# Georgia's Redesignation Request and Maintenance Plan for the Chattanooga NonattainrnentArea for the 1997 PM2.5 

# NAAQS For Catoosa and Walker Counties August 31, 2012

Prepared by: 

# Georgia Department ofNaturalResources Environmental Protection Division Air Protection Branch

### GeorgiaPortion of the Chattanooga PM 2.5

### NonuttainmentAreu RedesignationRequestundMaintenancePlan

Executive Summary This document contains Georgia's request under the Clean AirAct Amendments (CAA) of 1990 that the Georgia portion of the Chattanooga nonattainment area be redesignated to attainment with respect to the annual National Ambient Air Quality Standard (NAAQS) for 

### PM 25 (1997 fine patticulate matter standard, retained -in 2006). The document also includes Georgia's plan to maintain attainment of the PM2.5 standard in Catoosa and Walker counties. The Georgia Environmental Protection Division has developed its own separate maintenance plan for the Georgia pottion ofthe ChattanoogaPM2

_ 5 nonattainment area. This request is based on three years, 2007-2009, ofambient monitoring data showing attainment of the standard (15.0 ftg/m3) consistent with the clean data policy memo (Stephen Page 12/14/2004); the implementation of petmanent and enforceable reductions in PM2.5 and 

### PM25 precm·sor emissions; compliance with all applicable requirements; and the Georgia Pottion of Chattanooga Maintenance Plan with projections demonstrating maintenance ofthe standard through the year 2025.

### GeorgiaPortion of the ChattanoogaPM2.5NonattainmentArea RedesignationRequestandMaintenance Plan TABLE OF CONTENTS Executive Summary..........................................................................................................................i 

### 1.0 Introduction ................................................................................................................. 1 1.1 Nonattainment Designation and Attainment Demonstration..........................................! 1.2 Redesignation Request........................................................................................................2 1.3 Maintenance Plan
................................................................................................................3 

### 2.0 Redesignation Request ................................................................................................. 4 2.1 Attainment ofthe Annual PM2.5 NAAQS..........................................................................4 2.1.1 Monitoring Network
.......................................................................................................................4 2.1.2 Ambient PM 25 Data
........................................................................................................................6 2.1.3 Clean Data Determination
...............................................................................................................7 2.2 Implementation Plan Under Section llO(k) ......................................................................8 2.3 Permanent and Enforceable and Other Reductions in Emissions ..................................8 2.3 .I Source Apportionment ofAmbient PM25 .......................................................................................8 2.3.2 State Control Measures- Georgia
...................................................................................................9 2.3.2.1 S02 and NOx Controls and S02 Limits
................................................................................ I0 2.3.2.2 Smoke Management Plan
..................................................................................................... l6 2.3.3 Federal Control Measures
............................................................................................................. 17 2.3.3.1 Clean Air Interstate Rule
...................................................................................................... 18 2.3.3.2 Tier 2 Vehicle Standards and Low-Sulfur Gasoline
............................................................. l9 2.3.3.3 Heavy-Duty Gasoline and Diesel Highway Vehicles Standards & Ultra Low-Sulfur Diesel Rule
........................................................................................................................................20 2.3.3.4 Large Nonroad Diesel Engines Rule & Ultra Low-Sulfur DieselRule
................................20 2.3.3.5 Nonroad Large Spark-Ignition Engines and Recreational Engines Standard
.......................20 2.3.3.6 NO, SIP Call in Sunounding States
.....................................................................................21 2.3.4 S02 Emissions Reductions in Upwind States
................................................................................21 2.4 Section 110 and Pa11 D Requirements .............................................................................24 

### 3.0 MaintenancePlan...................................................................................................... 25 3.1 Maintenance Demonstration ............................................................................................25 3.1.1 Attainment Year Emissions Inventory
..........................................................................................25 3.1.1.1 PointSources
........................................................................................................................27 3.1.1.2 Nonpoint Sources
.................................................................................................................27 3.1.1.3 Onroad Mobile Sources
........................................................................................................29 3.1.1.4 Nonroad Mobile Sources
......................................................................................................29 3.1.1.5 Summary of2007 Emissions Inventmy
...............................................................................30 3.1.2 Projected Emissions Inventories
...................................................................................................30 3.1.2.1 Methods and Projected Inventories ...................................................................................... 3 l 3.1.2.2 Point Sources
........................................................................................................................32 3.1.2.3 Nonpoint Sources
.................................................................................................................32 3.1.2.4 Onroad Mobile Sources
........................................................................................................ 34 3.1.2.5 Nonroad Mobile Sources
......................................................................................................34 3.1.3 Emissions Projections Summary and Demonstration ofMaintenance ofAttainment..
.................35 3.1.4 Emissions Decreases
.....................................................................................................................37 3.1.5 Verification ofContinued Attainment.
..........................................................................................37
ii

### Georgia Portion of tlte Cltattlmooga PM 2.5

### NonattainmentArea Redesignation Request andMaintenancePlan 3.2 Contingency Provisions
.....................................................................................................38 3.2.1 Contingency Measure Triggers
.....................................................:...............................................3 8 3.2.2 Schedule and Procedure for Adoption and Implementation ofContingency Measures
................ 39 3.2.3 Contingency Measures
..................................................................................................................40 

### 4.0 Motor Vehicle Emissions Budget
............................................................................... 41 4.1 Pollntants
............................................................................................................................41 4.2 Methodology
.......................................................................................................................42 4.3 MotorVehicle Emissions Budgets and SafetyMargins
..................................................43 

### 5.0 Conclusion
................................................................................................................. 44 6.0 References
.................................................................................................................. 47

iii

### Georgia Portion ojtlte Chattanooga PM 2.5

### NonattainmentArea RedesigmttionRequest andMaintenance Plan
LIST OFFIGURES Figure 1-1. PM2.5 NouattainmeutAreas iu Georgia
......................................................................... 1 Figure 2-1. Locations ofChattanooga NonattaiumentArea PM2.5 Sampling Sites
......................5 Figure 2-2. Average factor contributions to PM2.5 (1.1g/m3) for2002-06 at the Chattanooga STN site using PMF
.............................................................................................................................9 Figure 2-3. Locations and 2007 Energy Production ofCoal-fired EGUFacilities in North Georgia
....................................................................................................................................... 12 Figure 2-4. S02 Emissions and Generation from North Georgia Coal-fired EGU Facilities, 2003- 2010
.................................................................................................................................. 15 Figure 2-5. Trend ofAggregatedAnnual S02 Emissions in States With Downwind Contributions to Georgia PM2.5 Exceeding 0.15 Jlg/m3

..........................................................23

iv

### Georgia Portion of the Chattanooga PM 2.5

### NonattainmentArea RedesignationRequestandMaintenancePlan
LIST OFTABLES Table 1-1. PM2.5 Design Value for Chattanooga NonattainmentArea
...........................................2 Table 2-1. Rossville-Maple St. PM2.5 Data Collection Site
..............................................................6 Table 2-2. Annual and Three-yearAverage AmbientPM2.5 Concentrations
.................................7 Table 2-3. Timetable ofState Measure Implementation
...............................................................10 Table 2-4. Annual S02 Emissions and Generation (106 MWh) from North Georgia Coal-fired EGU Facilities, 2003- 2010
....................................................................................................... 14 Table 2-5. Timetable ofFederal Measure Implementation
........................................................... 18 Table 2-6. Annual S02 Emissions in States With Downwind Contributions to GeorgiaPM2.5 Exceeding 0.15 ).lg/m3

