# Shelby County Redesignation Request

and
Maintenance Plan

(SCRRAMP

- 2015)

for the

2008 Eight

- Hour Ozone National Ambient Air Quality Standard

Prepared by:

Shelby County Health Department

Pollution Control Section

814 Jefferson Avenue

Memphis, Tennessee 38105

## Table of Contents

1. Petition for Redesignation 1



### 2. 2011 Emission Inventory 2



### 3. Attainment De termination 2

A

. ) Air Quality 2

B

. ) Environmental Justice 5

C

. ) Weather Analysis 6



### 4. SIP Approval 6



### 5. Emissions Reductions 8

A

. ) Permanent and Enforceable Improvements in Air Quality 8

i

. ) On

- Road Mobile Sources 8

ii

. ) Non

- Road Mobile Sources 10

iii

. ) Point Sources 11

B

. ) Other Measures 12

i

. ) Consent Decree s 12

ii

. ) Voluntary Efforts 12



### 6. Clean Air Act Section 110 and Part D Requirements 13



### 7. Maintenance Plan 1 4

A

. ) Base Year Inventory and Future Projections 15

B

. ) Motor Vehicle Emission Budge ts 19

C

. ) Air Quality Monitoring Network 2 0

D

. ) Emission Inventory 2 0

E

. ) Stationary Source Control 2 0

F

. ) Voluntary Measures 2 1

G

. ) Contingency P rovisions 2 1

## Attachments

Attachment I

- Technical Support Material (folder)

A. Historical Ozone WX Comparison ( Analysis of Ozone Concentrations... in the Memphis Metropolitan Area)

1. Historical Ozone WX Comparison .pdf

2. Graphs for WX

- O3 Comparison.xls

B. 2012 Shelby County, TN Emission Inventory Calculation Methodol ogy (folder)

1. 2012 Shelby County, TN Emission Inventory Calculation Methodology .pdf

2. AEO Fuel Consumption data for East South Central Sector.xls

3. Tennessee Employment Estimates by Sector Category.xls

4. 2010

- 2050 Shelby County Population Projections_by UTK dataCen ter .xls

5. Biogenic.pdf

C. Emission Inventory and Methodology Tables

1. 2012 2017 2020 and 2027 Onroad Mobile Source Emissions Summary

... of NOx CO VOC Final .xls

2. 2012 2017 2020 and 2027 NOx and VOC EI Summaries and Budgets (Final).xls

3. 2012 2017 2020 and 2027 Shelby County TN Emissions Summary of NOX CO VOC for all Categories FINAL .xls

4. 2012 2017 2020 and 2027 Nonroad Mobile Equipment Emissions Summary .xls

5. 2012 Shelby County TN Air port Emissions Estimates

... of NOx CO VOC Final .xls

6. 2012 Shelby County TN Area Source Emiss ions Estimates... of NOx CO VOC Final .xls

7. 2012 Shelby County TN Commercial Marine Vessel Emissions Estimates

... of NOx CO VOC Fina l .xls

8. 2012 Shelby County TN Locomotive Emissions Estimates

... of NOx CO VOC Final .xls

9. 2012 Shelby County TN Point Source Emissions Estimates

... of NOx CO VOC Final .xls

10. Proposed TVA Nat Gas EGU Plant. xls

11. 2014 8

- hr O3 Ambient Data for Maintenance Submittal.xls

12. Monitoring

– Memphis MSA Ozone Monitors.pdf

13. Monitoring

– Memphis TN

- MS

- AR MOA ltr 2015

- 02

- 16 .pdf

14. Monitoring

– Memphis TN

- MS

- AR MOA .pdf

15. Shelby NONROAD2008_MySQL Input files.zip

16. Shelby NONROAD2008_MySQL Output files.zip

17. 2012 Nonroad Fuel Default.xls

18. 2017 Nonroad Fuel Def.xls

19. 2020 Nonroad Fuel Def.xls



### Attachment II MOVES2014 O3 Input Files (folder)

1. 2012 Shelby County TN Avg SpeedDi stibution .xls

2. 2012 Shelby County TN Fuel Input.xls

3. 2012 Shelby County TN HourVMTFraction .xls

4. 2012 Shelby County TN HPMSVTypeVMT .xls

5. 2012 Shelby County TN IM .xls

6. 2012 Shelby County TN MOVES MYSQL Inputs. zip

7. 2012 Shelby County TN Ramp Fraction .xls

8. 2012 Shelb y County TN RoadTypeDistribution .xls

9. 2017 Shelby County TN AvgSpeedDistibution .xls

10. 2017 Shelby County TN Fuel Inputs w RVP Adjustments .xls

11. 2017 Shelby County TN HourVMTFraction .xls

12. 2017 Shelby County TN HPMSVTypeVMT .xls13. 2017 Shelby County TN MOVES MYSQL In puts. zip

14. 2017 Shelby County TN Ramp Fraction .xls

15. 2017 Shelby County TN RoadTypeDistribution .xls

16. 2020 Shelby County TN AvgSpeedDistibution .xls

17. 2020 Shelby County TN Fuel Input w RVP Adjustments .xls

18. 2020 Shelby County TN HourVMTFraction .xls

19. 2020 Shelby Coun ty TN HPMSVTypeVMT .xls

20. 2020 Shelby County TN MOVES MYSQL Inputs.zip

21. 2020 Shelby County TN Ramp Fraction .xls

22. 2020 Shelby County TN RoadTypeDistribution .xls

23. 2027 Shelby County TN AvgSpeedDistibution .xls

24. 2027 Shelby County TN Fuel Input w RVP Adjustments .xls

25. 2027 Shelby County TN HourVMTFraction .xls

26. 2027 Shelby County TN HPMSVTypeVMT .xls

27. 2027 Shelby County TN MOVES MYSQL Inputs.zip

28. 2027 Shelby County TN Ramp Fraction .xls

29. 2027 Shelby County TN RoadTypeDistribution .xls

30. Shelby County TN Age Distr i bution .xls

31. Shel by County TN DayVMTFraction .xls

32. Shelby County TN Meteorology .xls

33. Shelby County TN MonthVMTFraction .xls

34. Shelby County TN Sourcetype Population .xls



### Attachment I II

- MOVES2014 O3 Output Files (folder)

1. 2012 Shelby County TN MOVES Output .xls

2. 201 7 Shelby Cou nty TN MOVES Output .xls

3. 20 20 Shelby County TN MOVES Output .xls

4. 20 27 Shelby County TN MOVES Output .xls

5. 2012 Shelby County TN MOVES M YSQL Output .zip

6. 2017 Shelby County TN MOVES MYSQL Output.zip

7. 2020 Shelby County TN MOVES MYSQL Output.zip

8. 2027 Shelby County TN MOVES MYSQL Output.zip



### Attachment I V

- Intergovernmental Consultation (folder)

