Mississippi Redesignation Request a nd Maintenance Plan SIP Revision Technical Support Document Final, Adopted December 2, 2015 

### 1 MISSISSIPPI

DEPARTMENT OF ENVIRONMENTAL QUALITY

OFFICE OF POLLUTION CONTROL

TECHNICAL SUPPORT

DOCUMENT

ATTENDANT TO THE

STATE IMPLEMENTATION PLAN (SIP) REVISION

FOR PURPOSES OF A 2008 OZONE REDESIGNATION REQUEST AND

MAINTENANCE PLAN FOR THE

OZONE NONATTAINMENT AREA OF DESOTO COUNTY, MISSISSIPPI

ADOPTED DECEMBER 2, 2015Mississippi Redesignation Request a nd Maintenance Plan SIP Revision Technical Support Document Final, Adopted December 2, 2015 

### 2 TABLE OF CONTENTS

Discussion ............................................................................................................. Page 3

Purpose of the Revision. ....................................................................................... Page 4

Sources Affected by the Revision. ........................................................................ Page 4

Pollutants Involved. .............................................................................................. Page 4

Changes in Allowable Emissions. ........................................................................ Page 4

Location/Attainment Status. ................................................................................. Page 4

Part D SIP/Attainment Demonstration Impact. .................................................... Page 5

Air Quality Impacts. ............................................................................................. Page 5

Modeling. .............................................................................................................. Page 5

Compliance Methods to be Employed. ................................................................. Page 5

Public Comment Period. ....................................................................................... Page 5

Response to Comments on SIP Revision. ............................................................. Page 5

Regulation Changes. ............................................................................................. Page 6

Final Adoption of SIP Revision. ........................................................................... Page 6

ATTACHMENTS

Redesignation and Maintenance Plan Technical Analysis ........................ Attachment 1

Proofs of Publication. ................................................................................ Attachment 2

Notice of Public Comment Period

Proofs of Publication

Final Adoption Evidence. .......................................................................... Attachment 3 Commission Meeting AgendaMississippi Redesignation Request a nd Maintenance Plan SIP Revision Technical Support Document Final, Adopted December 2, 2015 

### 3 DISCUSSION:

The Mississippi Department of Environmental Quality, representing the Governor of the State of Mississippi formally requests the por tion of DeSoto County, Mississippi that was designated as nonattainment fo r the 2008 National Ambient Air Quality Standard (NAAQS) for ozone (O3) be redesignated to attainme nt pursuant to Section 107(d)(3) of the 1990 Clean Air Act Amendments (CAA).

In 2008, the EPA revised the NAAQS for ground- level ozone, setting the standard at 0.075 parts per million (ppm) averaged over an 8-hour period. Hourly average concentrations are recorded in ppm. Running 8-hour averages are computed from the hourly ozone concentration data for each hour of the year. The daily maximum 8-hour concentration for a given calendar day is the highest of the 24 po ssible 8-hour average concentrations computed for that day. The design value is the sta tistic to compare the 2008 8-hour ozone NAAQS and is a three-year average using the three most recent, consecutive calendar years of monitoring data. A violation of the 2008 8-hour ozone NAAQS occurs when the computed design value is greater than 0.075 ppm.

CAA requires the EPA to designate areas as attaining or not attaining that NAAQS. The EPA area designations were generally based on air quality monitoring data collected during the 2009, 2010, and 2011 ozone seasons. The highest monitor design value in an area was used to determine its designation. The CAA then specifies requirements for areas based on whether such areas are or are not attaining the NAAQS.

Because of EPA’s belief that it was contribu ting to ozone nonattainment for the Memphis area, that portion of DeSoto County, Missi ssippi within the Memphis Urban Area Metropolitan Planning Organization (MPO) was de signated nonattainment. At that time, the monitor in the Crittenden County, Arkansas ha d a design value above the 2008 8-hour ozone NAAQS. However, the monitor located in De Soto County had a design value of 0.073 ppm, which is below the 2008 8-hour ozone NAAQS. The TN-MS-AR Nonattainment Area for the 2008 Ozone NAAQS was classified as a Subpart 2 marginal nonattainment area.