................................................................................................................22 Table 3-1. 2007 Emissions Inventory Sources
................................................................................26 Table 3-2. Point Source Emissions for 2007 (tons, annual)
...........................................................27 Table 3-3. Nonpoint Source Emissions for 2007 (tons, annual)
....................................................28 Table 3-4. Largest NonpointPM2.5 Emissions by Source Classification
......................................28 Table 3-5. Onroad Mobile Source Emissions for 2007 (tons, annual)
..........................................29 Table 3-6. Nonroad Mobile Source Emissions for 2007 (tons, annual)
........................................30 Table 3-7. Attainment-year (2007) Emissions Inventory (tons, annual)
......................................30 Table 3-8. Bases ofControl and Growth Factors for2017 and 2025 Inventories
.......................31 Table 3-9. Projected Point Source Emissions (tons)
......................................................................32 Table 3-10. Projected Nonpoint Source Emissions (tons)
..............................................................33 Table 3-11. LargestNonpointPM2.5 Emissions by Source Classification,Year 2025
.................33 Table 3-12. Projected Onroad Mobile Source Emissions (tons)
...................................................34 Table 3-13. Projected Nonroad Mobile Source Emissions (tons).................................................. 35 Table 3-14. ProjectedEmissions- Total ofAll Sectors (tons)
.......................................................36 Table 3-15. Emissions Decrease
.......................................................................................................37 Table 4-1. 2025 MotorVehicle Emissions, Emissions Budgets, and Safety Margins
..................43 Table 5-1. Summary ofProjected S02 Emissions- Total ofAll Sectors (tons)
...........................44 Table 5-2. Summary ofProjected NO, Emissions- Total ofAll Sectors (tons)
...........................45 Table 5-3. Summary ofProjected PM2• 5 Emissions- Total ofAll Sectors (tons)
........................45

v

### GeorgiaPortion of the ChattanoogaPM 2.5

### NonattainmentArea Redesignation RequestandMaintenance Plan

LIST ofAPPENDICES AppendixA SourceApportionment ofPM2.5 in Georgia Appendix B Georgia's Basic Smoke Management Plan and Memorandum ofUnderstanding Appendix C Emissions Inventmy DevelopmentForTwo Georgia Counties in Chattanooga NonattainmentArea Appendix C- I Development ofthe Point Source Emissions Inventory for 2007 in the SESARM Region (Version l.IOa), Janumy 18,2012 Appendix C-2 Area and Nonroad 2007 Base Year Inventories, Revised Final Repmt, Jan 2012 Appendix C-3 Mobile Source Emissions Modeling for Catoosa and Walker Counties PM2.5 Maintenance Plan Motor Vehicle Emissions Budget Appendix C-4 Growth and Control Factors forAircraft, Commercial Marine Vessel, and Locomotive Emissions (includes memorandum from K. Thesing and two spreadsheets) Appendix C-5 Documentation ofthe 2012 Projection Emission Inventmy (VISTAS) Appendix C-6 Growth Factors, Control Factors, and Emission Summaries for Emission Inventory Appendix C-7 MACTEC, August 2009. Point Source, On-road, and Fire Base Year, Future Yem; and Control Strategy Emissions Inventories Draft QualityAssurance Project Plan Appendix C-8 E.H. Pechan and Associates, July 29, 2009. QualityAssurance Project Plan for Nonroad andArea Source BaseYear and Future Year Emissions Inventories

viAcronym AEO AERR
AIRS AQS
CAA CAIR CARB
CERR
CFR 

## co CSAPR DNR DOT EGAS EGU EPA
EPD ERTAC 

### Georgia Portion of the Clutttanooga PM2.s NonattainmentArea RedesignationRequestandMaintenance Plan

List ofAcronyms
Meaning Acronym Meaning Annual Energy Outlook FGD Flue Gas Desulfurization Annual Emissions Reporting FR Federal Register Requirements Aerometric Information Retrieval FRM Federal Reference Method System Air Quality Subsystem GDOT Georgia Department of Transp01tation CleanAirAct GFC Georgia Forestty Commission CleanAirh1terstate Rule HC Hydrocarbon California Air Resources Board HPMS Highway PerformanceMonitoring System Consolidated Emissions Repmting ICI Industrial and Rule Commercial/Institt1tional Code ofFederal Regulations MOU Memorandum ofUnderstanding Carbon Monoxide MOVES MotorVehicle Emissions Simulator Cross-state Air Pollution Rule MPO Metropolitan Planning Organization Department ofNatural Resources MVEB MotorVehicle Emissions Budget Department ofTranspmtation MWe Megawatt Electrical Economic GrowthAnalysis System MWh Megawatt Hours Electric Generating Unit NAA NonattainmentArea Envirolllllental ProtectionAgency NAAQS NationalAmbientAir Quality Standard Environmental Protection Division NCD NMIM County Database Eastern Regional TechnicalAdvisory Committee

viiAcronym NEI NMIM
NTE NO, OAQPS
PM 

### PM25 PMF Ppm RACM
RACT
RFP 

# sec GeorgiaPortion of tile Chattanooga PM 2.5

### NonattainmentArea Redesignation RequestandMaintenance Plan

Meaning Acronym Meaning National Emissions Inventory SCR Selective Catalytic Reduction National Mobile Inventory SEMAP Southeastem ModelingAnalysis Plan Model Not-To-Exceed SIP State Implementation Plan Nitrogen Oxides SMP Smoke Management Plan Office ofAir Quality 

### so2 Sulfur Dioxide Planning and Standards Particulate Matter SOA Secondary OrganicAerosols Fine Particulate Matter STN SpeciatedTrends Network Positive Matrix Factorization tpy tons per year parts per million 

# suv Spmt Utility Vehicle ReasonablyAvailable Control ULSD Ultra-Low Sulfur Diesel Measures ReasonablyAvailable Control VISTAS Visibility Improvement State and Tribal Technology Association ofthe Southeast Reasonable Further Progress VMT Vehicle Miles Traveled Source Classification Code WRD Wildlife Resources Division

viii

### Georgia Portion of the ChattanoogaPM 2.5

### NonattainmentArea Redesignation RequestandMaintenancePlan


### 1.0 Introduction This document contains the teclmical suppmt for the Georgia Environmental Protection Division's (EPD's) request that the Georgia portion ofthe Chattanooga nonattainment area be redesignated as an area attaining the 1997 annual fine particulate matter (PM25) National Ambient Air Quality Standard (NAAQS) pursuant to Sections 107(d)(3)(D) and (E) of the Clean Air Act (CAA), as amended. This redesignation request was prepared in accordance with U.S. EPA Guidance issued in 1992 (memorandum dated September 4 ofthat year from John Calcagni1). 

### 1.1 Nonattainment Designation and Attainment Demonstration In 2005, EPA designated four PM25 nonattainment areas in Georgia: Chattanooga (which also includes parts ofAlabama and Tennessee), Floyd County, Atlanta, and Macon. Figure 1-1 shows their locations. The Georgia pmtion of the Chattanooga nonattainment area is located in the nmthwest portion ofthe state and consists ofCatoosa and Walker counties.

QATLA>ITA OcHATTANOOGA IIIFLOYO !EmMACON



### Figure 1-1. PM2.s Nonattainment Areas in Georgia

1 "Procedures for Processing Requests to Redesignate Areas to Attairuuent," September 4, 1992. John Calcagni, Director, Air Quality Management Division, OAQPS, USEPA. 1 of47

## I GeorgiaPortion ojtlze Chattanooga PM 2.5

### NonattainmentArea Redesign(ltion RequestandMainten(lnceP/([11 EPA made initial designations ofnonattainment areas, including the Chattanooga nonattainment area, for the 1997 annual PM2.s NAAQS on Janumy 5, 2005 (70FR944), and amended the designations on AprilS, 2005 (70FR19844). The observed PM2.5 design value at three ofthe four nonattainment area monitors violated the annual standard, as shown in Table 1-1 below. Three of the monitors are located in Hamilton County, Tennessee, and one is located in Walker County, Georgia.


### Table 1-1. PM2.5 

### Design Value for Chattanooga Nonattainrnent Area SiteName 

## II Monitor ID 

## I PM2.5 DesignValue .. 2001-2003 (flg/m3) . Siskin Drive/UTC, Tennessee 470654002 15.2 Maxwell Road/EastRidge, 470650031 16.1 Tennessee Soddy-Daisy High School, 470651011 14.1 Tennessee Rossville- Maple St., Georgia 132950002 15.5

The State ofGeorgia prepared and submitted a PM2.s attainment demonstration plan for the Georgia portions ofthe Chattanooga nonattainment area to EPA Region 4 on October 27,2009 (cover date is October 16). The plan was based on modeling of the effects of existing m1d planned control measures on air quality in the Chattanooga area and demonstrated attainment ofthe standard byApril 5, 2010. Since EPA has detennined that the area has met the cleat1 data requirements (76FR 31239) and attained the standard prior to the attaimnent date (76FR 55774) (see Section 2), the SIP requirements that the October 27, 2009, attainment demonstration was required to fulfill are suspended. The attainment demonstration plan has been withdrawn and will be replaced with this maintenance plan. Relief from the requirement to submit an attainment demonstration as well as Reasonable Further Progress (RFP), associated RACM, and contingency requirements upon cleat1 data determination is specified in 40 CFR 51.1004(c) and also in a December 14, 2004, memo from Stephen D. Page of U.S. EPA. 

