### June 2010



## REDESIGNATION REQUEST
AND
MAINTENANCE DEMONSTRATION

Birmingham

24-Hour PM 2.5 

## Nonattainment Area

Prepared by:

Alabama Department of Environmental Management

Air Division

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

1-2 

### (This page has intentionally been left blank)

### TABLE OF CONTENTS 

### Executive Summary ..........................................................................................................v
1.0 Introduction ......................................................................................................... 1-1

1.1 Purpose ..........................................................................................................................1-1

1.2 Historic Background ................................................................................................1-1

1.3 Formation of PM 2.5 

### .....................................................................................................1-1

1.4 Criteria for Redesignation .....................................................................................1-1



### 2.0 Attainment Demonstration ............................................................................ 2-1

2.1 Demonstration that the NAAQS Has Been Attained ...................................2-1 2.1.1 Overview

............................................................................................................................... .... 2-1 2.1.2 PM 2.5 Monitoring Network .................................................................................................... 2-1 2.1.3 Ambient PM 2.5 Monitoring Data .......................................................................................... 2-2



### 2.2 Permanent and Enforceable Reductions in Emissions .............................2-3 2.2.1 Meteorological Analysis ......................................................................................................... 2-6


### 3.0 Fully Approved SIP, Section 110 and Part D Requirements ............3-1

3.1 Section 110 Implementation Plans .....................................................................3-1

3.2 Part D Plan Requirements for Nonattainment Areas ................................3-1 3.2.1 Nonattainment Areas in General ........................................................................................ 3-1


### 4.0 Maintenance Plan ..................................................................................................... 4-1

4.1 Overview ........................................................................................................................4-1

4.2 Attainment Inventory ..............................................................................................4-1 4.2.1 Overview

............................................................................................................................... .... 4-1 4.2.2 Point Sources ........................................................................................................................... 4-1 4.2.3 Area Sources ............................................................................................................................ 4-2 4.2.4 On-road Mobile Sources ......................................................................................................... 4-3 4.2.4.1 Mobile Source Attainment Budget ..................................................................................... 4-3 4.2.4.2 Projected Mobile Source Emissions Methodology ............................................................. 4-3 4.2.4.3 Mobile Source Maintenance Budget .................................................................................. 4-4 4.2.5 Non-road Mobile Sources ...................................................................................................... 4-5



### 4.3 Each county total is listed in summary Tables 4.3-1 through 4.3-3 under non-road sources.Maintenance Demonstration .........................................................................................4-6 4.3.1 Plan to Maintain Air Quality ............................................................................................. 4-10 4.3.2 Verification of Continued Attainment .............................................................................. 4-13 4.3.3 Contingency Plan .................................................................................................................. 4-13


### 5.0 Conclusion ............................................................................................................ 5-1

iii

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

iv TABLES
Table 2.1.2-1 Summary of 98th Percentiles of the 24-hour PM2.5 Concentrations ......................2-2 Table 2.2-1 Summary of RACT Controls.........................................................................................2- 5 Table 2.2-2 Summary of Utility Controls ........................................................................................ 2-6 Table 4.3-1 Birmingham 24-Hour PM 2.5

Attainment Area Maintenance Plan PM 2.5

Emissions (Tons per Day)................................................................................................................. ..................4-7 Table 4.3-2 Birmingham 24-Hour PM 2.5

Attainment Area Maintenance Plan NO X

Emissions (Tons per Day)................................................................................................................. ..................4-8 Table 4.3-3 Birmingham 24-Hour PM 2.5

Attainment Area Maintenance Plan SO 2 Emissions (Tons per Day)................................................................................................................. ..................4-9 Table 4.3.1-1 RACT Controls Instal led Prior to or During 2 009 ................................................4-13 Table 4.3.3-1 Proj ected Reductions............................................................................................. ...4-15 Table 4.3.3-2 SO 2 Emissions Re ductions.......................................................................................4-16 Table 4.3.3-3 NO X

Emissions Re ductions......................................................................................4-17 Table 4.3.3-4 Schedule for Permit Revisions or Rule Revisions for Contingency Measures.......4-18


### FIGURES
Figure 2.2-1 Locations of Local Sources Being Controlled for PM 2.5

in Relation to the North Birmingham PM 2.5

Monitor .............................................................................................................2-4 Figure 2.2-2 Locations of Local Sources Being Controlled for PM 2.5

in Relation to the Wylam PM 2.5 Monitor

............................................................................................................................... .....2-4 Figure 2.2.1-1 Number of Days > 35μg/m3 by Quarter for 2007 – 2009 .......................................2-7 Figure 2.2.1-2 PM 2.5

24hr > 35μg/m 3 vs. # of Days >= 90oF 2003-2009 .......................................2-8 Figure 2.2.1-3 PM 2.5

24hr > 35μg/m 3 vs. # of Days with Rain >=0.05” 2003-2009 ......................2-9 Figure 2.2.1-4 PM2.5 24hr>35μg/m3 vs. # of Days with Rain >=0.05” 2000-2009 ....................2-10 Figure 2.2.1-5 Number of Days > 35μg/m 3 vs. May-Sept Rainfall Totals ..................................2-11 Figure 4.3.1-1 Locations of Po wer Plants in Relation to the Birmingham 24-Hour PM 2.5 Nonattainment Area .......................................................................................................................4-12


### APPENDICES

PM 2.5

Monitor Locations............................................................................................................. .......... A AIRS AQS Report ................................................................................................................ .................B

Mobile Source P recursor Discu ssion............................................................................................. .......C

Emissions Documentatio n and Projections ........................................................................................ .D MOVES Modeling to Demons trate Mainte nance ................................................................................E

Point Source Closu re Documentation ............................................................................................. ..... F

### v 

## Executive Summary

This document contains Alabama's demons tration under the federal Clean Air Act Amendments of 1990 that the Birmingham 24-hour PM 2.5 

### Nonattainment Area (NAA) should be redesignated from nonattainment to attainment with respect to the National Ambient Air Quality Standard (NAAQS) for 24-hour fine particle pollution. The Birmingham NAA consists of two full counties, Jefferson and Shelby Counties, and one partial county, Walker County. This request is based on three years, 2007 to 2009, of ambient monitoring data at all ten PM 2.5 

### monitors in the Birmingham NAA showing no violation of the 24-hour PM 2.5 

### standard, the implementation of permanent and enforceable reductions in PM 2.5 

### and precursor emissions, compliance with Section 110 and Part D requirements of the Clean Air Act, and the Birmingham Mainte nance Plan with projections demonstrating that the 2009 emission levels in this area w ill not be exceeded through at least the year 2024.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

1-1 

## 1.0 Introduction

1.1 Purpose

This document contains the technical su pport necessary for the Alabama Department of Environmental Management's (ADEM) request that the Birmingham 24-hour PM 2.5 

### NAA be redesignated as an area attaining the 24-hour PM 2.5 

### NAAQS pursuant to §§107(d)(3)(D) and (E) of the Clean Air Act, as amended.



### 1.2 Historic Background
On October 8, 2009, the EPA designated Jeffe rson and Shelby Counties and a portion of Walker County as nonattainment for the 24-hour PM 2.5 

### standard. The official designations and classifications were printe d in the Federal Register on November 13, 2009 (74 FR 58688). This designation became effective on December 14, 2009.



### 1.3 Formation of PM 2.5 

### PM2.5, also known as particle pollution or fine particulate, is a complex mixture of extremely small particles and liquid droplets. Particle pollution is made up of a number of components, including nitrates and sulfates, organic chemicals, metals, and soil or dust particles. Fine particles, such as those found in smoke and haze, are 2.5 micrometers in diameter and smaller. Thes e particles can be directly emitted from sources such as forest fires, or they can form when gases emitted from power plants, industries and automobiles react in the air. The chemical makeup of PM 2.5 

### in Birmingham is similar to that of similar sites across the Southeast. PM 2.5 

### measurements are separated into several components: ammonium sulfate ((NH 4 

### ) 2 

### SO 4 

### ), ammonium nitrate (NH 4 

### NO 3 

### ), organic carbon mass (OC), elemental carbon (EC) and crustal materials, as well as a factor to correct for particles on the filter, characterized as passive mass. NH 4 

### NO 3 

### and (NH 4 

### ) 2 

### SO 4 

### are secondary pollutants formed in the atmosp here from primary emissions of sulfur dioxide (SO 2 

### ), nitrogen oxides (NO X 

### ) and ammonia (NH 3 

### ). OC is a mixture of primary carbon, predominantly from fuel combus tion and biomass burning, and secondary carbon, predominantly from biogenic emissi ons. EC and crustal components (fine soil & metals) are primary pollutants emitted directly into the atmosphere. OC and (NH 4 

### ) 2 

### SO 4 

### are the dominant contributors to PM 2.5 

### mass in the Birmingham area. SO 2 

### emissions, primarily from utility and industrial point sources, are the primary contributors to SO 4 

### . SO 4 

### mass is highest in the summer months, in part due to higher SO 2 

### emissions in the summer months and in part due to more active secondary photochemical formation under the higher temperatures, relative humidity, and oxidant loading of the summer months.