1. Public Notice.pdf



### Attachment V Public Participation (folder)

1. Public Notice.pdf



### Attachment VI Supplemental Support Documents (folder)

1. TN Code Annotated Se ction 68

- 201

- 115 Local Progams.pdf

2. 2008

- 2010 Certificate of Exemption.pdf

3. 2010

- 2012 Certificate of Exemption.pdf

4. 201 2 Title V Emissions Statements .pdf

5. 2012 Title V Emissions Statements 2.pdf

6. 2012 Title V Emissions Statements 3.pdf

7. 2012

- 2014 Certificate of Exemption.pdf

8. 201 4

- 201 6 Certificate of Exemption.pdf

9. Proposed TVA Nat Gas EGU Plant.pdf10. Source 00045 Cargill

– Idling 2015

- 01

- 29.pdf

11. Source 00045 Cargill

– Idling 2015

- 0 3

- 29.pdf

12. Source 00045 Cargill

– Idling 2015

- 03

- 13.pdf

13. Source 000 45 Cargill

– Permit Emission Summary 201 4

- 0 9

- 30 .pdf

14. Source 00045 Cargill

– Permit title page .pdf



### Attachment VII 2011 Emissions Statements (folder)

A. 2008 Ozone NAAQS 2011 EI & Statements 2014 Submittal (folder)

1. ATT01 SC 2011 Shelby County Point Source E mission Inventory Questionnaires.zip

2. ATT02 SC 2011 Pt. Srce Emission Statements (folder)

a. 2011 Certified Emissions Statements

– Major Sources.pdf

3. ATT03 SC Local Reporting Requirements (folder )

a. Arlington 8

- 5(16) Reporting Requirements.doc

b. Bartlett 05(16) Re porting Requirements.doc

c. Collierville 8

- 304(16) Reporting Requirements.doc

d. Germantown 9

- 21(16) Reporting Requirements.doc

e. Lakeland 9

- 6(16) Reporting Requirements.doc

f. Memphis 16

- 98 Reporting Rrequirements.doc

g. Millington 20

- 1 (1 6 ) Reporting Requirements.doc

h. S helby County 14.5

- 30 Reporting Requirements.doc

4. ATT04 SC 2011 Nonpoint (folder)

a. 2011 Nonpoint Emissions Inputs and Estimates.xls

5. ATT05 SC 2011 NonRoad Equipment (folder)

a. 2011 NonRoad2008a Model Inputs.pdf

b. 2011 NonRoad 2008a Model Inputs Emissions Estim ates.xls

6. ATT06 SC 2011 NonRoad Commercial Marine Vessels (folder)

a. 2011 NonRoad CM V Emissions Inputs and Estimates .xls

7. ATT07 SC 2011 NonRoad Locomotive (folder)

c. 2011 NonRoad Locomotive Emissions Inputs and Estimates.xls

8. ATT08 SC 2011 NonRoad Aircraft and GSE (folder)

a. 2011 NonRoad Aircraft and GSE Emissions Estimates .xls

9. ATT 09 SC 2011 OnRoad (folder)

a. 2011 Shelby OnRoad Emissions Summary.xls

b. 2011 Shelby AVFT Inputs.xls

c. 2011 Shelby AvgSpeedDistribution Inputs.xls

d. 2011 Shelby DayVMTFraction Inputs.xls

e. 2011 S helby Fuel Formulation Inputs .xls

f. 2011 Shelby Fuel Supply Inputs.xls

g. 2011 Shelby Hour VMTFraction Inputs.xls

h. 2011 Shelby HPMSVMTFraction Input.xls

i. 2011 Shelby Meteorology Inputs.xls j. 2011 Shelby MonthVMTFraction Inputs.xlsk. 2011 Shelby Ramp Fraction Inputs.xl s l. 2011 Shelby RoadTypeDistribution Inputs.xls

m. 2011 Shelby SourceTypePopulation Inputs.xls

n. 2011 Shelby withIM Inputs.xls

o. 2011 Shelby withoutIM Inputs.xls

10. ATT 10 SC 2011 Biogenic (folder)

a. Biogenic Emissions Estimates.xls

11. ATT1 1 SC QAPP (folder)

a. QAPP Approval ltr 2012

- 05

- 31 .pdf

b. SCHD

- PCS EI QAPP.pdf

12. ATT13 SC 2011 Emissions Inventory Summary (folder)

a. Shelby county 2011 Emission Inventory Summary.xls

13. 2008 O 3 NAAQS 2011 EI & Statements 2040717 Submittal.pdf

14. Shelby County 2011 Shelby Emissions Inventory Calculati on Methodology.pdfLIST OF ACRONYMS

Acronym Definition ADEQ Arkansas Department of Environmental Quality

AEO Annual Energy Outlook

AERR Air Emissions Reporting Requirement

AIRS Aerometric Information Retrieva l System

APC Division of Air Pollution Control, Tennessee Department & Conservation

CAA Clean Air Act

CAIR Clean Air Interstate Rule

CD Consent Decree

CERR Consolidated Emissions Reporting Rule

CFR Code of Federal Regulations

CMV Commerci al Marine Vessel

CO Carbon Monoxide

CTG Control Technology Guidance

DV Design Value

DVMT Daily Vehicle Miles Traveled

EIIP Emission Inventory Improvement Program EIQ Emissions Inventory Questionnaire

EPA U.S. Environmental Protection Agenc y oF Degrees Fahrenheit

FR Federal Register

GHG Greenhouse Gas

GVWR Gross Vehicle Weight Rating

HC Hydrocarbons

HPMS Highway Performance Monitoring System

IAC Interagency Consultation

I/M Inspection and Maintenance

MACT Maximum Achieva ble Control Technology

MSA Metropolitan Statistical Area MDEQ Mississippi Department of Environmental Quality

MOA Memorandum of Agreement

MOVES EPA‟s Motor Vehicle Emission Simulator model

MPO Memphis Metropolitan Planning Organization

MVEB Mo tor Vehicle Emissions Budget

MY Model Year NAAQS National Ambient Air Quality Standard

NEI National Emission Inventory

NLEV National Low Emission Vehicle

NOAA National Oceanic and Atmospheric Administration

NO x Nitrogen Oxides

NSPS New Sour ce Performance Standar d s OBD On

- Board Diagnostics

O3 Ozone ppb parts per billionppm Parts per million

PSD Prevention of Significant Deterioration QA/QC Quality Assure/Quality Controlled

RACT Reasonably Available Control Technology

RFP Re asonable Further Progress

RVP Reid Vapor Pressure

SAF Seasonal Activity Factor

SCC Source Classification Code

SCHD

- PCS Shelby County Health Department

– Pollution Control Section

SIP State Implementation Plan

TCM Transportation Control Measure

TDEC Tennessee Department of Environment and Conservation

TDM Travel Demand Model

TN

- AR

- MS Tennessee

- Arkansas

- Mississippi

TPD Tons Per Day or tons/day

TVA Tennessee Valley Authority

ULSD Ultra Low Sulfur Diesel

VMT Vehicle Miles Traveled

VOC Volatile Organic Compounds

WAF Weekly Activity Factor1



### 1. Petition for Redesignation

The Pollution Control Section of the Shelby County Health Depart ment (Department), through the Tennessee Air Pollution Control Board representing the Gov ernor of the State of Tennessee, is formally petitioning the United States Environmental Protection Agency (EPA) to redesignate Shelby County, Tennessee to attainment of the 2008 National Ambient Air Quality Standard (NAAQS) for ozone (O3) pursuant to Sect ion 107(d)(3) of the 1990 Clean Air Act Amendments (CAA).

In 2008, EPA promulgated a revised O3 standard that set the NAAQS at 0.075 ppm. Shelby County in Tennessee, Crittenden County in Arkansas, and the northern urbanized portion of Desoto County in Mi ssissippi were designated as the Memphis TN

- MS

- AR non

- attainment area of the

2008 O3 NAAQS effective July 20, 2012 ( 77 FR 30088 ) with a classification of marginal, as air quality monitors for the area indicated 8

- hour average ozone design value (DV) concen trations exceeded the standard. With this designation, the three county area was originally required to attain the standard by December 3 1 , 2015, but a court challenge to the designation rule changed the statutory attainment date to July 20, 2015.

Air qu ality data through the end of 2014 shows all area O3 monitors are now registering DVs below the O3 NAAQS which makes the area eligible to petition EPA for a redesignation to attainment. The Department has been in contact with State air agencies, local tra nsportation planners and the EPA during the development of this petition. During early discussions with the surrounding states, it was decided that, due to differences in population, industrial development, transportation planning and the political bounda ries, each area would develop its own petition. Similar petitions are being prepared by Arkansas and Mississippi for their respective portions of the nonattainment area. These petitions are expected to be submitted to EPA within a few weeks of this submi ttal.

With the exception of shared air quality data, the Department requests that EPA evaluates each petition on its own merits such that a deficiency in one petition which can be determined to have no relevant effect in the other two jurisdictions will n ot delay processing of the other petitions.

Section 107(d)(3)(E) of the CAA specifies the requirements for redesignation of nonattainment areas. A primary guidance relied on in preparing and processing redesignation requests is a 1992

EPA memorandum issu ed by the then Director of the EPA‟s Air Quality Management Division, John Calcagni and titled “Procedures for Processing Requests to Redesignate Areas to Attainment” (the Calcagni memo). This petition generally follows the format of the Calcagni memo wit h two additional requirements not directly addressed in the memo. Those are the inclusion of the CAA Section 182(a)(1) inventory and the development of the Motor Vehicle Emission Budget. The other requirements for redesignation of a nonattainment area in clude:

1. The EPA has determined that the NAAQS has been attained;

2. The applicable implementation plan has been fully approved by EPA under section 110(k);

3. The EPA has determined that the improvement in air quality is due to permanent and

enforceable reduc tions in emissions;

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

and2

5. The EPA has fully approved a maintenance plan, including a contingency plan, for the area as meeting the requirements of Section 175A.