### 1.2 Redesignation Request This document contains Georgia's request that the Georgia p01tion ofthe Chattanooga nonattairunent area be redesignated to attainment with respect to the annual NAAQS for PM2.5 (1997 fme pmticulate matter standard, retained in 2006). Section 107(d) ofthe CAA states that an area can be redesignated to attainment ifthe following conditions are met: I. TheEPA has determined that the NAAQS has been attained. 2. The applicable implementation plan has been fully approved by EPA under Section IIO(k). 2 of47

### Georgia Portion of the Chattanooga PM2.sNomtttainmentArea RedesignationRequestandMaintenance Plan 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 II0 and Patt D. 5. The EPA has fully approved a maintenance plan, including a contingency plan, for the area as required by CAA Section 175A. The suppmting documentation to show that the above conditions have been met is contained in Sections 2 and 3. EPA's approval ofthis document will satisfY the fifth condition. 

### 1.3 Maintenance Plan Themaintenance plan (see above) has two required components under Section 175A:
• A demonstration ofmaintenance ofthe standard for at leastten years after redesignation; and • Contingencyprovisions for prompt correction ofany future violations. Per EPA guidance', the Georgia portion ofthe Chattanooga PM2.5 maintenance plan also includes the following elements:
• An attainmentyear emissions inventory (to support the maintenance demonstration); • A commitment to continued operation ofambient monitoring equipment in the area; and • Verification ofcontinued attainment. The maintenance plan is presented in Section3.

2 "Procedures for Processing Requests to Redesignate Areas to Attairunent," September 4, 1992. John Calcagni, Director, Air Quality ManagementDivision, OAQPS, USEPA. 3 of47

### Georgia Portion of the Chattanooga PM 2.5

### Nonattainment Area RedesignationRequestandMaintenancePlan


## 2.0 Redesignation Request As noted in Section 1.2 of this document, Section 107(d) of the CAA states that an area can be redesignated to attainment ifthe following conditions are met: I. 

### The EPA has determined that the NAAQS has been attained. 2. The applicable implementation plan has been fully approved by EPA under Section 11O(k). 3. The EPA has detennined 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 tmder Section I I0 and Part D. 5. The EPA has fully approved a maintenance plan, including a contingency plan, for the area under CAA Section 175A. This section of the document includes supporting documentation for the following:
• Attainment ofthe annual PM25 

### NAAQS based on ambient data fi·om 2007 through 2009; • Approval by EPA ofthe implementation plan under Section llO(k); • hnprovement of air quality with respect to PM2.5 

### is due to permanent and enforceable reductions in emissions; and • The state has met all applicable requirements for the area under Section I I0 and Pmt D. 

### 2.1 Attainment oftheAnnual PM2.s 

### NAAQS A monitoring site is in attainment of the annual PM25 

### standard when the annual standard design value is less than or equal to 15.0 micrograms per cubic meter (1-1g/m3) 

### per Appendix N of40 CFR Pmt 50. The annual standard design value is the 3-year average ofthe annual mean, which is, in turn, the average ofone year's 4-calendar-quarter averages. The data must be complete and qualityassured, consistent with 40 CFR Part 58 requirements, and other relevant EPA guidmlCe. Therefore, for a single site to meet the standm·d, the annual design value calculated fi·om the previous three calendar years must be less than or equal to the standard. For a nonattainment area to achieve attaimnent, all monitoring sites in the nonattainment area must be in attainment. The Chattanooga area design value, based on data from 2007 through 2009, is 12.7 1-1g/m3 

### (Monitor ID 470654002), which demonstrates attainment of the standard. The monitoring network and ambient PM25 

### data are presented below. 

### 2.1.1 Monitoring Networ){ One PM25 

### Federal Reference Method (FRM) monitor and one PM2.5 

### speciation monitor m·e located at the Rossville-Maple Street site (13-295-0002) in the Georgia pmtion of the Chattanooga NAA. The PM2.5 

### FRM monitor was installed in accordance with 40 CFR 58 and has been collecting data since January I, 2000. Its sampling schedule was every six days until Janumy 3, 2007, when it slatted sampling every three days. The PM25 

### speciation monitor has been collecting data since March 23, 2005. The sampling schedule ofthe PM2.5 

### speciation monitor has been and remains every six days. Due to construction ofthe Rossville Health Depattment sampling location, these monitors were moved from the Rossville Health Depattment site to their current location on Maple Street. The samplers were temporarily shut down on June 11, 2007, and restarted on November 14, 2007. During this time, EPD actively searched and found a location to set up the monitoring equipment within the required distance to keep the smne AQS identification. 4 of47

### Georgia Portion of tile Chattanooga PM 2.5

### NonattainmentArea RedesignationRequestandMaintenance Plan The locations of the monitoring sites are shown in Figme 2-1. PM2.5 

### data collection dates at the Rossville-Maple Street site are presented in Table 2-1.

• FRM (2007) • FRM (2002) 

# + STN (2007)

Marion

DeKalb Bledsoe
Sequatchie Description ofArea []MPO Boundary**~CHATTANOOGA**

Bradley

Whitfield Murray

Gordon



### Figure2-1. Locations ofChattanooga NonattainmentArea PM2

### .s 

### Sampling Sites

5 

### of47

### Site Name I 

### Georgia Portion of tile ChattanoogaPM 2.5

### NonattainmentArea Redesignation RequestandMaintenance Plan
Table 2-1. Rossville-Maple St. PM2.5 

### Data Collection Site
StartDate-

# ·~~~~~~ .. 

### Start DateAQS* FRMData Speciation Site ID Collection Collection · Data Collection

·. 

### Eml DateSpeciation Data Collection Rossville 13-295-0002 Jan. I, 2000 June 11,2007 March 23, June II, 2007 2005 Maple Street 13-295-0002 Nov 14,2007 Nov 14,2007 *EPA's Air Quality System
2.1.2 Ambient PMz.s Data Table 2-2 shows the annual average PM2.5 

### concentrations and the associated 3-year average that demonstrate attainment of the standard in the Chattanooga nonattainment area. The 2007-2009 three-year design value is 12.7 ftg/m3
, 

### which is below the standard of 15.0 f!g/m3• 

### The table includes annual averages from 2003 through 2010, demonstrating the downward trend in the measured ambient PM2.5 

### level in the nonattainment area. The 2008-20I0 three-year design value (Monitor ID 470654002) is 11.6 ftg/m3 • 

### This provides continued evidence that the area is meeting the standard. To date the quality-assured annual average for 20II is not available. No data were collected from June 12-November 13,2007 at the Rossville-Maple Street site (13- 295-0002) becanse a new roof was installed in June of 2007. Because ofthe shutdown ofthe monitor, the Rossville site did not meet data completeness requirements for 2007. Georgia developed a weight-of-evidence approach for an alternative method of data substitution. The analysis used data from Siskin Drive (47-065-4002) and Tombras Avenue (47-065-0031) sites to detetmine the attainment status of the Rossville site. GA EPD's "Analysis of Rossville PM25 

### Data" can be found in the EPA docket at http://www.regulations.gov (docket ID Number EPA-R04- 0AR-2011-0084-0002). The EPA Office ofAir Quality Planning and Standards (OAQPS) ran a regression analysis in order to confirm Georgia's approach. OAQPS found that site substitution would be appropriate for data substitution.

6 of47

### Georgia Portion of the Chattanooga PM 2.5

### NonattainmentArea Redesignation RequestandMaintenance Plan

Table 2-2. 

### Annual and Three-yearAverage Ambient PM2.5 

### Concentrations

. 