### 1.4 Criteria for Redesignation
Section 107(d) of the federal Clean Air Act, as amended in 1990, states that an area can be redesignated to attainment if the following conditions are met:

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

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

1-2 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 reductions in emissions.

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

5. The EPA has fully approved a maintenance plan, including a contingency plan, for the area under Section 175A. The first and third of these requirements re late directly to air quality and the reasons for its improvement. These requirements are discussed together in Section 2 of this document. The second and fourth requirements relate to the implementation plan. The plan has been approved and all requirements under §110 and Part D of the Act have been met. These requirements are discussed in Section 3. The maintenance plan has two required components. First, the state must submit a revision to the state implementation plan (SIP), which provides for maintenance of the NAAQS in the area for at least ten years af ter the redesignation. EPA has up to 18 months after submittal of the redesignatio n request to approve or disapprove it. Therefore, EPA is required to make its deci sion by 2011 since this document is being submitted in mid-2010. Thus, the State must demonstrate that Birmingham will maintain the standard through at least 2021 [2011 + 10 = 2021]. Our plan goes out to 2024. Also, the plan revision must incorporate a contingency plan outlining commitments by the state to promptly correct any future violations. The maintenance demonstration and contingency plan are discussed in Section 4.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

2-1 

## 2.0 Attainment Demonstration

This section will focus on the first and third criteria discussed earlier in Section 1.3. Criterion 1. The EPA has determined that the NAAQS has been attained. Criterion 3. The improvement in air qua lity is due to permanent and enforceable reductions.



### 2.1 Demonstration that the NAAQS Has Been Attained

2.1.1 Overview Compliance with the NAAQS for 24-hour PM 2.5 

### is met if the 98 th 

### percentile of 24-hour PM 2.5 

### concentrations in a year, averaged over th ree years, is less than or equal to the level of the standard of 35 μ g/m 3 

### . The resulting concentration represents a 24-hour PM 2.5 

### design value. A violation of the 24-hour PM 2.5 

### NAAQS occurs when the design value exceeds 35 μ g/m 3 

### at any monitor. In other words, a design value higher than 35
μ g/m 3 

### at any monitor will constitute a violation of the 24-hour PM 2.5 

### NAAQS and could result in the area being designated nonattainment for the 24-hour PM 2.5 

### standard. The most recent three years of 24-hour PM 2.5 

### monitoring data (2007-2009) for the Birmingham NAA demonstrate compliance with the NAAQS for 24-hour PM 2.5, 

### as will be illustrated in the next section.

2.1.2 PM 2.5 

### Monitoring Network There are presently ten PM 2.5 

### monitoring stations in the Birmingham NAA installed in accordance with 40 CFR 58, which provide adequate coverage of the entire nonattainment area and have been representative of the area of highest concentrations [see Appendix A, Map of the PM 2.5 

### Monitoring Sites]. All monitors remained at their original locations during the period 2007-2009. Table 2.1.2-1 is a summary of the 98 th 

### percentiles of the 24-hour PM 2.5 

### concentrations for each year for each monitor and the 3-year average.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

2-2 Table 2.1.2-1 Summary of 98th Percentiles of the 24-hour PM2.5 Concentrations



### Monitor County 2007 2008 2009 3-Year Average

Corner Jefferson 32.5 30.0 21.3 28

Hoover Jefferson 29.8 25.9 20.4 25

Leeds Jefferson 33.0 24.6 19.1 26
McAdory Jefferson 30.9 25.8 21.3 26

Pinson Jefferson 34.2 26.4 21.3 27

Providence Jefferson 31.4 27.3 22.1 27
N. Birmingham Jefferson 42.8 33.5 24.4 34
Wylam Jefferson 37.7 33.5 25.2 32
Walker County Walker 30.9 24.3 22.1 26

Pelham Shelby 30.9 24.8 21.2 26

2.1.3 Ambient PM 2.5 

### Monitoring Data

All of the PM 2.5 

### ambient monitoring data that was collected during 2007, 2008, and 2009 was collected in accordance with 40 CFR 58 and has been stored in EPA's Aerometric Information Retrieval System (AIRS) Air Quality System (AQS). This process was completed in February, 2010. A copy of an AIRS printout showing the maximum PM 2.5 

### concentrations at these monitors for these years is included in Appendix B.

.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

2-3 

### 2.2 Permanent and Enforceable Reductions in Emissions
Since 2000, there have been several major federal and local programs enacted that have led to significant actual, enforceable PM 2.5 

### and PM 2.5 

### precursor emission reductions. The improvement in air quality that has resulted in attainment of the 24- hour PM 2.5 

### NAAQS can be reasonably attributed to these emissions reductions. These programs were established to provide reducti ons in emissions from the mobile source and industrial sectors. These programs are listed below:

1. Federal Tier II Motor Vehicle Emissions Standards

2. Federal On-road Diesel Engine Standards

3. Federal Non-road Diesel Engine Standards

4. Federal Marine Engine Requirements

5. Federal Locomotive Requirements

6. The Federal New Source Performance St andards under Section 111 (42 U.S.C 7411)

7. The Federal National Emission Stand ards for Hazardous Air Pollutants (NESHAP) under Section 112 (42 U.S.C. 7412)

8. The Federal NOx SIP Call

9. The Federal Clean Air Interstate Rule (CAIR) 1



### 10. Local NOx controls on some NAA ceme nt plants required by 8-Hour Ozone Contingency Plan

11. Local PM controls at Birmingham facilities associated with the Birmingham annual PM 2.5 

### SIP have provided reductions of ~62 tpy as of the end of 2009 (See Table 2.2-1 below) An extensive analysis of monitoring data in the Birmingham area was conducted as part of the local area analysis (the Enva ir Study), which investigated source contributions to elevated PM 2.5 

### concentrations at the North Birmingham (NBHM) and Wylam (WYL) monitors. A comparison of the PM 2.5 

### mass for across the Birmingham NAA provides a basis to estimate a regio nal background contribution, a general urban contribution and an incremental contributio n from local sources in the immediate vicinity of the NBHM and WYL sites. Thes e monitors collectively suggest a regional contribution of 12-14 μg/m 3 

### , an urban contribution of roughly 2 μg/m 3 

### , and a local contribution for NBHM of 2-3 μg/m 3 

### and for WYL of ~2 μg/m 3 

### . Therefore, decreases in emissions of direct PM 2.5 

### constituents, such as those detailed in the table below, have and will directly impact PM 2.5 

### concentrations.

1 On December 23, 2008, the United States Court of Appeals for the District of Columbia Circuit remanded CAIR to EPA, without vacatur, directing the Agency to remedy the rule’s flaws in accordance with the Court’s July 11, 2008, opinion in th e case of North Carolina v. EPA, 531 F. 3d 896, 901 (D.C. Cir. 2008). When EPA responds to the Court’s re mand, the request may need to be re vised to be consistent with the Agency’s new final action.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

Figure 2.2-1 Locations of Local Sources Being Controlled for PM 2.5 in Relation to the North Birmingham PM 2.5 Monitor

Figure 2.2-2 Locations of Local Sources Being Controlled for PM 2.5 in Relation to the Wylam PM 2.5 Monitor



### 2-4

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

2-5 Table 2.2-1 Summary of RACT Controls

Facility Source RACT Controls PM 2.5 RACT Reduct (TPY) RACT Date

Crucible furnaces Install baghouse 3.891 4Q2009 W.J. Bullock 2 Facility totals 3.891 Charge handling area Wet suppression 0.385 2008 McWane Pipe Facility totals 0.385 Coal piles Wet suppression 0.398 4Q2008 Sloss MW 3 and Sloss Coke Facility totals 0.398 Charge make-up Wet suppression 11.91 4Q2008 Roads & process areas Paving 3.58 2007/2008

