arriving at Look Rock with a relatively high concentration of CO would indicate that the sources 

of the ozone precursors were heavily influenced by mobile sources, while air masses with 

relatively low CO concentrations would be more indicative of ozone precursor source regions 

with a low density of mobile sources. Air masses predominated by mobile source emissions 

have been shown to have CO concentrations in excess of 140 ppb. Luria at 6953. An analysis of 

all the CO data available for 2009-2011 at Look Rock (not just the data for the nine events, but 

the entire data set for the three-year period) indicates the average CO concentration to be 

180 ppb with a standard deviation of 50 ppb. Therefore, a CO concentration at Look Rock of 

0-130 ppb was considered low and indicative of a small influence by mobile sources, 

a CO concentration of 131-230 was considered high and indicative of substantial influence from 

mobile sources, and a CO concentration greater than 230 was considered extremely high and 

strongly influenced by mobile sources. 

 A. June 25-26, 2009.

During the high-ozone event on June 25-26, 2009, the photochemical ages of 

the air masses arriving at Look Rock were generally in the old range (ages ranged from 0.69 to 

0.92 with an average of 0.78), and the CO concentrations were moderately high (CO ranged from 

134 to 207 ppb with an average of 161 ppb). The back trajectories were generally from 

the northeast to north during the period. Based on this analysis, it appears likely that the sources 

of the NOX emissions that created the high ozone event were from a combination of mobile and 
14 

point sources in the valley northeast of Look Rock, potentially from as far away as the Tri-Cities 

area, as well as areas in Hamblen and Jefferson Counties along the Interstate 81 corridor, in 

Cocke County along the Interstate 40 corridor, and in western Sevier County and eastern 

Knox County. With a photochemical age averaging 0.78, it is not likely that substantial ozone 

was produced from nearby NOX emissions in Blount County. 

 B. April 2-3, 2010. 

 During the high-ozone event on April 2-3, 2010, the photochemical ages of the air masses 

arriving at Look Rock were generally in the old range (ages ranged from 0.47 to 0.93 with an 

average of 0.81), and the CO concentrations were extremely high (CO ranged from 256 to 327 ppb 

with an average of 278 ppb). The back trajectories generally were from the south during 

the period. Based on this analysis, it appears likely that the sources of the NOX emissions that 

created the high ozone event were primarily the result of mobile sources. Examining the back 

trajectories strongly suggests these mobile source emissions emanated from north Georgia, 

possibly as far away as the Atlanta area. Because the air masses arriving at Look Rock during 

this event should not have received fresh NOX emissions during the last twelve hours prior to 

arriving at Look Rock (because they basically passed over the remote, forested areas of north 

Georgia, southeast Tennessee, and southwestern North Carolina), and because the photochemical 

ages of the air masses generally were in the old range, one can conclude that ozone may be 

transported to a site like Look Rock from vast distances. 

 C. April 13-14, 2010. 

During the high-ozone event on April 13 and the morning of April 14, 2010, 

the photochemical ages of the air masses arriving at Look Rock averaged in the moderate range 

(ages ranged from 0.08 to 0.91 with an average of 0.60), and the CO concentrations were high 
15 

(CO ranged from 189 to 240 ppb with an average of 221 ppb). With regard to the photochemical 

age, the air masses arriving at Look Rock were generally old, except for the period 1900 – 2100 

when NOX levels increased dramatically. This dramatic increase in NOX levels coincided with 

sundown and a slight increase in CO levels. These changes suggest impacts from nearby mobile 

sources. The back trajectories were generally from the south and west during the period. 

Specifically, the air mass arriving at Look Rock during the hour when the NOX levels were 

the highest and the photochemical age the lowest spent the preceding three hours over extreme 

southeastern Loudon County and extreme southwestern Blount County. Based on this analysis, 

it appears likely that the sources of the NOX emissions that created the high ozone event were 

primarily the result of mobile sources southwest and west of Look Rock, particularly in Monroe 

County and along the I-75 corridor in McMinn County. 

 D. April 14, 2010. 

 During the high-ozone event on the afternoon and evening of April 14, 2010, the 

photochemical ages of the air masses arriving at Look Rock were generally in the old range (ages 

ranged from 0.50 to 0.88 with an average of 0.80), and the CO concentrations were extremely 

high (CO ranged from 224 to 242 ppb with an average of 233 ppb). The air masses arriving at 

Look Rock during the 1700 – 2000 timeframe had slightly higher NOX levels and younger 

photochemical ages. Again, this increase in NOX levels coincided with sundown and, in this 

case, a dramatic shift in local wind direction. Since there was no change in the direction of the 

back trajectories, it is apparent that this shift in wind direction was due to the localized 

phenomenon identified by Tanner and is related to a shift in winds from up-slope to down-slope 

as the boundary layer settled below the Look Rock monitor. The back trajectories were 

generally from the south to the southwest during the entire period. Based on this analysis, 
16 

it appears likely that the sources of the NOX emissions that created the high-ozone event 

were primarily the result of mobile sources south and southwest of Look Rock, particularly in 

Hamilton, McMinn, and Monroe Counties. 

 E. April 15, 2010. 

During the high-ozone event on April 15, 2010, the photochemical ages of the air masses 

arriving at Look Rock were generally in the moderate range (ages ranged from 0.32 to 0.85 with 

an average of 0.66), and the CO concentrations were in the high range (CO ranged from 199 to 

248 ppb with an average of 217 ppb). As during some of the aforementioned events, the air 

masses arriving at Look Rock during 1900 – 2300 timeframe had slightly higher NOX levels and 

younger photochemical ages. Again, this increase in NOX levels coincided with sundown and 

a dramatic shift in local wind direction. As with the April 14 event, there was no change in 

the direction of the back trajectories during this period; therefore, it is apparent that this localized 

shift in wind direction was due to a shift in winds from up-slope to down-slope as the boundary 

layer settled below the Look Rock monitor. The back trajectories were generally from 

the southwest during the entire period. Based on this analysis, it appears likely that the sources 

of the NOX emissions that created the high-ozone event were primarily the result of mobile 

sources southwest of Look Rock, particularly along the I-75 corridor in Hamilton, Bradley, 

McMinn, and Monroe Counties.

 F. May 5-6, 2010. 

During the high-ozone event on May 5 and the morning of May 6, 2010, 

the photochemical ages of the air masses arriving at Look Rock were generally in the moderate 

range (ages ranged from 0.59 to 0.72 with an average of 0.63), and the CO concentrations were 

in the high range (CO ranged from 190 to 213 ppb with an average of 199 ppb). 
17 

The back trajectories were generally from the south and southwest during the entire period and 

did not cross heavily populated areas or major transportation corridors after crossing over 

the I-75 corridor in north Georgia eighteen to twenty-four hours before the high-ozone event. 

Based on this analysis, it appears likely that the sources of the NOX emissions that created 

the high-ozone event were primarily the result of mobile sources southwest of Look Rock, 

possibly in the north Georgia area. 

 G. May 6-7, 2010. 

During the high-ozone event on the afternoon of May 6 and May 7, 2010, 

the photochemical ages of the air masses arriving at Look Rock were generally in the moderate 

range (ages ranged from 0.13 to 0.90 with an average of 0.60), and the CO concentrations were 

in the high range (CO ranged from 202 to 228 ppb with an average of 213 ppb). As with some of 

the aforementioned events, the NOX levels increased and the photochemical age declined at 

sundown as the local winds shifted from up-slope to down-slope. The back trajectories during 

the event began primarily from the south and shifted during the event toward the west and 

northwest. Based on this analysis, it appears likely that the sources of the NOX emissions that 

created the high-ozone event were primarily the result of mobile sources from the I-75 corridor 

southwest of Look Rock and from Monroe, Loudon, southern Knox, and northwestern 

Blount Counties. 

 H. October 11-12, 2010. 

During the high-ozone event on October 11-12, 2010, the photochemical ages of the air 

masses arriving at Look Rock were generally old (ages ranged from 0.78 to 0.88 with an average 

of 0.82), and the CO concentrations were in the high range (CO ranged from 158 to 169 ppb with 

an average of 164 ppb). The back trajectories during the event were generally from 
18 

the southwest during the entire event. Based on this analysis, it appears likely that the sources of 

the NOX emissions that created the high-ozone event were primarily the result of mobile sources 

from Bradley, McMinn, and Monroe Counties along the I-75 corridor and potentially from 

the Chattanooga and North Georgia areas. 

 I. August 3, 2011. 

During the high-ozone event on August 3, 2011, the photochemical ages of the air masses 

arriving at Look Rock were generally old (ages ranged from 0.71 to 0.90 with an average of 

0.83), and the CO concentrations were extremely high – some of the highest measured in 

the 2009-2011 timeframe (CO ranged from 454 to 567 ppb with an average of 332 ppb). 

The back trajectories during the event were generally from the southwest during the entire event. 

Based on this analysis it appears likely that the sources of the NOX emissions that created 

the high ozone event were primarily the result of mobile sources from Bradley, McMinn, and 

Monroe Counties along the I-75 corridor and potentially from the Chattanooga area or 

farther south. 

 In summary, the back trajectory information for these nine events is consistent with 

the data from the NWS meteorological monitoring station at the Knoxville Airport in that 

the predominant direction from which air masses arrive at Look Rock is the south and southwest. 

Generally, the photochemical age of the air masses arriving at Look Rock is in the old range, 

although during several of the nine events as the sun set and localized wind directions (measured 

at Look Rock) shifted from up-slope to down-slope, NOX levels increased and photochemical 

age decreased. During those periods, however, wind directions based on back trajectories were 

normally not from Knox, northern Blount, or Anderson Counties. Also, CO levels were generally 
19 

high, which indicates that the sources of ozone precursors during these nine high ozone events 

were likely primarily mobile sources as opposed to industrial point sources. 

 IV. CSAPR and 2008 STANDARD MODELING. 

 In her September 22, 2011 memorandum to EPA Regional Air Division Directors, 

Assistant Administrator Gina McCarthy states that “EPA’s modeling indicates that 

approximately half of the 52 areas [not attaining the 2008 standard] would attain the 0.075 ppm 

standard by 2015 (the expected deadline for Marginal areas) as a result of the emission-reducing 

rules already in place.” Memorandum from Gina McCarthy to Air Division Directors 

(Sept. 22, 2011) 2 (“McCarthy Memo.”). Later in that same memorandum, Ms. McCarthy lists 

some of the “emission-reducing rules” to which her earlier statement refers, such as 

the Cross-State Air Pollution Rule (“CSAPR”),6

 the Portland Cement Rule, the Light and 

Heavy Duty Vehicle standards, the Boiler Maximum Achievable Control Technology, the 

Mercury and Air Toxics Standards for power plants, the New Source Performance Standards for 

Commercial Incinerators/Solid Waste Incinerators and the Oil/Gas sector, and the Tier 3 vehicle 

and fuel standards. Id. She notes, “These federal actions will ensure steady forward progress to 

clean up the nation’s air and protect the health of American families, while minimizing and in 

many cases eliminating the need for states to use their scarce resources on local actions.” Id. 

 In support of these statements, Ms. McCarthy refers to modeling described in the 

Spreadsheet projecting the hypothetical 8-hour ozone nonattainment areas for the 75 ppb 

NAAQS to 2015 to estimate the number of marginal nonattainment areas that are expected to 

                                                            

6

 In light of several petitions for review of CSAPR, the U.S. Appeals Court for the D.C. Circuit stayed CSAPR on 

December 30, 2011, and ordered that the Clean Air Interstate Rule (“CAIR”) remain in effect pending resolution of 

the petitions for review. On August 21, 2012, the D.C. Circuit vacated CSAPR and reinstated CAIR. See Order, 

EME Homer City Generation, L.P. v. EPA, No. 11-1302 (D.C. Cir. Aug. 21, 2012). 
20 

attain the NAAQS by their attainment date of 2015, (EPA-HQ-OAR-2010-0885-0064). In that 

document, EPA describes how it used CSAPR modeling to make projections for the ozone 

monitors across the country for 2015. Basically, the approach projects the 2008‐2010 ozone 

design values to 2015 using the modeled average percent per year change in ozone from the 2014 

CSAPR final rule modeling (i.e., the CSAPR remedy case). The CSAPR modeling used a base 

year of 2005 and a future year of 2014 – a nine-year projection. EPA pro-rated the percent 

average annual ozone changes over the nine-year period to estimate the expected change in 

ozone between the 2008‐2010 period and 2015, the year Marginal nonattainment counties must 

attain the 2008 standard. Because there are five years between 2010 and 2015, EPA used 5/9ths 

of the modeled percent change (between 2005 and 2014) and applied this pro-rated factor to 

the 2008-2010 design value for each monitor. 

 The CSAPR modeling is described in detail in Air Quality Modeling Final Rule 

Technical Support Document, US EPA, OAQPS, Air Quality Assessment Division, Research 

Triangle Park, NC (June 2011). EPA used 2005 as the base year for the CSAPR modeling 

because it was the most current year for which EPA had a complete National Emissions 

Inventory (“NEI”) available. Id. at 2. In addition to the 2005 base case, three future scenarios 

were modeled – 2012 base case, 2014 base case, and 2014 remedy. Id. The 2014 remedy case 

contained the emission reductions resulting from CSAPR plus all the other “emission-reducing 

rules” expected to come into effect between 2012 and 2014. Id. at 50 n.55. In contrast, the other 

future scenarios were based on just the other “emission-reducing rules” coming into effect 

between 2012 and 2014. Id. 

 The details of the emission inventories used in creating the emissions inputs for the 

modeling are described in Emissions Inventory Final Rule Technical Support Document, US 
21 

EPA, OAQPS, Air Quality Assessment Division, Research Triangle Park, NC (June 28, 2011). 

According to this document, emission inputs for the 2012 and 2014 scenarios generally take into 

account “Federal and State measures already promulgated before emissions processing on 

the Transport Rule [CSAPR] began in December, 2010.” Id. at 68. With respect to 

electric generating unit (“EGU”) emissions, the document states that “the emissions reflect state 

rules and federal consent decrees through December 1, 2010.” Id. For mobile sources, “all 

national measures for which data were available at the time of the modeling” were included. Id.

However, for non-EGU point sources and nonpoint sources, local control programs that might 

have been necessary for areas to attain the 1997 PM2.5 annual NAAQS, the 2006 PM2.5 24-hour 

NAAQS, and the 1997 ozone NAAQS were generally not included in the future scenarios. Id. 

 The Emissions Inventory Final Rule Technical Support Document’s “Emissions 

Summaries”7

 spreadsheet provides the specific emission levels used in the CSAPR modeling by 

type of emission source and by state. The Counties used the values in this spreadsheet to 

perform the technical analysis described below. Table 5 in Appendix 1 summarizes the NOX and 

VOC emission levels used in the modeling along with the percentage of emission reductions by 

emission source type for Tennessee. As can be seen, emissions of ozone precursors are projected 

to drastically decrease across Tennessee between 2005 and 2014 due to nation-wide 

“emission-reducing rules” included in the CSAPR modeling. NOX emissions are projected to 

decrease by about 43% in that timeframe while VOC emissions are projected to decrease by 

about 23%. 

                                                            

7 Available at http://www.epa.gov/airtransport/techinfo.html. 
22 

 Using an approach similar to that taken by EPA for comparison with the 2008 ozone 

NAAQS, the Counties extrapolated the CSAPR modeling for 2014 to 20158

 by taking 

the average annual 2005 to 2014 emission reduction percentages for Tennessee listed in Table 5 in 

Appendix 1 and applying them to the corresponding 2008 emissions for the twelve counties in the 

Knoxville CSA. In other words, the Counties divided the 2005 to 2014 emission reduction 

percentages in Table 5 in Appendix 1 by nine (for the nine-year period between 2005 and 2014) 

and multiplied the resulting average annual emission reduction percentage by seven (for the 

seven years between 2008 and 2015). The county-level emissions used in the analysis are from 

the 2008 NEI, v2.9

 These 2008 emission levels vary somewhat from the emission levels 

referenced by EPA in its attachment to Gwendolyn Keyes Fleming’s December 8, 2011 letter to 

Governor Bill Haslam (concerning EPA’s intentions to designate certain counties in Tennessee 

as nonattainment) due to EPA’s use of an earlier version (v1.5) of the 2008 NEI. Version 1.5 is 

no longer available. Tables 6 and 7 in Appendix 1 summarize the results of the Counties’ 

analysis of the projected NOx and VOC reductions in the CSA from 2008-2015. 

 As can be seen in Tables 6 and 7 in Appendix 1, based on this analysis, emissions of NOX

and VOCs are projected by EPA to drastically decrease in the twelve counties making up the 

Knoxville CSA. Of note is that NOX emissions are projected to decrease by about 32% in the 

three counties EPA has designated as nonattainment (Knox, Blount, and Anderson), while VOC 

emissions are projected to decrease by about 16%. These are significant reductions and will 

come at a cost to the citizens and businesses in the Knoxville area. 