Section 107(d)(3)(E) of the CAA, as amende d, states an area can be redesignated to attainment if the following conditions are met:

The EPA has determined that the NAAQS have been attained. For ozone, the areas must show that the average of the 4th highest 8- hour ozone values from three (3) complete, consecutive calendar years of qual ity-assured air quality monitoring data must be equal to or below 0.075 ppm.

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

The EPA has determined that the improvement in air quality is due to permanent and enforceable reductions in emissions. To demonstrate this, the State should estimate theMississippi Redesignation Request a nd Maintenance Plan SIP Revision Technical Support Document Final, Adopted December 2, 2015 

### 4 percent reduction (from the year used to de termine the design value for designation and classification) achieved from federal, state, and local measures.

The EPA has fully approved a maintenance pla n, including a contingenc y plan, for the areas

under section 175A.

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

Appendix V contains the technical data nece ssary to show that the portion of DeSoto County, Mississippi within the Memphis MPO designated as a moderate nonattainment area for the 2008 8-hour ozone NAAQS as part of th e TN-MS-AR Marginal Nonattainment Area has attained and is expected to mainta in the 2008 8-hour ozone NAAQS, and has met the requirements for redesignation set forth above.

PURPOSE OF THE REVISION:

The purpose of this SIP Revision is to forma lly request that the portion of DeSoto County, Mississippi that has been designated as nona ttainment for the 2008 National Ambient Air Quality Standard (NAAQS) for ozone (O3) be re designated to attainment pursuant to Section 107(d)(3) of the 1990 Clean Air Act Amendments (CAA).

SOURCES AFFECTED BY THE REVISION:

This SIP revision potentially affects all sources and practices subject to air pollution control regulations in Mississippi.

POLLUTANTS INVOLVED:

The pollutant affected by this SIP Revision is ground-level ozone as well as the precursors to ground-level ozone. This SIP Revision is for the purposes of redesignation for the 2008 National Air Quality Standard for ozone.

CHANGES IN ALLOWABLE EMISSIONS:

This SIP Revision does not include any provisions for emission limitation changes.

LOCATION/ATTAINMENT STATUS:

The northern portion of DeSoto County, Mississippi has been classified as Marginal Nonattainment for the 2008 National Ambient Air Quality Standard (NAAQS) for Ozone. All other areas of the state are designated attainment for all NAAQS.Mississippi Redesignation Request a nd Maintenance Plan SIP Revision Technical Support Document Final, Adopted December 2, 2015 

### 5 PART D SIP/ATTAINMENT DEMONSTRATION IMPACT:

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

AIR QUALITY IMPACTS:

This SIP Revision will have no adverse impact on air quality.

MODELING:

Air quality modeling for this SIP Revision is discussed in the Technical Analysis in Appendix 1 of this SIP Revision.

COMPLIANCE METHODS TO BE EMPLOYED:

No compliance methodology is applicable to this SIP Revison.

PUBLIC COMMENT PERIOD:

Public participation for the 2008 Ozone Rede signation Request and Maintenance Plan SIP Revision was achieved by a public comment pe riod that began on October 6, 2015 and ended on November 5, 2015 on which date a public hear ing was held to receive comments. The public notice was published consistent with procedures approved by EPA.

The notice of public comment period was publis hed on October 6, 2015, in daily newspapers in the cities of Jackson, and Tupelo, Mississippi as well as in a twice-weekly newspaper in Hernando, Mississippi. The notice of public hearing, and the draft SIP , were made available for public review in the main branches of the public libraries in Hernando and Tupelo, Mississippi and at the Mississippi Department of Environmental Quality, 515 E. Amite St., Jackson, Mississippi, 39201 and was made available on the Department’s website http://www.deq.state.ms.us.