Cupola melting furnace New cupola/BH & spray suppression 5.84 2007/2008 Sand & cement storage silos Baghouse 0.09 2008 ACIPCO

Facility totals 21.42

Meltshop fugitives Route to BH, other physical improvements 28.1 4Q2008 Nucor Steel Facility totals 28.1 Cupola charge makeup Wet suppression 1.818 4Q2008 Sand/cement silos Install bin vents 5.93 4Q2008 U.S. Pipe 4 Facility totals 7.748
TOTAL 61.942



### 12. Local NO X 

### and SO 2 

### controls at utilities around the Birmingham area have provided reductions of ~18,761 tpy of NO X 

### and ~33,769 tpy of SO 2 

### as of the end of 2009 (See Table 2.2-2).

2 W.J. Bullock ceased all operations as of October 2009, resulting in a 0.1263 ton reduction.

3 Sloss Mineral Wool announced its closure in December 2009, resulting in a 130 ton reduction.

4 U.S. Pipe ceased production on March 31, 2010, resulting in a 46 ton reduction.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

2-6 Table 2.2-2 Summary of Utility Controls

Date Control

Installed Projected Reductions (TPY) Facility
NOX SO2 NOX SO2 APCo Miller Unit 3 2008 1,726 APCo Miller Unit 4 2008 1,800 APCo Gorgas Unit 8 Dec-2007 5,387 APCo Gorgas Unit 9 Dec-2007 4,493 APCo Gorgas Unit 10 Dec-2007 23,889 Total Reductions 3,526 33,769

• 

### Installation of FGD on Units 8 – 10 at Alabama Power’s Gorgas Plant in 2007. The FGD was added in anticipation of CAIR.

• 

### Installation of SCR on Units 3 & 4 at Alabama Power’s Miller Plant in 2003 with a Consent Decree requiring year ro und operation beginning in 2008. SCRs were added as a result of the NO X 

### SIP Call. Year-round operation of all SCRs was planned in anticipation of the annual NO X 

### CAIR rule. The consent decree further required year-round operation of the SCRs on Units 3 and 4. The consent decree requirements have been inco rporated into the facility’s Title V permit and are enforceable.

2.2.1 Meteorological Analysis

The purpose of this section is to comple ment Section 2.2, which states that the improvement in air quality that has resulted in attainment of the 24-hour PM 2.5 

### NAAQS can be reasonably attributed to permanent and enforceable emissions reductions. The analyses presented in this section will show that there is both an emissions reduction and meteorological sig nal in the air quality and meteorological data. In evaluating the relationship between elevated PM 2.5 

### concentrations and meteorology, a focus on the meteorological variables associated with the bulk of the elevated concentrations was needed. The warm weathe r months of the year (May - September) were where this meteorological analysis prim arily focused. Figure 2.2.1-1 below helps inform this decision. As can be seen, the greatest number of high PM 2.5 

### days over the three year period across Alabama and the Sout heast in general are found in the third quarter (summer). Therefore, this analysis is intended to evaluate the relationship between weather and elevated PM 2.5 

### during this time period.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

Number of Days >35ug/m3 by Quarter for 2007-2009

0 2 4 6 8 10 12 14 16 18

Q1 Q2 Q3 Q4
QuarterNumber of Days >35ug/m3

Exceedence Days

Figure 2.2.1-1 Number of Days > 35μg/m3 by Quarter for 2007 – 2009



### The analysis below shows the relationship between high PM 2.5 

### concentrations and weather conditions. The two meteorological variables that show the best relationship are temperature and precipitation. This analysis also shows that, after analyzing the different variables, lower emissions are likely contributing to lower PM 2.5 

### concentrations. As stated above, PM 2.5 

### concentrations are usually higher on days with high temperatures, especially during the summer mo nths. In Figure 2.2.1-2, this pattern can be seen in the years 2003-2005 when looking at the total number of days with a high temperature equal to or above 90oF and the total numbers of days in which the 24- hour PM 2.5 

### concentration was greater than 35 μg/m 3 

### . Both the number of days with high temperatures greater than or equal to 90oF and the number of days with PM 2.5 

### concentrations greater than 35 ug/m3 showed an increase during this period. However, from 2006-2007, the number of days with a high temperature equal to or above 90oF increased sharply, while the number of days with a 24-hour PM 2.5 

### concentration greater than 35 μg/m 3 

### decreased. This indicates that lower emissions may have led to lower PM 2.5 

### concentrations. A sharper decline in PM 2.5 

### concentrations can be seen between 2008-2009, along with a decrease in the number of days with a high at or above 90oF. Both weather conditions and emission reducti ons likely led to this sharper decline.

2-7

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

PM2.5 24hr > 35 ug/m3 vs. # of Days>=90F 2003-2009

0 10 20 30 40 50 60 70 80 90 100

2003 2004 2005 2006 2007 2008 2009

YearNumber of Days >=90F

0 5 10 15 20 25 30 35 40 45Number of Days > 35 ug/m3

# of Days >=90F > 35 ug/m3

Figure 2.2.1-2 PM 2.5 24hr > 35μg/m 3 vs. # of Days >= 90oF 2003-2009



### The same general pattern can be seen when looking at precipitation amounts. Figure 2.2.1-3 shows the number of days with rainfall amounts greater than or equal to 0.05 inches compared to the number of days in which the PM 2.5 

### 24-hour concentration was greater than 35 μg/m 3 

### from 2003-2009. In general, PM 2.5 

### concentrations are higher when rainfall amounts are lower. However, looking at Figure 2.2.1-3, from 2005-2007, both the number of days with rainfall amounts greater than or equal to 0.05 inches and PM 2.5 

### concentrations showed a general decrease. This also indicates that lower emissions may have led to lower PM 2.5 

### concentrations.

2-8

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

PM2.5 24hr > 35 ug/m3 vs. # of Days with Rain >=0.05" 2003-2009

0 20 40 60 80 100 120

2003 2004 2005 2006 2007 2008 2009

Year# of days with rain >=0.05"

0 5 10 15 20 25 30 35 40 45# of days > 35 ug/m3

# of Days it Rain >= 0.05 > 35 ug/m3

Figure 2.2.1-3 PM 2.5 24hr > 35μg/m 3 vs. # of Days with Rain >=0.05” 2003-2009



### A sharper decline in PM 2.5 

### concentration can be seen from 2008-2009 when the number of days with precipitation greater than or equal to 0.05 inches increased. Both weather conditions and emission reductions likely le d to this sharper decline. To better separate the weather’s influence from the influence of emission reduction on PM 2.5 

### , trend lines were added to the graph above as can be seen below. As shown, the trend line for rainfall has little to no slope, while the PM 2.5 

### trend line slopes steadily downward. This demonstrates that wh ile rainfall clearly has an impact on PM 2.5 

### , the decline in concentrations can be attributed to both a decrease in emissions and weather.

2-9

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

PM2.5 24hr > 35 ug/m3 vs. # of Days with Rain >=0.05" 2000-2009

0 20 40 60 80 100 120

2003 2004 2005 2006 2007 2008 2009

Year# of days with rain >=0.05"

0 5 10 15 20 25 30 35 40 45# of days > 35 ug/m3

# of Days it Rain >= 0.05 > 35 ug/m3 Rainfall Trend PM2.5 Trend

Figure 2.2.1-4 PM2.5 24hr>35μg/m3 vs. # of Days with Rain >=0.05” 2000-2009



### To further illustrate an emission reduction si gnal, Figure 2.2.4-5 shows that during the typically higher PM 2.5 

### months of May-September, from 2005-2007 the number of high PM 2.5 

### days continued to decrease even th ough the May-September precipitation amounts decreased. A sharper decrease in high PM 2.5 

### days can be seen from 2008- 2009, when precipitation amounts increased. This also indicates that both weather conditions and emission reductions likely led to the sharper decline in high PM 2.5 

### days in 2008-2009.

2-10

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

Number of Days >35ug/m3 vs. May-Sept Rainfall Totals

0 5 10 15 20 25 30 35 40 45 50

2003 2004 2005 2006 2007 2008 2009

YearRainfall May-Sept (in)

0 5 10 15 20 25 30 35 40 45Number of Days > 35 ug/m3

May -Sept Precip > 35 ug/m3
Figure 2.2.1-5 Number of Days > 35μg/m 3 vs. May-Sept Rainfall Totals 

### With respect to the meteorology associat ed with the 2007 – 2009 time period, the following should be noted:

• The graphs above include trend lines wh ich provide valuable information about emissions reductions that have occurred over the last few years.