### Year Monitor Monitor . 

## . I· Monitor Monitor 13-295-0002 47-065-0031 47-065-1011 47-065-4002

(J.tg/m3) (J.tg/m3) (Jlglm3 ) (J.tg/m3)

. 2003 15.9 16.5 14.3 14.9 2004 14.9 15.6 13.3 14.5 2005 16.4 16.1 13.8 15.5 2006 14.4 14.3 13.1 15.0 2007 13.7* 14.9 14.2 15.0 2008 12.5 12.3 11.4 12.7 2009 10.7 10.5 9.5 10.5 2010 8.9 12.0 13.3 11.7 2007-2009 12.3* 12.6 11.7 12.7 2008-2010 10.7 11.6 11.4 11.6 *Values subJect to data substttutwn (76 FR 15895) 

### 2.1.3 CleanDataDetennination On May 31, 2011, EPA promulgated its determination (76 FR 31239) that the Chattanooga nonattainment area had attained the 1997 atrnual average 

### PM25 National Ambient Air Quality Standard (NAAQS). This determination was based upon quality-assured and certified ambient air monitoring data for the 2007-2009 period which showed a design value of 12.7 11g/m3• With the clean data determination, EPA suspended the requirements for the nonattainment area to submit an attainment demonstration, a reasonable further progress (RFP) plan, associated RACM, and contingency measures. These requirements are suspended as long as the area continues to attain the standard. This final rule became effective on June 30, 2011.

7 of47

### Georgia Portion oftlte ChattanoogaPM 2.5

### NonattainmentArea RedesignationRequestandMaintenance Plan 

### 2.2 Implementation Plan Under Section 

### llO(k) Section IIO(k) of the CAA addresses EPA's actions on state implementation plan submittals (completeness, deadline for action byEPA, etc.). A September 4, 1992 memo from Jolm Calcagni of EPA states the following: "The SIP for the area must be fully approved under section IIO(k), and must satiszy all requirements that apply to the area. It should be noted that approval action on SIP elements and the redesignation request may occur simultaneously." The State of Georgia has prepared and submitted a PM2.5 attaimnent demonstration plan for the Georgia portion ofthe Chattanooga nonattainment area. The plan was submitted for approval to EPA Region 4 on October 27, 2009. As discussed in Section 1.1 of this redesignation request and maintenance plan, the attainment demonstration, RFP, associated RACM, and contingency requirements that the October 27, 2009, SIP revision was required to fulfill have been suspended. Therefore, the attainment demonstration has been withdrawn and substituted with submittal ofthis maintenance plan. There are no longer any Section I IO(k) requirements to be met. 

### 2.3 Permanent and Enforceable and Other Reductions in Emissions In order for the nonattainment area to be redesignated to attainment, the State must demonstrate (and EPA must determine) that the improvement of ambient PM25 concentrations during the years 2007 through 2009 is due to permanent and enforceable reductions, unless otherwise stated, in emissions that were implemented following the nonattaimnent design value period (2001

- 2003). This subsection contains Georgia EPD's demonstration that the improved air quality is due to permanent and enforceable emissions reductions. The elements ofthe demonstration described below are as follows:
• Source appmtiomnent, which links individual observed ambient PM25 species to specific e1nissions sources;
• State control measures and associated emissions reductions;
• Federal control measures and associated emissions reductions; and
• Reductions,in S02 emissions from upwind states. 

### 2.3.1 SourceApportionmentofAmbientPM2.s Source apportionment of speciated ambient pollutant measurements is an important tool for the prioritization of pollutant control strategies. Presented here are source-appmtionment results for 2002-2006 speciated PM25 measurements for a standalone analysis conducted at the Hamilton County STN monitor (47-065-4002) (Figure 2-2). The source-apportionment results are based on Positive Matrix Factorization (PMF), a factor analytic method that distinguishes correlation patterns among speciated PM2.5 measurements in a given location. More detailed information on source apportionment is presented inAppendixA.



### 8 of47

### Georgia Portion of tire Chattanooga PM 2.5

### NonattainmentArea RedesignationRequestamiMaintenance Plan

6.27 IIi! 

### Mobile-sources IIIII Biomass-burning DSoil D Zn-rich IIIII Fe-rich IIi! 

### Na-rich 1111 Ca-rich D Sec. Sulfate IIIII Sec. Nitrate IIIIISOA D Unspecified 

### Figure 2-2. Average factor contributions to PM2• 5 

### (J.lg/m3) 

### for 2002-06 atthe Chattanooga STN site using PMF These source-appmtionment results are useful for a preliminary assessment of control strategies. Given the large contributions to PM2.5 

### from the secondary-sulfate factm; itis evident that controlling S02 

### emissions (mainly from coal-buming EGUs) would reduce PM 25 

### levels in the Chattanooga MSA. Controlling emissions of SOA precursors would also be usefhl. Unfortunately, these are not yet well understood, and limited available knowledge suggests biogenic sources as the primary SOA precursors. Reducing primary PM25 

### may be best achieved by emission reduction measures for mobile-source emissions and biomass burning. Contributions from all other source-categories were small in general. 

### 2.3.2 StateControlMeasures -Georgia Based on source factor analysis, Georgia's control strategy is focused on the reduction ofemissions associated with secondary sulfates and nitrates and biomass burning. Control of S02 

### is the most impmtant component of the strategy, as secondmy sulfates make up the largest controllable contribution to ambient PM 25• 

### State measures that target reduction ofthese emissions are:
• S02 

### and NOx controls on EGUs (rule (sss))
• S02 

### limits on EGUs (rule (uuu))
• Smoke Management Plan

9 of47

### Georgia Portion of the ClwttanoogaPM 2.5

### NonuttainmentAreu Redesignation RequestandMuintenance P/un Table 2-3 shows the timetable ofimplementation ofthese measures as well as the species controlled by each. The con·elation between the drop in PM2.5 

### annual averages and the implementation ofthe control measures, particularly Georgia Rule 391-3-l-.02(2)(sss), lends strong evidence that the improvements in air quality are a result of reduction in emissions and not a meteorological influenced phenomenon. Detailed discussions of the measures are presented in the following subsections. Table 2-3. Timetable ofState Measure Implementation Measure Species 2001 '.02 '03 '04 I 

### '05 '06 '07 '08 '09 I 

### '10 controlled

. I 

### PM2.5ann. 16.1 14.7 14.9 14.5 15.5 15.0 15.0 12.7 I

### 0.5 11.7 avg.**(~tg/m ),**  

### (Monitor 47- 065-4002)

### ~"~~ Rule (sss) SO,,NOx

## ~~~~~ Smoke PM,NOx

# ~**~~** Management

# ~~~~ Plan

### ~ 

### wft Rule (uuu) 

## so,

# ~ *Controls were required on December 31, 2008, but were actually slatted up in the first halfofthe year.
2.3.2.1 S0 2 andNO, Controls andS0 2 Limits 

### Atmospheric secondaty sulfate is formed from emissions of S02 . 

### Coal-fired EGUs are by far the most significant source of S02 

### emissions in Georgia and in the Southeast. Georgia's Multipollutant Rule [391-3-l-.02(2)(sss)] requires flue gas desulfurization (FGD) and selective catalytic reduction (SCR) controls on the majority of coal-fired EGUs in Georgia. This state enforceable rule was promulgated in 2007 for the purposes of lowering ozone and PM25 

### concentrations by controlling precursor emissions and for reducing mercury deposition. The FGD controls reduced S02 

### emissions rates from the affected emissions units by at least 95 percent and the SCR controls reduced NOx emissions rates by approximately 85 percent. The S02 

### and NOx controls were required in suppmt of EPA's CAIR rule, which was promulgated in 2005 and required state-wide caps for NOx and S02 

### beginning in2009 and 2010, respectively. The CAIR rule is discussed fmther in Section 2.3.3. Georgia Rule (uuu), S02 

### Emissions from Electric Utility Steam Generating Units, is a companion rule to Rule (sss) and is both state and federally enforceable upon approval by EPA. Both ofthese rules were implemented in response to CAIR and require emissions reductions consistent with CAIR's original schedule slatting in 2009. The rule requires 95% reduction of S02 

### emissions from the majority ofGeorgia's coal-fired EGUs, with the requirement being phased in fi·om 20 I

### 0 through 2016.



### I0 of47

### Georgia Portion oftlte ChattanoogaPM 2.5

### NonattainmentArea Redesignation RequestandMaintenancePlan Ithas been well demonstrated that ambient secondary sulfate in a given location can be significantly affected by S02 emissions from distant sources. Even though the Georgia portion of the Chattanooga area has no EGU facilities, the secondary sulfate in the Chattanooga nonattainment area is affected by S02 emissions from coal-fired EGUs in Nmth Georgia and the Alabama pmtion ofthe Chattanooga NAA. Figure 2-3 shows the locations ofthe coal-fired EGU facilities in the nmthern halfofGeorgia as well as their respective energy production (in million megawatt-hours) in the year 2007. Plant Hammond is located approximately 25 miles south of the nonattainment area. Plant Bowen, which is located approximately 35 miles south-southeast of the nonattaimnent area, was a close second to Plant Scherer in energy production and historically has been by far the highest SO,- emitting facility in the state. Plant Wansley is located approximately 80 miles south of the Chattanooga nonattainment area. The facilities shown in the figure comprise seven ofthe ten coalfired EGU facilities that were operated in Georgia in 2007. In 2007, the energy produced by the seven facilities made up 97 percent ofthe state-wide energy production from coal-fired facilities.