### 2. 20 11 Emission Inventory

The 2011 emiss ion inventory for Shelby County is included here as Attachment VI I to satisfy the requirement of CAA Section 182(a)(1) and the O3 implementation rule (80 FR 12264 ). This inventory was developed in accordance with the A ir Emissions Reporting Rule (AERR) requirements and has been submitted into the National Emission Inventory (NEI) database.

This is the baseline inventory required by all nonattainment areas. Its purpose is to set an O3 precursor emission baseline for an area to develop subsequent rules in an attainment plan. Since the Memphis TN

- MS

- AR nonattainment area was classified as marginal nonattainment of the O3 NAAQS, there is no requirement to develop attainment plans.

The inventory to be incorporated into t he State Implementation Plan (SIP) is the 2012 attainment inventory found in the Maintenance Plan portion of this document as that is what the 10 year maintenance plan will rely on in future years. Note that though both inventories relied on the most

curre nt available data, in the interim between compiling the 2011 and 2012 inventories, the local Metropolitan Planning Agency (MPO) developed updated model inputs for analyzing on

- road emissions. Therefore no comparison should be made between the on

- road emiss ions from these

inventories.



### 3. Attainment Determination

A

. ) Air Quality

Crittenden County Arkansas and Shelby County Tennessee share a common border and are separated by the Mississippi River. DeSoto County Mississippi and Shelby County share a com mon border but are not otherwise separated by topography. The area is located in the lower Mississippi river valley. There is very little variation in topography ranging from flat delta to low rolling hills. Crittenden, DeSoto, and Shelby counties are a part of the Memphis, TN

- AR

- MS metropolitan statistical area (MSA), which includes three counties in Tennessee, five counties in Mississippi, and one county in Arkansas. According to data from the U. S. Census Bureau for 2013, the MSA has a population of 1, 341,746. Shelby County is mostly urbanized and, with 939,465 residents, accounts for 70% of the MSA population. Crittenden County is mostly rural except for a small urbanized area on the east side of the county and has a population estimate of 49,746. Wit h the exception of a significant urbanized area just south of Shelby County in DeSoto County, Mississippi (population 168,240), the remainder of the MSA is almost completely rural. Previous studies have shown area emissions generally follow population dis tribution.

Since the 1970‟s, the area has experienced a general decline in its manufacturing base. However, during this same period it has grown to become a major distribution center. The area lies at the intersection of two major interstates and is hom e to the world‟s second busiest cargo airport, the

third largest rail center in the U.S. and the fourth largest inland port in the U.S.3

In years past, Shelby County has attained the NAAQS for particulate matter, carbon monoxide, lead, and for multiple O 3 standards, most recently attaining the 1997 8

- hour O 3 NAAQS of 0.08 parts per million (ppm) on February 3, 2010 ( 75 FR 56 , January 4, 2010 ). In 2008 EPA promulgated a revised standard that set the 8

- hour O 3 NAAQS at 0.075 ppm. Shelby, DeSoto, and

Critten den Counties were designated marginal non

- attainment of the O 3 NAAQS effective July 20, 2012 ( 77 FR 30088 ), as air quality monitors for the area indicated 8

- hour average ozone design value (DV) concentrations exceeded the standard. A monitor DV is an aver age of the fourth highest annual O3 value at a monitor over the most recent past three years. An area‟s DV is the highest monitor‟s DV in the area.

At the end of 2014, data from O 3 monitors in the Shelby/DeSoto/Crittenden nonattainment area

indicate atta inment of the O 3 NAAQS. The monitors recording this data are subject to quality control standards set forth in 40 CFR 58. Shelby County O 3 monitoring data fo r 2014 has been

submitted to EPA and has been certified as accurate . The 2014 O3 data from the m onitors in Crittenden County Arkansas and DeSoto County Mississippi has also been submitted to EPA and certified as accurate. The most recent three years of monitoring data (2012

– 2014) is presented in Table I showing the 3

- year design value data for all of the nonattainment monitors.

Table I : Memphis, TN

- MS

- AR Non

- Attainment Area Ozone Design Value

State County Site Name Monitor ID Design Value

2012 2013 2014

TN Shelby Frayser 47

- 157

- 0021 0.0 79 0.0 77 0.0 73

TN Shelby Edmund Orgill Park 47

- 157

- 1004 0.0 78 0.0 74 0.0 70

TN Shelby Shelby Farms 47

- 157

- 0076 N/A 0.0 78 0.0 73

MS Desoto Hernando 28

- 033

- 00002 0.07 4 0.0 70 0.06 9

AR Crittenden Marion 05

- 035

- 0005 0.079 0.0 76 0.07 1

*N OTE : The 1 st full year of operation of the Shelby Farms monitor was 2011 meaning no design value was

available at this monitor in 20124

Figure 1 depicts the DV of the nonattainment area by showing the highest DV recorded at any area monitor for each year from 2005 to 2014. The DV for each monitor for 2005 to 2014 is shown in Figu re 2. Not only did the area achieve compliance with the standard in 2014, the final DV is at such a level as to allow a substantial safety margin moving into the 2015 monitoring season. For the area to record a violation in 2015, monitors would have to re cord O 3 levels not seen since 2002. Figure 3 is a map of the Memphis MSA ozone monitors.

Figure 1

Figure 25 

### Figure 3

– Map of the Memphis MSA Ozone Monitors

B

. ) Environmental Justice

SCRAAMP 2015 does not relax control measures on existing sources and therefore will not cause emissions increases from those sources. Thus, no adverse human health or environmental effect on any individuals, including minority or low

- income populations associated with this redesignation request. The area has demonstrated that it has met the 2008 8

- hour ozone standard through permanent and enforceable measures and limitations. The maintenance plan actually projects a decline in emissions following the redesignati on, and that the area will continue to meet this NAAQS.6

C

. ) Weather Analysis

Weather has long been known to have been a driving force along with emissions in the
production of ground

- level ozone. Over the past decade, there have been vast reductions in both
the overall ground

- level ozone concentration levels as well as the number of days when the 8

- hour daily ozone maximum has exceeded the National Ambient Air Quality Standard (NAAQS).
The Department conducted an analysis (Analysis of Ozone Concentrat ions Between Select Days
During 2005

- 2006 and Recent Years (2012

- 2014) Using Comparative Weather Conditions in the
Memphis Metropolitan Area) to determine if recent weather conditions were the root cause in the
reduction of ground

- level ozone. The analysis can be found in A ttachment I.

The investigation focused on the isolation of the days with the highest 8

- hour ozone maxima in

2005

- 2006 and determining comparative weather conditions in recent years (2012

- 2014) with
those historic days in order to later c ompare ozone concentrations on an equal footing. Overall,
the study found that the ozone concentrations in 2005

- 2006 were significantly higher (an average
increase of 51.3% using methods developed for this specific analysis) than the comparative days

in re cent years (2012

- 2014). This strongly suggests that factors other than weather conditions
were the driving force behind the reduction in ozone concentrations and number of days
exceeding the 8

- hour ozone NAAQS over the last decade. Known emission reduction s are the
most likely reason for the substantial improvement in air quality for the Memphis metropolitan

area.



### 4

. SIP Approval

Regulations for Memphis and Shelby County were originally approved by the EPA on May 31, 1972 ( 37 FR 10842 ) as an appendix to t he Tennessee SIP. The SIP contained a section that recognized the Department as the agency with authority for the control of air pollution in Shelby County and included a control strategy demonstration along with the Department‟s regulations. In
1978, a portion of the City of Memphis was designated nonattainment for carbon monoxide and all of Shelby County was designated nonattainment for ozone. Nonattainment plans, along with new control strategy demonstrations, were developed for Memphis and Shelby Cou nty and in 1980 and7

1981 ( 45 FR 8004, 45 FR 53809

, and 46 FR 43970 ), the EPA approved those plans. The Department revised the regulations in several administrative and substantive areas. The Department adopted certain portions of the State regulations, revised old regulations and recodified the air pollution control section of Memphis and Shelby County Codes accordingly. On July 7, 1986, the State of Tennessee submitted to the EPA Memphis and Shelby County regulations (Board

Order 17

- 86) as a revision to the SIP. The EPA placed the regulations on hold until the federally approved SIP for Tennessee and Memphis could be compiled. The EPA compared the federally approved State regulations and the federally approved Memphis regulations to determine the

app rovability of the revised Memphis regulations. The EPA's direct final approval/disapproval of

the 1986 submittal was formalized in the Federal Register ( 54 FR 25456, June 15, 1989 ) and became effective on August 14, 1989.