 First, 2007 was an extremely hot and dry year. Most of the state experienced severe drought conditions, yet the moni tored concentrations decreased from the previous years. This would be contra ry to what would be expected and is a strong indication that emissions reducti ons likely played a role in the lower monitor values.

 Similarly, beginning in middle 2008 to 2009, milder and wetter conditions occurred than were previously experience d, and while monitor values decreased, the trend line relative to the monitor values show an even larger signal than would be expected (i.e. especially rela tive to the wetter years of 2003-2004). Again, this a strong indication of an emissions signal. Meteorology will always play a role in attainment demonstrations and redesignation requests. The responsibility of the State or local agency is to reasonably demonstrate that regardless of that role, that an area is achieving improved air quality through permanent and enforceable emissions reductions. The State of Alabama believes that this request documents these reductions.

2-11

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

3-1 

## 3.0 Fully Approved SIP, Section 110 and Part D Requirements
Criterion 2: The applicable implementation plan has been fully approved by the EPA under Section 110(k). Criterion 4: The State has met all applic able requirements under Section 110 and Part D.



### 3.1 Section 110 Implementation Plans
Alabama’s CAIR SIP was fully approved by EPA on October 1, 2007 (72 FR 55659), and become effective on October 31, 2007. The annual PM2.5 attainment demonstration was submitted by ADEM to EPA in May 2009. Thus, Criterion 2 has been met. The general elements required in a SIP are listed in §110(a). These elements include procedures for air quality monitoring and mo deling; criteria for establishing stationary source controls, monitoring and reporting; implementation of permitting programs under Part C (Prevention of Significant Dete rioration or PSD) and Part D (New Source Review or NSR); and provisions for public involvement. Alabama has a fully approved SIP under the authority of §110. On Sept ember 23, 2009, ADEM submitted a letter to EPA certifying that Alabama’s existing SIP m eets all Section 110(a)(2) provisions of the Clean Air Act that address the requirement s for the 2006 particulate matter NAAQS. This, in addition to the discussion in Section 3.2, meets Criterion 4.



### 3.2 Part D Plan Requirements for Nonattainment Areas

3.2.1 Nonattainment Areas in General Section 172(c) – In May of 2009, ADEM submitted to EPA the “Attainment Demonstration for the Birmingham, Alabama, Annual PM 2.5 

### Nonattainment Area”. This plan demonstrates attainment of the annual PM 2.5 

### NAAQS beginning in 2012 based on implementation of a combination of federal measures including CAIR, other regional controls, mobile source controls and local controls on industrial sources of direct PM 2.5 

### . Thus, ADEM has met the requirement of Section 172(c). Section 176(c) - The concept of transportation conformity was introduced in the Clean Air Act of 1977, but the requirements became substantially more rigorous in the Amendments of 1990. The CAA and the Safe, Accountable, Flexible, Efficient Transportation Equity Act – A Legacy for Users (SAFETEA-LU) define the framework for effective integration of trans portation and air quality planning. Transportation conformity is a process by which it is determined that on-road mobile (highway) source emissions evaluated from the Transportation Improvement Program (TIP) and/or Long Range Transportation Pl an (LRTP) will not adversely impact air quality in a determined area of nonattainment. Federal funding and approval are given to transportation activities that are consistent with air quality goals. The State has developed a SIP for the purpos es of addressing conformity. This SIP delineates the interagency consultative process between the Metropolitan Planning Organization (MPO), the Environmental Protection Agency (EPA), the Federal Highway Administration (FHWA), the Federal Transit Authority (FTA), State and local

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

3-2 transportation and air quality agencies, as well as, the public participation process for stakeholders and citizens in the Birmingham NAA. The Alabama Conformity SIP under the PM 2.5 

### NAAQS was approved on March 26, 2009 (74 FR 13170), with an effective date of May 26, 2009.

This SIP revision will establish a MVEB for NO X 

### and primary PM 2.5 

### for the year 2024.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-1 

## 4.0 Maintenance Plan

4.1 Overview
Criterion 5. The EPA has fully approved a maintenance plan, including a contingency plan, for the area under §175A. Section 175A of the Clean Air Act Amendments of 1990 defines the general framework of a maintenance plan. The core provisions include the attainment inventory, the maintenance demonstration, the verificati on of continued attainment, and the contingency plan.



### 4.2 Attainment Inventory

4.2.1 Overview

Monitored attainment of the 24-hour PM 2.5 

### standard was achieved for the 2007 - 2009 three-year period. The most recent comp rehensive periodic (triennial) emissions inventory for the Birmingham NAA was compiled for 2005 pursuant to §182(a)(3)(A). According to federal requirements, the next triennial inventory for 2008 is expected for submission to EPA no later than June 2010. According to the September 4, 1992, EPA gu idance document entitled, "Procedures for Processing Requests to Redesignate Area s to Attainment", the base attainment inventory should be consistent with EP A's most recent guidance on emission inventories and should represent the emissions during the time period associated with the monitoring data showing attainment. For purposes of demonstrating maintenance of the standard, 2009 is the attainment year, representing the monitoring period of 2007 - 2009 The inventory years were generally chosen as 2009 (the attainment year), with interim years set as 2012, 2015, 2018, 2021 and 2024, which is the end of the first 10-year maintenance period. VISTAS/ASIP developed emissions inventories for regional haze, 8-hr ozone and annual PM2.5 attainment demonstrations for the years 2009, 2012 and 2018. These inventories were used to deve lop point, area and off-model non-road inventories for 2015, 2021 and 2024. Version 3 of the 2002 NEI and the development of the 2008 NEI were applied to determine reaso nableness in the area source inventory. Non-road mobile and on-road mobile source emissions were calculated for 2009-2024 based on EPA-approved models. Necessary ca lculations for the projections were made using Microsoft Excel © 

### software. The following section describes how growth factors for each emission category were obtained and used. The documentation for emissions inventory development and growth is included in Appendix D.

4.2.2 Point Sources Major point sources are defined as stationar y sources that emit greater than 100 tons per year (TPY) of a criteria pollutant. The source emissions are calculated from data

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-2 collected annually from the sources. VISTAS/ASIP 5 

### used actual annual 2002 emissions data for point sources to calculate point source emissions for 2009, 2012 and 2018. All point source emissions information, with the exception of Jefferson County, is stored in ADEM's Microsoft Access© database. The po int source data for Jefferson County is obtained from the Jefferson County Departme nt of Health’s Air Program. Actual 2008 point source data was used to establish any shutdowns or new sources that were not accounted for in the VISTAS/ASIP inventor ies. Actual 2009 data was used where available. The emissions were grown for 2012 (where actual 2009 emissions were available), 2015, 2018 (where actual 2009 emissions were available), 2021 and 2024 using EGAS 5.0 and compared against unit/facility allowable limits to prevent overgrowth. Utilities with installed controls were kept steady rather than applying growth factors. The downward trend in point source PM 2.5 

### emissions is due to both the implementation of RACT controls on local Birmingham source s and the closing of three facilities: Sloss Industries Corporation – Mineral Wool, W.J. Bullock Incorporated, and U.S. Pipe and Foundry Company, LLC – North Birmingham 6 

### . Point source SO 2 

### emissions are projected to drop significantly from 2009 to 20 12 due to installed controls on utilities as a result of CAIR 7 

### . These controls are listed in Table 4.3.3-1. For conservatism due to the uncertain status of CAIR, no additional reductions in SO 2 

### or NO x 

### emissions from utilities were assumed to occur beyond 2012. Appendix D provides information on how emi ssions were projected for point sources. Each county total is listed in summary Tables 4.3-1 through 4.3-3 under point sources.

4.2.3 Area Sources

Area sources can be defined as those sources and activities that are too small or too numerous to be handled individually in a point source inventory. Cutoff levels are those levels below the point source level di scussed above. For area source emission projections, emission growth factors were derived from EGAS, BEA factors and EPA projections. The application of these growth factors for each projection was then used for area sources. Appendix D provides info rmation on how emissions were projected for area sources. Each county total is listed in summary Tables 4.3-1 through 4.3-3 under

area sources.

5 The BAPS inventory was used in conjunction with the VISTAS/ASIP inventory for the Jefferson County point source base and future year inventories.