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### GeorgiaPortion oftlte Chattanooga PM2.5 NonattainmentArea Redesignation RequestandMaintenance Plan

Tennessee



# I

million MWh (2007) 0 5 10 20 

## •• 30 N. Carolina
S.Carolina



### Figure 2-3. Locations and 2007 EnergyProduction ofCoal-fired EGU Facilities in North Georgia

The required FGD control implementation date varies by EGU, starting on December 31,2008. S02 controls were actually stmted on five units in May 2008. S02 controls were operating for the entire year of2009 as follows:
• Plant Hammond

- controls on 4 of4 units;
• PlantBowen- controls on 2 of4 units; and
• Plant Wansley- controls on 

### I of

### 2 units. 12 of47

### Georgia Portion of the Chattanooga PM 2.5

### NonattainmentArea RedesignationRequestandMaintenancePlan S02 controls on a third unit at Plant Bowen and the second unit atPlant Wansley began operation on April!, 2009. Rule (sss) requires SCR controls to be operated year-round, starting at six EGUs in 2008 and 2009 (Bowen Units 2, 3, and 4; Wansley Units 1 and 2; and Hammond Unit 4). However, these NOx controls were already in place and operating during the ozone season by the end of2003. The Title V permit ofeach ofthe above facilities has been amended to permit operation ofthe FGD and SCR controls. Table 2-4 shows the annual S02 emissions for the coal-fired facilities in Nmth Georgia for the period 2003 tln·ough 2010. The table also includes the electrical generation, a measure ofproduction, for the facilities for the same time period. This data is presented in graphical form in Figure 2-4. For the seven facilities, S02 emissions were reduced by 60.2% and generation was down by only 4.7%. These statistics provide clear evidence that the reduction in PM2.s concentration is due to permanent and enforceable controls rather than to reduced production.

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### Georgia Portion of the Chattanooga PM 2.5

### NonattainmentArea RedesignationRequestandMaintenance Plan

Table 2-4. Annual 

### S02 Emissions and Generation (106 MWh) from North Georgia Coal-fired EGU Facilities, 2003

- 2010 

### Facility 2003 2004 2005 2006 2007 2008 2009 Hammond 

## so, (tpy) 35,900 37,700 39,500 40,600 47,800 12,500* 900* generation 4.79 4.11 4.64 4.27 5.09 4.32 3.73 Bowen 

## so, (tpy) 164,900 165,900 186,500 206,400 196,800 148,100* 54,800* generation 21.9 21.9 23.3 23.7 24.0 23.4 22.9 Branch 

## so, (tpy) 64,800 70,100 90,500 96,000 98,400 94,000 60,100 generation 8.28 7.97 10.3 10.8 10.9 10.7 6.82 McDonough 

## so, (tpy) 23,900 22,700 27,700 28,800 28,500 24,300 15,900 generation 3.75 3.52 3.92 4.07 4.07 3.43 2.34 Scherer 

## so, (tpy) 83,900 79,700 82,900 74,200 76,500 77,700 69,500 generation 21.3 24.6 25.5 24.5 26.5 25.7 24.3 Wansley** 

## so, (tpy) 94,000 99,000 101,500 96200 93,900 74,300* 7400* generation 13.7 14 15.1 14.8 16.1 15.5 11.8 Yates 

## so, (tpy) 44,900 50,600 66,500 75,500 77,200 68,200 45,500 generation 6.73 6.22 7.37 7.49 8.10 7.37 4.90 TOTAL 

## so, Tons/yr 512,300 525,700 595,100 617,700 619,100 499,100 254,100 TOTAL Generation 106 MWh 80.45 82.32 90.13 89.6 94.76 90.42 76.79 Ambient PM2.5, annual Monitor 47- average 065-4002 (ng/m3) 14.9 14.5 15.5 15.0 15.0 12.7 10.5



## ... Source: EPA Clean An· Markets DivisiOn * S02 control, required by Georgia Rule (sss), was operational on one or more EGUs for partial or full year 

## ** does not include emissions fi·om facility's gas-fired units

14 of47 2010

. 2,427

3.23 7,618

24.7 53,258

6.09 17,115

2.28 69,862

24.5 2,343 9.8 54,256

6.06 203,879

76.65

11.7

### Georgia Portion of the Chattanooga PM2. 5

### NonattainmentArea Redesignation RequestandMaintenance Plan

700000 100 90 600000 80 500000 70 60 400000 lillllillliiiiS02 (tpy) 

### 50 300000 40 

### --+- gen (million l'v1Wh) 

### 200000 30 20 100000 10 0 0 C') 

# " L() 

# "' 1'- 00 0> 0 0 0 0 0 0 0 0**~** 0 0 0 0 0 0 0 0 

# "' "' "' "' 

# "' "' "' "' Figure 2-4. S02 

### Emissions and Generation from North Georgia Coal-fired EGU Facilities, 2003

- 2010

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### Georgia Portion of the ChattanoogaPM 2.5

### NonattainmentArea RedesignationRequestandMaintenancePlan

2.3.2.2 Smoke Management Plan Forestry and agriculh1re, two of Georgia's most significant industries, utilize prescribed burning practices to support production. Prescribed burning is the controlled application of fire to existing vegetative fuels to accomplish platmed land management objectives or to mitigate catastrophic wildfires. In addition to managing forests and agricultural resources, prescribed burning helps protect lives and property by reducing accumulations offorest fuels and helps to sustain imperiled species and ecosystems. The Georgia General Assembly enacted the Georgia Prescribed Burning Act to authorize and promote the use of prescribed burning for community protection and for silvicultural, environmental, and wildlife purposes. Large prescribed burns can produce significant PM2.5 emissions. These emissions, if not properly managed, can reach smoke-sensitive areas and have significant negative impacts on the air quality in these areas. Smoke-sensitive areas include Georgia's heavily populated areas and PM2.s nonattainment areas. Without a prescribed burning program, there is a higher probability of catastrophic wildfires, which can threaten personal property and can have even higher negative impacts on air quality. To prevent negative air quality impacts from prescribed burning, Georgia DNR and the Georgia Foreshy Commission (GFC) formulated and adopted Georgia's Basic Smoke Management Plan (SMP) dated April 16, 2008. The plan was developed in accordance with EPA's "The Interim Air Quality Policy on Wildland and Prescribed Fires" and the draft EPA guidance document, "Elements ofa Smoke Management Program." The purpose ofthe SMP is to allow fire to function in its natural role in maintaining healthy wildland ecosystems while protecting public health and welfare by mitigating the impacts of air pollutants from wildland and prescribed fires on air quality and visibility. The plan is a necessary component in determining Exceptional Events related to prescribed burning and is an element ofGeorgia's Regional Haze SIP. The GFC, Georgia DNR's EPD, and Georgia DNR's Wildlife Resources Division (WRD) signed a Memorandum Of Understanding (MOU) to implement the SMP on April 16, 2008. The SMP and the MOU are included as Appendix B. The SMP identifies the following components that should be considered in the plmming of prescribed burns:
• smoke mitigation,
• smoke dispersion evaluation,
• public notification, and
• air quality monitoring. Smoke mitigation, smoke dispersion evaluation, and air quality monitoring are important to mitigating the effects ofprescribed burns on air quality in smoke-sensitive areas. Smoke mitigation is accomplished by avoiding smoke-sensitive areas, performing burns under favorable smoke dispersion conditions, and managing the generation and release of emissions over time. Smoke dispersion evaluations are performed by GFC-certified prescribed fire managers and are supported by the GFC's full-time fire weather meteorologist. Air quality monitoring and forecasting, performed by Georgia EPD, provides impmtant air quality data to assist fire managers with their decisions on when to schedule prescribed burns. 16 of47