TSD Attachment 2 contains a copy of the noti ce of public hearing and copies of proofs of publication of the notice of public hearing.

RESPONSE TO COMMENTS ON PLAN REVISION:

No comments regarding the SIP Revision were received during the public comment period.

EPA did submit a comment letter dated Novemb er 5, 2015 indicating that EPA did not have

any comments.Mississippi Redesignation Request a nd Maintenance Plan SIP Revision Technical Support Document Final, Adopted December 2, 2015 

### 6 REGULATION CHANGES:

No regulation changes were necessary for this SIP Revision.

FINAL ADOPTION OF PLAN REVISION:

TSD Attachment 3 contains evidence of final adoption of the SIP revision.Mississippi Redesignation Request a nd Maintenance Plan SIP Revision Technical Support Document Final, Adopted December 2, 2015 

### ATTACHMENT 1

2008 OZONE REDESIGNATION REQUEST AND MAINTENANCE PLAN

TECHNICAL ANALYSISMississippi Redesignation Request a nd Maintenance Plan SIP Revision Technical Support Document Final, Adopted December 2, 2015 

### ATTACHMENT 2

NOTICE OF PUBLIC HEARING

PROOFS OF PUBLICATIONMississippi Redesignation Request a nd Maintenance Plan SIP Revision Technical Support Document Final, Adopted December 2, 2015 MISSISSIPPI COMMISSION ON ENVIRONMENTAL QUALITY MISSISSIPPI DEPARTMENT OF ENVIROMENTAL QUALITY

NOTICE OF PUBLIC HEARING PUBLIC NOTICE START DATE: October 6, 2015 DEADLINE FOR COMMENTS November 5, 2015

PLEASE TAKE NOTE that the Mississippi Commission on Environmental Quality (“Commission”) is considering adopting a Revision to the State Implementation Plan for Control of Air Pollution (SIP Revision) for purposes of a Redesignation Request and Maintenance Plan for DeSoto County, Mississippi.

I. Substance of the proposed action:

The Mississippi Department of Environmental Quality is considering the adoption of a SIP Revision for the purposes of a redesignation request and maintenance plan for the portion of DeSoto County, Mississippi that is designated as nonattainment for the 2008 National Ambient Air Quality Standard (NAAQS) for groundlevel ozone. The Department plans to request that th e U.S. Environmental Protection Agency redesignate the aforementioned portion of DeSoto County, Mississippi as attainment for the 2008 ozone NAAQS pursuant to Section 107(d)(3) of the 1990 Clean Air Act Amendments (CAA).

II. Manner By Which the Public May Comment.

Copies of the proposed SIP Revision may be obtaine d by calling Mr. Keith Head at 601-961-5577 or writing to Mississippi Department of Environmental Quality, Air Division, P.O. Box 2261, Jackson, Mississippi 39201. For persons with internet access, the proposed SIP Revision may be found on the Mississippi Department of Environmental Quality’s website at http://www.deq.state.ms.us under Programs/Air Quality/New Information. Also, the proposed SIP Revision will be available for public review through November 5, 2015 in the main branches of the public libraries in Hernando and Tupelo, Mississippi. The proposed SIP Revision may also be reviewed in the offices of the Mississippi Department of Environmental Quality, 515 E. Amite Street, Jackson, Mississippi. Please contact Mr. Lorenzo Boddie at (601) 961-5171 to schedule an appointment.

Members of the public may present verbal or written co mments at the public hearing described below. Also, written statements regarding the proposed SIP Revision w ill be made part of the public hearing record if delivered by 5:00 p.m., Thursday, November 5, 2015, to the attention of Mr. Dallas Baker at the address

shown above.

III. Notice of Public Hearing.

A public hearing to receive comments regarding th e proposed SIP Revision will be held on Thursday, November 5, 2015, 1:30 p.m. in the DeSoto County Ad ministration Building, Board of Supervisors Meeting Room, Third Floor, 365 Losher Street, Hernando, MS 38632.