                                                            

8 See pages 20-21 supra, describing the approach used in Spreadsheet projecting the hypothetical 8-hour ozone 

nonattainment areas for the 75 ppb NAAQS to 2015 to estimate the number of marginal nonattainment areas that 

are expected to attain the NAAQS by their attainment date of 2015, (EPA-HQ-OAR-2010-0885-0064)). 9 Available at http://www.epa.gov/ttn/chief/net/2008inventory.html. 
23 

 With regard to EGU emissions in the Knoxville CSA, TVA has already significantly 

reduced NOX emissions at both its Bull Run Power Plant in Anderson County and its Kingston 

Power Plant in Roane County. NOX emissions have been reduced at Bull Run by about 89% on 

an annual basis, while annual emissions have been reduced by about 91% at Kingston. In both 

cases these reductions exceed the 55.7% reduction the Counties assumed in their analysis. These 

reductions have been achieved by adding SCR to all units at both plants. Table 8 in Appendix 1 

summarizes the NOX emissions levels and rates for Bull Run Power Plant for the last seven 

years, and Table 9 in Appendix 1 summarizes the emission levels and rates for Kingston. Note 

that the annual NOx emission rates have decreased at Bull Run and Kingston by about 80% and 

74%, respectively. Neither NOx emissions nor the NOx emission rate from the Bull Run or 

Kingston Power Plants is expected to increase through the foreseeable future due to (1) the 

continued effect of CAIR;10 (2) the requirements of a federally enforceable consent decree (See 

Consent Decree, Alabama v. TVA, No. 3:11-cv-00170 (E. D. Tenn. June 6, 2011) (requiring TVA 

to, inter alia, cap system-wide NOx emissions through 2018 and each year thereafter); and (3) 

TVA’s own commitments to reduce its load growth and install emission reduction equipment 

and new technology to control emissions from over 80% of fossil generation in the next ten 

years. (See “2010 Review of TVA’s 2008 Environmental Policy” 8, attached hereto as Appendix 

4). 

 Table 10 in Appendix 1 summarizes the results of the modeling done for CSAPR and the 

extrapolations made by EPA for the 2008 ozone NAAQS for the Knoxville CSA from 

Spreadsheet projecting the hypothetical 8-hour ozone nonattainment areas for the 75 ppb 

NAAQS to 2015 to estimate the number of marginal nonattainment areas that are expected to 

                                                            

10 On August 21, 2012, the D.C. Circuit vacated CSAPR and reinstated CAIR. See Order, EME Homer City 

Generation, L.P. v. EPA, No. 11-1302 (D.C. Cir. Aug. 21, 2012). 
24 

attain the NAAQS by their attainment date of 2015, (EPA-HQ-OAR-2010-0885-0064). These 

ozone levels represent the improvements to air quality projected to result from the emission 

reductions EPA projects will be made in the Knoxville area, as well as across the region. As can 

be seen, all nine of the monitors in the area are projected to be well below the 2008 ozone 

NAAQS by 2014 and 2015, including Look Rock, based on EPA’s modeling. As described 

above and mentioned in the McCarthy Memo, these monitors are projected to be 7-16% below 

the NAAQS by 2015 due to “emission-reducing rules already in place” and without “the need for 

states to use their scarce resources on local actions.” 

CONCLUSION 

 Only one monitor out of nine in the Knoxville CSA had a 2009-2011 design value that 

exceeded the NAAQS. That monitor is located at Look Rock in Blount County. Blount County 

has a second monitor located just nine miles from Look Rock -- the Cades Cove monitor -- with 

a design value well below the NAAQS. 

 As noted above, Look Rock is one of the most instrumented and studied ozone 

monitoring stations in the southeastern United States. However, instead of relying on readily 

available (and extensive) Look Rock research, EPA took a simplistic approach to determining 

which counties in the Knoxville CSA to designate nonattainment and ignored much of what is 

known about the air quality and meteorology of this very complex Look Rock site. 

 EPA itself concluded in the TSD that high-ozone events at Look Rock were due to totally 

anomalous conditions, not representative of the vast majority of the Knoxville CSA. 

Nonetheless, it used the 2009-2011 Look Rock design value exceedance of the NAAQS to 

designate the entirety of two counties and a portion of a third as nonattainment. 
25 

 Because EPA was unaware of or disregarded the wealth of information that exists 

regarding air quality and meteorological conditions at Look Rock, it attributed the influences it 

identified as “valley” impacts to Knoxville. EPA’s erroneous conclusion concerning the source 

areas of ozone precursors during high ozone events led it to designate the entirety of Knox and 

Blount Counties and a portion of Anderson County nonattainment. However, the back trajectory 

analyses conducted by both the Counties and TVA clearly demonstrate that air masses arriving at 

Look Rock during the high-ozone periods come from a variety of directions, most often from the 

south to southwest. Thus, EPA’s determination that ozone exceedances will decrease as a result 

of reducing Knoxville-area emissions (through the nonattainment designation) is arbitrary and 

capricious. 

 In addition, EPA’s modeling for CSAPR projects significant NOX and VOC emission 

reductions in the twelve-county Knoxville CSA between 2005 and 2014. EPA’s modeling for 

implementation of the 2008 standard extrapolated the CSAPR modeling to 2015 and found that 

approximately half of all currently nonattaining areas nationwide would meet the 2008 standard 

in 2015, due to national and regional “emission-reducing rules already in place” and without 

“the need for states to use their scarce resources on local actions.” McCarthy Memo. at 2. 

The Counties calculated the county-by-county emissions projected for the Knoxville CSA by 

2015 and found that NOX emissions in the CSA are projected to decrease by over 25,000 tons per 

year or about 33% between 2008 and 2015 and that VOC emissions are projected to decrease by 

over 10,000 tons per year or about 19% over the same time period. See Tables 6 and 7 in 

Appendix 1. Based on the CSAPR modeling and EPA’s 2008 ozone standard modeling, all 

monitors in the Knoxville CSA are projected to be well below the 2008 ozone NAAQS by 2014 

and 2015. 
26 

 The Counties’ analysis of nine high-ozone events at Look Rock indicated that the ozone 

precursor NOX emissions that contributed to the high ozone levels were primarily from mobile 

sources. The Counties’ analysis of emission reductions that result from national and regional 

emission-reducing rules indicates that between 2008 and 2015, mobile source NOX emissions 

across the twelve-county Knoxville CSA are projected to decrease by 15,695 tons per year or 

about 33%, while mobile source VOC emissions are projected to decrease by 8,880 tons per year 

or about 33%. 

 Further, TVA already has reduced NOX emissions at both its Bull Run Power Plant and 

its Kingston Power Plant to levels well below what is reflected in the CSAPR modeling by 

adding SCRs to all units at both plants (emissions in 2009, 2010, and 2011 were already at this 

level). 

 EPA promised to “minimize the regulatory burdens on the States” in making its ozone 

designations. McCarthy Memo. at 1. Nonetheless, EPA has designated Blount County, 

Knox County, and a portion of Anderson County nonattainment when (1) EPA’s analysis 

indicates that high-ozone events at the lone (high-altitude) nonattainment monitor are due to 

anomalous conditions; and (2) EPA’s modeling shows that the entire Knoxville CSA will be in 

attainment with the 2008 standard in 2015. EPA has acted arbitrarily, capriciously, in abuse of 

its discretion, and otherwise not in accordance with law in making its Knoxville CSA 

nonattainment designations, and the Counties ask for reconsideration of the Final Rule. 

 

28 

Appendix 1 

Data Tables. 
29 

Table 1: Pertinent Nitrogen Data Used in the Counties’ Analysis. 

Date Time

Ozone 

(μg/m3) NOZ/NOY

NO 

(μg/m3)

NO2

(μg/m3) 

NOX

(μg/m3)

NOZ

(μg/m3)

NOY

(μg/m3

20090625 13:00 70 0.79 0.05 0.5 0.55 2.09 2.64 20090625 14:00 79 0.82 0.05 0.58 0.63 2.81 3.44 20090625 15:00 88 0.77 0.05 0.9 0.95 3.19 4.14 20090625 16:00 92 0.81 0.05 0.87 0.92 3.82 4.74 20090625 17:00 93 0.75 0.32 1.01 1.33 3.91 5.24 20090625 18:00 89 0.79 0.22 0.84 1.06 3.88 4.94 20090625 19:00 81 0.76 0.12 0.6 0.72 2.22 2.94 20090625 20:00 81 0.72 0.22 0.55 0.77 1.97 2.74 20090625 21:00 76 0.78 0.05 0.47 0.52 1.82 2.34 20090625 22:00 76 0.69 0.32 0.49 0.81 1.83 2.64 20090625 23:00 76 0.75 0.05 0.47 0.52 1.52 2.04 20090626 0:00 75 0.92 0.05 0.13 0.18 2.02 2.2 

Ave. 81.3 0.78 0.13 0.62 0.75 2.59 3.34 

Max. 93 0.92 0.32 1.01 1.33 3.91 5.24 

Min. 70 0.69 0.05 0.13 0.18 1.52 2.04 
30 

Table 1: Pertinent Nitrogen Data Used in the Counties’ Analysis. 

Date Time

Ozone 

(μg/m3) NOZ/NOY

NO 

(μg/m3)

NO2

(μg/m3) 

NOX

(μg/m3)

NOZ

(μg/m3)

NOY

(μg/m3

20100402 13:00 0.85 0.12 0.91 1.03 5.81 6.84 20100402 14:00 0.90 0.12 0.41 0.53 4.61 5.14 20100402 15:00 79 0.88 0.22 0.37 0.59 4.15 4.74 20100402 16:00 81 0.86 0.22 0.48 0.70 4.34 5.04 20100402 17:00 79 0.84 0.12 0.64 0.76 3.88 4.64 20100402 18:00 80 0.77 0.32 0.84 1.16 3.78 4.94 20100402 19:00 89 0.47 2.92 1.2 4.12 3.62 7.74 20100402 20:00 87 0.69 1.02 0.65 1.67 3.77 5.44 20100402 21:00 81 0.89 0.05 0.41 0.46 3.58 4.04 20100402 22:00 81 0.90 0.05 0.34 0.39 3.65 4.04 20100402 23:00 84 0.93 0.05 0.25 0.30 3.94 4.24 20100403 0:00 83 0.84 0.35 0.37 0.72 3.72 4.44 20100403 1:00 79 0.78 0.55 0.33 0.88 3.06 3.94 20100403 2:00 77 0.80 0.15 0.72 0.87 3.47 4.34 20100403 3:00 76 0.80 0.15 0.66 0.81 3.33 4.14 20100403 4:00 74 0.80 0.05 0.76 0.81 3.33 4.14 

Ave 80.7 0.81 0.40 0.58 0.99 3.88 4.87 

Max 89 0.93 2.92 1.20 4.12 4.34 7.74 

Min 74 0.47 0.05 0.25 0.30 3.06 3.94 
31 

Table 1: Pertinent Nitrogen Data Used in the Counties’ Analysis. 

Date Time

Ozone 

(μg/m3) NOZ/NOY

NO 

(μg/m3)

NO2

(μg/m3) 

NOX

(μg/m3)

NOZ

(μg/m3)

NOY

(μg/m3

20100413 15:00 74 0.84 0.42 0.23 0.65 3.34 3.99 20100413 16:00 76 0.85 0.32 0.26 0.58 3.41 3.99 20100413 17:00 79 0.91 0.05 0.34 0.39 3.80 4.19 20100413 18:00 81 0.67 1.52 0.36 1.88 3.81 5.69 20100413 19:00 81 0.08 17.42 0.79 18.21 1.48 19.69 20100413 20:00 81 0.10 8.52 0.33 8.85 0.94 9.79 20100413 21:00 81 0.43 4.02 0.44 4.46 3.33 7.79 20100413 22:00 82 0.68 1.22 0.3 1.52 3.17 4.69 20100413 23:00 79 0.66 1.32 0.29 1.61 3.08 4.69 20100414 0:00 79 0.70 1.01 0.4 1.41 3.27 4.68 20100414 1:00 78 0.74 0.71 0.74 1.45 4.13 5.58 20100414 2:00 76 0.80 0.21 0.91 1.12 4.36 5.48 20100414 3:00 73 0.78 0.05 1.27 1.32 4.76 6.08 

Ave 78.5 0.63 2.83 0.51 3.34 3.30 6.64 

Max 82 0.91 17.42 1.27 18.21 4.76 19.69 

Min 73 0.08 0.05 0.23 0.39 0.94 3.99 
32 

Table 1: Pertinent Nitrogen Data Used in the Counties’ Analysis. 

Date Time

Ozone 

(μg/m3) NOZ/NOY

NO 

(μg/m3)

NO2

(μg/m3) 

NOX

(μg/m3)

NOZ

(μg/m3)

NOY

(μg/m3

20100414 11:00 74 0.83 0.21 0.6 0.81 4.07 4.88 20100414 12:00 79 0.86 0.11 0.67 0.78 4.60 5.38 20100414 13:00 83 0.88 0.11 0.51 0.62 4.76 5.38 20100414 14:00 84 0.88 0.21 0.51 0.72 5.16 5.88 20100414 15:00 86 0.88 0.11 0.59 0.70 5.38 6.08 20100414 16:00 84 0.85 0.31 0.57 0.88 4.80 5.68 20100414 17:00 85 0.80 0.61 0.65 1.26 5.02 6.28 20100414 18:00 85 0.73 1.11 0.86 1.97 5.31 7.28 20100414 19:00 82 0.50 2.71 1.08 3.79 3.79 7.58 20100414 20:00 78 0.72 0.51 0.79 1.30 3.38 4.68 20100414 21:00 71 0.82 0.11 0.53 0.64 2.84 3.48 

Ave 81.0 0.80 0.56 0.67 1.22 4.46 5.69 

Max 86 0.88 2.71 1.08 3.79 5.38 7.58 

Min 71 0.50 0.11 0.51 0.62 2.84 3.48 
33 

Table 1: Pertinent Nitrogen Data Used in the Counties’ Analysis. 

Date Time

Ozone 

(μg/m3) NOZ/NOY

NO 

(μg/m3)

NO2

(μg/m3) 

NOX

(μg/m3)

NOZ

(μg/m3)

NOY

(μg/m3

20100415 14:00 75 0.84 0.14 0.58 0.72 3.92 4.64 20100415 15:00 78 0.85 0.14 0.57 0.71 4.13 4.84 20100415 16:00 79 0.81 0.44 0.59 1.03 4.31 5.34 20100415 17:00 80 0.83 0.05 0.77 0.82 3.92 4.74 20100415 18:00 80 0.80 0.05 0.81 0.86 3.48 4.34 20100415 19:00 75 0.67 0.44 1.31 1.75 3.49 5.24 20100415 20:00 75 0.32 3.24 0.89 4.13 1.91 6.04 20100415 21:00 74 0.55 1.64 0.97 2.61 3.13 5.74 20100415 22:00 76 0.42 2.34 0.76 3.10 2.24 5.34 20100415 23:00 73 0.52 1.84 0.55 2.39 2.55 4.94 

Ave 76.5 0.66 1.03 0.78 1.81 3.31 5.12 

Max 80 0.85 3.24 1.31 4.13 4.31 6.04 

Min 73 0.32 0.05 0.55 0.71 1.91 4.34 
34 

Table 1: Pertinent Nitrogen Data Used in the Counties’ Analysis. 

Date Time

Ozone 

(μg/m3) NOZ/NOY

NO 

(μg/m3)

NO2

(μg/m3) 

NOX

(μg/m3)

NOZ

(μg/m3)

NOY

(μg/m3

20100505 18:00 74 0.62 0.58 0.6 1.18 1.92 3.10 20100505 19:00 77 0.61 1.08 0.4 1.48 2.32 3.80 20100505 20:00 76 0.63 0.88 0.45 1.33 2.27 3.60 20100505 21:00 76 0.60 1.08 0.49 1.57 2.33 3.90 20100505 22:00 80 0.63 1.08 0.5 1.58 2.72 4.30 20100505 23:00 86 0.59 1.48 0.57 2.05 2.95 5.00 20100506 0:00 84 0.72 1.01 0.4 1.41 3.69 5.10 20100506 1:00 73 0.65 1.01 0.43 1.44 2.66 4.10 

Ave 78.3 0.63 1.03 0.48 1.51 2.61 4.11 

Max 86 0.72 1.48 0.60 2.05 3.69 5.10 

Min 73 0.59 0.58 0.40 1.18 1.92 3.10 
35 

Table 1: Pertinent Nitrogen Data Used in the Counties’ Analysis. 