6 The closings resulted in a reduction of ~177 tons of PM2.5. For further information concerning these facility closures, please see Appendix F.

7 On December 23, 2008, the United States Court of A ppeals for the District of Columbia Circuit remanded CAIR to EPA, without vacatur, directing the Agency to remedy the rule’s flaws in accordance with the Court’s July 11, 2008, opinion in th e case of North Carolina v. EPA, 531 F. 3d 896, 901 (D.C. Cir. 2008). When EPA responds to the Court’s re mand, the request may need to be re vised to be consistent with the Agency’s new final action.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-3 4.2.4 On-road Mobile Sources

4.2.4.1 Mobile Source Attainment Budget On-road mobile sources are vehicles that travel on local roads, state highways and interstates. Currently, no motor ve hicle emissions budget (MVEB) has been established for 24-hour PM 2.5 

### for this area. Conformity is determined by a “No Greater Than Baseline” test. However, pursuant to 40 CFR 93.118(b)(2)(i) of the conformity regulations, a new MVEB is proposed for the year 2024. The 2024 MVEB is to be used for required analysis years of 2024 and beyond . The “No Greater Than Baseline” test will remain in effect and will be used for any required analysis years prior to 2024. A discussion follows in Section 4.2.4.3.

4.2.4.2 Projected Mobile Source Emissions Methodology

The MOVES2010 mobile source emissions model was utilized to estimate emissions for Alabama’s 24-Hour PM 2.5 

### redesignation request for Jefferson and Shelby Counties and a portion of Walker County. A total of ni ne runspecs were established representing 2009, 2015 and 2024. Each county had one runs pec per year. Data for 2012, 2018 and 2021 was not modeled; however, emissions fo r these years were interpolated. All runspecs were set to the county scale and inventory was chosen as the calculation type. In the time span section, the aggregation leve l was set to hour, along with the selection of all months, all days and all hours. In the geographic bounds section, the state and appropriate county were selected for each run. All relevant gasoline and diesel vehicles were chosen, as well as, all road types. The pollutants of concern were NO x 

### , PM 2.5 

### and SO 2 

### . For those pollutants where the emissions calculation is based on prior calc ulation of another pollutant, the appropriate base pollutants were also selected. “Tons” was selected as the emissions unit and the emissions detail was aggregated to “day” in or der to retrieve data in tons/day. Input data was then imported through the County Data Manager (CDM). MOVES2010 default data was exported, revi ewed and re-imported for the following CDM inputs: Age Distribution, Average Spee d Distribution, Fuel Supply, Meteorology and Ramp Fraction. Source Type Popula tion, Vehicle Type VMT and Road Type Distribution were derived from either an a dditional MOVES run, manual calculation or by using one of the converters provided by EPA. For Fuel Formulation, RVP adjustments were made for May-September, with the default RVP being used for all other months. The Reid Vapor Pressure (RVP) for gasoline sold in Jefferson and Shelby Counties will assume an RVP of 7.8 du ring summer months in all future year inventory projections for the years 2012, 2015, 2018, 2021 and 2024, in the maintenance demonstration. The SIP requires a lower RVP as a control during summer months, and it is not being removed from the SIP at this time. The maintenance plan is not considering the reductions gained from using the SIP RVP limit in the future year projections because the state is consider ing rescinding the SIP RVP limit at a later date. The maximum federal limit for summertime RVP in specified ozone nonattainment/maintenance areas is 7.8 psi. The vehicle miles traveled (VMT) used in MOVES was determined by the network modeling process conducted by the Regional Planning Commission of Greater Birmingham (RPCGB) and Alabama Department of Transportation (ALDOT).

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-4 TranPlan , the transportation model currently utilized by RPCGB and ALDOT, is a travel demand model used to forecast travel demands along a defined transportation network. In developing the TranPlan model run, RPCGB used the latest planning assumptions available. 2000 Census data were used for population, employment and journey to work estimates. The RPCGB gr ew 2005 data that had been obtained from ALDOT to provide 2009, 2015, 2017 and 2025 VMT data. The 2024 VMT data was then interpolated from the data provided by the RPCGB. This VMT data was used to make the appropriate calculations. The process of data collection and emissi ons modeling was conducted in accordance with the Technical Guidance on the Use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity. The methodology and data used were agreed up on through interagency consultation. The VMT from the TranPlan output files and the MOVES documentation are found in Appendix E. The Birmingham area mobile source emissions totals are listed in summary Tables 4.3- 1 through 4.3-3 under mobile sources.

4.2.4.3 Mobile Source Maintenance Budget In accordance with the Transportation Conformity Rule, this maintenance plan establishes a MVEB for the last year of the maintenance plan (2024). This MVEB will be in effect for required analys is years for the year 2024 and beyond. As stated in Section 4.2.4.1, the current method for determining conformity is the “No Greater Than Baseline” test. This maintenance plan will establish a 2024 MVEB for NO X 

### and primary PM 2.5 

### . In the Birmingham, Alabama, annual PM2.5 SIP submitted in May 2009, ADEM determined that SO 2 

### emitted by the mobile source sector is insignificant. EPA in its Federal Register notice for PM 2.5 

### does not address the mobile sector in its listing of significant sources of SO 2 

### emissions. Since the mobile source SO 2 

### contribution is insignificant, ADEM is not establishing MVEBs for this precursor. A discussion of precursor significance is located in Appendix C. This maintenance plan establishes an attainment inventory for the year 2009. This attainment inventory identifies the level of emissions in the area which is sufficient to attain the 24-hour PM 2.5 

### NAAQS. Maintenance of the 24-hour PM 2.5 

### NAAQS is demonstrated by showing that future emissions of direct PM 2.5 

### , SO 2 

### and NO X 

### will not exceed the level of the attainment inventory. Direct PM 2.5 

### , SO 2 

### and NO X 

### emissions from on-road mobile sources were proje cted for the year 2024 using the methodology discussed in Section 4.2.4.2. Direct PM 2.5 

### , SO 2 

### and NO X 

### emissions were also projected for the year 2024 for point, area and non-road mobile sources as described in Sections 4.2.2, 4.2.3, and 4.2.5, respectively. These projections are shown in Tables 4.3-1 through 4.3-3. As can be seen in Tables 4.3-1 through 4.3-3, total emissions of direct PM 2.5 

### , SO 2 

### and NO X 

### are projected to decrease from the attainment year (2009) through the year 2024. Specifically, PM 2.5 

### emissions are projected to decrease by 0.58 tons/day and NO X 

### emissions are projected to decrease by 76.32 tons/day. These projected decreases in emissions from the attainment year through 2024 are termed the “safety margin”. In establishing a MVEB for the last year of the maintenance plan (2024 in

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-5 this case), all or a portion of the safety margin may be allocated to the on-road MVEB. An interagency consultation meeting was held on April 19, 2010 to discuss this issue. As a result of the interagency consultation meeting on April 19, 2010, this maintenance plan establishes the MVEB at 0.7850 tons/day for PM 2.5 

### and 60.48 tons/day for NO X



### . This MVEB will be in effect for any re quired analysis years for the year 2024 and beyond. The MVEB for PM 2.5 

### will be the projected 2024 emissions for on-road mobile sources in addition to approximately 25 percent of the safety margin for PM 2.5 

### . The MVEB for NO X 

### will be the projected 2024 emissions for on-road mobile sources in addition to approximately 25 perce nt of the safety margin for NO X 

### . The Birmingham area emissions and safety margins are listed in Tables 4.3-1 and 4.3-3. The calculations below show how the MVEB was determined for the year 2024 and beyond.