### Georgia Portion of tlte ChattanoogaPM 2.5

### NonattainmentArea RedesignationRequestandMaintenancePlan In addition to mitigating the impacts ofprescribed bums on air quality, the implementation ofa SMP has benefits with regard to the computation ofair quality design values. Design values are statistical measures of historical ambient pollutant concentrations that are compared to EPA's air quality standards to detennine ifattainment ofthe standard has been achieved. An atypical event, such as an unusually large forest fire, can produce PM25 emissions that will significantly increase ambient concentration measurements, and therefore design value computations, in a nonattainment area. EPA will allow the atypical ambient measurements to be excluded from the design value computation if the fire event is deemed to be an "exceptional event". In order for a large fire to qualify as an exceptional event, the EPA has stated that a state must demonstrate that a certified SMP was in place at the time of the event, or that the state must ensure that the burner employs basic smoke management practices. All outdoor buming is subject to enforcement through law enforcement officers ofGFC, DNR and local law enforcement. The enforcement authority is tl1e Georgia Forest Fire ProtectionAct, as well as EPD's authority to enforce Federal and State air quality regulations and laws. In addition, GFC has the authority to void certification of ce1tified prescribed burners if investigation reveals that disregard for basic smoke management practices contributed to smoke intrusion into a smokesensitive area. This measure is State enforceable. It is not necessary for the continued maintenance of attainment in the Chattanooga area. However, implementation of the SMP will suppmt the maintenance ofthe annual PM 2.5 NAAQS. 

### 2.3.3 Federal ControlMeasures Federal control measures related to ambient PM25 are focused on the reduction of emissions associated with sulfates, nitrates, and direct PM. Federal measures that targeted reduction ofthese emissions between nonattainment designation and the clean data period are as follows: • CleanAir Interstate Rule/Cross StateAirPollution Rule; • Tier 2 Vehicle Standards; • Heavy-duty Gasoline and Diesel Highway Vehicles Standards and Ultra-Low Sulfur Diesel (ULSD) Rule; • Large Nonroad Diesel Engines Rule and ULSD Rule; • Non-Road Spark Ignition Engines and Recreational Engines Standard; and • NOx SIP Call in Surrounding States. All ofthe measures were in place prior to 2007, with the exception ofthe large nonroad diesel rule (effective in 2008) and CAIR. Reductions associated with vehicles and engines will increase during the maintenance period as older engines are removed from service and replaced by new engines. Table 2-5 shows the timetable ofimplementation ofthese measures as well as the species controlled by each. The drop in PM2.5 concentration from 2005 through 2010 demonstrates that the improvement of air quality is due to the implementation of the control measures. Detailed discussions ofthe measures are presented in the following subsections.

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### Georgia Portion of tlze Chattanooga PM2.sNomtttainmentArea RedesignationRequestandMaintenancePlan

PM2.5 ann. avg. (r.tg/m3) Monitor 47-065-4002 CleanAir Interstate Rule (CAIR) Tier 2 vehicle standards HeavyDuty Engine Standard, first phase

Large Nomoad Diesel Rule and ULSD Table 2-5. Timetable ofFederal Measure Implementation Species 2001 '02 '03 '04 '05 '06 '07 '08 '09 '10 controlled
.

NO, NO, 

## voc

PM, NO, 

## so, 16.1 14.7 14.9 14.5 15.5 15.0 15.0 12.7 10.5 11.7



## * S02 controls required beginning 20I0


### 2.3.3.1 CleanAirInterstate Rule On May 12, 2005, the U.S. EPA promulgated the "Rule To Reduce Interstate Transp01t of Fine Patticulate Matter and Ozone (Clean Air Interstate Rule)" referred to as CAIR. This rule established the requirement for States to adopt rules limiting the emissions ofNO, and sulfur dioxide (S02 ) and a model rule for the states to use in developing their rules. The purpose ofthe CAIR was to reduce interstate transpmt ofprecursors to fine patticulate and ozone.

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### GeorgiaPortion of the Chattanooga PM 2.5

### NonattainmentArea Redesignation RequestandMaintenance Plan The CAIR rule applied to fossil-fuel-fired electric generation units (EGUs), including certain cogeneration units, with nameplate capacities of greater than 25 MWe. This rule set annual state caps for NOx and S02 in two phases, with the Phase I caps starting in 2009 and 2010, respectively. Phase II caps for NOx and S02 were to become effective in 2015. As part ofthe CAIR rule, EPA determined that Georgia contributed significantly to downwind PM2.5 nonattainment areas and/or interfered with maintenance ofthe PM2.5 NAAQS (70 FR 25246-25250). Accordingly, a State CAIR rule [Georgia rule 391-3-1-.02(13)] was promulgated that, for the most patt, mirrors the provisions ofthe federal rule. On July 11, 2008, the U.S. District Comt ofAppeals in the District ofColumbia vacated the Clean Air Interstate Rule and remanded it to EPA. A rehearing ofthe Comt's decision was requested and granted. On December 23, 2008, the court remanded CAIR to EPA without vacatur (i.e., the rule was still in place). EPA was directed to correct the deficiencies in CAIRthat were identified in the court's decision. To replace CAIR, EPA promulgated the final Cross-State Air Pollution Rule (76 FR 48208) on August 8, 2011. The Cross-state rule imposes restrictions on emissions ofNOx and S02 from states identified as having significant impacts on ozone and/or PM2.5 NAAQS attainment or as interfering with maintenance ofthese same standards in downwind states. The requirements ofthe Cross-state Rule were to become effective in 2012 aud 2014, which is beyond the 2007-to-2009 clean data period for the Chattanooga nonattainment area. However, before that date arrived, the D.C. Circuit Comt ofAppeals stayed the implementation ofthe rule. Then, on August 21, 2012, the D.C. Circuit Court ofAppeals issued the following order to EPA: "We vacate the Ti·amport Rule [aka CSAPR] and the Ti·ansport Rule F!Ps and remand thisproceeding to EPA. EPA must continue administering CAIR pending the promulgation ofa valid replacement." At this point in time, EPA has not announced their intended response to the comt's ruling. So, it is unknown whether or not EPA will appeal the decision (either to a full panel ofthe D.C. Circuit or the U.S. Supreme Comt), if it will conduct rulemaking in response to the court's decision, or take some other path forward. Regardless, emissions ofNOx and S02 have declined significantly and are expected to continue to decrease in the future due to the continuation ofCAIR and Georgia's own EGU emission rules.
2.3.3.2 Tier 2 Vehicle Standards andLow-Sulfur Gasoline Federal Tier 2 vehicle standards will reduce NOx emissions fi·om passenger vehicles. The standards require all passenger vehicles in a manufacturer's fleet, including light-duty trucks and sport utility vehicles (SUVs), to meet an average standard of0.07 grams ofNOx per mile. Implementation began in 2004 and was completely phased in by 2007. The Tier 2 standards will also cover passenger vehicles over 8,500 pounds gross vehicle weight rating (the larger pickup tmcks and SUVs), which are not covered by the current Tier 1 regulations. For these vehicles, the standards were phased in beginning in 2008 with full compliance in 2009. The new standards require vehicles to be 77% to 95% cleaner than those on the road prior to implementation ofTier 2. The Tier 2 rule also reduced the sulfur content ofgasoline to 30 patts permillion (ppm) slatting in Janumy of2006. Sulfur occurs naturally in gasoline but intetferes with the operation ofcatalytic convetters on vehicles resulting in higher emissions. Lower-sulfur gasoline is necessary to achieve the Tier 2 vehicle emission standards.