Date Time

Ozone 

(μg/m3) NOZ/NOY

NO 

(μg/m3)

NO2

(μg/m3) 

NOX

(μg/m3)

NOZ

(μg/m3)

NOY

(μg/m3

20100506 11:00 68 0.84 0.41 0.07 0.48 2.52 3 20100506 12:00 80 0.87 0.31 0.16 0.47 3.23 3.7 20100506 13:00 81 0.88 0.31 0.1 0.41 2.99 3.4 20100506 14:00 82 0.90 0.21 0.14 0.35 3.25 3.6 20100506 15:00 79 0.89 0.21 0.13 0.34 2.86 3.2 20100506 16:00 78 0.85 0.31 0.2 0.51 2.89 3.4 20100506 17:00 77 0.83 0.41 0.18 0.59 2.81 3.4 20100506 18:00 76 0.61 1.21 0.26 1.47 2.33 3.8 20100506 19:00 80 0.13 5.11 0.34 5.45 0.85 6.3 20100506 20:00 79 0.47 2.71 0.46 3.17 2.83 6 20100506 21:00 80 0.32 3.01 0.48 3.49 1.61 5.1 20100506 22:00 79 0.24 5.31 0.35 5.66 1.74 7.4 20100506 23:00 76 5.11 0.67 5.78 20100507 0:00 77 3.28 0.68 3.96 20100507 1:00 76 0.49 2.08 0.39 2.47 2.36 4.83 20100507 2:00 76 0.40 1.98 0.57 2.55 1.68 4.23 20100507 3:00 75 0.37 2.08 0.58 2.66 1.57 4.23 

Ave 77.6 0.61 2.00 0.34 2.34 2.37 4.37 

Max 82 0.90 5.31 0.68 5.78 3.25 7.40 

Min 68 0.13 0.21 0.07 0.34 0.85 3.00 
36 

Table 1: Pertinent Nitrogen Data Used in the Counties’ Analysis. 

Date Time

Ozone 

(μg/m3) NOZ/NOY

NO 

(μg/m3)

NO2

(μg/m3) 

NOX

(μg/m3)

NOZ

(μg/m3)

NOY

(μg/m3

20101011 17:00 75 0.82 0.05 0.2 0.25 1.13 1.38 20101011 18:00 79 0.80 0.05 0.26 0.31 1.27 1.58 20101011 19:00 77 0.78 0.05 0.26 0.31 1.07 1.38 20101011 20:00 75 0.78 0.05 0.23 0.28 1.00 1.28 20101011 21:00 76 0.82 0.05 0.2 0.25 1.13 1.38 20101011 22:00 78 0.85 0.05 0.18 0.23 1.35 1.58 20101011 23:00 78 0.83 0.05 0.23 0.28 1.40 1.68 20101012 0:00 77 0.84 0.05 0.18 0.23 1.24 1.47 20101012 1:00 78 0.88 0.05 0.14 0.19 1.38 1.57 20101012 2:00 75 0.83 0.05 0.17 0.22 1.05 1.27 

Ave 76.8 0.82 0.05 0.21 0.26 1.20 1.46 

Max 79 0.88 0.05 0.26 0.31 1.40 1.68 

Min 75 0.78 0.05 0.14 0.19 1.00 1.27 
37 

Table 1: Pertinent Nitrogen Data Used in the Counties’ Analysis. 

Date Time

Ozone 

(μg/m3) NOZ/NOY

NO 

(μg/m3)

NO2

(μg/m3) 

NOX

(μg/m3)

NOZ

(μg/m3)

NOY

(μg/m3

20110803 12:00 73 0.89 0.06 0.05 0.11 0.93 1.04 20110803 13:00 80 0.84 0.05 0.16 0.21 1.13 1.34 20110803 14:00 78 0.90 0.05 0.11 0.16 1.48 1.64 20110803 15:00 77 0.88 0.05 0.16 0.21 1.53 1.74 20110803 16:00 76 0.90 0.06 0.1 0.16 1.38 1.54 20110803 17:00 82 0.82 0.05 0.21 0.26 1.18 1.44 20110803 18:00 78 0.84 0.05 0.13 0.18 0.96 1.14 20110803 19:00 77 0.81 0.05 0.09 0.14 0.60 0.74 20110803 20:00 78 0.72 0.05 0.1 0.15 0.39 0.54 20110803 21:00 72 0.71 0.05 0.05 0.10 0.24 0.34 

Ave 77.1 0.83 0.05 0.12 0.17 0.98 1.15 

Max 82 0.90 0.06 0.21 0.26 1.53 1.74 

Min 72 0.71 0.05 0.05 0.1 0.24 0.34 
38 

Table 2: Pertinent Meteorological, Carbon, and Particulate Data Used in the Counties’ An

Date Time 

Ozone 

(μg/m3)

Wind 

Direction 

(degrees) 

Sigma 

Theta 

(degrees)

Wind 

Speed 

(m/s) 

Solar 

Radiation

(Wh/m2) 

CO 

(μg/m3)

PM2.5

(μg/m3)

20090625 13:00 70 338 17 3.1 891 190.9 31.4 20090625 14:00 79 335 19 2.7 871 196.9 15.5 20090625 15:00 88 330 16 2.3 752 207.4 18.5 20090625 16:00 92 337 19 1.8 586 172.9 24.0 20090625 17:00 93 7 21 0.9 417 166.2 23.4 20090625 18:00 89 360 16 0.8 213 142.8 14.4 20090625 19:00 81 37 20 1.7 46 133.9 17.9 20090625 20:00 81 52 28 1 0 141.5 13.6 20090625 21:00 76 48 22 1.9 0 138.7 12.6 20090625 22:00 76 79 30 0.7 0 144.0 13.1 20090625 23:00 76 151 8 1.2 0 150.8 18.6 20090626 0:00 75 151 10 0.8 0 143.4 21.2 

Ave. 81.3 19 1.6 160.8 18.7 

Max. 93 30 3.1 207.4 31.4 

Min. 70 8 0.7 133.9 12.6 
39 

Table 2: Pertinent Meteorological, Carbon, and Particulate Data Used in the Counties’ An

Date Time 

Ozone 

(μg/m3)

Wind 

Direction 

(degrees) 

Sigma 

Theta 

(degrees)

Wind 

Speed 

(m/s) 

Solar 

Radiation

(Wh/m2) 

CO 

(μg/m3)

PM2.5

(μg/m3)

20100402 13:00 28 90 0.8 109 295.4 NA 20100402 14:00 334 25 2.2 532 266.5 NA 20100402 15:00 79 311 22 3 584 262.2 NA 20100402 16:00 81 311 24 2.6 372 268.8 NA 20100402 17:00 79 309 17 2.2 193 268.4 NA 20100402 18:00 80 299 17 2.3 31 274.7 NA 20100402 19:00 89 248 31 0.8 0 288.4 NA 20100402 20:00 87 148 11 3 0 284.4 NA 20100402 21:00 81 160 10 4.6 0 269.0 NA 20100402 22:00 81 161 13 4.5 0 274.7 NA 20100402 23:00 84 160 11 5.1 0 318.3 NA 20100403 0:00 83 160 18 3.7 0 326.7 NA 20100403 1:00 79 172 34 3 0 279.4 NA 20100403 2:00 77 168 21 4.5 0 256.3 NA 20100403 3:00 76 166 16 5 0 258.6 NA 20100403 4:00 74 162 13 6.5 0 259.7 NA 

Ave 80.7 23 3.4 278.2 NA 

Max 89 34 6.5 326.7 NA 

Min 74 10 0.8 256.3 NA 
40 

Table 2: Pertinent Meteorological, Carbon, and Particulate Data Used in the Counties’ An

Date Time 

Ozone 

(μg/m3)

Wind 

Direction 

(degrees) 

Sigma 

Theta 

(degrees)

Wind 

Speed 

(m/s) 

Solar 

Radiation

(Wh/m2) 

CO 

(μg/m3)

PM2.5

(μg/m3)

20100413 15:00 74 324 41 1.9 671 189.0 16.4 20100413 16:00 76 308 31 2 478 196.7 18.3 20100413 17:00 79 329 24 2.2 264 209.2 17.7 20100413 18:00 81 315 32 1.2 75 220.6 14.5 20100413 19:00 81 240 30 0.2 1 234.1 15.4 20100413 20:00 81 289 5 1 0 237.7 16.4 20100413 21:00 81 280 18 0.9 0 229.0 18.1 20100413 22:00 82 298 8 1.5 0 220.3 16.3 20100413 23:00 79 248 30 1 0 216.3 15.5 20100414 0:00 79 323 24 0.8 0 216.9 18.5 20100414 1:00 78 11 15 2.6 0 227.7 18.4 20100414 2:00 76 359 10 2.1 0 230.8 19.6 20100414 3:00 73 346 6 2.4 0 240.1 18.9 

Ave 78.5 21 1.5 220.6 17.2 

Max 82 41 2.6 240.1 19.6 

Min 73 5 0.2 189.0 14.5 
41 

Table 2: Pertinent Meteorological, Carbon, and Particulate Data Used in the Counties’ An

Date Time 

Ozone 

(μg/m3)

Wind 

Direction 

(degrees) 

Sigma 

Theta 

(degrees)

Wind 

Speed 

(m/s) 

Solar 

Radiation

(Wh/m2) 

CO 

(μg/m3)

PM2.5

(μg/m3)

20100414 11:00 74 331 22 3.4 859 234.1 23.8 20100414 12:00 79 330 19 3.8 903 242.9 21.5 20100414 13:00 83 333 22 3.8 881 233.0 21.4 20100414 14:00 84 342 26 3.9 799 235.5 22.9 20100414 15:00 86 341 26 3.9 658 228.7 18.2 20100414 16:00 84 350 30 3.2 475 224.2 19.6 20100414 17:00 85 354 29 2.5 264 230.3 19.8 20100414 18:00 85 22 22 2 80 236.2 17.9 20100414 19:00 82 110 29 1.4 1 229.8 17.8 20100414 20:00 78 144 11 2.9 0 234.9 17.4 20100414 21:00 71 146 6 3.2 0 235.2 18.8 

Ave 81.0 22 3.1 233.2 19.9 

Max 86 30 3.9 242.9 23.8 

Min 71 6 1.4 224.2 17.4 
42 

Table 2: Pertinent Meteorological, Carbon, and Particulate Data Used in the Counties’ An

Date Time 

Ozone 

(μg/m3)

Wind 

Direction 

(degrees) 

Sigma 

Theta 

(degrees)

Wind 

Speed 

(m/s) 

Solar 

Radiation

(Wh/m2) 

CO 

(μg/m3)

PM2.5

(μg/m3)

20100415 14:00 75 315 20 3.3 812 247.9 19.6 20100415 15:00 78 333 22 3.1 677 242.2 20.1 20100415 16:00 79 337 26 2.6 492 222.6 19.4 20100415 17:00 80 320 18 2.8 283 217.6 18.0 20100415 18:00 80 314 11 3.1 84 210.9 14.3 20100415 19:00 75 343 18 2.7 1 208.5 13.8 20100415 20:00 75 76 23 0.4 0 199.0 15.2 20100415 21:00 74 171 16 1.4 0 200.5 18.8 20100415 22:00 76 191 42 1.1 0 213.1 16.1 20100415 23:00 73 228 62 0.8 0 209.2 16.1 

Ave 76.5 26 2.1 217.2 17.1 

Max 80 62 3.3 247.9 20.1 

Min 73 11 0.4 199.0 13.8 
43 

Table 2: Pertinent Meteorological, Carbon, and Particulate Data Used in the Counties’ An

Date Time 

Ozone 

(μg/m3)

Wind 

Direction 

(degrees) 

Sigma 

Theta 

(degrees)

Wind 

Speed 

(m/s) 

Solar 

Radiation

(Wh/m2) 

CO 

(μg/m3)

PM2.5

(μg/m3)

20100505 18:00 74 281 42 1.1 134 191.2 10.6 20100505 19:00 77 251 32 1.5 8 195.2 11.3 20100505 20:00 76 256 35 1.5 0 195.9 10.8 20100505 21:00 76 205 59 0.6 0 195.6 11.4 20100505 22:00 80 170 56 0.9 0 190.3 13.2 20100505 23:00 86 181 63 0.7 0 207.4 14.0 20100506 0:00 84 207 65 0.7 0 212.5 14.3 20100506 1:00 73 235 56 1 0 204.6 14.8 

Ave 78.3 51 1.0 199.1 12.6 

Max 86 65 1.5 212.5 14.8 

Min 73 32 0.6 190.3 10.6 
44 

Table 2: Pertinent Meteorological, Carbon, and Particulate Data Used in the Counties’ An

Date Time 

Ozone 

(μg/m3)

Wind 

Direction 

(degrees) 

Sigma 

Theta 

(degrees)

Wind 

Speed 

(m/s) 

Solar 

Radiation

(Wh/m2) 

CO 

(μg/m3)

PM2.5

(μg/m3)

20100506 11:00 68 300 26 1.7 909 208.9 17.1 20100506 12:00 80 309 25 2 945 209.5 17.1 20100506 13:00 81 308 29 2 927 208.1 18.7 20100506 14:00 82 310 28 2.3 845 207.7 14.8 20100506 15:00 79 314 24 2.4 708 207.7 16.7 20100506 16:00 78 315 26 1.6 525 202.4 17.2 20100506 17:00 77 307 25 1.3 321 206.1 17.9 20100506 18:00 76 302 49 0.7 123 210.1 14.3 20100506 19:00 80 240 29 0.7 8 227.7 16.7 20100506 20:00 79 193 13 0.9 0 212.6 16.4 20100506 21:00 80 179 9 1 0 210.0 15.6 20100506 22:00 79 160 53 0.2 0 221.5 16.1 20100506 23:00 76 138 14 1.1 0 217.2 16.4 20100507 0:00 77 156 14 1.4 0 215.7 16.0 20100507 1:00 76 163 33 1.1 0 215.1 16.0 20100507 2:00 76 165 34 1.1 0 216.0 16.7 20100507 3:00 75 151 17 1.7 0 219.2 17.4 

Ave 77.6 26 1.4 212.7 16.5 

Max 82 53 2.4 227.7 18.7 

Min 68 9 0.2 202.4 14.3 
45 

Table 2: Pertinent Meteorological, Carbon, and Particulate Data Used in the Counties’ An

Date Time 

Ozone 

(μg/m3)

Wind 

Direction 

(degrees) 

Sigma 

Theta 

(degrees)

Wind 

Speed 

(m/s) 

Solar 

Radiation

(Wh/m2) 

CO 

(μg/m3)

PM2.5

(μg/m3)

20101011 17:00 75 255 39 0.9 34 157.7 18.8 20101011 18:00 79 176 33 1 0 162.7 18.0 20101011 19:00 77 157 21 1.6 0 161.9 17.4 20101011 20:00 75 172 52 0.8 0 165.7 17.3 20101011 21:00 76 168 45 1 0 168.7 19.3 20101011 22:00 78 166 42 1 0 163.4 23.0 20101011 23:00 78 166 36 1.2 0 164.4 18.5 20101012 0:00 77 163 30 1.6 0 162.1 17.7 20101012 1:00 78 169 42 1.3 0 165.9 18.0 20101012 2:00 75 181 61 0.8 0 165.1 18.2 

Ave 76.8 40 1.1 163.8 18.6 

Max 79 61 1.6 168.7 23.0 

Min 75 21 0.8 157.7 17.3 
46 

Table 2: Pertinent Meteorological, Carbon, and Particulate Data Used in the Counties’ An

Date Time 

Ozone 

(μg/m3)

Wind 

Direction 

(degrees) 

Sigma 

Theta 

(degrees)

Wind 

Speed 

(m/s) 

Solar 

Radiation

(Wh/m2) 

CO 

(μg/m3)

PM2.5

(μg/m3)

20110803 12:00 73 314 31 2.4 815 331.5 20.0 20110803 13:00 80 321 41 1.3 927 365.8 20.1 20110803 14:00 78 231 74 0.3 871 444.1 20.2 20110803 15:00 77 187 58 0.7 635 527.8 17.9 20110803 16:00 76 246 67 0.6 479 567.3 20.9 20110803 17:00 82 259 64 0.7 325 551.8 17.8 20110803 18:00 78 253 45 1.1 128 513.1 17.9 20110803 19:00 77 260 49 1 12 465.8 15.5 20110803 20:00 78 243 63 0.8 0 408.2 16.8 20110803 21:00 72 193 70 0.7 0 367.8 

Ave 77.1 56 1.0 454.3 18.6 

Max 82 74 2.4 567.3 20.9 

Min 72 31 0.3 331.5 15.5 
47 

Table 3: Analysis of Wind Direction Data for Look Rock 

Based on CASTNET Measurements for 2009-2011. 

Average Hourly Ozone Above 75 ppb 

Wind Direction 

Number of Hours 

Wind From 

(hrs) 

Percent of Time 

Wind From 

(%) 

Average Solar 

Radiation 

(Whrs/m2) 

N 135 47.4 385 

E 37 13.0 18 

S 71 24.9 21 

W 42 14.7 251 

Average Hourly Ozone 75 ppb or Below 

Wind Direction 

Number of Hours 

Wind From 

(hrs) 

Percent of Time 

Wind From 

(%) 

Average Solar 

Radiation 

(Whrs/m2) 

N 7181 30.6 221 

E 1015 4.3 54 

S 7842 33.3 97 

W 747 31.8 196 
48 

Table 4: Detailed Look Rock Back Trajectory Analysis. 

Episode 

Date(s) 

Times 

1-Hr Ozone 

75 ppb 

(24-hr 

Clock) 

General 

Direction of 

Back 

Trajectory 

Did Back Trajectory Cross Any 

Portion of Knox County? 