EPA concluded that the control s trategy demonstration was adequate in protecting the National Ambient Air Quality Standards. Consequently, the EPA approved the local regulations as a transfer of enforcement authority rather than as a substantive revision to the SIP. The EPA used the

fo llowing conditions and conclusions to arrive at the above procedure:

The local regulations must be equal to the corresponding federally approved State regulation The local regulations cannot be treated as separable from the SIP, which the State submits

an d implements, but must be considered part of the SIP As Tennessee State law requires that a local regulation be equivalent to or not less stringent than the corresponding state regulation, the State of Tennessee must certify to the EPA that each regulation has been reviewed by the State and found to meet this requirement Tennessee must retain overall authority and responsibility for developing and implementing, including enforcing, the SIP

The Tennessee Code Annotated, Section 68

- 201

- 115 ( see Attachment VI ), requires geopolitical areas within Tennessee that desire to have their own air pollution control programs to adopt regulations as stringent as State of Tennessee regulations. After review by and upon the

recommendation of the Tennessee Air Pollution Co ntrol Division, the Tennessee Air Pollution Control Board issues a certificate granting this authority but subject to limitations as established by the Board. This authority continues to be granted to Shelby County and all included municipalities

every tw o years, the most recent certificate having been issued for the 2014

- 2016 period. Copies of

these recent certificates are also found in Attachment VI

.

Regulatory changes made by the State of Tennessee will be adopted by reference by the Department

when a nd where applicable prior to the granting of authority by the Tennessee Air Pollution Control Board to the Department as provided by the Tennessee Code Annotated and the Certificate of Exemption process. Where such authority is not transferred it remains with the State of Tennessee.

There are no local SIP elements that are subject to disapproval; a finding of failure to submit or implement a SIP; or partial, conditional, or limited approval.8



### 5. Emissions Reductions

Measured reductions in ozone concentra tions in the area are largely attributable to reductions from emission sources of volatile organic compounds (VOC‟s) and nitrogen oxides (NOx), which are precursors in the formation of ozone. Results of several local modeling studies show that between

10 to 30 percent of measured O3 concentrations are the result of local emissions. The remainder is from emission sources outside of the area as well as natural background concentrations. However, standard practice is to only take credit for emission reducti ons within a nonattainment area.

To determine permanent and enforceable emission reductions, the Calcagni memo directs that “the state should estimate the percent reduction (from the year that was used to determine the design value for designation and cla ssification) achieved from Federal measures such as the Federal Motor Vehicle Control Program and fuel volatility rules as well as control measures that have been adopted and implemented by the state”. The relevant time period for this analysis would be a ny of the three years that resulted in the nonattainment DV; 2009

- 2011, and the three years that resulted in having a DV meeting the NAAQS; 20012

- 2014. The marginal O3 nonattainment classification has no requirement to adopt an attainment SIP, so no new state or local rules have been implemented during this period. The marginal classification assumes existing rules in place that

continue to result in emission reductions will be sufficient to return an area to attainment within the expected time period. In submission of this request, Shelby County demonstrates that this has

occurred.

A

. ) Permanent and Enforceable Reductions in Emissions

i

. ) On

- Road Mobile Sources

Inventory analysis shows the majority of NOx emissions in the area are attributable t o mobile sources. Significant reductions in emissions have occurred and will continue to occur from on

- road mobile sources. Federal requirements for cleaner cars and trucks have contributed to the lessening of pollution from these sources.

Tier 1 stan dards under the National Low Emission Vehicle (NLEV) program were implemented from 1999 to 2001 for light duty cars and trucks. Tier 2 standards added additional reductions and covered a larger class of vehicles. The Tier 2 standards were implemented in different classes of vehicles from model years 2006 through 2009. In addition to the new technology standards, Tier 2 required the reduction of sulfur in gasoline from up to 300 parts per million (ppm) to 30 ppm beginning in January 2006. This also resul ted in reduced emissions from the existing older fleet of vehicles already on the road by improving the operation of catalytic converters. Also, beginning in model year 2007, all on

- road diesel engines were required to meet new standards designed to

reduc e particulate matter emissions by 90% and NOx emissions by 95%. Finally several federal rules have been issued for highway motorcycles implementing changes from model year 2006 through 2010 to reduce emissions of VOCs and NOx from those vehicles.

As the older more polluting fleet has been replaced with cleaner vehicles, on

- road emissions have decreased on a grams per mile basis as well as in total. Emission from on

- road sources are estimated through the use of locally gathered information from the Memphi s Area MPO on vehicle9

population and miles driven, as well as other inputs, combined with EPA‟s Motor Vehicle Emission Simulator (MOVES) model. Emission reduction estimates for Shelby County alone from 2009 to 2012 are 2.05 tons per day (tpd) for NOx, r epresenting a 4.7% reduction, and 0.54 tpd for VOCs, representing a 3% reduction. It should be noted that this occurred during an economic recovery period where VMT was reported to increase by 9.3%. It is certain that similar substantial

on

- road emission reductions are occurring in all surrounding areas.

The Maintenance Plan portion of this petition contains a Motor Vehicle Emission Budget (MVEB) that must be approved by EPA and must be used by local planners to periodically demonstrate that

transporta tion changes and plans conform to the requirements of the CAA. This budget is based on the 2012 attainment emission inventory year. A conformity determination means that during the life of the maintenance plan, on

- road emissions are not allowed to exceed the base year MVEB.

Effective in 2005, the Tennessee Air Pollution Control Board promulgated a statewide motor

vehicle anti

- tampering rule. This rule, defined in the Tennessee Department of Environment and Conservation, Chapter 1200

- 3

- 36 , Motor Vehicle Tampering, was promulgated to reduce excess air pollution caused by tampering with a motor vehicle‟s emissions control system. The rule defines tampering as modifying, removing or rendering inoperative any air pollution emission control device, which resul ts in an increase in emissions beyond established federal motor

vehicle standards. Below is Table I I

, which is adapted from a 2013 EPA publication titled “2009

- 2011 Compliance Report

– Vehicle and Engine Compliance Activities ” (EPA

- 420

- R

- 13

- 006)

which des cribes the variety of recent on

- road mobile source rules.

Table I I

Affected Industry Sector/Category On

- Road Mobile Program/Rulemaking Description Effective

Model

Year2

Light

- Duty

Vehicles Tier 2 Emission Standards and Gasoline Sulfur Fuel Control

– St rengthened emission standards for light

- duty vehicles and significantly reduced sulfur levels in gasoline

On

- Board Diagnostics (OBD)

– Established new emissions system monitoring requirements for light duty diesel vehicles

Revisions to Motor Vehicle Fuel Economy Labeling

– Updated EPA method for determining fuel economy label values to better represent typical driving patterns and more accurately estimate actual consumer fuel economy

Mobile source Air Toxics

– Set standards to lower gasoline benzene cont ent, reduce cold temperature exhaust emissions, and reduce evaporation and permeation from portable fuel containers Clean Alternative Fuel Vehicle and Engine Conversions3

- Updated anti

- tampering provisions applicable to manufacturers of clean alternative fuel conversion systems for highway vehicles and engines Light

- Duty Greenhouse Gas (GHG) Emission Standards

– Established the first

mobile

- source emission standards for greenhouse gases including carbon dioxide,
methane, and nitrous oxide

Revisions and Ad ditions to Motor Vehicle Fuel Economy Label

– Redesigned label provides new information on vehicle fuel economy, energy use, fuel costs, and environmental impacts for conventional and advanced technology vehicles 2004

2005

2008

2010

All 4

2012

201 3

Highway Highway Motorcycle Exhaust Emissions

-10

Affected Industry Sector/Category On

- Road Mobile Program/Rulemaking Description Effective

Model

Year2 Motorcycles Class I and II: Established more stringent HC and added new optional hydrocarbons

+ oxides of nitrogen (HC + NOx) standards; Added Class 1a (<50cc)

Class III: Established new Tier 1 HC + NOx standard Class III: More stringent Tier II HC + NOx standard

Highway Motorcycle Permeation Emissions

- Established new evaporative/permeation

standards for fuel tanks and lines 2006

2006

2010

2008

Heavy

- Duty Highway Engines

and Vehicles Light Heavy

- Du ty OBD

– Established OBD monitoring requirements for heavy

duty chassis certified vehicles, and for engines certified for use in heavy

- duty vehicles between 8,500 and 14,000 pounds gross vehicle weight rating (GVWR) Heavy