IV. Additional Information.

For additional information, please contact Mr. Keith Head at 601-961-5577.Mississippi Redesignation Request a nd Maintenance Plan SIP Revision Technical Support Document Final, Adopted December 2, 2015 

### ATTACHMENT 3

EVIDENCE OF ADOPTION OF SIP REVISIONMISSISSIPPI COMMISSION ON ENVIRONMENTAL QUALITY

Wednesday
, December 2 , 201 5

9:00 A.M.

Room 104A

515 East Amite Street Jackson, Mississippi 39201

AGENDA

1

. Call to Order

- Chair

2. Approval of Minutes of October 22 , 201 5 Meeting

3. Commission Approval of Brownfield Obligation Transfer

On April 26, 2011, the Commission reached a Brownfield Agreement (#5953

- 11) with the City of Picayune and Stockstill Brothers Investment, LLC for the remediation of the former Arizona Chemical facility in Picayune, Mississippi. In accordance with Rule 2.1.5.C of Part 3, Chapter 2: Final Regulations Governing Brownfield Voluntary Cleanup and Redevelopment in Mississippi, the City of Picayune, Stockstill Brothers Investment, LLC and Huey P. Stockstill , LLC jointly have provided a petition to the MCEQ t hat Huey P. Stockstill , LLC has the financial, managerial, and technical resources to complete performance of the Brownfield Agreement obligations and agrees to complete this performance. The staff of the MDEQ has reviewed the petition, and hereby

reco mmends that the Commission issue an order in accordance with the Brownfield Regulations approving the transfer of those obligations in Brownfield Agreement #5953

- 11 from the City of Picayune and Stockstill Brothers Investment, LLC to Huey P. Stockstill , LLC . Huey P. Stockstill

, LLC plans to continue to use the property as an asphalt and concrete facility.

4. Commission Approval of Environmental Covenant

The staff recommends that the Commission approve the Environmental Covenant between the

Commi ssion and the Mississippi Department of Transportation regarding the remediation of property located adjacent to 5160 Highway 49E in Rising Sun, Mississippi, referred to as the “UMOJA Market Site." The UMOJA Market facility was a convenience store that operated

above

- ground fuel tanks. Leaks from above ground storage tanks, fuel dispensers and fuel distribution lines have each contributed to petroleum contamination at the site. Therefore, remediation of the site is necessary . The portion of the site owned by MDOT serves as a right

- of

- way easement for Highway 49E. The staff of the MCEQ has evaluated the proposed Environmental Covenant and believes that, with the conditions and restrictions contained within, the site will be in compliance with appl icable State and Federal laws and standards and will be protective of the public health and the environment.

5. Commission Approval of Environmental Covenant

The staff recommends that the Commission approve two Environmental Covenants between the

Co mmission and Washington County and the Washington County Economic Development Authority regarding the remediation of property located in Greenville, Mississippi, referred to as the Moore Company facility. The Moore Company facility manufactured automoti ve parts utilizing a stamping operation. Improper handling of chlorinated solvents used as a degreaser in their operation contributed to soil and groundwater contamination at the site. Therefore, remediation of the site is necessary . The former facili ty is currently being utilized by a company performing a similar operation on the original plant site owned by the Washington County Economic Development Authority. The adjacent property owned by Washington County is currently leased by a manufacturer of marine components. The staff of the MCEQ has evaluated the proposed Environmental Covenant and believes that, with the conditions and restrictions contained within, the site will be in compliance with applicable State and Federal laws and

standards and will be protective of the public health and the environment.