Back 

Trajectory 

Reference 

(Appendix 2) 

6/25/2009 1400-2300 Northeast Yes, sparsely populated eastern 

portion Figure 1 

4/2-3/2010 1500-0400 South No Figure 2 

4/13-14/10 1600-0300 South to 

southwest No Figure 3 

4/14/2010 1200-2000 South to 

southwest No Figure 4 

4/15/2010 1500-2200 South to 

southwest No Figure 5 

5/5-6/10 1900-0000 South to 

southwest No Figure 6 

5/6-7/10 1200-0200 South to 

southwest No Figure 7 

7/7/2010 1500-1900 North Yes, densely populated central 

portion Figure 8 

7/8/2010 1100-1900 North to 

northeast 

Yes, densely populated central 

portion Figure 9 

9/2/2010 1200-1900 North Yes, densely populated central 

and west portions Figure 10 

9/21-22/10 2000-0100 South to 

southeast No Figure 11 

10/11-12-10 1800-0100 South to 

southwest No Figure 12 

6/2-3/11 1500-0600 North to 

northeast 

Yes, densely populated central 

and west portions Figure 13 

6/3-4/11 1200-0600 East to northeast Yes, only 500 m over sparsely 

populated eastern portion Figure 14 

6/4/2011 1300-2100 North to 

northeast 

Yes, densely populated central 

and west portions Figure 15 

6/6/2011 1600-2200 North to 

northeast 

Yes, sparsely populated eastern 

portion Figure 16 

6/30/2011 1500-2300 Northeast Yes, sparsely populated eastern 

portion Figure 17 

7/2/2011 0000-0600 East No Figure 18 

7/2/2011 1200-2200 North to 

northeast 

Yes, densely populated central 

portion Figure 19 

7/13/2011 1300-1700 North Yes, densely populated central 

portion Figure 20 

8/3/2011 1300-2000 Southwest No Figure 21 

8/12/2011 1400-2300 North to 

northeast 

Yes, densely populated central 

portion Figure 22 

9/2/2011 1400-2100 South to 

southwest 

Yes, sparsely populated southwest 

portion Figure 23 
49 

Table 5: NOX and VOC Emission Levels and Emission Reduction Percentages 

Used in CSAPR Modeling by Source Type for Tennessee. 

Source Type 2005 Emissions (TPY) 

NOX VOC 

2005 EGU 102,934 798 

2005 Non-EGU Point 54,255 79,846 

2005 Nonpoint 18,676 143,122 

2005 Non-road 82,331 58,612 

2005 On-road 267,818 100,951 

Fires 1,012 10,803 

2005 Total 527,026 394,132 

Source Type 2012 Emissions (TPY)/Reductions (%)

2012 EGU 37,694/63.4 863/-8.11

2012 Non-EGU Point 51,355/5.3 66,682/16.5 

2012 Nonpoint 18,483/1.0 136,736/4.5 

2012 Non-road 65,209/20.8 42,527/27.4 

2012 On-road 164,294/38.7 62,182/38.4 

2012 Fires 1,012/0.0 10,803/0.0 

2012 Total 338,047/35.9 319,793/18.9 

Source Type 2014 Emissions (TPY)/Reductions (%)

2014 EGU 29,276/71.6 773/3.1 

2014 Non-EGU Point 49,126/9.5 66,476/16.7 

2014 Nonpoint 18,184/2.6 133,244/6.9 

2014 Non-road 60,111/27.0 37,647/35.8 

2014 On-road 144,394/46.1 56,570/44.0 

2014 Fires 1,012/0.0 10,803/0.0 

2014 Total 302,103/42.7 305,513/22.5 
50 

Table 6: Projected 2008-2015 NOX Emission Reductions by County and Source 

Type for the Knoxville CSA Based on CSPAR Modeling and the 2008 NEI. 

State/County/Emission 

Source Type 

2008 NOX

Emissions1

(TPY) 

2008-2015 

Percent 

NOX

Emission 

Reduction2

(%) 

Projected 

2015 NOX

Emissions3

(TPY) 

Projected 

2008-2015 

NOX 

Emission 

Reduction4

(TPY) 

Anderson

EGU 8725.87 55.7 3,869.35 4,856.52 

Non-EGU Point 1134.78 7.4 1,051.33 83.45 

Nonpoint 60.55 2.0 59.30 1.24 

Nonroad 831.99 21.0 657.34 174.64 

Onroad 2,353.52 35.8 1,509.92 843.59 

Fires 57.54 0.0 57.54 0.00 

Total 13,164.25 7,204.48 5,959.44 

Blount

EGU 7.87 55.7 3.49 4.38 

Non-EGU Point 881.60 7.4 816.77 64.83 

Nonpoint 75.42 2.0 73.88 1.55 

Nonroad 888.62 21.0 702.90 186.53 

Onroad 2,340.07 35.9 1,501.30 838.78 

Fires 36.67 0.0 36.67 0.00 

Total 4,230.25 3,135.01 1,096.07 

Campbell

EGU 0.00 55.7 0.00 0.00 

Non-EGU Point 164.55 7.4 152.45 12.10 

Nonpoint 32.64 2.0 31.97 0.67 

Nonroad 593.12 21.0 468.62 124.50 

Onroad 3,182.45 35.9 2,041.73 1,140.72 

Fires 53.82 0.0 53.82 0.00 

Total 4,026.58 2,748.59 1,277.99 

Cocke

EGU 0.00 55.7 0.00 0.00 

Non-EGU Point 145.04 7.4 134.37 10.67 

Nonpoint 18.31 2.0 17.93 0.38 

Nonroad 263.01 21.0 207.80 55.21 

Onroad 1,898.44 35.8 1,217.97 680.48 

Fires 75.64 0.0 75.64 0.00 

Total 2,400.44 1,653.71 746.74 
51 

Table 6: Projected 2008-2015 NOX Emission Reductions by County and Source 

Type for the Knoxville CSA Based on CSPAR Modeling and the 2008 NEI. 

State/County/Emission 

Source Type 

2008 NOX

Emissions1

(TPY) 

2008-2015 

Percent 

NOX

Emission 

Reduction2

(%) 

Projected 

2015 NOX

Emissions3

(TPY) 

Projected 

2008-2015 

NOX 

Emission 

Reduction4

(TPY) 

Grainger

EGU 0.00 55.7 0.00 0.00 

Non-EGU Point 82.47 7.4 76.40 6.06 

Nonpoint 6.64 2.0 6.50 0.14 

Nonroad 155.33 21.0 122.73 32.61 

Onroad 645.61 35.9 414.20 231.41 

Fires 39.49 0.0 39.49 0.00 

Total 929.54 659.32 270.22 

Hamblen

EGU 0.00 55.7 0.00 0.00 

Non-EGU Point 4,470.59 7.4 4,141.83 328.75 

Nonpoint 24.68 2.0 24.17 0.51 

Nonroad 673.54 21.0 532.16 141.38 

Onroad 2,128.19 35.9 1,365.36 762.83 

Fires 2.54 0.0 2.54 0.00 

Total 7,299.54 6,066.06 1,233.47 

Jefferson

EGU 0.00 55.7 0.00 0.00 

Non-EGU Point 252.20 7.4 233.65 18.55 

Nonpoint 21.75 2.0 21.30 0.45 

Nonroad 539.67 21.0 426.38 113.28 

Onroad 3,255.31 35.9 2,088.48 1,166.83 

Fires 24.65 0.0 24.65 0.00 

Total 4,093.58 2,794.46 1,299.11 

Knox

EGU 0.00 55.7 0.00 0.00 

Non-EGU Point 1,745.91 7.4 1,617.52 128.39 

Nonpoint 254.48 2.0 249.36 5.22 

Nonroad 3,271.83 21.0 2,585.04 686.79 

Onroad 13,976.54 35.9 8,966.79 5,009.75 

Fires 27.36 0.0 27.36 0.00 

Total 19,276.12 13,446.07 5,830.15 
52 

Table 6: Projected 2008-2015 NOX Emission Reductions by County and Source 

Type for the Knoxville CSA Based on CSPAR Modeling and the 2008 NEI. 

State/County/Emission 

Source Type 

2008 NOX

Emissions1

(TPY) 

2008-2015 

Percent 

NOX

Emission 

Reduction2

(%) 

Projected 

2015 NOX

Emissions3

(TPY) 

Projected 

2008-2015 

NOX 

Emission 

Reduction4

(TPY) 

Loudon 

EGU 3.64 55.7 1.61 2.03

Non-EGU Point 1,070.50 7.4 991.78 78.72

Nonpoint 40.41 2.0 39.58 0.83

Nonroad 503.65 21.0 397.93 105.72

Onroad 2,979.14 35.8 1,911.30 1,067.84

Fires 6.94 0.0 6.94 0.00

Total 4,604.28 3,349.14 1,255.14 

Roane 

EGU 7,927.21 55.7 3,515.20 4,412.01

Non-EGU Point 176.60 7.4 163.61 12.99

Nonpoint 40.41 2.0 39.58 0.83

Nonroad 693.65 21.0 548.05 145.61

Onroad 2,866.05 35.8 1,838.74 1,027.31

Fires 16.42 0.0 16.42 0.00

Total 11,720.34 6,121.6 5,598.75 

Sevier 

EGU 0.00 55.7 0.00 0.0

Non-EGU Point 212.16 7.4 195.56 15.60

Nonpoint 31.38 2.0 30.74 0.64

Nonroad 357.87 21.0 282.75 75.12

Onroad 2,653.30 35.8 1,702.25 951.05

Fires 38.76 0.0 38.76 0.00

Total 3,293.47 2,250.06 1,042.41 

Union 

EGU 0.00 55.7 0.00 0.00

Non-EGU Point 57.89 7.4 53.63 4.26

Nonpoint 5.74 2.0 5.62 0.12

Nonroad 150.92 21.0 119.24 31.68

Onroad 283.08 35.8 181.62 101.47

Fires 22.02 0.0 22.02 0.00

Total 519.65 382.13 137.53 

1. 2008 emissions are from the 2008 NEI, v2 found at 

http://www.epa.gov/ttn/chief/net/2008inventory.html. 

2. Based on the emission reductions for 2005-2014 from the CSAPR modeling. 2005-2014 

percent reductions were divided by nine and multiplied by seven. 

3. Based on 2008 emissions minus the percent reduction from column 3 times the 2008 emissions. 

4. The difference between 2008 emissions and the projected 2015 emissions. 
53 

Table 7: Projected 2008-2015 VOC Emission Reductions by County and Source 

Type for the Knoxville CSA Based on CSPAR Modeling and the 2008 NEI. 

State/County/Emission 

Source Type 

2008 VOC 

Emissions1

(TPY) 

2008-2015 

Percent 

VOC 

Emission 

Reduction2

(%) 

Projected 

2015 VOC 

Emissions3

(TPY) 

Projected 

2008-2015 

VOC 

Emission 

Reduction4

(TPY) 

Anderson

EGU 47.18 2.5 46.02 1.16 

Non-EGU Point 607.66 13.0 528.52 79.14 

Nonpoint 884.27 5.4 836.80 47.47 

Nonroad 745.04 27.8 537.76 207.28 

Onroad 886.75 34.2 583.53 303.21 

Fires 903.15 0.0 903.15 0.00 

Total 4,074.05 3,435.78 638.26 

Blount

EGU 0.57 2.5 0.55 0.02 

Non-EGU Point 2,422.09 13.0 2,106.65 315.45 

Nonpoint 1,306.76 5.4 1,236.61 70.15 

Nonroad 1,106.39 27.8 798.58 307.81 

Onroad 1,255.48 34.2 826.19 429.30 

Fires 369.56 0.0 369.56 0.00 

Total 6,460.85 5,338.14 1,122.73 

Campbell

EGU 0.00 -- 0.00 0.00 

Non-EGU Point 175.92 13.0 153.00 22.91 

Nonpoint 394.91 5.4 373.71 21.20 

Nonroad 459.64 27.8 331.76 127.88 

Onroad 649.82 34.2 427.62 222.20 

Fires 915.97 0.0 915.97 0.00 

Total 2,596.26 2,202.06 394.19 

Cocke

EGU 0.00 -- 0.00 0.00 

Non-EGU Point 235.72 13.0 205.02 30.70 

Nonpoint 475.34 5.4 449.83 25.52 

Nonroad 891.16 27.8 643.23 247.93 

Onroad 594.11 34.2 390.96 203.15 

Fires 1,078.79 0.0 1,078.79 0.00 

Total 3,275.12 2,767.83 507.30 
54 

Table 7: Projected 2008-2015 VOC Emission Reductions by County and Source 

Type for the Knoxville CSA Based on CSPAR Modeling and the 2008 NEI. 

State/County/Emission 

Source Type 

2008 VOC 

Emissions1

(TPY) 

2008-2015 

Percent 

VOC 

Emission 

Reduction2

(%) 

Projected 

2015 VOC 

Emissions3

(TPY) 

Projected 

2008-2015 

VOC 

Emission 

Reduction4

(TPY) 

Grainger

EGU 0.00 -- 0.00 0.00 

Non-EGU Point 55.03 13.0 47.86 7.17 

Nonpoint 231.28 5.4 218.87 12.42 

Nonroad 580.22 27.8 418.80 161.42 

Onroad 303.22 34.2 199.54 103.68 

Fires 830.06 0.0 830.06 0.00 

Total 1,999.81 1,715.13 284.69 

Hamblen

EGU 0.00 -- 0.00 0.00 

Non-EGU Point 1,187.29 13.0 1,032.66 154.63 

Nonpoint 1,679.47 5.4 1,589.31 90.15 

Nonroad 642.49 27.8 463.74 178.75 

Onroad 974.10 34.2 641.02 333.08 

Fires 24.14 0.0 24.14 0.00 

Total 4,507.49 3,750.87 756.61 

Jefferson

EGU 0.00 -- 0.00 0.00 

Non-EGU Point 336.16 13.0 292.38 43.78 

Nonpoint 799.60 5.4 756.68 42.92 

Nonroad 1,131.49 27.8 816.70 314.79 

Onroad 823.62 34.2 541.99 281.63 

Fires 332.90 0.0 332.90 0.00 

Total 3,423.77 2,740.65 638.12 

Knox

EGU 0.00 -- 0.00 0.00 

Non-EGU Point 751.13 13.0 653.30 97.83 

Nonpoint 4,273.79 5.4 4,044.37 229.42 

Nonroad 2,507.66 27.8 1,810.00 697.66 

Onroad 5,922.24 34.2 3,897.20 2,025.04 

Fires 470.01 0.0 470.01 0.00 

Total 13,924.83 10,874.88 3,049.95 
55 

Table 7: Projected 2008-2015 VOC Emission Reductions by County and Source 

Type for the Knoxville CSA Based on CSPAR Modeling and the 2008 NEI. 

State/County/Emission 

Source Type 

2008 VOC 

Emissions1

(TPY) 

2008-2015 

Percent 

VOC 

Emission 

Reduction2

(%) 

Projected 

2015 VOC 

Emissions3

(TPY) 

Projected 

2008-2015 

VOC 

Emission 

Reduction4

(TPY) 

Loudon 

EGU 2.90 2.5 2.83 0.07

Non-EGU Point 1,020.28 13.0 887.40 132.88

Nonpoint 528.01 5.4 499.66 28.34

Nonroad 758.42 27.8 547.42 211.00

Onroad 783.95 34.2 515.89 268.06

Fires 96.96 0.0 96.96 0.00

Total 3,190.52 2,550.16 640.35

Roane 

EGU 152.07 2.5 148.34 3.74

Non-EGU Point 226.76 13.0 197.23 29.53

Nonpoint 532.44 5.4 503.86 28.58

Nonroad 907.01 27.8 654.67 252.34

Onroad 1,013.70 34.2 667.07 346.62

Fires 189.31 0.0 189.31 0.00

Total 3,021.29 2,360.48 660.81

Sevier 

EGU 0.00 -- 0.00 0.00

Non-EGU Point 192.24 13.0 167.21 25.04

Nonpoint 954.67 5.4 903.42 51.25

Nonroad 2,388.01 27.8 1,723.64 664.37

Onroad 1,267.42 34.2 834.04 433.38

Fires 556.71 0.0 556.71 0.00

Total 5,359.05 4,185.02 1,174.04

Union 

EGU 0.00 -- 0.00 0.00

Non-EGU Point 64.18 13.0 55.82 8.36

Nonpoint 214.44 5.4 202.93 11.51

Nonroad 480.14 27.8 346.56 133.58

Onroad 133.86 34.2 88.09 45.77

Fires 398.96 0.0 398.96 0.00

Total 1,291.58 1,092.36 199.22

1. 2008 emissions are from the 2008 NEI, v2 found at 

http://www.epa.gov/ttn/chief/net/2008inventory.html . 

2. Based on the emission reductions for 2005-2014 from the CSAPR modeling. 2005-2014 

percent reductions were divided by 9 and multiplied by 7. 