On-Road Mobile PM 2.5 

### Emissions for 2024 (0.64 TPD) + approximately 25% of PM 2.5 

### Safety Margin (0.1450 TPD) = 2024 PM 2.5 

### MVEB (0.7850 TPD)

On-Road Mobile NO X 

### Emissions for 2024 (41.4 TPD) + approximately 25% of NO X 

### Safety Margin (19.08 TPD) = 2024 NO X 

### MVEB (60.48 TPD)

4.2.5 Non-road Mobile Sources

Non-road mobile sources are mobile sources that do not travel on local roads, state highways and interstates. Non-road mobile so urce emissions result from the use of fuel in a diverse collection of vehicles and equipment:

 agricultural equipment, such as tractors;

 aircraft, such as jets and prop planes;

 airport ground-support equipment, such as terminal tractors;

 commercial equipment, such as gene rators, air compressors, and pressure washers;

 construction and mining equipment, such as graders and back hoes;

 industrial equipment, such as fork lifts and sweepers;

 lawn and garden equipment, such as lawn mowers and leaf and snow blowers;

 logging equipment, such as chain saws and shredders;

 marine vessels, such as power boats and oil tankers;

 railroad equipment, such as train engines; and

 recreational vehicles and watercrafts, such as all-terrain vehicles, off-road motorcycles, and boats. For non-road emission projections, EP A's NONROAD2008a Model was used. Normal average high, average low, and average daily temperatures were obtained from the National Weather Service for the Birmingham area. As discussed in Section 4.2.4.2, the gasoline Reid Vapor Pressure (RVP), for use in the NONROAD model, will assume an RVP of 7.8 psi in all future year inventory projections for the years 2012, 2015, 2018, 2021 and 2024 in this maintenance demonstration. At this time, the current non-road model does not calculate emission s for railroad, commercial marine vessel, and airport activity emissions. Emission growth factors were derived from EGAS for

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-6 railroad, commercial marine vessel, and airpo rt activity emissions. These factors were applied to the 2009, 2012 and 2018 VISTAS/ASIP inventories for railroad, commercial marine vessel, and airport activity emissions and subsequently grown for 2015, 2021, and 2024. The 2009 non-road and future year estimates can be found in Appendix D. Each county total is listed in summary Ta bles 4.3-1 through 4.3-3 under non-road

sources.



### 4.3 Maintenance Demonstration
The required maintenance plan must become a part of the SIP and provide for maintenance of the air quality in the affected area for at least 10 years after designation. Specifically, the Clean Air Act requirement is that a maintenance plan that is at least 10 years in length (i.e., after EPA’s expected approval) be submitted with the redesignation request. Subse quently, 8 years after redesignation and submittal of the initial maintenance plan, the State is required to submit an additional maintenance plan that shows maintenance for the remainder of the 20 year period. Alabama has chosen 2024 as the end year of the initial maintenance plan for the Birmingham NAA. The general approach used for the maintenance plan to demonstrate that attainment of the 24-hour PM 2.5 

### standard will continue to be maintained is based upon restricting the future anthropogenic emissions to a level that is representative of attainment of the standard. If these future emissions are no greater than the actual emissions during a year in which attainment of the standard was monitored, then it can be assumed that attainment of the standard will also be achieved in future years. Tables 4.3-1 through 4.3-3 show a calculated safety margin for PM 2.5 

### , NO X 

### and SO 2 

### for each year in the maintenance plan.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-7 Table 4.3-1 Birmingham 24-Hour PM 2.5 Attainment Area Maintenance Plan PM 2.5 Emissions (Tons per Day)

County Source Category 2009 2012 2015 2018 2021 2024

Point 7.92 6.86 7.26 7.72 8.22 8.77

Area 8.73 8.55 8.67 8.80 8.92 9.05

Non-road 1.06 0.98 0.85 0.72 0.65 0.61

Mobile 1.7 1.33 0.96 0.81 0.67 0.52 Jefferson

Total 19.42 17.72 17.74 18.04 18.46 18.94

Point 2.85 2.44 2.57 2.71 2.79 2.88

Area 3.16 3.18 3.24 3.31 3.37 3.44

Non-road 0.53 0.50 0.46 0.42 0.40 0.39

Mobile 0.4 0.305 0.21 0.18 0.14 0.11 Shelby

Total 6.94 6.41 6.48 6.62 6.70 6.82

Point 0.45 0.45 0.45 0.45 0.45 0.45

Area 8 0.46 0.46 0.46 0.47 0.48 0.49

Non-road 0.02 0.01 0.01 0.01 0.01 0.01

Mobile 0.02 0.0145 0.009 0.01 0.01 0.005 Walker (partial county)

Total 0.94 0.93 0.93 0.94 0.95 0.96

Point 11.22 9.75 10.29 10.88 11.47 12.10

Area 12.35 12.18 12.37 12.57 12.78 12.98

Non-road 1.60 1.49 1.32 1.15 1.05 1.00

Mobile 2.12 1.65 1.18 1.00 0.82 0.64 Total for the Bham NAA

Total 27.29 25.07 25.16 25.60 26.12 26.71

Maintenance Plan Decrease from 2009 (PM 2.5 Safety Margin*) -2.22 -2.13 -1.69 -1.17 -0.58

*After assigning 0.1450 TPD of the PM 2.5 safety margin to the MVEB, the revised 2024 PM 2.5 safety margin will be 0.4350 TPD.

8 Area and nonroad emissions for Walker County were ca lculated for the entire county then apportioned to the partial area by population.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-8 Table 4.3-2 Birmingham 24-Hour PM 2.5 Attainment Area Maintenance Plan NO X Emissions (Tons per Day)

County Source Category 2009 2012 2015 2018 2021 2024

Point 40.27 39.68 40.52 41.41 42.41 43.47

Area 9.11 9.26 9.41 9.55 9.70 9.85

Non-road 20.56 18.55 16.44 14.71 14.58 14.79

Mobile 58.8 47.15 35.5 30.53 25.57 20.6 Jefferson

Total 128.74 114.64 101.86 96.20 92.26 88.71

Point 41.09 41.84 42.60 43.36 44.34 45.32

Area 1.97 2.00 2.03 2.05 2.08 2.11

Non-road 6.31 5.64 4.92 4.38 4.26 4.26

Mobile 58.8 47.15 35.5 30.53 25.57 20.6 Shelby

Total 108.17 96.63 85.05 80.32 76.25 72.29

Point 14.89 14.89 14.89 14.89 14.89 14.89

Area 0.15 0.16 0.16 0.16 0.16 0.16

Non-road 0.44 0.41 0.38 0.57 0.36 0.37

Mobile 0.55 0.44 0.33 0.29 0.24 0.2 Walker (partial county)

Total 16.03 15.90 15.76 15.91 15.65 15.62

Point 96.25 96.41 98.01 99.66 101.65 103.69

Area 11.24 11.42 11.59 11.77 11.94 12.12

Non-road 27.31 24.60 21.74 19.65 19.19 19.42

Mobile 118.15 94.74 71.33 61.35 51.38 41.40 Total for the Bham NAA

Total 252.95 227.17 202.67 192.43 184.16 176.63

Maintenance Plan Decrease from 2009 (NO X Safety Margin*) -25.78 -50.28 -60.52 -68.79 -76.32

*After assigning 19.08 TPD of the NO X safety margin to the MVEB, the revised 2024 NO X safety margin will be 57.24 TPD.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-9 Table 4.3-3 Birmingham 24-Hour PM 2.5 Attainment Area Maintenance Plan SO 2 Emissions (Tons per Day)

County Source Category 2009 2012 2015 2018 2021 2024

Point 188.21 32.67 32.92 33.22 33.66 34.15

Area 0.64 0.66 0.67 0.69 0.71 0.73

Non-road 0.34 0.13 0.12 0.12 0.13 0.13

Mobile 0.35 0.30 0.24 0.25 0.26 0.27 Jefferson

Total 189.54 33.75 33.95 34.28 34.76 35.28

Point 290.52 156.36 156.81 157.27 157.86 158.45

Area 0.13 0.13 0.14 0.14 0.14 0.15

Non-road 0.15 0.07 0.06 0.06 0.06 0.07

Mobile 0.08 0.07 0.05 0.05 0.06 0.06 Shelby

Total 290.88 156.63 157.06 157.52 158.12 158.73

Point 14.68 14.68 14.68 14.68 14.68 14.68

Area 0.30 0.30 0.31 0.31 0.31 0.31

Non-road 0.008 0.004 0.004 0.005 0.004 0.004

Mobile 0.003 0.06 0.002 0.11 0.21 0.32 Walker (partial county)

Total 14.99 15.04 15.00 15.11 15.20 15.31

Point 493.41 203.71 204.41 205.17 205.841 206.92

Area 1.06 1.09 1.11 1.14 1.16 1.19

Non-road 0.50 0.20 0.19 0.19 0.19 0.20

Mobile 0.43 0.42 0.29 0.41 0.53 0.65 Total for the Bham NAA

Total 495.40 205.42 206.00 206.91 206.20 207.28

Maintenance Plan Decrease from 2009 (SO 2 Safety Margin) -289.98 -289.40 -288.49 -289.20 -288.12

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-10 4.3.1 Plan to Maintain Air Quality