- Duty Highway Rule

– Established mor e stringent exhaust emission standards for heavy duty vehicles and engines; required Ultra Low Sulfur Diesel (ULSD) fuel (15 ppm sulfur maximum) Heavy

- Duty Engines OBD Rule

– New OBD monitoring requirements for engines certified for use in Heavy

- duty vehicle s above 14,000 pounds GVWR Heavy

- Duty GHG Standards

– Established first emission standards for greenhouse gas pollutants from heavy

- duty engines and heavy

- duty vehicles 2004

2007

2010

2014

2 Effective model year refers to the first year of a new progr am. Many programs are phased in over multiple model years.

ii

. ) Non

- Road Mobile

A wide variety of Federal non

- road mobile source initiatives have occurred resulting in reduced emissions. These measures continue to be phased in which will result in more emission reductions

from non

- road mobile sources in the future. No attempt has been made to quantify recent local emissions reductions from these measures, but future projects show significant reductions from this source category. This category covers e verything from small gardening equipment through barge and locomotive engines. Data concerning non

- road mobile source emissions can be found in

Attachment I

. Table III is adapted from the previously mentioned EPA publication and contains

information abou t recent non

- road mobile rules that have, and will continue to result in emission reductions from this source category.

Table III

Affected Industry Sector/Category Non

- road Mobile Program/Rulemaking Description Effective

Model

Year

Nonroad Compressio n Ignition Engines & Equipment Construction

& Agricultural Tier

- 3/Interim Tier 4

– Established more stringent emission standards

for engines between 37 and 560 kilowatts (50 and 750 hp)

Tier

- 4 Nonroad Diesel Rule

– Established more stringent emissions

st andards for all engines greater than 19 kilowatts (25 hp) and lowered nonroad diesel fuel sulfur to 15 ppm maximum 2006

2010

Marine

Diesel Engines Tier 3 and Tier 4 Emission Standards for Marine Diesel Engines

–

Established more stringent emission stan dards for newly built and remanufactured engines 2009

Locomotives Tier 3 and Tier 4 Emissions for Locomotive Diesel Engines Established

more stringent emission standards for newly built and remanufactured engines 2011

Nonroad Spark Small Spark

Ignition Control of Emissions From Nonroad Spark Ignition Engines and

Equipment

–

Established more stringent exhaust emission standards for11

Affected Industry Sector/Category Non

- road Mobile Program/Rulemaking Description Effective

Model

Year Ignition Engines & Equipment Engines

(Small SI) Class I (MY2012) and Class II (MY2011) engines below 19 kilowatts;

and fuel permeation standards for all engines below 19 kilowatts 2011

2012

Marine Spark Ignition Engines (Marine SI) Control of Emissions From Nonroad Spark Ignition Engines and

Equipment

–

Established first federal exhaust emission standards for

sterndriv e and inboard Marine SI engines and increased the stringency of exhaust emission standards for outboard and personal watercraft engines. Established new evaporative emission standards for all Marine SI engines 2010

Large Spark Ignition Engines (Large SI ) New Emissions Standards for Large SI Engines

– Established new

emission standards, diagnostic capability and portable Emission testing provisions

Tier 1

Tier 2 2004

2007

Recreational Vehicles New Exhaust Emission Standards for RVs

– Tier 1

Tier 2

Tier 3

New permeation standards for fuel components 2006

2006

2010

2012

2008

Aircraft 5 Established more stringent NOx exhaust emission standards for aircraft

engines

Established new NOx emission standards for aircraft, engines consistent

with international standards 2005

2012

iii

. ) Point Sources

Shelby County continues to experience significant reducti ons in regulated air pollutant emissions from permitted industrial sources. From 2004 to 2014, reported industrial emissions fell by nearly 30%. Some of this change is from changes in the mix of local sources with older facilities ceasing operation and newer, cleaner facilities moving in, and some of the change comes simply from industry efforts to operate in a more environmentally responsible way. However, a substantial portion of these reductions are a result of the implementation of new federal rules and activities in

the area.

New and modified rules that have recently been implemented and have had an effect on local

sources of O3 precursor emissions include Standards of Performance for New Stationary Sources (NSPS) rules found at 40 CFR Part 60, and National Emission Standards for Hazardous Air Pollutants (MACT) found at 40 CFR Part 63.12

B) Other Measures

i ) Consent Decree s

In addition to new rules being implemented, in recent years, other federal actions have led to significant permanent reductions in point source O3 precursor emissions at three local facilities.

In 2006, EPA entered into a Consent Decree (CD) with Cargill Corn Milling. The CD required Cargill to install new control equipment and to conduct studies to optimize other existing controls. The controls specifically targeted emissions of VOCs and NOx. The CD involved multiple Cargill

facilities across the count ry and it allowed the company some flexibility in achieving total reductions across all affected facilities. Though reduced maximum emission limits for NOx were placed on several large fuel burning sources, it appears the addition of new fuel burning cont rol units may have offset these reductions such that facil i ty

- wide NOx emissions remained stable. However, when fully implemented, the additional VOC controls resulted in a total actual reduction

of VOC emissions of 994 tons per year ( tpy ) between 2009 an d 2014. The requirements of the CD have been incorporated into the company‟s recently renewed Title V major source operating permit.

Valero Refining entered into a CD with EPA on November 20, 2007, which required extensive

emission controls to be install ed progressively until December 31, 2013. The CD resulted in reductions of multiple pollutants, but regarding NOx sources, it required the retirement of 4 large legacy boilers and additional controls on a 5 th production unit. Together, these resulted in actual NOx reductions of 236 tpy from 2007 through 2014.

There are t wo actions, which when combined, have resulted in significant NOx reductions from the Tennessee Valley Authority‟s Allen Fossil Plant (TVA

- Allen). EPA‟s Clean Air Interstate Rule (CAI R) updated and expanded the NOx Budget Trading Program set up as a result of the 1998 NOx SIP call and required additional NOx reductions in 2009 through 2014. This rule gives allocations to states and allows trading among plants within the state, so it i s not necessarily an enforceable reduction at any given plant. However, on April 14, 2011, TVA entered into a CD to resolve allegations of New Source Review violations. The CD requires system

- wide annual limitations for NOx beginning in 2011 with further reduced limits through 2017. It also requires TVA to surrender NOx allowances from the TVA system for 2011 and subsequent years that TVA does not need in order to meet its own federal and/or state Clean Air Act regulatory requirements for that calendar y ear . In addition, the CD requires continuous operation of the installed selective catalytic reduction system at Allen. This greatly reduced TVA‟s flexibility to allow NOx emissions to rise at any given plant. TVA Allen reported 8061 tons of NOx emitted in 2008 and 2606 tons in 2009, the first year of CAIR. 2009 through 2011 emissions averaged 2548 tpy. After the CD, emissions for 2012 through 2014 averaged 1908 tpy.

ii ) Voluntary Efforts

Due in large measure to local political leadership, there has been a sharp increase in interest and application of sustainable practices in recent years. Many public, private and non

- profit organizations are actively involved in projects ranging from massive infrastructure improvements to small alternative energy p rojects.13

In 2008, over 130 residents of the City of Memphis and Shelby County developed the Sustainable Shelby Implementation Plan. The plan was completed in early 2009 and laid out 151 strategies for a greener, smarter, and more sustainable future in Memphis and Shelby County. The strategies focused on areas such as neighborhood planning, energy efficiency and renewable energy, resource conservation, recycling, transportation, and community health amongst other issues. The Office of Sustainability was formed to oversee the strategies set and to report progress on these initiatives to the public. In April 2011, City of Memphis Mayor A C Wharton, Jr. and Shelby County Mayor Mark Luttrell, Jr. formed the Memphis and Shelby County Office of Sustainability . The Office is located in the joint City/County Division of Planning and Development.

The completed and ongoing projects are too numerous to list here and some of the projects do not directly result in improved air quality. But taken together, they rep resent a shift in the public‟s attitude to not only expect, but also to participate in projects and practices that are more environmentally acceptable than past practices. Two global measures that represent the success of these initiatives are a report th at from 2009 through 2013, total annual energy consumption in Shelby County was reduced by 16.45%, and that from 2008 through 2013, bicycle use as a measure of transportation mode share increased by nearly 500%.