3. Based on 2008 emissions minus the percent reduction from column 3 times the 2008 emissions. 

4. The difference between 2008 emissions and the projected 2015 emissions. 
56 

Table 8: 2008-2011 NOX Emissions and Emission Rates for 

TVA’s Bull Run Power Plant.1

Year 

Annual Emissions

(TPY) 

Annual Emission Rate 

(lbs/mmBTU) 

2005 11,487.6 0.358 

2006 8,352.0 0.370 

2007 11,929.8 0.362 

2008 8,622.3 0.387 

2009 1,270.7 0.086 

2010 1,221.0 0.068 

2011 911.9 0.069 

1. Source: EPA Air Markets Program Data. 

 
57 

Table 9: 2008-2011 NOX Emissions and Emission Rates for TVA’s 

Kingston Power Plant.1

Year 

Annual Emissions

(TPY) 

Annual Emission Rate 

(lbs/mmBTU) 

2005 14,318.4 0.284 

2006 13,953.2 0.260 

2007 12,541.5 0.235 

2008 7,927.8 0.148 

2009 549.3 0.053 

2010 1,602.8 0.091 

2011 1,532.5 0.058 

1. Source: EPA Air Markets Program Data. 

 
58 

Table 10: Summary of the CSAPR Modeling and EPA’s Extrapolations 

for the 2008 Ozone NAAQS for the Knoxville CSA. 

County Monitor Location 

2003-

2007 DV

(ppb) 

CSAPR 

Projected 

2014 DV 

(ppb) 

2008-

2010 DV 

(ppb) 

2015 

Extrapolated 

DV 

(ppb) 

Anderson Freels Bend 77.3 63.4 70 63.0 

Blount Cades Cove 68.5 57.5 69 62.9 

Blount Look Rock 85.3 71.3 77 70.0 

Jefferson Lost Creek 82.3 68.3 74 67.1 

Knox Mildred Drive 85.0 71.5 76 69.3 

Knox Rutledge Pike 78.7 66.1 71 64.7 

Loudon Roberts Road 85.0 68.9 73 65.3 

Sevier Clingmans Dome 80.7 67.6 76 69.2 

Sevier Cove Mountain 79.0 65.6 76 68.9 

1. From Spreadsheet projecting the hypothetical 8-hour ozone nonattainment areas for the 

75 ppb NAAQS to 2015 to estimate the number of marginal nonattainment areas that are 

expected to attain the NAAQS by their attainment date of 2015, (EPA-HQ-OAR-2010-

0885-0064). 
9125915.11 

Appendix 2 

EnSafe’s Back Trajectories. 
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Look

Rock

X:\Waller\All72Trajectory_DataDrivenPages.mxd

Basemap Source: ESRI, i-cubed, USDA FSA, USGS, AEX, GeoEye, Getmapping, Aerogrid, IGP

0 12.5 25 50 Miles

FIGURE 1

NOAA HYSPLIT Backward Trajectory

1-800-588-7962

WWW.ENSAFE.COM

DATE: 10/10/2012

DRAWN BY:

J. Shipp/B. Bolton

PROJECT NO: 0888812099

N. Rinehart

REQUESTED BY:

0 30 60 15 Kilometers 500.0 m AGL Trajectory

100.0 m AGL Trajectory

Highways

Great Smoky Mountains

National Park Boundary

Statistical Boundary

10.0 m AGL Trajectory

Ending at 2100 UTC 25 June 2009

(1700 EDT 25 June 2009)
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Mountains

National Park

Clarksville

Nashville-Davidson Winston-Salem Greensboro

High Point Durham

Knoxville Raleigh

Asheville

Charlotte

Memphis

Chattanooga Fayetteville

Huntsville

Columbia

Atlanta

Birmingham

Tuscaloosa

North

Charleston

Macon

Charleston Columbus

Montgomery Jackson

Savannah

Albany

Mobile

Tallahassee

Jacksonville

New

Orleans

Kenner

Metairie

Gainesville

GSMNP

Look Rock

X:\Waller\All72Trajectory_DataDrivenPages.mxd

Basemap Source: ESRI, i-cubed, USDA FSA, USGS, AEX, GeoEye, Getmapping, Aerogrid, IGP

0 37.5 75 150 Miles

FIGURE 2

NOAA HYSPLIT Backward Trajectory

1-800-588-7962

WWW.ENSAFE.COM

DATE: 10/10/2012

DRAWN BY:

J. Shipp/B. Bolton

PROJECT NO: 0888812099

N. Rinehart

REQUESTED BY:

0 80 160 40 Kilometers 500.0 m AGL Trajectory

100.0 m AGL Trajectory

Highways

Great Smoky Mountains

National Park Boundary

Statistical Boundary

10.0 m AGL Trajectory

Ending at 2300 UTC 2 April 2010

(1900 EDT 2 April 2010)
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Knoxville High Point

Asheville

Charlotte Chattanooga

Huntsville

Columbia Sandy

Springs

Atlanta

Birmingham

Tuscaloosa

North

Charleston Macon

Charleston

Columbus

Montgomery

Savannah

Albany

GSMNP

Look

Rock

X:\Waller\All72Trajectory_DataDrivenPages.mxd

Basemap Source: ESRI, i-cubed, USDA FSA, USGS, AEX, GeoEye, Getmapping, Aerogrid, IGP

0 25 50 100 Miles

FIGURE 3

NOAA HYSPLIT Backward Trajectory

1-800-588-7962

WWW.ENSAFE.COM

DATE: 10/10/2012

DRAWN BY:

J. Shipp/B. Bolton

PROJECT NO: 0888812099

N. Rinehart

REQUESTED BY:

0 60 120 30 Kilometers 500.0 m AGL Trajectory

100.0 m AGL Trajectory

Highways

Great Smoky Mountains

National Park Boundary

Statistical Boundary

10.0 m AGL Trajectory

Ending at 2300 UTC 13 April 2010

(1900 EDT 13 April 2010)
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Knoxville

Asheville

Chattanooga

Huntsville

Sandy

Springs

Atlanta

Birmingham

Tuscaloosa

GSMNP

Look

Rock

X:\Waller\All72Trajectory_DataDrivenPages.mxd

Basemap Source: ESRI, i-cubed, USDA FSA, USGS, AEX, GeoEye, Getmapping, Aerogrid, IGP

0 20 40 80 Miles

FIGURE 4

NOAA HYSPLIT Backward Trajectory

1-800-588-7962

WWW.ENSAFE.COM

DATE: 10/10/2012

DRAWN BY:

J. Shipp/B. Bolton

PROJECT NO: 0888812099

N. Rinehart

REQUESTED BY:

0 40 80 20 Kilometers 500.0 m AGL Trajectory

100.0 m AGL Trajectory

Highways

Great Smoky Mountains

National Park Boundary

Statistical Boundary

10.0 m AGL Trajectory

Ending at 1900 UTC 14 April 2010

(1500 EDT 14 April 2010)
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Mountains

National Park

Clarksville

Nashville-Davidson

Knoxville

Asheville

Chattanooga

Huntsville

Sandy

Springs

Atlanta

GSMNP

Look

Rock

X:\Waller\All72Trajectory_DataDrivenPages.mxd

Basemap Source: ESRI, i-cubed, USDA FSA, USGS, AEX, GeoEye, Getmapping, Aerogrid, IGP

0 15 30 60 Miles

FIGURE 5

NOAA HYSPLIT Backward Trajectory

1-800-588-7962

WWW.ENSAFE.COM

DATE: 10/10/2012

DRAWN BY:

J. Shipp/B. Bolton

PROJECT NO: 0888812099

N. Rinehart

REQUESTED BY:

0 40 80 20 Kilometers 500.0 m AGL Trajectory

100.0 m AGL Trajectory

Highways

Great Smoky Mountains

National Park Boundary

Statistical Boundary

10.0 m AGL Trajectory

Ending at 2200 UTC 14 April 2010

(1800 EDT 14 April 2010)
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Mountains

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Clarksville

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Knoxville

Asheville

Chattanooga Charlotte

Huntsville

Columbia

Sandy

Springs

Atlanta

Birmingham

Tuscaloosa

Macon

GSMNP Look Rock

X:\Waller\All72Trajectory_DataDrivenPages.mxd

Basemap Source: ESRI, i-cubed, USDA FSA, USGS, AEX, GeoEye, Getmapping, Aerogrid, IGP

0 25 50 100 Miles

FIGURE 6

NOAA HYSPLIT Backward Trajectory

1-800-588-7962

WWW.ENSAFE.COM

DATE: 10/10/2012

DRAWN BY:

J. Shipp/B. Bolton

PROJECT NO: 0888812099

N. Rinehart

REQUESTED BY:

0 50 100 25 Kilometers 500.0 m AGL Trajectory

100.0 m AGL Trajectory

Highways

Great Smoky Mountains

National Park Boundary

Statistical Boundary

10.0 m AGL Trajectory

Ending at 0200 UTC 6 May 2010

(2200 EDT 5 May 2010)
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Carolina

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Mountains

National Park

Clarksville

Nashville-Davidson

Knoxville

Asheville

Memphis

Chattanooga

Huntsville

Sandy

Springs

Atlanta

Birmingham

Tuscaloosa

Macon

Columbus

Montgomery Jackson

GSMNP

Look

Rock

X:\Waller\All72Trajectory_DataDrivenPages.mxd

Basemap Source: ESRI, i-cubed, USDA FSA, USGS, AEX, GeoEye, Getmapping, Aerogrid, IGP

0 25 50 100 Miles

FIGURE 7

NOAA HYSPLIT Backward Trajectory

1-800-588-7962

WWW.ENSAFE.COM

DATE: 10/10/2012

DRAWN BY:

J. Shipp/B. Bolton

PROJECT NO: 0888812099

N. Rinehart

REQUESTED BY:

0 60 120 30 Kilometers 500.0 m AGL Trajectory

100.0 m AGL Trajectory

Highways

Great Smoky Mountains

National Park Boundary

Statistical Boundary

10.0 m AGL Trajectory

Ending at 1800 UTC 6 May 2010

(1400 EDT 6 May 2010)
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Alabama Georgia

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Carolina

Great Smoky

Mountains

National Park

Knoxville

Asheville

Chattanooga

GSMNP

Look

Rock

X:\Waller\All72Trajectory_DataDrivenPages.mxd

Basemap Source: ESRI, i-cubed, USDA FSA, USGS, AEX, GeoEye, Getmapping, Aerogrid, IGP

0 12.5 25 50 Miles

FIGURE 8

NOAA HYSPLIT Backward Trajectory

1-800-588-7962

WWW.ENSAFE.COM

DATE: 10/10/2012

DRAWN BY:

J. Shipp/B. Bolton

PROJECT NO: 0888812099

N. Rinehart

REQUESTED BY:

0 30 60 15 Kilometers 500.0 m AGL Trajectory

100.0 m AGL Trajectory

Highways

Great Smoky Mountains

National Park Boundary

Statistical Boundary

10.0 m AGL Trajectory

Ending at 2200 UTC 7 July 2010

(1800 EDT 7 July 2010)
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Carolina

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Mountains

National Park

Louisville

Lexington-Fayette

Knoxville

Asheville

Charlotte

GSMNP

Look

Rock

X:\Waller\All72Trajectory_DataDrivenPages.mxd

Basemap Source: ESRI, i-cubed, USDA FSA, USGS, AEX, GeoEye, Getmapping, Aerogrid, IGP

0 15 30 60 Miles

FIGURE 9

NOAA HYSPLIT Backward Trajectory

1-800-588-7962

WWW.ENSAFE.COM

DATE: 10/10/2012

DRAWN BY:

J. Shipp/B. Bolton

PROJECT NO: 0888812099

N. Rinehart

REQUESTED BY:

0 40 80 20 Kilometers 500.0 m AGL Trajectory

100.0 m AGL Trajectory

Highways

Great Smoky Mountains

National Park Boundary

Statistical Boundary

10.0 m AGL Trajectory

Ending at 2000 UTC 8 July 2010

(1600 EDT 8 July 2010)
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Alabama Georgia

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Carolina

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Mountains

National Park

Knoxville

Asheville

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GSMNP

Look

Rock

X:\Waller\All72Trajectory_DataDrivenPages.mxd

Basemap Source: ESRI, i-cubed, USDA FSA, USGS, AEX, GeoEye, Getmapping, Aerogrid, IGP

0 12.5 25 50 Miles

FIGURE 10

NOAA HYSPLIT Backward Trajectory

1-800-588-7962

WWW.ENSAFE.COM

DATE: 10/10/2012

DRAWN BY:

J. Shipp/B. Bolton

PROJECT NO: 0888812099

N. Rinehart

REQUESTED BY:

0 30 60 15 Kilometers 500.0 m AGL Trajectory

100.0 m AGL Trajectory

Highways

Great Smoky Mountains

National Park Boundary

Statistical Boundary

10.0 m AGL Trajectory

Ending at 2000 UTC 2 September 2010

(1600 EDT 2 September 2010)
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National Park

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Winston-Salem Greensboro

High

Point

Knoxville

Asheville

Chattanooga Charlotte

Huntsville

Columbia Sandy

Springs

Atlanta

Birmingham

North

Charleston Macon

Charleston

GSMNP Look Rock

X:\Waller\All72Trajectory_DataDrivenPages.mxd

Basemap Source: ESRI, i-cubed, USDA FSA, USGS, AEX, GeoEye, Getmapping, Aerogrid, IGP

0 25 50 100 Miles

FIGURE 11

NOAA HYSPLIT Backward Trajectory

1-800-588-7962

WWW.ENSAFE.COM

DATE: 10/10/2012

DRAWN BY:

J. Shipp/B. Bolton

PROJECT NO: 0888812099

N. Rinehart

REQUESTED BY:

0 50 100 25 Kilometers 500.0 m AGL Trajectory

100.0 m AGL Trajectory

Highways

Great Smoky Mountains

National Park Boundary

Statistical Boundary

10.0 m AGL Trajectory

Ending at 0500 UTC 22 September 2010

(0100 EDT 22 September 2010)
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Mountains

National Park

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Asheville

Chattanooga

Huntsville

Sandy

Springs

GSMNP Look

Rock

X:\Waller\All72Trajectory_DataDrivenPages.mxd

Basemap Source: ESRI, i-cubed, USDA FSA, USGS, AEX, GeoEye, Getmapping, Aerogrid, IGP

0 15 30 60 Miles

FIGURE 12

NOAA HYSPLIT Backward Trajectory

1-800-588-7962

WWW.ENSAFE.COM

DATE: 10/10/2012

DRAWN BY:

J. Shipp/B. Bolton

PROJECT NO: 0888812099

N. Rinehart

REQUESTED BY:

0 40 80 20 Kilometers 500.0 m AGL Trajectory

100.0 m AGL Trajectory

Highways

Great Smoky Mountains

National Park Boundary

Statistical Boundary

10.0 m AGL Trajectory

Ending at 0300 UTC 12 October 2010

(2300 EDT 11 October 2010)
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Kentucky

Virginia

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Great Smoky

Mountains

National Park

Louisville

Lexington-Fayette

Asheville

GSMNP

Look

Rock

X:\Waller\All72Trajectory_DataDrivenPages.mxd

Basemap Source: ESRI, i-cubed, USDA FSA, USGS, AEX, GeoEye, Getmapping, Aerogrid, IGP

0 15 30 60 Miles

FIGURE 13

NOAA HYSPLIT Backward Trajectory

1-800-588-7962

WWW.ENSAFE.COM

DATE: 10/10/2012

DRAWN BY:

J. Shipp/B. Bolton

PROJECT NO: 0888812099

N. Rinehart

REQUESTED BY:

0 40 80 20 Kilometers 500.0 m AGL Trajectory

100.0 m AGL Trajectory

Highways

Great Smoky Mountains

National Park Boundary

Statistical Boundary

10.0 m AGL Trajectory

Ending at 2100 UTC 2 June 2011

(1700 EDT 2 June 2011)
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NOAA HYSPLIT Backward Trajectory

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NOAA HYSPLIT Backward Trajectory

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NOAA HYSPLIT Backward Trajectory

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NOAA HYSPLIT Backward Trajectory

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PROJECT NO: 0888812099

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NOAA HYSPLIT Backward Trajectory

1-800-588-7962

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DATE: 10/10/2012

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PROJECT NO: 0888812099

N. Rinehart

REQUESTED BY:

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Ending at 2000 UTC 2 September 2011

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9125915.11 

Appendix 3 

TVA’s “Cluster Analysis of Look Rock High Ozone Events 

and Related Air Parcel Trajectories for 2009-2011.” 

 
1 

Cluster Analysis of Look Rock High Ozone Events and 

Related Air Parcel Trajectories for 2009-2011

Prepared by Stephen F. Mueller, CCM 

Tennessee Valley Authority 

September 2012 

Cluster analysis is a statistical procedure designed to explore relationships within groups of data. 

As such its primary use is to identify commonalities across different sets of variables with no 

assumed prior knowledge of how such variables might be related (Wilks, 2006). Cluster analysis 

has been applied in studies of atmospheric and climate data. The SAS® statistical software 

package provides tools for performing cluster analysis. An analysis of Look Rock ozone and 

trajectory data during 2009-2011 high ozone events was performed using the SAS ACECLUS 

and CLUSTER procedures1

 (SAS version 9.2). 

The ACECLUS procedure analyzes raw data to convert it into variables better suited for cluster 

analysis. This analysis converts data that are elliptical in n-dimensional space (i.e., exhibit more 

variation in one direction than the other) into spherical data that are then re-configured into n

canonical (transformed) variables representing different combinations of the original data. In 

this way, ACECLUS performs a procedure similar to what is done in computing principal 

components for principal component analysis. The resulting canonical variables are then made 

available for analysis using CLUSTER. 