ADEM has implemented programs that will remain enforceable and are hereby submitted as the plan to ensure that maintenance of the 24-hour PM 2.5 

### standard will continue. Sources are prohibited from redu cing emission controls ('anti-backsliding') following the redesignation of the area unles s such a change is first approved by the EPA as a revision to the Alabama SIP that is consistent with Section 110(l) of the Clean Air Act. The following regulatory programs will re main for place in the Birmingham NAA:

• Federal Tier II Motor Vehicle Emissions Standards

• Federal On-road Diesel Engine Standards

• Federal Non-road Diesel Engine Standards

• Federal Marine Engine Requirements

• Federal Locomotive Requirements

• The Federal New Source Performance St andards under Section 111 (42 U.S.C. 7411)

• The Federal National Emissions Stand ards for Hazardous Air Pollutants (NESHAP) under Section 112 (42 U.S.C 7412)

• The Federal NO X 

### SIP Call

• The Federal Clean Air Interstate Rule (CAIR) 9



### • The Local Jefferson and Shelby County Burn Ban

• Local voluntary on and off-road diesel retro fit projects have been initiated in the nonattainment area. These projects utilize diesel emission control equipment as well as locomotive idle reduction equipm ent to lessen the particulate emissions from these engines. The reductions are not officially quantified and credit was not taken for these reductions.

• Installation of Selective Catalytic Reduction (SCR) and Low NO X 

### Burners (LNB) on Units 7 & 8 at TVA’s Widows Creek Pl ant in 2003/2004. Also, Unit 8’s Flue Gas Desulfurization (FGD) was upgraded in efficiency in 2004. LNB and SCR were added as a result of the NO X 

### SIP Call. As a result of the addition of SCR to Unit 5, the existing FGD on Unit 5 requi red a re-build, which, in turn, increased its SO 2 

### removal efficiency.

• Installation of LNB on Units 1-4 at TVA’s Colbert Plant in 2006 and SCR on Unit 5 in 2004. LNB and SCR were added as a result of the NO X 

### SIP Call.

9 On December 23, 2008, the United States Court of Appeals for the District of Columbia Circuit remanded CAIR to EPA, without vacatur, directing the Agency to remedy the rule’s flaws in accordance with the Court’s July 11, 2008, opinion in th e case of North Carolina v. EPA, 531 F. 3d 896, 901 (D.C. Cir. 2008). When EPA responds to the Court’s re mand, the request may need to be re vised to be consistent with the Agency’s new final action.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-11 • Installation of LNB on Units 6 & 7 at Alabama Power’s Gorgas Plant in 2003 and SCR on Unit 10 in 2002. Also, the installation of FGD on Units 8 – 10 in 2007. LNB and SCR were added as a result of the NO X 

### SIP Call. The FGD was added in anticipation of CAIR.

• Installation of SCR on Units 3 & 4 at Alabama Power’s Miller Plant in 2003 with a Consent Decree requiring year ro und operation beginning in 2008. Also, the installation of SCR on Units 1 & 2 in 2005. All 4 SCRs were added as a result of the NO X 

### SIP Call. Year-round operation of all SCRs was planned in anticipation of the annual NO x 

### CAIR rule. The consent decree further required year-round operation of the SCRs on Units 3 and 4. The consent decree requirements have been incorporated into the facility’s Title V permit and are enforceable.



### • Installation of SCR on Unit 5 at Alabama Power’s Gast on Plant in 2006 was added as a result of the NO X 

### SIP Call and in anticipation of CAIR.

• Installation of Low NO X 

### Burner Technology for Cell Burners (LNCB) with overfire air (OFA) on Unit 1 at Alabama Po wer’s Greene County in 2003. Also, the installation of OFA on the LNB on Unit 2 in 2004. LNCB and OFA were added as a result of the NO X 

### SIP Call.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

Figure 4.3.1-1 Locations of Power Plants in Relation to the Birmingham 24-Hour PM 2.5 Nonattainment Area



### 4-12

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-13 Table 4.3.1-1 RACT Controls Installed Prior to or During 2009 

### Facility Source RACT Controls
McWane Pipe Charge handling area Wet suppression

Sloss Coke Coal plies Wet suppression Charge make-up Wet suppression Roads & process areas paving Cupola melting furnace new cupola/BH & spray suppression ACIPCO

Sand & cement storage silos Baghouse Nucor Steel Meltshop fugitives route to BH, other physical improvements Cupola charge makeup Wet suppression US Pipe 10 Sand/cement silos install bin vents



### 4.3.2 Verification of Continued Attainment Verification of continued attainment is monitored through operation of the ambient fine particulate matter monitor network and the maintenance of updating the area's emissions inventory.

The current ten ambient PM 2.5 

### monitors that are operating in the 24-hour PM 2.5 

### nonattainment area will continue to operate unless a change(s) is approved by EPA. No plans are underway to discontinue oper ation, relocate, or otherwise affect the integrity of the ambient monitoring network in place. Any change would only be made if it is consistent with 40 CFR Part 58. The Air Emissions Reporting Requirement s (AERR) was promulgated by EPA on December 5, 2008. For the purposes of verifying continued attainment based upon the emissions inventory, the three main compon ents of the inventory, point, area and mobile, will be updated on different schedules. The major point sources of air pollution will continue to submit data on their emissions on an annual basis. This has been required under 40 CFR 51, Subpart Q for many years. For the area source and mobile source portions of the inventory, these emi ssions will continue to be quantified on a three-year cycle. As required by the AERR, the next overall emissions inventory will be compiled for the calendar year 2008.

4.3.3 Contingency Plan Section 175A(d) of the Clean Air Act Amendmen ts requires the inclusion of contingency provisions that would be implemented by the State to correct any future violation of the NAAQS in areas that had been redesignated as an attainment area. Alabama commits to adopt, within 18 months of certification of a violation of the 24-hour PM 2.5 

### standard, one or more control measure(s) (contingency measures) as needed to re-attain the standard. The State of Alabama will use actual ambient monitoring data as the indicator or trigger to determine when th ese contingency measures would be implemented. In accordance with 40 CFR 58, ambient fine particulate matter monitoring data that

10 U.S. Pipe ceased produc tion on March 31, 2010.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-14 indicates a future violation of the 24-hour PM 2.5 

### NAAQS will begin the process to implement these contingency measures. Also, in the event that the 98 th 

### percentile of 24-hour PM 2.5 

### concentrations in a year at any indi vidual monitor in the nonattainment area records a reading of 36 μ g/m 3 

### or higher, the state will evaluate existing control measures to determine whether any further emission reduction measures should be implemented at that time.

Several factors will be considered in dete rmining the need for additional control measures in the event of a future year violation of the 24-hour PM 2.5 

### standard. Depending on when such future year violat ion occurs, additional local and regional emissions reductions may still be on the way from various regulatory programs. If a future year violation occurs, ADEM will consider the air quality impact of these various regulatory programs in determining the n eed for additional local reductions in emissions of direct PM 2.5 

### and/or SO 2



### . In May of 2009, ADEM submitted to EPA the “Attainment Demonstration for the Birmingham, Alabama Annual PM 2.5 

### Nonattainment Area”. This plan demonstrates attainment of the annual PM 2.5 

### NAAQS beginning in 2012 based on implementation of a combination of federal measures includin g CAIR, other regional controls, mobile source controls and local controls on industrial sources of direct PM 2.5 

### . As shown in the Table 4.3.3-1 below, this plan is based on reductions in direct PM 2.5 

### , NO X 

### and SO 2 

### emissions that will occur through the year 2012.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-15 Table 4.3.3-1 Projected Reductions