More detailed information can be found in t he 2014 Sustainable Shelby Progress Report: http://www.sustainableshelby.com/sites/default/files/Implementation%2 0Plan/Sustainable%20Shel by%20Progress%20Report%202014.pdf



### 6. Clean Air Act Section 110 and Part D Requirements

As previously noted in Section 3 of this petition, with the exception of certain administrative portions of the local codes, Shelby County a nd the associated municipalities adopt the State of Tennessee Air Pollution Control Rules by reference. The Department has worked closely with

TDEC‟s Division of Air Pollution Control to harmonize state

- level rules to reflect requirements

within the Count y.

With respect to Section 110(a)(2) requirements , these are general requirements that have been in force and in place at the State and local level for many years. And, as noted earlier, no portion of these plans is currently subject to disapproval; a fi nding of failure to submit or implement a SIP; or partial, conditional, or limited approval.

Part D became effective as part of the 1990 amendments and consists of several subparts where subpart 1 provides general requirements for all nonattainment areas and the other subparts are pollutant

- specific. In this case, subpart 2 contains the additional provisions for ozone

nonattainment areas. Note

, that in some cases, the subpart 1 general requirements may be subsumed within, or superseded by, the more speci fic subpart 2 requirements.

Under the marginal nonattainment classification in subpart 2, there is no requirement to develop and submit an attainment plan as required for more polluted areas under Section 172(c). This leaves Section 173, Permit Requireme nts, and Section 176, Limitations on Certain Federal Assistance (generally referred to as „conformity‟). Soon after the 1990 amendments, Shelby14

County, along with the state, adopted all new permitting requirements under part D. These have been periodic ally updated since then, but remain affective and in force. Also, the State has approved conformity provisions found at Tennessee Rule 1200

- 03

- 34 which has been adopted into local regulations.

Plan Submissions and Requirements for Marginal Areas: Sectio n 182(a) 1) Inventory: An inventory was prepared for 2011, but the Department failed to finalize it through all administrative steps. Before that was completed, the area recorded clean data and resources were redirected to preparing an redesignation request and maintenance plan

. It is noted the two year inventory requirement is meant to be used to develop Reasonable Further Progress (RFP) plans for areas classified moderate and higher. For redesignation, the Calcagni memo states that the requirements for a n emission inventory will be satisfied by the inventory requirement of the maintenance plan. Since the 2012 inventory discussed in the maintenance plan is the area‟s „attainment inventory‟, The Department requests that this is the inventory that should be identified in the SIP. 2) SIP Corrections

a. RACT Corrections: All required VOC RACT corrections were approved by EPA

on June 17, 1994 ( 59 FR 18310 ). Changes and additions to those rules occurred 2 years later as a result of operation of the approved mainten ance plan for the 1979 1

- hr. O3 NAAQS.

b. Savings Clause for Vehicle Inspection and Maintenance: Though the City of Memphis operated a vehicle inspection and maintenance (I/M) program for many years, its purpose was for control of carbon monoxide (CO), not O3. There was never any CAA or plan requirement to have a county

- wide I/M program for the

control of O3.

c. Permit Programs: Shelby County is subject to Tennessee‟s fully

- approved part D NSR permitting program, most recently updated on February 7, 2012 ( 77 FR 6016 ). 3) Periodic Inventory:

a. General Requirements: Shelby County is submitting a 2011 inventory and a 2012 base year inventory with this petition and is committed to continue preparing and submitting a comprehensive triennial emission inventory in compli ance with the

AERR.

b. Emissions Statements: The emission statement requirements were initially approved on February 16, 1995 (60 FR 3352 ). We note the State rule was amended

on March 5, 2015 (80 FR 11887 ). This change not only added emissions statements requirements for East Tennessee counties, it also clarified some of the language. During the local update process, this clarified language will be adopted.



### 7. Maintenance Plan

In accordance with Sections 107(d)(3)(E) and 175A, the following demonstrate s maintenance of the O3 NAAQS throughout the maintenance period. This plan sets forth measures to be carried out after a redesignation request is approved by the EPA to prevent deterioration of the area‟s air quality. The Department has developed this pl an to demonstrate maintenance of the O3 NAAQS from approval of the plan through 2027. During these years, the plan contains commitments to15

continue existing programs and to implement programs and measures depending upon emission inventory and air qualit y monitoring results. Provisions of this plan assure both an on

- going effort to maintain the NAAQS and the obligation to implement new measures in the event of unforeseen developments.

A ) Base Year Inventory and Future Projections

An attainment year in ventory can be developed for any of the three years in which an attaining design value is computed. 2012 was chosen as the attainment year inventory for the Memphis

TN

- AR

- MS nonattainment area after consultation with the surrounding states, EPA regions 4 and 6, and the Memphis area MPO. Use of 2012 as the attainment year is believed to be representative of emissions during the three

- year attainment period of 2012

- 2014. This inventory represents a comprehensive and accurate inventory of actual emissions f rom all sources of VOCs and NOx for 2012 within Shelby County. Future year emissions were projected from the 2012 base year for 2017, 2020 and 2027.

Point Sources

The base

- year point source emissions inventory is based on the 2012 Shelby County, Tennes see Emissions Inventory Questionnaire (EIQ) which is an annual emissions inventory survey conducted by the Department. The EIQ process is as follows, an EIQ containing data submitted the previous year is sent to the designated facility contact via e

- mail. All facilities receiving the EIQ are required to update the data and return the information to the Department in an electronic format accompanied by a hardcopy printout.

While emissions are reported in the EIQ on an annual basis, facilities are requir ed to account for summer operations by providing the annual throughput, the seasonal throughput percentage, and the weekly operations schedule. In addition, it is understood that summer season percentage constitutes 25% of the year. Taking all of these fa ctors into account, typical summer/O3 season day emissions are determined in tons per day using the following equation:

Summer Season Day Emissions (tons per day) = ((Annual Throughput x SAF)/ (WAF x Weeks per Year))

Where :

SAF = Seasonal Throughput Per centage/ Percentage of Months Associated with Summer WAF = Weekly Activity Factor (The Number of Days of operation per Week)

Nonpoint Sources

The 2012 base

- year nonpoint source emissions inventory was developed using the methodologies provided in the Em issions Inventory Improvement Program (EIIP), Procedures for the Preparation of Emissions Inventories for Carbon Monoxide and Precursors of Ozone (Procedures Manual), as16

well as the methodologies developed by E.H. Pechan & Associates, Inc. (Pechan) for t he USEPA

and used in the 2008 NEI.

N onpoint sources are sources of emissions too small to be inventoried individually but which collectively contribute significant emissions. Nonpoint sources include smaller stationary point sources not included in the po int source invento ry, such as, printing establishments, dry cleaners, and auto refinishing companies ; as well as

, non

- stationary sources.

N onpoint source emissions are estimated by multiplying an emission factor by an activity factor that is representati ve of the nonpoint source category. An activity factor is any parameter associated with the activity level of a source that can be correlated with the air pollutant emissions from that source, such as production, number of employees, or population. Doubl e counting of emissions can occur when there is overlap between point and nonpoint emissions categories. To avoid double counting in this emissions inventory, overlap categories were identified and point subtraction was performed where needed.

To charac terize nonpoint source emissions that result from summertime operations, the following equation was used to estimate typical summer day emissions in ton per day:

Summer Season Day Emissions (tons per day) = ((Annual Throughput x SAF)/ (WAF x Weeks per Yea r))

Where :

SAF = Seasonal Throughput Percentage/ Percentage of Months Associated with Summer WAF = Weekly Activity Factor (The Number of Days of operation per Week)

Non

- road Mobile Sources

Nonroad mobile sources represent a large diverse set of off

- ro ad vehicles and non

- stationary equipment. For the purpose of developing emission estimates, nonroad vehicles and equipment are grouped into four source category types, as follows: 1.) non

- road equipment

– such as, agriculture, construction, lawn and garden, a nd recreational, 2.) aircraft

– commercial, military, and private aircraft

, 3.) commercial marine vessels

– typically towboat s, crew boats, and refueling boats ( vessels

other than recreational ) 4.) locomotives

– Class I line haul, switchyard, and passenger

.