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### GeorgiaPortion oftlte ChattanoogaPM 2.5

### NonattainmentArea RedesignationRequestandMaintenance Plan 2.3.3.3 Heavy-Duty Gasoline andDiesel Highway Vehicles Standards & Ultra Low-Suifitr Diesel Rule New U.S. EPA standards designed to reduce NO, and VOC emissions from heavy-duty gasoline and diesel highway vehicles (14001 pounds or more) began to take effect in 2004. A second phase of standards and testing procedures, which began in 2007, will reduce particulate matter from heavyduty highway engines and will also reduce highway diesel fuel sulfur content to 15 ppm to prevent damage to the emission control devices. The total program is expected to achieve a 90% reduction in patiiculate matter (PM) emissions and a 95% reduction in NO, emissions for these new engines using low sulfur diesel, compared to older engines using diesel with higher sulfur content. S02 emissions will also be reduced due to the lower fuel sulfur content.
2.3.3.4 Large NonroadDieselEngines Rule & Ultra Low-Suifiw DieselRule In May 2004, the U.S. EPA promulgated new rules for large nonroad diesel engines, such as those used in construction, agricultural, and industrial equipment, to be phased in between 2008 and 2014. The nonroad diesel rules also reduce the allowable sulfur in nonroad diesel fuel by over 99%. Prior to 2006, nonroad diesel fuel averaged about 3,400 ppm sulfur. The rule limits nonroad diesel sulfur content to 500 ppm in 2006 and 15 ppm in 2010. The combined engine and fuel rules would reduce NO, and PM emissions from large nonroad diesel engines by over 90%, compared to older engines using diesel with higher sulfur content. S02 emissions will also be reduced due to the lower fuel sulfur content.
2.3.3.5 NonroadLarge Spark-Ignition Engines andRecreationalEngines Standard This standard, effective in July 2003, regulates NO" hydrocarbons (HC) and carbon monoxide (CO) for groups ofpreviously unregulated nonroad engines. The new standard applies to all new engines sold in the United States and imported after these stat1dards began and apply to large spark-ignition engines (forklifts and airport ground service equipment), recreational vehicles (off-highway motorcycles and all-terrain-vehicles), and recreational marine diesel engines. The regulation varies based upon the type ofengine or vehicle. The large spark-ignition engines contribute to ozone formation and ambient CO and PM levels in urban areas. Tier I ofthis standard was implemented in 2004 and Tier 2 statied in 2007. Like the large spark-ignition engines, recreational vehicles contribute to ozone formation and ambient CO and PM levels. For the off-highway motorcycles and all-terrain-vehicles, model year 2006, the new exhaust emissions standard was phased-in by 50% and for model years 2007 and later at I00%. Recreational marine diesel engines over 37 kilowatts are used in yachts, cruisers, and other types of pleasure craft. Recreational marine engines contribute to ozone formation and PM levels, especially in marinas. Depending on the size ofthe engine, the standard began phasing in during 2006. When all of the nonroad spark-ignition engines and recreational engines standards m·e fully implemented, an overall 72% reduction in HC, 80% reduction in NO" and 56% reduction in CO emissions are expected by 2020. These controls will help reduce ambient concentrations of ozone, CO, and fine PM.

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### GeorgiaPortion of the Chattanooga PM 2.5

### NonattainmentArea RedesignationRequestandMaintenancePlan 2.3. 3.6 NO., SIP Call in Surrounding States In October 1998, the US EPA made a finding of significant contribution of NO, emissions from certain states and published a rule that set ozone season NO, budgets for the purpose ofreducing regional transport of ozone (63 FR 57356). This rule, referred to as the NOx SIP Call, called for ozone season controls to be put on utility and industrial boilers, as well as internal combustion engines in 22 states in the Eastern United States. A NOx emissions budget was set for each state and the states were required to develop rules that would allow the state to meet their budget. A NOx trading program was established, allowing sources to buy credits to meet their NOx budget as opposed to actually installing controls. The emission budgets were to be met by the beginning of 2004. 2.3.4 S0 2 Emissions Reductions 

### in Upwind States As noted previously, secondary sulfate concentrations in a given location can be significantly affected by S02 emissions from distant sources. During the period of2003 through 2009, S02 emissions from coal-fired electric generation facilities upwind ofGeorgia have been significantly reduced. EPA promulgated the Cross-State Air Pollution Rule (76 FR48208) on August 8, 2011, and projected future emissions to suppmt the rulemaking. Modeling in support ofthe Cross-State Rule has established linkages between emissions from upwind states and ambient PM2.s concentrations in downwind receptor states. EPA's projections indicate that 2012 emissions for the base case (which disallows reductions from existing or future CAIRcontrols) from ten upwind states will contribute 0.15 flg/m3 (1 %ofthe 1997 annual PM2.5 standard) or more to ambient PM2.5 concentrations in Georgia's 2012 projected nonattainment area (Atlanta). The ten states are Alabama, Illinois, Indiana, Kentucky, North Carolina, Ohio, Pennsylvania, South Carolina, Tennessee, and WestVirginia. [Source: Appendix D ofthe Air Quality Modeling Final Rule Technical Support Document, June 2011, docket item EPA-HQ-OAR-2009-0491-4140.] Table 2-6 shows the S02 emissions trends from coal-fired EGU facilities in the ten upwind states during the period 2003 through 2009. The total S02 emissions from the ten states dropped approximately 15 percent from 2003 to 2007 and over 50 percent from2003 to 2009. The trend of aggregated S02 emissions from these states is presented in Figure 2-5.

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### Georgia Portion of the Chattanooga PM 2.5

### NonattainmentArea Redesignation RequestandMaintenancePlan
Table 2-6. Annual SO, Emissions in States With Downwind Contributions to Georgia 

### PMz.s Exceeding 

### 0.15 )tg/m3



### State 2003 2005
. 2007 2009 

### AL 458,622 460,072 447,189 277,972 IL 365,333 326,632 272,571 229,364 IN 804,829 870,812 714,529 413,726 

### KY 529,559 500,224 379,837 252,002 

### NC 462,041 500,936 370,826 110,948 

### OH 1,175,905 1,085,485 954,646 600,687 PA 967,185 985,508 951,186 573,618 

## sc 203,956 217,386 172,726 97,941 

### TN 339,536 266,081 237,231 108,042 

## wv 539,858 467,082 371,996 174,583 

### TOTAL 5,846,824 5,680,218 4,872,738 2,838,883 Source: EPA CleanAirMarkets Division, Acid Rain Program EPD understands that the emissions reductions in the upwind states are not permanent and enforceable reductions in Georgia. However, we believe thatthe reductions provide further evidence that the reduced PM2.5 levels in Georgia during the period 2007

- 2009 are due to S02 emissions reductions achieved both within and outside Georgia. The majority ofupwind reductions result from state rules or consent orders requiring reduced S02 emissions. Withthe promulgation ofthe CrossState Air Pollution Rule, it is highly unlikely thatthese reductions will be reversed in the future. (It should be noted that onAugust 21, 2012, the D. C. Circuit Court of Appeals issuedthe following order to EPA: "We vacate the TransportRule [aka CSAPR] andthe Ti·ansport Rule FIPs and remandthisproceeding to EPA. EPA mustcontinue administering CAIRpending thepromulgation of a validreplacement. " Atthis point in time, EPAhas not announced their intended response to the court's ruling. So, it is unknown whether ornotEPAwill appeal the decision (either to a full panel ofthe D.C. Circuit or the U.S. Supreme Court), ifitwill conduct rulemaking in response to the comt's decision, ortake some otherpath forward. Regardless, emissions ofS02 from upwind states have declined significantly and are expected to continueto decrease inthe future.)

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### Georgia Portion of the Chattanooga PM 2.5

### NonattainmentArea Redesignation RequestandMaintenance Plan
7,000,000 6,000,000 5,000,000 

# § 4,000,000 [fiUp;,;ind States 

## I :!:. 

# "' 3,000,000 0 rn 2,000,000 1,000,000 0 2003 2005 2007 2009 

### Figure 2-5. Trend ofAggregated Annual 802 

### Emissions in States With Downwind Contributions to Georgia PM2.5 

### Exceeding 0.15 

### )tg/m3

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### Georgia Portion of the Chattanooga PM 2.5

### NonattainmentArea Redesignation RequestandMaintenance Plan



### 2.4 Section 110 and PartD Reqnirements Section 110 of the CAA contains the requirements for state implementation plans (SIPs). The purpose of a SIP is to provide for the implementation, maintenance, and enforcement of national primmy ambient air quality standards. Pmt D, Subpatt 1, of CAA Title 1 (Sections 171 to 179) contains general requirements for areas that have been designated nonattaimnent. As stated in Section 1.1 ofthis maintenance plan, the Chattanooga area was designated as nonattainment for the 1997 mmual fine PM standard in April of 2005. The area is not now and has not previously been designated nonattainment for any otherNAAQS. Georgia EPD submitted a PM25 nonattainment plan for the Georgia pottion of the Chattanooga nonattainment area per Title I Patt D. With the determination that the Chattanooga nonattainment area has attained the 1997 annual fine PM standard (Section 2.1.3), the area is no longer subject to the nonattainment provision of CAA Section 110 m1d Pmt D requirements for demonstrating attainment, RFP, associated RACM, m1d contingency requirements for areas designated as nonattainment with the NAAQS. Therefore, the nonattainment plan was subsequently withdrawn. All other Section 110 and Part D requirements pertaining to the Chattanooga area have previously been approved or are currently subject to approval by EPA.