Date Control Installed Projected Reductions (TPY) Facility PM2.5 NOX SO2 PM2.5 NOX SO2 W.J. Bullock 11 Dec-2009 3.9 McWane Pipe 2009 14.7 Sloss MW 12 Oct-2011 16.8 Sloss Coke 2009 0.4 ACIPCO 2007/2008 21.4 Nucor Steel 2008/2009 28.1 US Steel Jun-2011 2.5 US Pipe 13 Jan-2012 16.8 APCo Miller Unit 1 2005 2011 5,664 9,223 APCo Miller Unit 2 2005 2011 5,464 8,482 APCo Miller Unit 3 2003/2008 12/31/2011 6,446 9,714 APCo Miller Unit 4 2003/2008 12/31/2011 7,238 11,654 APCo Gaston Unit 5 2006 Jan-2010 10,483 51,017 APCo Gorgas Unit 8 Dec-2007 5,387 APCo Gorgas Unit 9 Dec-2007 4,493 APCo Gorgas Unit 10 2002 Dec-2007 5,077 23,889 TVA Colbert Unit 5 2004 3,467 22,732 TVA Widows Creek Unit 7 2003 3,463 TVA Widows Creek Unit 8 2004 2004 (upgrade) 5,689 3,741 GA Bowen Unit 1 2008 2009 3,613 36,951 GA Bowen Unit 2 2008 Jun-2009 4,213 37,210 GA Bowen Unit 3 2008 Jan-2009 9,630 40,431 GA Bowen Unit 4 2008 Jan-2009 9,401 40,100 GA Wansley Unit 1 2008 Jan-2009 8,531 36,851 GA Wansley Unit 2 2008 Jan-2010 7,458 35,240 GA Hammond Unit 1 Jan-2009 3,675 GA Hammond Unit 2 Jan-2009 3,832 GA Hammond Unit 3 Jan-2009 4,005 GA Hammond Unit 4 Jan-2009 Jan-2009 2,101 17,007 GA Scherer Unit 3 Jan-2012 Jan-2012 2,614 26,348 GA McDonough Unit 1 Apr-2012 Apr-2012 1,821 11,114 GA McDonough Unit 2 Jan-2012 Jan-2012 1,876 11,448 Total Reductions from Base Year (AL only) 105 52,991 150,332 Total Reductions from Base Year (includes GA EGUs) 105 104,246 454,543



### The Attainment Demonstration for the Annual PM 2.5 

### NAAQS also contained contingency measures to be undertaken if the area fails to attain the annual PM 2.5 

### NAAQS by the 2012 attainment date. The contingency measures rely on emissions

11 W.J. Bullock ceased all operations as of October 2009.

12 Sloss Mineral Wool announced its closure in December 2009.

13 U.S. Pipe ceased produc tion on March 31, 2010.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-16 reductions that will occur as a result of CAIR and the Georgia multi-pollutant rule. The Georgia multi-pollutant rule (Georgia Department of Natural Resources’ Air Quality Rule 391-3-1-.02(2)(sss), “Multipo llutant Control for Electric Utility Steam Generating Units”), requires permitted NO X 

### and SO 2 

### controls at several western Georgia utilities. All controls relied on as contingency measures in the plan are based on controls that are scheduled to be installe d in the year 2012 or later. These programs are expected to result in additio nal reductions in emissions of SO 2 

### and NO X 

### through the year 2015. The Tables 4.3.3-2 and 4.3.3-3 below depict these emissions reductions for SO 2 

### and NO X



### . Table 4.3.3-2 SO 2 Emissions Reductions

Emissions (t/y)

Facility Unit Control Installation Date** 2012 PostControl Δ

TVA Plant Colbert 1 FGD 2015* 7121.58 356.08 6765.50
TVA Plant Colbert 2 FGD 2015* 7088.45 354.42 6734.03
TVA Plant Colbert 3 FGD 2015* 7106.34 355.32 6751.02
TVA Plant Colbert 4 FGD 2015* 7079.83 353.99 6725.84
TVA Plant Colbert 5 FGD 2015* 4597.90 229.90 4368.00
GPC Plant Scherer 4 FGD December 31, 2012 26616.20 1330.80 25285.40
GPC Plant Branch 3 FGD December 31, 2013 20105.10 1005.30 19099.80
GPC Plant Scherer 2 FGD December 31, 2013 26074.60 1303.70 24770.90
GPC Plant Branch 4 FGD June 1, 2014 19663.00 983.20 18679.80
GPC Plant Branch 1 FGD December 31, 2014 10732.90 536.60 10196.30
GPC Plant Branch 2 FGD December 31, 2014 12993.80 649.70 12344.10
GPC Plant Scherer 1 FGD December 31, 2014 26264.50 1313.20 24951.30

GPC Plant Yates 6 FGD June 1, 2015 14207.20 6334.00 (2015)
710.40 (Post-2015) 7873.20 (2015)
13496.80 (Post-2015)

GPC Plant Yates 7 FGD June 1, 2015 14348.40 6397.00 (2015)
717.40 (Post-2015) 7951.40 (2015)
13631.00 (Post-2015)

*Projected start-up date
**The installation date listed for Georgia sources is required by Georgia rules.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-17 Table 4.3.3-3 NO X Emissions Reductions

Emissions (t/y)
Facility Unit Control Installation Date** 2012 PostControl Δ

TVA Plant Colbert 1 SCR 2015* 3126.37 468.96 2657.41
TVA Plant Colbert 2 SCR 2015* 3111.82 466.77 2645.05
TVA Plant Colbert 3 SCR 2015* 3119.68 467.95 2651.73
TVA Plant Colbert 4 SCR 2015* 3108.04 466.21 2641.83
GPC Plant Scherer 4 SCR December 31, 2012 4821.76 2410.90 2410.86
GPC Plant Scherer 2 SCR December 31, 2013 4723.64 2361.80 2361.84
GPC Plant Branch 4 SCR June 1, 2014 6899.85 1207.50 5692.35
GPC Plant Branch 1 SCR December 31, 2014 5130.36 897.80 4232.56
GPC Plant Branch 2 SCR December 31, 2014 4475.81 783.30 3692.51
GPC Plant Scherer 1 SCR December 31, 2014 4758.04 2379.00 2379.04

GPC Plant Yates 6 SCR June 1, 2015 3009.54 1561.20 (2015)
526.70 (Post-2015) 1448.34 (2015)
2482.84 (Post-2015)

GPC Plant Yates 7 SCR June 1, 2015 3039.45 1576.70 (2015)
531.90 (Post-2015) 1462.75 (2015)
2507.55 (Post-2015)

*Projected start-up date
**The installation date listed for Georgia sources is required by Georgia rules.



### As shown above, several regulatory progra ms will result in continued reductions in emissions of direct PM 2.5 

### , SO 2 

### and NO X 

### through the year 2015. In the event of a future violation of the 24-hour PM 2.5 

### standard, ADEM will consider the air quality impact of all of these regulatory programs and any other new programs at the time in determining the need for additional lo cal reductions in emissions of direct PM 2.5 

### and/or SO 2 

### . Even though there is some uncertainty as to the status of CAIR, ADEM will evaluate the status of CAIR 14 

### and all regulatory programs at the time of a future year violation of the 24-hour PM 2.5 

### NAAQS. In the event that further reductions are needed, the list of culpable sources that was developed in the PM 2.5 

### Annual SIP will be evaluated for additional control of direct

14 On December 23, 2008, the United States Court of Appeals for the District of Columbia Circuit remanded CAIR to EPA, without vacatur, directing th e Agency to remedy the rule’s flaws in accordance with the Court’s July 11, 2008, opinio n in the case of North Carolina v. EPA, 531 F. 3d 896, 901 (D.C. Cir. 2008). When EPA responds to the Court’s remand, the requ est may need to be revised to be consistent with the Agency’s new final action.

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-18 PM 2.5 

### emissions. Also, the possibility of expa nding the current voluntary diesel retrofit program operating in the Birmin gham area will be explored. A timeline for the development of NO X 

### , PM 2.5 

### and/or SO 2 

### regulations or permit conditions follows. This schedule initiate s with certification of ambient air quality monitoring data indicating a violation of the 24-hour PM2.5 NAAQS:

Table 4.3.3-4 Schedule for Permit Revisi ons or Rule Revisions for Contingency Measures



### 1. Identify and quantify the emissions reductions expected to result in the future from existing and future state and federal regulatory programs. 3 months

2. Use the best available air quality modeling to evaluate the air quality improvement expected to result in Birmingham from the programs and emissions reductions identified in step 1 above. 6 months

3. Draft any needed permit conditions or SIP regulations. 3 months

4. Complete rulemaking or permit revision process and submit to EPA. 6 months

Completion no later than: 18 months

### Birmingham 24-Hour PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

5-1 

## 5.0 Conclusion
The most recent three years of quality-assured PM 2.5 

### monitoring data for the Birmingham area demonstrate compli ance with the NAAQS for 24-hour PM 2.5 

### . Since the late 1970's, there have been many major programs enacted in the Birmingham area that have led to significant actual, enforce able emissions reductions, which have led to improvements in the air quality in Birmin gham. This redesignation request and maintenance demonstration has been prepared to meet the requirements of the 1990 Clean Air Act Amendments.