CLUSTER performs a hierarchical analysis starting with all data points in their own separate 

cluster. In a continuous sequence, the data points are combined (“agglomerated”) into fewer 

clusters by associating data pairs having the most similarities based on the relative separation 

between the cluster-mean values of the canonical variables. The relative degree of reduction in 

total parametric variance across the remaining clusters provides a measure of how the clustering 

process reduces variations from more to fewer data clusters. SAS CLUSTER documentation 

provides guidance, based on several statistical metrics, on how to identify significant numbers of 

clusters. This guidance was used in developing the clustering results described here. 

Data

Simulated air parcel coordinates (latitude and longitude) for trajectories arriving at Look Rock 

during high ozone episodes form the basis of this cluster analysis along with ozone levels 

measured at Look Rock. HYSPLIT model trajectories arriving at 10, 100 and 500 m above Look 

Rock were provided for different hours during 23 high 8-hr ozone periods of 2009-2011. Data 

for 63 sets of trajectories were combined with the maximum hourly and 8-hr average ozone 

(centered on the maximum hourly ozone level) mixing ratios measured on a given day. A subset 

of 9 high ozone events--represented by 40 sets of trajectories--were accompanied by other air 

 

1

 Documentation found at 

http://support.sas.com/documentation/cdl/en/statug/63033/HTML/default/ viewer.htm#aceclus_toc.htm 

(ACECLUS) and 

http://support.sas.com/documentation/cdl/en/statug/63033/HTML/default/viewer.htm#cluster_toc.htm (CLUSTER). 
2 

quality data to provide a more detailed picture of the conditions associated with the high ozone 

events. Thus, 14 events were characterized only by ozone and 23 sets of trajectory data. 

For the 9 “detailed” events, data provided 8-hr averages and hourly maximum mixing ratios of 

CO, NO, NO2, NOy and photochemical age (τ=NOz/NOy), along with 8-hr average solar 

radiation flux and ridge top wind direction and speed. These 8-hr averages coincided with the 8-

hr ozone averages previously mentioned. 

Analysis

Trajectory coordinates and ozone mixing ratio (hourly maxima or 8-hr averages) provide 

excellent variables for cluster analysis because they are linear variables with little covariance 

between data pairs. The canonical variable equivalents input into CLUSTER were selected for 

their expected ability to characterize Look Rock high ozone events. Although any and all 

trajectory coordinates could have been used, it is best to minimize the number of parameters in a 

cluster analysis for ease of interpretation. To this end, CLUSTER was run with trajectory 

coordinates for 10 and 100 m trajectories (lat10, lon10, lat100 and lon100) at 12 hr upwind of Look 

Rock in combination with either the 8-hr average (C8h) or maximum hourly (Cmax) ozone mixing 

ratio for each event. Both 3 and 5 variable clustering were examined (3 parameter clustering 

used one ozone metric and one set of trajectory coordinates; 5 parameter clustering used one 

ozone metric and both sets of trajectory coordinates). Additional parameters add more canonical 

variance to each analysis (and more potential clusters) and there can be a trade-off between the 

useful information derived from the clusters and quantity of results to be interpreted. 

Although both C8h and Cmax were tested, neither was clearly superior in providing more 

definitive clusters. A bit more variance was contained in the fewest significant clusters using 

Cmax in combination with both trajectory points. Also, more clusters were needed to identify a 

major portion of the overall parametric variances when data from both trajectories were used 

rather than only one of the two trajectories. However, given the complexity of boundary layer 

airflow and the potential for emissions from different locations to contribute to ozone formation 

in an environment characterized by complex topography, it was decided that more useful results 

could be obtained by jointly analyzing the 10- and 100-m trajectory coordinate fields. 

After reviewing results based on Cmax, lat10, lon10, lat100 and lon100 (a 5-parameter model) it was 

evident that the 9 event days accompanied by detailed Look Rock data could be grouped into 

only 5 clusters representing 79 percent of the total parametric variance in the data. However, to 

achieve a similar degree of parametric variance (80 percent) required 11 clusters for the larger 23 

event/63 trajectory data set. Clusters are labeled using C1, C2, ...Cn for an n-cluster result. The 

first cluster represents the largest set of agglomerated variance with each subsequent cluster 

representing decreasing amounts of variance. Comparing trajectories common to both sets of 

results (i.e., for the 9 event subset and the 23 events) it is possible to identify how well the 9-

event subset represents the larger 3-year data base. Table 1 summarizes the commonalities and 

differences between the two clustering analyses. 

There is no perfect one-to-one match between the two sets of clusters. The larger number of 

clusters needed to characterize the 23-event data set introduces more clusters than could be 
3 

identified using the smaller event subset. This 

causes some trajectories clustered together in 

the smaller subset analysis to split across 

multiple clusters in the larger set. However, 

some clusters remained intact between the two 

analyses. The most important (largest 

contribution to total variance) cluster for the 

9-event subset, C1, was contained entirely in 

the second cluster of the full data set (denoted 

FC2). The second subset cluster (C2) was 

mostly included in FC3 although small 

portions were also found in FC7 and FC10. All 

of C3 mapped to FC4, all of C4 mapped to FC7

and all of C5 mapped to FC8. C6 and FC11 also 

had a large degree of overlap and both 

included the largest number of individual data 

points with the smallest relative contributions 

to total variance within their data sets. Other 

subset clusters were split across the clusters of 

the full data set in varying amounts. The 

complete data set identified 3 clusters--FC1, 

FC5 and FC6--that had no cross-mapping with 

the subset. These 3 unmapped clusters 

represent 37 percent of the total variance in 

the larger set of data. 

To better understand how well the subset represents the full set it is imperative to examine the 

relative spatial representations of the different clusters regarding air pollutant transport and the 

comparative ozone values between the two sets of clusters. Plots of 12-hr upwind 10- and 100-m 

trajectory locations averaged by cluster are illustrated in Figure 1. Except for FC8, the clusteraverage 10- and 100-m trajectory locations at 12 hr upwind from Look Rock fall within 40 km 

and one direction sector of each other. Therefore, the trajectories at the two levels are mutually 

consistent and do not indicate airflow from vastly different origins. 

Figures 2 and 3 compare average C8h and Cmax for the data that fall into the clusters of the full 

data set. Subset clusters that mapped to the larger cluster set do a good job of representing the 

average cluster C8h (Figure 2) even though this parameter was not included in the clustering 

procedure. For Cmax, the match between the two data sets (Figure 3) was excellent as would be 

expected because Cmax was used to define the clusters. Other parameters that match well 

between the two data sets are the upwind distances (relative to Look Rock) of the 10- and 100-m 

trajectories (Figures 4 and 5). 

Interpretation

With 8 of 11 clusters containing detailed data from the 9-event subset it is possible to determine 

how most subsets differ from the others. Figures 6-8 illustrate cluster averages of 8-hr NOy, CO 

Table 1. Relative mapping between clusters 

derived from the full 3-year 23-event data set 

and the 9-event subset. 

Clustersa

23-Event Set 9-Event Subset Mappingb

FC1 

FC2 C1 (100%) 

FC3 C2 (67%) 

FC4 C3 (100%) 

FC5 

FC6 

FC7 C2 (17%) & C4 (100%) 

FC8 C5 (100%) & C6 (5%) 

FC9 C6 (14%) 

FC10 C2 (17%) & C6 (9%) 

FC11 C6 (73%) a

The cluster designations in each column 

refer to the designations used for the 

individual cluster analyses and are not 

equivalent across columns. 

b

Values in () denote the fraction of 

observations in the subset cluster that 

contributed to the clusters from the larger 

data set.
4 

and photochemical age (τ). Of those clusters containing data, FC8 had the highest NOy levels 

while FC9 had the lowest. The airmasses in FC9 had the highest mean τ while the lowest was 

found for FC8. In general, τ was inversely associated with NOy. FC9 had the highest average CO 

levels and FC2 had the lowest. From these data the clusters can be characterized as summarized 

in Table 2. 

Clusters 1, 2 and 6 

The highest ozone was associated with clusters FC1 and FC2 and the transport directions were 

very similar with 12-hr origins being farther upwind for FC2 (i.e., winds were stronger for FC2). 

Table 2. Summary of event cluster characteristics. 

Cluster 

% of 

Trajectories O3

a NOy/Age CO Transportb

1 10 Highest N/A N/A From NNE within 40-45 km (i.e., 10 

km ENE of downtown Knoxville) 

2 14 High Moderate/ 

high 

Low From NNE/NE within 75-80 km 

3 6 Moderately 

high 

Moderate/ 

high 

Moderate From S/SSW within 150-200 km 

(passing east of Atlanta) 

4 3 Moderately 

high 

Moderate/ 

high 

Moderate From S within 185-200 km 

5 3 Moderate N/A N/A From NE within 100-150 km 

6 11 Moderately 

low 

N/A N/A From NNE/NE within 70-80 km 

7 5 Moderately 

low 

Moderately 

high/ high 

Moderate From SE within 145-160 km 

8 8 Moderate High/low Moderate From ESE through SSW sectors 

within 15-35 km 

9 5 Moderately 

low 

Low/high High From WSW within 135-140 km 

(Chattanooga) 

10 5 Moderately 

low 

Moderate/ 

moderate 

Moderate From SW within 80-100 km 

11 30 Moderately 

low 

Moderate/ 

moderate 

Moderate From WSW within 75-80 km 

a

Ratings are relative across the population of all event clusters. All 8-hr average ozone levels 

exceed 75 ppb except for cluster 6 (74 ppb). 

b

Distances refer to transport during the 12 hours preceding arrival at Look Rock and include 

information from both the 10- and 100-m trajectories. 
5 

Detailed air quality data other than ozone were not available for FC1, but given the similarities in 

transport directions and ozone levels (with lower ozone levels associated with higher transport 

speeds as expected) it is likely that the air quality signatures of these two clusters are similar. 

FC2 had moderate NOy levels, high τ and low CO. Thus, the airmasses associated with FC2 do 

not have a strong urban signature despite passing only 10 km or so east of downtown Knoxville. 

Instead, they appear more strongly associated with transport from more distant sources despite 

the fact that 12-hr transport distances were not that high. FC6 transport overlapped completely 

with that of FC1 and FC2 with speeds intermediate between FC1 and FC2. FC6 ozone levels were 

lower than either FC1 or FC2 and, like FC1, FC6 did not have detailed air quality data. Thus, all 

that can be deduced is that conditions (either meteorology or ozone precursors) were not as 

amenable to ozone formation in cluster 6. 

Cluster 5

Cluster 5 is set apart from the other clusters by the strength of its transport and the direction (NE) 

of its origins. With air originating in northeast Tennessee during the 12 hours preceding arrival 

at Look Rock, it is most likely that FC5 ozone levels were influenced by sources near Kingsport, 

TN. No detailed air quality data were available. 

Clusters 3 and 4

Clusters 3 and 4 are unique in that they have the highest transport speeds during the 12 hours 

preceding arrival at Look Rock and originate from well south of Look Rock over north central 

Georgia. Ozone levels are relatively high, NOy and CO levels are moderate, and τ is high. These 

clusters could be associated with emissions east of Atlanta and are definitely not due to 

emissions anywhere near Look Rock. 

Clusters 7 and 8

Clusters FC7 and FC8 share several features--both originate southeast of Look Rock, both have 

moderately high ozone and CO levels and both have relatively high NOy levels. The primary 

differences are in transport speeds/distances and τ. FC7 is associated with very aged air (high τ) 

and high transport speeds; 12-hr airmass origins are over extreme northeast Georgia and extreme 

western South Carolina. However, FC8 is associated with the lowest transport speeds of any 

cluster and the largest directional divergence between 10- and 100-m trajectories. Airmass 

origins are within 30 km of Look Rock, essentially over the Great Smoky Mountains National 

Park (GSMNP) and nearby national forests and wilderness areas. There are no significant source 

regions in this area. Despite this, τ was lower for FC8 than any other cluster and this implies a 

nearby source of NO. Given the transport directions and low winds it is likely that Look Rock 

air quality in cluster 8 was influenced by emissions from the small Happy Valley community 

east of the Look Rock/Foothills Parkway (Chilhowee Mountain) and west of GSMNP and, 

perhaps to some extent, by the Look Rock campground east of the air monitoring station. 

Emissions from fireplaces, wood stoves and campfires could contribute the relatively fresh NO 

emissions and moderate CO levels that were measured. 
6 

Clusters 9 and 11

Clusters FC9 and FC11 share a common transport direction (WSW) and moderately low high 

ozone levels. However, they differ considerably in their transport speeds and other air quality 

characteristics. FC9 has low NOy but high τ and CO. Given the 12-hr transport distances and 

directions it is likely that FC9 events were influenced by Chattanooga emissions. The relatively 

high CO levels may reflect the fact that FC9 trajectories follow the Chattanooga-Knoxville 

transportation and industrial corridor for much of the 12-hr period prior to arrival at Look Rock. 

FC11 events follow similar paths but transport speeds are lower and both CO and τ are lower than 

for FC9. The lower FC11 speeds put the Chattanooga source region further upwind in time than 

for FC9. The lower τ for these events implies that more nearby sources are important than for 

FC9 events and the lower CO suggests that they are not mobile sources. FC11 comprises the 

largest single cluster with 30 percent of all computed trajectories. 

Cluster 10

Trajectories for cluster 10 originate in northwest Georgia 12 hours upwind of Look Rock. This 

region does not have large urban areas but it does include a variety of industrial facilities and 

electric generating stations. Air quality data suggest that these moderately low high ozone 

events are associated with moderate levels of emissions. 

Summary

A cluster analysis of high ozone events at Look Rock provides insight into the sources and 

conditions associated with various categories or clusters of events. The data suggest that, out of 

11 distinct clusters, only 4 (FC1, FC2, FC5 and FC6) are likely to have any contributions from the 

Knoxville urban area. Of these 4, one (FC5) has such strong transport from the northeast that 

airmasses spend very little time over Knoxville-area emissions sources. Of the remaining 3 

clusters, FC1 has the highest ozone levels and the greatest potential for Knoxville-area 

contributions because of the relatively long time spent by sampled air parcels traveling across the 

urban source region. Clusters 1, 2 and 6 with the highest potential impacts from the Knoxville 

area comprise 35 percent of the computed air parcel trajectories associated with Look Rock high 

ozone events. In other words, 65 percent of the Look Rock high ozone events are not associated 

with or significantly impacted by Knoxville-area emissions. 

Reference

Wilks, D.S. Statistical Methods in the Atmospheric Sciences, Academic Press, New York, 2006, 

549-559. 

 
7 

 

Figure 1. Cluster-averaged 10- and 100-m trajectory locations at 12 hours upwind of Look 

Rock during high ozone events. Locations are labeled by cluster number. Pink ovals denote 

ozone precursor source regions at 12 hours prior to arrival at Look Rock. 
8 

 

Figure 2. Comparison of cluster averaged 8-hr ozone mixing ratios for periods centered on 

the maximum observed one hour ozone value on Look Rock high ozone event days. Note that 

this is not the same as the daily maximum 8-hr average ozone value. 

70

75

80

85

1 2 3 4 5 6 7 8 9 10 11

ppb

Cluster

All Events 9 Event Subset
9 

 

Figure 3. Comparison of cluster averaged maximum hourly ozone mixing ratios observed at 

Look Rock on high ozone event days. 

75

80

85

90

95

1 2 3 4 5 6 7 8 9 10 11

ppb

Cluster

All Events 9 Event Subset
10 

 

Figure 4. Cluster average computed trajectory distances upwind of Look Rock at 12 hr 

preceding arrival at Look Rock during high ozone events for trajectories arriving at a height 

10-m above the destination. 

0

50

100

150

200

1 2 3 4 5 6 7 8 9 10 11

km

Cluster

All Events 9 Event Subset
11 

 

Figure 5. Cluster average computed trajectory distances upwind of Look Rock at 12 hr 

preceding arrival at Look Rock during high ozone events for trajectories arriving at a height 

100-m above the destination. 

0

50

100

150

200

250

1 2 3 4 5 6 7 8 9 10 11

km

Cluster

All Events 9 Event Subset
12 

 

Figure 6. Cluster average NOy mixing ratios for 8-hr periods centered on the daily maximum 

hourly ozone mixing ratio measured during high ozone events at Look Rock. 

0

2

4

6

8

1 2 3 4 5 6 7 8 9 10 11

ppb

Cluster
13 

 

Figure 7. Cluster average CO mixing ratios for 8-hr periods centered on the daily maximum 

hourly ozone mixing ratio measured during high ozone events at Look Rock. 

0

100

200

300

400

500

1 2 3 4 5 6 7 8 9 10 11

ppb

Cluster
14 

Figure 8. Cluster average photochemical age (τ) for 8-hr periods centered on the daily 

maximum hourly ozone mixing ratio measured during high ozone events at Look Rock. 