With the exception of air craft , commercial marine vessels, and locomotives, emissions estimates

for non

- road mobile equipment sources were generated with EPA‟s NONROAD2008 model, which includes estimates for growth based on expected future economic conditions as well as national

controls. Aircraft emissions estimates were projected to 2012 by applying growth factors to EPA‟s 2011 National Emission Inventory. Commercial marine vessel emissions estimates were developed from information obtained in the 2012 Waterb orne Commerce, which is a reference source provided by the US Corp of Engineers, in combination with technical incite from US Corp of Engineers personnel and EPA emissions factors. Locomotives emissions estimates were generated from a 2012 survey of railro ad companies operating in Shelby County. If railroad company officials fail to respond, locomotive emissions estimates were flat

- lined based on previous

submittal. Files containing non

- road mobile source data are found in Attachments I.17

On

- road Mobile S ources

The on

- road mobile source emissions inventory was developed with EPA‟s Motor Vehicle Emissions Simulator model (MOVES2014), using input data provided by the Memphis area Metropolitan Planning Organization (MPO). The 2012 base

- year on

- road mobile i nventory was developed in accordance with the guidance provided in the document titled, “MOVES2014 Technical Guidance: Using MOVES to Prepare Emissions Inventories in State Implementation Plans and Transportation Conformity, EPA

- 420

- b

- 15

- 007”. For the 2012 model run , the RVP input parameter was set to the summertime regulatory limit of 7.8.

Future Year Projections

In accordance with Sectio n 175 A of the CAA, t he 2012 base year emissions estimates were projected to 2017, 2020, and 2027. These future year projections indicate that the emissions of

VOC and NOx in Shelby County, Tennessee will remain below the estimates determined for the 2012 attainment base year , and thus, will demonstrate maintenance of the NAAQS for at least 10 years after redesignation. T he methodologies used to develop all of the emission inventory categories is provided in the document titled “ 2012 Shelby County TN Emissions Inventory

Calculation Methodology” which is provided in Attachment I of this document. A brief discussion

of the future year projection methodology is provided below.

Future year p oint source emissions estimates for 2017, 2020, and 2027 were projected with growth factors developed from the United States Department of Energy, 2014 Annual Energy Outlook (AEO projecti ons and the University of Tennessee, Data Center, 2014 Econometric Model

Forecast. As a conservative measure

, a value of 1 was substituted for all negative growth factors. Files containing point source data can be found in Attachment I

.

Similarly, future year n onpoint source emissions estimates for 2017, 2020, and 2027 were projected with growth factors developed from the United States Department of Energy, 2014 Annual Energy Outlook (AEO) projections and the University of Tennessee, Data Center, 2014 Eco nometric

Model Forecast. As a conservative measure

, a value of 1 was substituted for all negative growth

factors. Files containing nonpoint source data can be found in Attachment I

.

With the exception of nonroad mobile equipment, which utilized NONROAD20 08 to generate
emissions estimates for future

- year 2017, 2020, and 2027, the future

- year emissions estimates for the nonroad mobile categories of air craft , commercial marine vessels, and locomotives were project ed with growth factors developed from the Uni ted States Department of Energy, 2014 Annual Energy Outlook (AEO) projections

. Files containing nonroad mobile source data can be

found in Attachment I

.

Future

- year o n

- road mobile source emissions estimates for 2017, 2020, and 2027 were generated

with MO VES2014

. For the 2017, 2020, and 2027 model runs , the RVP input parameter was set to

9.0. The future year fuels were selected by exporting the default fuel specifications for Shelby County, Tennessee from the MOVES2014 fuel input screen panel, making the a ppropriate RVP adjustments, and then consulting with the MOVES Team via EPA Region 4 to determine if the fuels selected and adjustments performed were appropriate

. Files containing on

- road mobile source data are found in Attachments II through III

.18

Thoug h all details of the base year and future projected inventory can be found in the attachments, it is important to point out several details regarding the on

- road mobile analysis. In the MOVES model, the 2012 base year inventory is set to record the effect s of a tailpipe only I/M program within the Memphis city limits and of the federally required summer gasoline volatility standard of 7.8 Reid Vapor Pressure (RVP) while the future years are run with both of these measures removed

from the model.

The City of Memphis closed the Inspection and Maintenance ( I/M ) program in July of 2013. This program was a requirement of the CO maintenance plan and was never relied on for ozone control. In fact, the area‟s second 10

- yr CO maintenance plan clearly demonstrate d it was not necessary for continued maintenance of that standard. However, though it was never incorporated as a Transportation Control Measure (TCM) in the 1997 8

- hour O3 NAAQS maintenance plan, the CO plan relied on continuation of the program in model ing the on

- road MVEBs. The shut down of the program required Shelby County to submit an amended O3 maintenance plan to account for the loss of expected emission reductions from the program. That amended SIP traded excess emissions

that were available for stationary source offsets from a recently shuttered manufacturing facility in exchange for the predicted rise in emissions from closing the program. This permanently removed those excess emissions from the local nonattainment offset „bank‟, making them u navailable for use as emission offsets for nonattainment stationary source permitting. Details on that SIP amendment

are available at the following website: https://xfer.shelbycountytn.gov/ . To access it, enter “public” for the username and password in the Serv

- U login screen panel and then left

- click on “Login”. With the website open, select the folder “Pollution Control

– Air Program” and then

select the sub

- folder “Shelby County Maint. Plan Rev. 2014

- 05

- 01”. In that amendment, it was necessary to adjust the MVEB used for conformity to update the inventory based on the new MOVES model rather than the old MOBILE6 model, as well as to account for the minor changes in

the on

- road and point source categories a ffected by the shut down of the local I/M program. At the time of preparation of this document, that SIP amendment has not yet been approved.

With Stage 1 vapor controls on gasoline distribution and the proven widespread use of onboard refueling vapor r ecovery (ORVR) ( 77 FR 28772 ), the emission reductions due to lower vapor pressure summertime gasoline has become negligible and it is believed the requirement is no longer

cost

- effective. Shelby County intends to work with the State of Tennessee to prepar e a petition in the near future to remove the reduced fuel vapor pressure requirement in Shelby County and the affected middle Tennessee counties. By modeling future year on

- road emissions with the 7.8 RVP summer gasoline standard relaxed to 9.0 RVP , this offers a more conservative estimate of actual expected emissions thereby making the maintenance demonstration more robust.19

The Shelby County base year and future year emission inventory estimates are presented in Table

IV

. Table IV

Summer Season Tons Pe r Day Shelby County Volatile Organic Compounds Emission Inventory

Type Year Area Non

- Road On

- Road Point Total

Base Y ear 2012 44.04 28.44 19.01 9.30 100.79

Interim Projection 2017 45.33 21.32 11.22 6.64 84.51

Interim Projection 2020 4 5

. 53 19.76 8.75 6.2 2 80.26

Maintenance Year 2027 46.30 19.33 5.81 6.24 77.69

Shelby County Nitrogen Oxides Emission Inventory

Base Y ear 2012 4.11 35. 93 61.56 13.87 115.4 7

Interim Projection 2017 4.18 32.0 9 31. 30 13.45 81.01

Interim Projection 2020 4.2 4 30.5 7 22. 42 8.34 65.56

Maintenance Year 2027 4.3 4 29. 77 12. 51 8.43 55.05

B ) Motor Vehicle Emissions Budgets

The transportation conformity rule found in 40 CFR Part 93 requires specific emission budgets to

be defined for the on

- road mobile sources portion of the Shelby County emission inventory. These budgets are to be used by transportation authorities to assure that transportation plans, programs, and projects are consistent with, and conform to, the maintenance of acceptable air quality in Shelby County throughout t he term of the maintenance plan. Section 93.118(b) states in part:

Consistency with the motor vehicle emissions budget(s) must be demonstrated for each year for which the applicable (and/or submitted) implementation plan specifically establishes

motor ve hicle emissions budget(s), for the attainment year (if it is within the timeframe of the transportation plan), for the last year of the transportation plan's forecast period, and for any intermediate years as necessary so that the years for which consisten cy is demonstrated are no more than ten years apart, ...