6. Adoption of a Revision to the State Implementation Plan for the Purposes of a Redesignation Request and Maintenance Plan for DeSoto County, Mississippi

A public hearing was held on November 5, 2015, concerning a proposed Revision to the State Implementation Plan for the Control of Air Pollution (SIP Revision) for the Purposes of a Redesignation Request and Maintenance Plan for the portion of DeSoto Coun ty, Mississippi that isdesignated as nonattainment for the 2008 National Ambient Air Quality Standard for ground

- level ozone. The Department plans to request that the U.S. Environmental Protection Agency redesignate the aforementioned portion of DeSot o County, Mississippi as attainment for the 2008 ozone air quality standard pursuant to Section 107(d)(3) of the 1990 Clean Air Act Amendments. No comments from the public were received during the 30

- day comment period. A transcript of the public hear ing proceeding has been provided. We are recommending that the Commission adopt the SIP Revision.

7

. Consideration of the Mississippi State Oil and Gas Board Amended Rule 68 Related to the
Disposal of Naturally Occurring Radioactive Materials (NORM) As sociated with the
Exploration and Production of Oil and Gas

The Commission is required by statute to approve Mississippi State Oil and Gas Board Rules
related to disposal of waste products brought to the surface from oil and gas wells. The Oil and
Gas Board has been directed in a recent Mississippi Supreme Court decision to have the
Commission approve Oil and Gas Board Rule 68 which is entitled “Disposal of Naturally
Occurring Radioactive Materials (NORM) Associated with Oil and Gas Exploration an d
Production”. The principal thrust of the Rule is to authorize the surface and subsurface
landspreading of NORM materials as additional disposal options available to oil and gas operators.
Natural radioactive elements are present in low concentration s in the earth’s crust and these
elements are brought to the surface through oil and gas exploration and production activities and
must be properly disposed of. After the Supreme Court’s decision, MDEQ established a work

committee to review the Oil an d Gas Board Rule 68. The work committee included waste and
groundwater experts from MDEQ with input from the State Health Department’s Division of
Radiological Health. The work committee also reviewed other NORM land spreading regulations

in Texas, Ne w Mexico and Kansas. In addition, the committee met with industry representatives
and the Oil and Gas Board to understand the provisions of Rule 68 as it was adopted. The
committee recommended seven (7) changes to strengthen Rule 68, all of which have been adopted
by the Oil and Gas Board at its meeting on November 18, 2015. The adopted Rule, including the
changes recommended by MDEQ have been through public comment prior to the adoption by the
Oil and Gas Board. The recommended changes include the integration of a concentration
level for Radium 226 or Radium 228 of 5 pCi/g; l imitation on the landspreading activity to the
site of generation; requirement of surface land owner consent for landspreading activities; a

minimum setback of 300 feet to an inhabited dwelling; clarification that landspreading is limited to
noncommercial activities; confinement of landspreading activity to NORM

- impacted soils and

NORM

- impacted scale; and the defined permit duration or term of up to five (5) years. Copi es of
a comment letter from oil and gas companies; the submittal letter from the Oil and Gas Board ; and
the Findings of Fact, and Conclusion of Law and Order from the Oil and Gas Board which includes

Amended Oil and Gas Board Rule 68 are being provided to the Commission members for review.
Staff of MDEQ recommends the Commission approve the Oil and Gas Board Amended Rule 68.

8

. Asbestos Certifications

We have issued 81 asbestos certifications since the last report. This list will be available at the
Commission meeting.

9

. Lead Paint Certifications

We have issued 54 lead paint certifications since the last report. This list will be available at the
Commission meeting

.

10

. Underground Storage Tanks (UST) Certifications

We have issued 13 certification s to those who install

, alter

, or remove underground storage tanks since the last report. This list will be available at the Commission meeting.

11

. Wastewater Operator Certifications

We have issued 76 wastewater operator certifications since the last report. This list will be
available at the Commission meeting.12

. Emergency Clean

- Up Expenses

We have 11 emergency expenditures since the last report . See Attachment 1 at the end of this agenda.

1 3

. Administrative Orders

We have issued 18 administrative orders since the last report and they should be added to the
minutes. The staff will highlight any orders that we think are especially noteworthy. S ee
Attachment 2 at the end of this agenda.

1 4

. Other Business

1 5

. Confirmation of meeting on January 28, 2016

1 6

. Adjournment