0.6

0.7

0.8

0.9

1 2 3 4 5 6 7 8 9 10 11

NOz/NOy

Cluster
9125915.11 

Appendix 4 

TVA’s “2008 Environmental Policy.” 
tennessee valley authority

2008 Environmental Policy
Message from the CEO 1

Chapter 1 – Environmental Policy 2

Background 2

Environmental Policy 2

Guiding Principles 3

Policy Development 3

Stakeholder Involvement 3

Chapter 2 – Environmental Objectives 

and Critical Success Factors 4

Chapter 3 – Environmental Areas 6

Climate Change Mitigation 6

Air quality Improvement 8

Water Resource Protection and Improvement 9

Waste Minimization 10

Sustainable Land Use 10

Natural Resource Management 11

Chapter 4 – Commitments 12

Commitments to Our Customers 12

Performance Indicators 12

Online Resources 12

CHAIRMAN WILLIAM SANSOM of Knoxville, Tennessee, is chairman 

and chief executive officer of The H.T. Hackney Co., and has held that 

position since 1983. Hackney is a diversified company involved in 

wholesale grocery, gas and oil, and furniture manufacturing.

DENNIS BOTTORFF of Nashville, Tennessee, serves as chairman 

and partner of Council Ventures, a venture capital firm. He was 

chairman of AmSouth Bancorporation until his retirement in 2001 

and previously was chief executive officer of First American Bank.

DON DEPRIEST of Columbus, Mississippi, is chairman of a venture 

capital firm headquartered in Alexandria, Virginia, that has founded or 

invested in such companies as American Telecasting, now merged 

with Sprint. His Charisma Communications Corp. was a pioneer in 

the cellular phone business. He previously chaired the Columbus, 

Mississippi, Utilities Commission. 

MIKE DUNCAN of Inez, Kentucky, is chairman, chief executive 

officer, and director of Community Holding Co.; chairman, CEO, 

and director of Inez Deposit Bank; and chairman of the Republican 

National Committee. He is a director of the Regional Center for 

Rural Development. 

THOMAS GILLILAND of Blairsville, Georgia, recently retired as 

executive vice president, general counsel, and secretary of United 

Community Banks Inc. He is a former chief of staff to Georgia Lt. 

Gov. Pierre Howard, and he served as chairman of the Stone Mountain 

Authority under Georgia governors Roy Barnes and Sonny Perdue.

SKILA HARRIS of Washington, D.C., is a native of Bowling Green, 

Kentucky, and served as a full-time TVA director from November 

1999 through March 2006. She previously held positions in the U.S. 

Department of Energy, the White House, and energy-management 

and engineering-consulting firms. 

HOWARD THRAILKILL of Huntsville, Alabama, recently retired as 

president and chief operating officer of Adtran, Inc., in Huntsville, 

which supplies equipment for telecommunications service providers 

and corporate end-users. Previously, he was president and chief 

executive officer of Floating Point Systems.

The TVA Board

Table of Contents
Message from the CEO

Stewardship of the Tennessee Valley

We are very much aware of the impact that the Tennessee Valley Authority’s operations have on the environment, and we 

are working in partnership with others to further the region’s environmental quality. In fulfilling its historic mission, TVA

has contributed to the region’s economic progress by meeting an ever-increasing demand for electricity while significantly 

reducing its impact on the environment. Yet, we recognize that greater challenges lie ahead to meet higher environmental 

standards and ensure the finite water and land resources under our stewardship are available for future generations.

The annual demand for electricity in the TVA service region is forecast to grow more than the national average. To offset 

the impact of meeting this demand, we are increasing our efforts in energy efficiency to reduce demand growth, investing 

in lower-carbon generating sources for meeting any additional growth, and lowering emissions from our current generating 

plants. This approach will help us improve performance and be proactive in our environmental stewardship responsibilities, 

while meeting the demand for more power at an affordable cost. However, future decisions to take further actions in these 

areas could put an upward pressure on power rates. 

This policy sets out environmental objectives that will help us make decisions about our business and identifies areas that 

will allow TVA to produce cleaner and still-affordable electricity and provide environmental leadership in partnership with 

our stakeholders. We are establishing this policy because I, and all the people at TVA, appreciate the opportunity to provide 

cleaner power to you and your family now and in the generations to come.

Tom Kilgore

President and Chief Executive Officer

TVA Environmental Policy 1
Chapter 1

Environmental Policy

BACKGROUND

As stated in the 2007 TVA Strategic Plan, “TVA will be proactive in addressing environmental concerns, including those 

related to global climate change.” This Environmental Policy provides board-level guiding principles to successfully lead TVA 

to reduce its environmental impact while continuing to provide reliable and competitively priced power to the Valley. There 

is a growing recognition of the environmental and economic need for an increased emphasis on actions that support 

sustainable initiatives to most effectively meet the three dimensions of the TVA mission. In the Strategic Plan, about half 

of the identified strategic objectives and critical success factors relate directly to TVA’s environmental-related activities and 

policy-making. Following the release of the Strategic Plan, the board asked for the development of an integrated environmental 

policy to outline objectives and critical success factors across the multiple areas of TVA’s activities. The policy also addresses 

TVA’s response to the uncertain future of legislation on greenhouse gases (GHGs), including carbon, and the scarcity of 

available mitigating technologies in a carbon-constrained future. 

ENVIRONMENTAL POLICY

TVA’s overarching Environmental Policy objective is to 

provide cleaner, reliable, and still-affordable energy, support 

sustainable economic growth in the Tennessee Valley, and 

engage in proactive environmental stewardship in a balanced 

and ecologically sound manner. 

In this context, the Environmental Policy directly aligns 

with the threefold TVA mission of Energy, Economic Development, and Environment, and as shown in the center 

of Exhibit 1, accents and integrates environmental leadership into all aspects of the TVA mission. 

The Environmental Policy itself is not intended to serve 

as TVA’s response to future environmental regulations, 

nor is it intended to outline a specific regulatory forecast 

for planning purposes. Rather, the policy establishes an 

overarching framework to guide decision-making and 

future strategic development. The board of directors will 

review the Environmental Policy every two years. More 

frequent reviews may be needed to respond to significant 

market and regulatory changes and ensure alignment with 

TVA’s strategic priorities.

Cleaner, reliable, and still-affordable energy 

TVA has an enduring responsibility to deliver reliable and 

affordable power to the residents and businesses in the 

Tennessee Valley. We have made investments to comply 

with environmental regulations in an efficient and 

affordable manner. We recognize the challenge ahead to 

achieve continuous improvements to make our generation 

portfolio cleaner while still meeting our commitment to a 

reliable and affordable energy supply.

Sustainable economic development

Growth is an important component of maintaining the 

economic vitality of the Tennessee Valley, and TVA

is committed to continued leadership in economic 

Exhibit 1 

Overall Environmental Policy Alignment With TVA’s Mission

2 TVA Environmental Policy
development. We recognize unplanned growth can place 

great demands on all of our resources and lead to outcomes 

that can erode the quality of life within the Tennessee 

Valley. We believe the solution lies in achieving sustainable 

community and economic growth while considering 

environmental impacts.

Proactive environmental stewardship

Looking forward, we see the magnitude of the environmental challenges growing larger and requiring increasing 

innovation and leadership to find practical, effective, 

and affordable answers to our stewardship challenges. To 

meet the environmental challenges of the 21st century 

and beyond, we must be proactive in our commitment to 

provide both affordable energy and environmental stewardship. We must work together to reduce the “footprint” 

we all impose upon the environment. 

GUIDING PRINCIPLES

TVA will continue to integrate responsible environmental 

practices into its business operations by establishing 

goals, measuring progress, and reporting performance 

through a comprehensive environmental management 

system. Employees are trained on their environmental 

responsibilities and factor environmental considerations into 

business decisions. TVA remains committed to complying 

with environmental laws and regulations, with a goal of 

continuous improvement.

Climate Change Mitigation

TVA plans to actively reduce its carbon emissions through 

cleaner energy options and energy efficiency initiatives.

Air Quality Improvement

TVA improves regional air quality by installing emission 

control equipment on existing generation and planning 

for cleaner future energy options.

Water Resource Protection and Improvement

TVA manages an integrated river system for multiple uses 

while striving to provide clean and sufficient water for the 

Valley’s needs.

Waste Minimization

TVA surveys all aspects of its operational and business 

functions to implement ways to reduce waste and increase 

recycling.

Sustainable Land Use

TVA manages public lands for multiple benefits, striving 

to keep them in good environmental health while balancing 

the need for sustainable development.

Natural Resource Management

TVA protects natural resources while providing recreational 

opportunities across the Valley.

POLICY DEVELOPMENT

The development of the Environmental Policy followed four 

phases. The first phase identified the key environmental 

focus areas and established an overarching framework 

for the policy. The evaluations performed in the second 

phase analyzed market forces and established a range of 

possible regulatory outcomes, highlighting the potential 

impacts of both on TVA. The third phase defined a series of 

environmental objectives and identified the critical success 

factors necessary to meet those objectives. The fourth 

phase asked for public comments and incorporated those 

comments into the final document, subject to approval of 

the policy by the TVA Board of Directors.

STAKEHOLDER INVOLVEMENT

TVA’s evaluation of stakeholders’ suggestions and feedback 

revealed four emerging themes they believe TVA should 

emphasize: 

Leadership

TVA must take a leadership position in areas of its core 

competency such as nuclear power and hydroelectric power.

Partnerships

TVA should expand partnership opportunities with 

stakeholders, such as local, federal, and state institutions, 

in specific focus areas.

Coordination

TVA should leverage its credibility and position as a federal 

agency to foster coordination among multiple parties to 

achieve common goals.

Commitment

TVA should clearly articulate its environmental commitment, 

preferred strategies for least-cost solutions, and associated 

performance metrics. 

TVA Environmental Policy 3
Climate change mitigation

Environmental Objective

TVA will stop the growth in volume of emissions and reduce the 

rate of carbon emissions by 2020 by supporting a full slate of 

reliable, affordable, lower-carbon-dioxide (CO2) energy-supply 

opportunities and energy efficiency.

Critical Success Factors

•	 Reduce load growth by at least one-fourth over five years, through

energy efficiency and demand-side management initiatives.

•	 Meet the remaining load growth through lower-carbon-emitting

energy sources such as affordable renewables, nuclear, and 

combined heat and power.

•	 Improve the efficiency of the transmission network, including the

use of technologies such as Smart Grid, which helps achieve 

environmental benefits through improved communication and 

remote control, making the system more responsive in real time.

•	 Strive to reduce the rate of carbon and other GHG emissions

from the existing generation fleet.

•	 Use affordable regional resources to comply with renewable

and clean-energy standards and mandates, limiting the use of 

purchased compliance credits.

•	 Invest in a technology portfolio that supports low- or zero-carbon

emitting generation options and electricity grid infrastructure 

to support a lower-carbon economy. 

•	 Promote public education and outreach to encourage energy efficiency, clean end-user energy generation, premium green-energy 

offerings, and regional climate change mitigation opportunities.

Air quality improvement

Environmental Objective

TVA will continue efforts to reduce sulfur-dioxide, nitrogen-oxide, 

mercury, and particulate emissions and engage regional and national 

stakeholders to develop better ways to understand, monitor, and 

improve regional air quality, including all regulated air emissions.

Critical Success Factors

•	 Reduce emissions across the system by continuing to install

emission reduction equipment and new technology to control 

over 80 percent of fossil generation in the next 10 years. 

•	 Allow for earlierretirement of coal-fired plants if energy efficiency,

renewables, and clean-energy gains exceed targets.

•	 Elevate air quality improvement as a critical component in

evaluating future capacity-planning decisions.

•	 Promote open exchange and collaboration with others to improve

the industry’s air quality control technology and modeling.

Chapter 2 

Environmental Objectives and Critical Success Factors

The Environmental Policy is organized into six environmental areas that encompass the variety of issues faced by TVA. 

These areas are climate change mitigation, air quality improvement, water resource protection and improvement, waste 

minimization, sustainable land use, and natural resource management.

4 TVA Environmental Policy
Water resource protection 

and improvement

Environmental Objective

TVA will improve reservoir and stream-water quality, reduce the 

impact of its operations, and leverage alliances with local and 

regional stakeholders to promote water conservation.

Critical Success Factors

•	 Mitigate TVA’s impact on aquatic systems while balancing

thermal cooling needs with consumptive use. 

•	 Demonstrate a sustainable reduction of consumptive use of

water at TVA’s metered facilities.

•	 Integrate the impacts of water quality and quantity into the

long-range planning and decision-making process.

•	 Maintain river system infrastructure for safe operation while

operating in compliance with the operating policy from TVA’s 

Reservoir Operations Study (ROS).

•	 Promote the integration of energy efficiency and water conservation into community planning and building construction.

•	 Collaborate in community outreach and partnerships through

voluntary demonstrations of the efficient use of water resources 

and protection of water quality.

Waste minimization

Environmental Objective

TVA will drive increased sustainability in existing compliance programs and waste management practices by focusing on waste 

avoidance, minimizing waste generation, and increasing recycling to reduce environmental impacts.

Critical Success Factors

•	 Reduce the waste footprint of all TVA facilities by pursuing

operational and business practices to decrease waste generation 

and improve recycling.

•	 Increase the percentage of recycled coal-combustion waste.

•	 Minimize low-level nuclear waste and contribute to efforts by

industry groups and agencies to formulate innovative and sustainable solutions for the management of spent nuclear fuel waste.

•	 Further reduce the risk of polychlorinated biphenyl (PCB)

releases to the environment over time by eliminating use of 

PCBs in large electrical equipment.

Sustainable land use

Environmental Objective

TVA will strive to maintain the lands under its management in 

good environmental health, balancing their multiple uses, and will 

improve its land transaction processes to support sustainable 

development.

Critical Success Factors

•	 Actively manage TVA lands to meet the desired conditions for

their purpose as defined in the Reservoir Land Management 

Plans.

•	 Develop a policy for managing TVA’s mineral rights that

considers the potential environmental impacts.

•	 Improve reservoir shoreline conditions through collaborative

partnership initiatives and balance the multiple uses of 

the reservoirs in accordance with TVA’s Land Policy and 

Shoreline Management Policy.

•	 Manage TVA lands, mineral rights, and shoreline access

to better achieve environmental commitments while 

meeting the needs for recreation, residential access, and 

economic development.

Natural resource management

Environmental Objective

TVA will be a leader in natural resource management through 

the implementation of sustainable practices in dispersed 

recreation while balancing the protection of cultural, heritage, 

and ecological resources.

Critical Success Factors

• 	 Allow for properly managed, eco-friendly dispersed recreation while balancing the protection of biological, cultural, and 

heritage resources.

•	 Promote ecological diversity and wildlife habitats on TVA

lands through partnerships and voluntary initiatives.

•	 Increase the level of environmental quality and management

consistency among TVA-managed and -leased recreation 

facilities.

TVA Environmental Policy 5
Greenhouse gases are produced by many natural and 

industrial processes. In order of abundance, the top four 

gases are water vapor, CO2, methane, and nitrous oxides. 

GHGs are important to maintaining the temperature on 

the earth. Over the past decade, the impact of man-made 

GHG emissions has been the focus of much scientific, 

business, and policy debate in the United States and 

abroad. Man-made CO2 originates primarily from fossilfuel combustion for transportation, electricity generation, 

and industrial processes, accounting for more than 80 

percent of the nation’s total GHG emissions. Forty percent 

of the nation’s CO2 emissions can be directly attributed to 

electricity generation.

TVA is a large emitter in the power sector due to the size of 

its fossil generation portfolio. However, about 30 percent of 

TVA’s current generation comes from non-carbon-emitting 

sources — nuclear, hydropower, and renewables – and 

that figure is forecast to be over 50 percent by 2020. 

TVA’s generating portfolio emissions “intensity” (tons-ofCO2-per-megawatt-hour) is near the national average and 

considerably better than that of most utilities in the Southeast.

Legislation has been introduced in the United States 

Congress requiring reductions of GHG emissions, specifically 

focusing on CO2. If enacted, such legislation could result 

in significant additional costs for TVA. To prepare to respond 

to this issue, TVA has undertaken a study of the opportunities to reduce GHG emissions in the Valley. In order 

to understand the cost-effectiveness of TVA’s available 

actions relative to others within the Valley economy, TVA

has created a comprehensive catalog of specific opportunities to reduce GHGs and estimated the corresponding 

volumes and relative costs associated with each. Those 

opportunities for carbon abatement that are within TVA’s 

control or influence are shown with dark-green bars. 

Preliminary output from this analysis is depicted in 

Exhibit 2 on the next page.