Under 40 CFR 93.101, the safety margin is the difference between the attainment level and the projected level, from all sources, of emissions in the maintenance plan. The attainment level of

emission s is the 2012 base year inventory. The available safety margin for a pollutant in any future year is the difference in the total inventory for each pollutant from the base year to the future year projections. Using allocations from the safety margin, dif ferent MVEBs may be set at different years over the course of the maintenance plan if needed to balance out expected increases and decreases in source category emissions in a manner to help insure no future year total inventory will exceed the base year at tainment inventory and to insure no future year on

- road emissions as determined by periodic conformity determinations will exceed the MVEB for that year. Since significant emission reductions will occur in both on

- road and point source categories over the life of the maintenance plan, no reallocation of a safety margin is needed . Therefore, after consultation with the local MPO and Tennessee State Air Program, it was decided the safety margin attributable

to on

- road reductions in NOx and VOC emissions wil l be allocated to the on

- road projections for

2027

. In particular, 49. 04 tpd of NOx and 13. 19 tpd of VOC will be allocated to the 2027 MVEB resulting in a balance of 11. 38 tpd of NOx and 9.9120

tpd of VOC remaining in the safety margin. The MVEBs for VOCs and NOx are presented below

in Table V

. Table V Summer Season Tons Per Day Volatile Organic Compounds On

- Road Emission Budget

Year Area Non

Road On

Road Point Total Safety Margin On

- Road

Safety Margin

Allocation On

- Road

Budget Remaining

Safety Margin

2012 44.04 28.44 19.01 9.30 100. 7 9 N/A N/A 19.01 N/A

2027 46. 30 19.33 5. 81 6.24 77.69 23.10 1 3

. 19 19.01 9.91

Nitrogen Oxides On

- Road Emission Budget

2012 4.11 35. 93 61.56 13.87 115.4 7 N/A N/A 61.56 N/A

2027 4.34 29. 7 7 12. 51 8.43 55. 05 60. 42 49. 04 61. 56 11. 3 8

C. Air Quality Monitoring Network

The existing Shelby County ozone air quality monitoring network will continue to be operated in its present configuration. Any change will be in accordance with the Memorandum of Agreement (MOA) finalized o n June 20, 2008 between the Shelby County Government, Arkansas Department of Environmental Quality (ADEQ) and the Mississippi Department of Environmental Quality (MDEQ) and as discussed in a letter dated February16, 2015. This MOA is in accordance with 40 CFR 58 Appendix D, Section 2(e) and is located in Attachment I along with a map showing area monitor locations in the Memphis MSA (see file re: Monitoring) and the aforementioned 2015

letter.

D. Emission Inventory

In order to track the progress of the maintenance plan, emission inventories of actual emissions for Shelby County will be performed using the latest emission factors, models and methodologies to include area, non

- road mobile, on

- road mobile and point sources of VOC and NOx. The major poi nt source inventory will be updated annually while the full inventory will be updated every three years in accordance with the AERR beginning no later than the 2015 emission year.

E. Stationary Source Control

After redesignation to attainment, sources wishing to expand or locate in Shelby County will continue to undergo new source review requirements, except under PSD requirements for permitting in attainment areas found at Tennessee Rule 1200

- 3

- 9

- .01 (4) and all existing stationary

source controls wil l remain in force. Companies will continue to be sought for the purpose of voluntarily reducing VOC and/or NOx emissions where possible.

In addition to maintaining the point source regulatory program, there are developments at two local

industrial sites which will result in significant reductions in point source O3 precursor emissions.21

Cargill Corn Milling (source # 00045 ) is in the process of shutting down almost all of its local operations which in 2014 emitted 743 tons of VOC and 525 tons of NOx. A t the time of preparation of this document, the company had not yet surrendered its permit or submitted a modification application, but it is in the process of disassembling and removing large emission source equipment. Also, TVA has announced plans to sh ut down TVA

- Allen (source # 00528 ) by the end of 2018 to finalize compliance with the CD. They have submitted an application to build a new natural gas

- fired combined cycle turbine generating unit in place of the Allen plant. This is expected to result in NOx emission reductions in excess of 1000 tons per year.

F. Voluntary measures

Many of the projects mentioned in Section 5. B ) ii.) of this document are ongoing and are expected to further help reduce local harmful emissions through energy conservation efforts and transportation

- related projects

The Department maintains a meteorologist on staff to produce local air quality forecasts. These forecasts have been recognized by the states of Tennessee, Arkansas and Mississippi as the primary

forecasts for t he region and use them to conduct outreach to the counties surrounding Shelby County. Whenever the Department forecasts ozone levels above the NAAQS, an air quality alert is issued and the following actions take place: The Department has developed a good working relationship with the local media and the air quality alert is typically included as part of the area‟s weather reports across multiple media platforms. All open burning permits issued by the Department are suspended until the forecast shows improv ement. During the summer season, holders of such permits are required to contact the office on a daily basis to determine if burning will be allowed. Air quality alerts are posted on the Intelligent Transportation System boards located on the

expressway s ystem in Shelby County encouraging motorists to take actions to reduce

emissions. The Department has adopted a provision included in all stationary source permits for

emergency power generators that prohibit their operation for maintenance and testing on a ir quality alert days. There are several very large stand

- by power generation installations in Shelby County. Besides these provisions, the Department will continue to look into effective ozone alert day measures and will continue an aggressive public edu cation and outreach program begun in 2009. The Department will continue to work with State and local agencies to encourage adoption of measures to reduce ozone formation at all times, but especially during air quality alerts.

G. Contingency Provisions

Section 175A requires a maintenance plan to include contingency provisions to promptly correct any violation of the NAAQS which occurs after redesignation of an area to attainment. In addition, in order for an area to take early action to address potenti al violations of the NAAQS before they occur, it is recommended that contingency provisions will be enacted when specified action levels22

indicate the need. Shelby County is adopting a two

- phase approach to addressing ozone related air quality problems i n the area. Each phase includes increasingly aggressive provisions to be implemented in the event of specified indicators.

Phase 1 of the plan addresses potential future problems as a result of unanticipated increases in

local emissions. This will be i mplemented when the certified triennial emissions inventory of VOCs or NOx (summer season tons per day) exceeds the 2012 base year attainment inventory by ten percent (10%) or more and any area monitor has recorded at least one exceedance of the O3 NAAQS a ccording to certified data during the most recent monitoring season. On this occurrence, the Department will conduct an investigation into the possible causes to determine if they are attributable to reporting errors or a non

- recurring anomaly in the loca l emission profile. The investigation will last no longer than three months when the results will be reported to the EPA and

the Tennessee Air Pollution Control Division.

If the investigation reveals the data are valid and are not due to unusual circumst ances, further action is required. Following consultation with the Tennessee Air Pollution Control Division and the EPA, the Department will seek to expand voluntary programs and develop regulations for submission to the Shelby County Commission or Tennes see State Air Board, as appropriate, to address the causes of concern. Proof of adoption of such regulations will be submitted to the EPA within nine months after the end of the investigation. All regulatory programs will be implemented within eighteen t o twenty

- four months after verification of a monitor exceedance by certified data. Such measures could include, but are not limited to:

Programs or incentives to decrease motor vehicle use; Programs to require additional emissions reductions on stationar y sources; Restrictions of certain roads or lanes for, or construction of such roads or lanes for use by, passenger buses or high

- occupancy vehicles Employer

- based transportation incentive plans; and, Additional programs for new construction of paths for u se by pedestrian or non

- motorized vehicles when economically feasible and in the public interest.

Phase 2 will be implemented when a monitored violation of the 2008 ozone NAAQS occurs in the nonattainment area according to certified data during the most r ecent monitoring season. Similar to Phase 1, on that occasion, the Department will conduct an investigation to determine if the cause of the violation can be attributed to errors or clearly identifiable exceptional events outside of local

control. Prior to certification of the data, the Department will solicit the involvement of all State agencies having jurisdiction in the surrounding area. The investigation will last no longer than three months when the results will be reported to the EPA and the Tenne ssee Air Pollution Control

Division.

If the investigation reveals the data are valid, further action is required. In addition to the provisions described in Phase 2, following consultation with the Tennessee Air Pollution Control Division and the EPA, th e Department will seek to expand voluntary programs and develop additional regulations for submission to the Shelby County Commission and Tennessee State Air23

Board, as appropriate, to address the causes of concern. All regulatory programs will be imple mented within eighteen to twenty

- four months after verification of a violation by certified

data. Such measures will include all measures which were contained in the state implementation plan for the area before redesignation of the area as an attainment area, and may also include :

A Reasonably Available Control Technology (RACT) regulation for legacy major sources of NOx emissions in Shelby County. Adoption of all industrial and commercial VOC controls as provided in final EPA

- approved Control Technolog y Guidelines (CTGs) through the date of the recorded violation.

Within six months of the conclusion of the investigation, the Department will prepare regulations for submission to the Shelby County Commission or Tennessee State Air Board, as appropriate, to adopt these controls. The effective date of these controls will be targeted to be within eighteen to

twenty

- four months after verification of the triggering event.