Chapter 3 

Environmental Areas

CLIMATE CHANGE MITIGATION

6 TVA Environmental Policy
Source: TVA – Team analysis

Exhibit 2 

Tennessee Valley’s Carbon Abatement Opportunities and TVA Opportunities (TVA shown as dark-green bars)

-40 

-20 

-120 

-100 

80 

60 

40 

20 

0 10 20 30 40 50 60 70 80 90 100 110 120 130 140 150 160 170 180 190

200 

Abatement cost 

2008 $/ton CO2 equivalent 

-80 

-60 

Buildings – shell retrofit

Hybridization – light duty vehicle

Gas plants dispatch 

Coal rebuild with carbon capture and storage 

Dedicated biomass 

Agricultural N2O

management

Wind 

Additional

hydro units

Nuclear new

builds – future

Buildings – commercial CHP 

Large hydro units

on unpowered dam 

Industrial CHP 

Agricultural – CH4

management

Buildings – water heaters

Biomass cofiring 

Nuclear construction

completion 

Hybridization – medium

and heavy trucks 

Nuclear new

builds – planned 

Waste heat recovery 

Natural gas 

systems – CH4 

management 

Buildings – HVAC equipment efficiency 

Land fill – CH4 management 

Appliances 

Plug-in hybrids – light duty vehicle 

Manufacturing – HFCs management

Industrial N2O management

Soil management

Fuel economy package – medium and heavy trucks 

Land

fill gas

Coal mining – CH4 management 

Nuclear

start-up

Industrial

process

improvement 

Cellulosic biofuels 

Buildings – refrigeration 

Heat rate

improvement 

Hydro modernization 

Buildings – new 

shell improvement 

Nuclear license

extension

Buildings – lighting 

Industrial steam 

system improvement 

Buildings – electronics 

Fuel economy package – 

light duty vehicle 

Buildings – controls systems 

Industrial product recycling and recovery 

Solar

PV

Opportunities TVA could exercise or influence 

Electric motor

systems improvement

Afforestation and

forestry management

Abatement volume

Million tons CO2 equivalent/yr 

The abatement curve visualized in Exhibit 2 illustrates the 

range of actions the Valley can take to reduce carbon 

emissions, including non-CO2 gases. Each bar denotes a 

single type of opportunity to reduce carbon emissions or 

increase carbon absorption. The width of the bar represents the total net annual emissions reduction that would 

result from pursuing the opportunity. The height of the 

bar highlights the cost of pursuing each option relative to 

the costs that would be incurred if the current practices 

were maintained. Sequencing the options from least cost 

to highest cost helps provide a sense of the relative priority of the abatement measures and can be used to identify 

the least-cost approach to achieving any targeted level of 

emissions reduction.

The shape of the curve warrants explanation. The societal costs associated with each measure can be positive 

or negative in the aggregate. The benefits received are 

spread over time to one or more beneficiaries who may 

be different from those making the initial investments. A

“negative cost” implies that pursuing the related option 

will result in a net savings over the life cycle of the opportunity relative to what would be incurred in the businessas-usual case. These savings are frequently the result of 

reduced energy costs associated with improved energy 

efficiency. The positive cost options require an incremental expense to abate emissions above and beyond the 

business-as-usual case.

TVA Environmental Policy 7
TVA is a regional leader in the installation and operation 

of air emission control equipment through an aggressive 

investment of more than $4.8 billion. This investment has 

reduced TVA’s sulfur-dioxide emissions by about 83 percent 

since 1977, and lowered nitrogen-oxide emissions during 

the summer ozone season by 81 percent since 1995. As 

an additional benefit of these controls, mercury emissions 

also have been reduced. TVA’s efforts have contributed 

to continued air quality improvement across the region. 

These improvements are important to the quality of life 

and economic sustainability in the Valley. The fundamentals 

of TVA’s program focus on complying with air pollution 

control requirements, considering air-quality impacts on 

urban and environmentally sensitive areas, and supporting 

stakeholder interests. TVA’s Clean Air Program is based on 

a strategy of self-compliance that involves the installation 

of controls on fossil plants to achieve tangible air quality 

and health benefits for Valley citizens with a limited use 

of the allowance markets.

Despite these successes, work remains. EPA’s Clean Air 

Interstate Rule, more-restrictive National Ambient Air 

Quality Standards, and future mercury and regional haze 

requirements will ensure that regional air quality continues 

to improve. In the ongoing effort to contribute to that 

improvement, TVA will continue to reduce its sulfur-dioxide, 

nitrogen-oxide, mercury, and particulate emissions. We will 

pursue this objective by continuing to invest in assets that 

AIR QUALITY IMPROVEMENT

8 TVA Environmental Policy

Five key insights have emerged from this analysis that are of 

critical relevance to TVA’s Environmental Policy:

•	 A significant amount of energy-efficiency potential exists

within the Valley and requires a corresponding level of 

investment to realize that potential. 

•	 Nuclear power options available to TVAcan provide significant

abatement potential at a modest incremental cost.

•	 Compared to other regions, the Valley has a limited supply

of renewable energy to support carbon and clean-energy 

objectives.

•	 Coal generation remains an important resource to meet

TVA’s mission to deliver low-cost power.

•	 Modern transmission and distribution grid technologies

can help support the transition to a lower-carbon energy 

supply by improved real-time information and controls.

Given the potential for legislation that will require 

TVA to find ways to reduce GHG emissions – particularly 

carbon emissions – we must position TVA to address the 

challenge of operating in a carbon-constrained world. 

Specifically, TVA will continue to reduce the carbon 

intensity of its generating system and take advantage 

of lower-CO2-emitting energy sources consistent with 

maintaining a reliable and affordable energy supply. 

Technology innovations will be needed to address the 

intermittency of many renewable generation sources. 

TVA will target reducing load growth by at least 

one-fourth in five years through energy efficiency and 

demand response while meeting the remaining load 

growth through lower-carbon-emitting options.
TVA operates the Tennessee River System to provide a 

wide range of public benefits: year-round navigation, 

flood-damage reduction, affordable electricity, improved 

water quality, water supply, land use, and recreation. 

In 2004, the TVA Board approved a new operating policy 

based on the results of the agency’s Reservoir Operations 

Study. The policy maintains TVA’s ability to meet its 

fundamental responsibilities for flood control, commercial 

navigation, and power production while protecting water 

quality and accommodating the increased demands created 

by recreational and residential growth. It shifts the focus of 

TVA’s reservoir operations from achieving specific summer 

pool elevations on the reservoirs to managing the flow of 

water throughout the river system in an integrated way to 

support multiple demands. 

TVA pursues its progressive management of water quality 

and water quantity impacts through the permitting of 

activities on and around TVA reservoirs; the collection, 

maintenance, and distribution of water quality information; 

targeted water quality improvement initiatives; and strategies 

to manage increased water demand. 

The increasing demand for water due to residential, 

commercial, and industrial growth requires a focus on 

resource conservation in the Tennessee Valley region. In 

addition, chronic rainfall deficits can result in low water 

flows, which could lead to future constraints on power 

operations. Rapid growth coupled with the challenge of 

availability further amplifies the importance of balancing 

resource management activities for multiple, and often 

competing, uses across the Valley.

Facing these challenges, TVA will lead by example. TVA

will demonstrate an efficient use of water in its operations 

and will collaborate and coordinate with internal and 

external stakeholders to protect and improve water quality 

and sufficiency, while maintaining an in-depth knowledge 

of changing conditions in the river system. TVA’s goal is 

to mitigate its impact on aquatic systems while balancing 

thermal cooling needs with consumptive use. At the same 

time, TVA will continue to improve river system operations 

to balance diverse demands.

WATER RESOURCE protection and IMPROVEMENT

TVA Environmental Policy 9

will measurably reduce emissions from fossil-fired plants 

and thereby improve air quality. This investment will reduce 

emissions across the system through the installation of emission 

reduction equipment and new technology to control over 

80 percent of fossil generation in the next 10 years. It’s possible 

that, if energy efficiency efforts yield higher load reductions 

than forecast, we will have an opportunity to retire higheremitting fossil plants earlier. In addition, TVA will continue 

to engage regional and national stakeholders to develop better 

ways to understand, monitor, and improve regional air quality. 
SUSTAINABLE LAND USE

TVA manages public lands for multiple benefits, including 

economic development, conservation, and recreation. TVA

is the steward of 293,000 acres of public land and 11,000 

miles of shoreline in the Valley along the Tennessee River. 

In addition, TVA maintains 293,000 acres of flowage easement 

rights, 258,000 acres of transmission rights-of-way, 35,000 

acres of facility properties, and 159,000 acres of mineral rights.

When deciding the proper uses of TVA-managed lands 

and shoreline or acquiring properties for its operations, 

TVA, while ensuring compliance with appropriate laws 

and regulations, considers the effects of these activities 

on the environment. 

Section 26a of the TVA Act gives TVA permitting jurisdiction 

over proposed construction in and along the Tennessee 

River and its tributaries. Under this jurisdiction, TVA has 

the responsibility to address obstructions that might affect 

navigation, flood control, and public lands. 

Increasing growth within the region necessitates a balance 

of resource conservation, sustainable economic development, 

and eco-friendly recreation. To demonstrate and promote 

best practices in sustainable land use, TVA intends to lead 

by example. It will maintain the public lands under its 

management in good environmental health to support 

multiple uses in meeting diverse stakeholder expectations. 

It will also improve its acquisition, development, and disposal 

of managed lands to support sustainable development in 

the Valley. 

These efforts will align with TVA’s Land Policy, approved 

by the TVA Board in November 2006, and its Shoreline 

Management Policy, approved by the board in June 1999. 

10 TVA Environmental Policy

TVA manages an array of different wastes, including 

municipal solid waste, wastewater, hazardous waste, 

low- and high-level nuclear waste, other regulated wastes 

(e.g., asbestos and PCBs), scrap metal, office waste, and 

coal-combustion waste, which includes fly ash, bottom 

ash, and gypsum. One of TVA’s strengths is its waste 

management system and the day-to-day implementation of 

this system at the various facilities by trained environmental 

personnel. Employees help integrate waste-management 

expertise at every level of TVA to minimize the impact on 

Valley resources.

TVA has a strong focus on the use of coal-combustion 

waste, which comprises its single largest waste stream. 

Approximately 43 percent of this waste is recycled into 

by-products. Similarly, TVA recycles the majority of its 

electronic waste and scrap metal. While focusing on 

compliance with waste requirements, TVA uses a team 

approach to seek out and implement further wasteminimization opportunities. In addition, the agency is 

collaborating with others to identify sustainable solutions 

for better management of nuclear waste. 

TVA will reduce its waste footprint in regulated materials 

and increase the percentage of recycled coal-combustion 

waste. In this effort, TVA will augment its existing compliance 

programs and waste management practices by focusing on 

waste reduction at the source (in part through improved 

procurement practices), avoiding waste generation, and 

increasing recycling efforts (especially of municipal waste). 

WASTE MINIMIZATION 
NATURAL RESOURCE MANAGEMENT

TVA manages natural resources in the Valley while 

providing for many types of recreational opportunities. 

The agency has set aside more than 181,000 acres of public 

land for natural resource management, which includes the 

enhancement of wildlife habitat and dispersed informal 

recreation. TVA also oversees and manages an additional 

31,000 acres for sensitive resources. The guidelines for 

use of these sensitive land resources include restrictions 

on activities that might endanger significant cultural or 

natural features.

TVA has more archaeological sites per acre under its 

management than any other federal agency—over 10,000 

archaeological sites have been identified on TVA-managed 

lands. Since 1976, TVA has maintained information on rare 

plants and animals, caves, and other environmentally sensitive 

resources in the 80,000-square-mile TVA service area. 

In its approach to natural resource management, TVA will 

demonstrate leadership through the ecologically sound 

management of natural resources and the protection of 

cultural and heritage resources. TVA is committed to 

increasing the proportion of TVA-managed resources that 

meet the desired environmental conditions of sustainable 

recreation, ecological diversity, and cultural resource 

protection. More and more residents and visitors are 

enjoying the diverse, unique natural resources of the 

Valley by engaging in dispersed recreation activities 

such as hiking, bird watching, and fishing. An increase 

in outdoor activity has been shown to result not only in 

a healthier lifestyle but also a greater awareness of the 

importance of natural resource conservation. An increase 

in conservation practices by the public helps ensure the 

unique and beautiful Valley resources will be preserved 

for the continued enjoyment of generations to come. 

To support this objective, TVA will pursue collaboration 

and partnerships to improve the delivery of its natural 

resource management activities, while also increasing the 

effectiveness of dispersed public recreation and reducing 

the impact of human uses on the environment. TVA will 

allow for properly managed, eco-friendly dispersed recreation 

on the lands it manages while balancing that goal with the 

protection of biological, cultural, and heritage resources.

TVA Environmental Policy 11

These policies direct TVA to manage and balance the 

multiple uses of lands under its jurisdiction and use its 

environmental decision-making process to minimize the 

environmental liabilities and impacts and ensure compliance. 

TVA will continue to actively manage its public lands to 

meet the desired conditions for their defined purpose, 

and it will also develop a policy for managing mineral 

rights that considers the potential environmental impacts.
Chapter 4 

Commitments

COMMITMENTS TO OUR CUSTOMERS

In collaboration with our 159 distributors, TVA is committed 

to providing low-cost, reliable power to more than 8.8 

million residents and businesses and 62 directly served 

large industrial and federal facilities in the seven states of 

the Tennessee Valley. TVA’s new Environmental Policy, 

in accordance with the 2007 TVA Strategic Plan, emphasizes three issues that are important from its customers’ 

perspective: maintaining affordable rates, expanding 

collaboration, outreach, and education, and furthering the 

Valley’s quality of life.

Affordable rates

•	 TVA will strive to manage potential future rate increases

for new generation and transmission construction by 

collaborating with distributors and customers to pursue 

lower-cost energy-efficiency and load-management 

options that may partially offset the need for capacity 

additions.

•	 For large commercial and industrial customers, TVA

will continue to focus on rates as a principal measure 

of affordability and competitiveness when promoting 

cost-effective energy-efficiency and load-management 

programs.

•	 For residential and small commercial customers, TVA

will emphasize the total bill impact by focusing on the 

combined effect of rate and consumption.

Collaboration, outreach, and education 

•	 TVA will increase its focus on education and outreach

to inform Valley residents on key issues, including 

energy efficiency and renewables, water conservation, 

and natural resource protection.

•	 TVA will collaborate with distributors and directly

served customers to implement enabling technologies 

for clean-energy and energy-efficiency solutions.

Quality of life

•	 TVA will continue to promote an improved quality

of life with an emphasis on the deployment of clean, 

low-carbon emissions technology in the Valley.

•	 TVA will consider the environmental footprint of

industries recruited into the Valley.

•	 TVA will improve air quality and continue to promote

the sustainable management of land, water, and natural 

resources.

•	 TVA will provide for the expansion of ecologically

friendly recreation activities within the Valley. 

PERFORMANCE INDICATORS

TVA has an established set of metrics to monitor how 

well its performance fulfills the threefold TVA mission 

highlighted in the 2007 Strategic Plan, which outlines the 

policy level direction for TVA. Examples of these metrics 

are shown in Exhibit 3 on the next page. They include 

the metrics that are found in TVA’s Strategic Plan, such as 

delivered cost of power, economic development index, 

and environmental performance, and additional ones 

associated with the Environmental Policy. This combined set 

of performance metrics establishes the successful translation 

of the TVA Environmental Policy into specific and measurable 

indicators that can be monitored for implementation of the 

policy. TVA will implement these metrics in an integrated 

approach to close the gap between the current level and 

desired improvement in environmental performance.

12 TVA Environmental Policy
Affordable, 

Reliable Energy

Standard

Of Living

Quality

Of Life

Cleaner

Energy

Environmental

Stewardship

Sustainable

Growth

Economic

Development

Exhibit 3 

Aligning TVA’s Mission With Environmental Commitments and Performance Measures

The large circles represent the threefold TVA mission, while the intersections of the circles represent a higher quality of life realized 

through an integrated approach of pursuing cleaner energy, promoting sustainable growth, and providing proactive stewardship.

TVA Environmental Policy 13

Standard of Living

•	 Customer Satisfaction

•	 TFO/Asset Value

•	 Quality of Jobs

•	 Recordable Injury Rate

•	 Cultural Health Index

Affordable, Reliable Energy

•	 Connection Point Interruptions

•	 Equivalent Availability Generation Assets

•	 Productivity

Cleaner Energy

•	 Energy Efficiency Targets:

– Participation in DSM Initiatives

– MW Reduction

•	 Renewables Targets

•	 Emission Rates (CO2, SOX, NOX, Hg)

Environmental Stewardship 

•	 Environmental Performance

•	 Stream Miles Improvement

•	 Waste Reduction

•	 Recreational Use

•	 Land Meeting Desired Uses

Economic Development

•	 Economic Development Index

•	 Jobs Created and Retained

•	 Environment Footprint of

 Recruited Industries

Sustainable Growth

•	 Average Retail Price of Power

TVA Strategic Plan Metrics

Additional Environmental Metrics

Online Resources

View this policy electronically at www.tva.com/environment/policy.htm

View the 2007 TVA strategic plan at www.tva.gov/stratplan

View the results of the Reservoir Operations Study at www.tva.gov/environment/reports/ros_eis/index.htm

View TVA’s Land Management Policy at www.tva.gov/river/landandshore/land_policy.htm

View TVA’s Shoreline Management Policy at www.tva.gov/river/landandshore/landuse_shore.htm
Tennessee Valley Authority | 400 W. Summit Hill Drive | Knoxville, Tennessee 37902 

 www.tva.com

This report is printed on 100% post-consumer recycled paper and uses soy-based inks. 08-157 5/08