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### Georgia Portion of the Chattanooga PM 2.5

### NonattainmentArea Redesignation RequestandMaintenance Plan


### 3.0 Maintenance Plan Section 175A of the Clean Air Act Amendments of 1990 defines the general framework of a maintenance plan. The core provisions of Section 175A are a quantitative demonstration of maintenance ofthe standard (PM2.5 in this case) and contingency provisions for prompt adoption of corrective measures ifattainment is not maintained. Per guidance from EPA,3 this maintenance plan includes a method to verifY continued attainment to support the maintenance demonstration. Per the same guidance, this plan also includes a plan to use the ambient monitoring network for verification ofcontinued attainment or, ifapplicable, for triggering contingency provisions. 

### 3.1 Maintenance Demonstration Section l75A ofthe CAA requires a state that is requesting redesignation to submit a revision to its SIP which provides for maintenance ofthe applicable standard for a minimum of 10 years after the redesignation date. Section 107(d)(3)(D) provides EPA up to 18 months from receipt ofa complete submittal to process a redesignation request. Therefore, Georgia EPD is providing a demonstration ofmaintenance through the year 2025. There are two generally-accepted methodologies for demonstrating maintenance. Under the first method, an emissions inventory is compiled for one ofthe three years which are used to show clean (i.e., attaining) ambient data (see Section 2.1). This year is the baseline or attainment year. Emissions projections are fmmulated for the fmal year of the maintenance period and for intermediate years. If each of the projected emission levels is less than the emission level for the attainment year, maintenance of the standard is demonstrated. This assumes that ambient concentrations will remain below the standard if future annual emissions are kept below the inventoried emissions in the chosen attainment year. Under the second maintenance demonstration method, air quality modeling is used to project ambient pollutant concentrations and annual design values for the final year and intermediate years. Ifall ofthe modeled rolling 3-year averages ofthe annual design values are below the standard, maintenance is demonstrated. Georgia EPD has adopted the method ofcomparing attainment year emissions to projected emissions for this maintenance plan. This approach has been used in the previous maintenance plans submitted by EPD and approved by EPA. The following sections discuss the attainment year inventory, the projected inventories, and verification ofcontinued attainment. 3.1.1 Attainment Year Emissions Inventory Georgia EPD has selected 2007 as the year for the attainment year emissions inventmy. 2007 is one ofthe three years (2007- 2009) on which the Chattanooga area's clean data determination is based. The pollutants inventoried and addressed in this maintenance plan are direct PM 2.5, S02, and NO,. The following emissions sectors are included in the inventmy: • Point sources (EGU and non-EGU). • Nonpoint sources (including fire),

3 "Procedures for Processing Requests to Redesignate Areas to Attainment," September 4, 1992. John Calcagni, Director, Air Quality Management Division, OAQPS, USEPA. 25 of47

### Georgia Portion of the Chattanooga PM 2.5

### NonattainmentArea RedesignationRequestamiMaintenancePlan

• Omoad mobile sources, and • Nonroad mobile sources (including marine vessels, aircraft, and rail). The 2007 inventmy, with the exception of on-road mobile emissions, was prepared for Georgia by the contractors for the Southeastern Modeling, Analysis, and Planning (SEMAP) project. SEMAP is funded by the same ten states that participated in the Visibility Improvement

- State and Tribal Association ofthe Southeast (VISTAS) project. Under the SEMAP project, emissions estimates are repmted by county and somce classification code (SCC). The SEMAP emissions inventories were developed using data fi'mn a number of sources, including state and local agencies and EPA's National Emissions Inventmy (NEI). Georgia Depmtment of Transportation developed the 2007 inventory ofon-road mobile emissions. The data sources for the attainment-year em1sswns inventories are summarized in Table 3-1. Additional details on the data somces and inventmy methods are presented in the following subsections and in Appendix C. Table 3-1. 2007 Emissions Inventory Sources

.. 

### Emissions Source Inventory Source Version I

### Year Basis Sector Generated

. · . 

### Point- non-EGU SEMAP Version 1.10, 2012 EPA's NEI Nonpoint SEMAP Revised Final EPA'sNEI Report, 2012
Omoad Mobile GDOT 2012 Georgia DOT (travel demand model and Highway Performance Monitoring System (1-IPMS)) and MOVES2010a Nonroad Mobile SEMAP Revised Final NMIM2008, 2007 NMIM Report, 2012 County Database, 2008 NEI, ERTAC

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### Georgia Portion of the Chattanooga PM 2.5

### NonattainmentArea Redesignation RequestandMaintenance Plan

3.1.1.1 Point Sources Point sources captured in the inventmy include stationary sources whose actual emissions equal or exceed I00 tons peryear ofS02, NO, orpatticulate matter. Emissions from point sources have been calculated for EGU and non-EGU sources. There are no EGU facilities in Catoosa orWalker counties. There is only one non-EGU point source, and it is in Walker County. The facility is C!ystal Springs Print Works, Inc. The 2007 emissions of S02, NO, and PM25 fi·om EGU and non-EGU facilities are presented inTable 3-2.

Table 3-2. Point Source Emissions for 2007 (tons, annual) Pollutant EGU Non-EGU Total Point 

## so, 0 280 280 NOx 0 48 48 PM25 0 0 0

The 2007 point source inventmy for the Georgia portion of the Chattanooga PM2.5 nonattainment area is based on the National Emissions Inventory (NEI) reports for reporting years 2005 and 2008. 2007 emissions were estimated based on a linear interpolation between facility level 2005 and 2008 emissions on a pollutant-by-pollutant basis to calculate facility-level 2007 emissions. See Appendices C and C-1 for more details on the development of the 2007 point source emissions inventmy.
3.1.1.2 Nonpoint Sources Nonpoint sources captured in the inventory include stationmy sources whose emissions levels of S02, NO, and particulate matter m·e each less than 100 tons per year. Emissions from nonpoint sources in 2007 were obtained fi·om the SEMAP final nonpoint source inventory Version 1.1. A default 2007 nonpoint source inventory was createdthat includes all ofthe source categories covered bythe 2008 nonpoint source NEI. For all source categories except industrial and commercial/institutional (ICI) fuel combustion, emissions data finn the 2008 nonpoint source NEI were directly incorporated when the NEI emissions were based on 2007 emissions activity data. The NEI emissions estimates were recalculated to reflect 2007 activity levels when the NEI emissions reflected 2006 or 2008 activity levels. Emissions associated with activity reflected in the point source inventmy were removed from the nonpoint inventory. For ICI fuel combustion, the 2008 nonpoint source NEI developed emissions activity estimates rather than emission estimates. Because ofthe potential impot1ance ofthese source categories and the availability of methodological improvements, Pechau utilized an emissions estimation method for ICI fuel combustion that incorporates a few refinements to the NEI method. These emissions 27 of47

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were supplemented with carry-forward categories fi·om Georgia's 2005 CERR submission grown using EPA's Economic Growth Analysis System (EGAS). For more information regarding the SEMAP nonpoint inventory, please refer to Appendices C and C-2. The 2007 nonpoint source emissions for Catoosa and Walker counties are presented in Table 3-3. The largest contributor to S02 

### emissions was residual-oil-fired industrial boilers. The largest contributor to NOx emissions was industrial wood-fired boilers. The largest contributor to PM 25 

### emissions was road dust from unpaved roads. Emissions fi·om fires in 2007 were obtained from the SEMAP final "actual" fire emissions inventmy and are shown in Table 3-3. This inventory was developed using 2007 burned area data submitted by Georgia, as well as updated fuel consumption and emissions factors.

Table 3-3. Nonpoint Source Emissions for 2007 (tons, annual) Pollutant Nonpoint Fire Total (excludine: fire) Nonpoint 

## so, 68 9 77 

### NOx 303 55 359 PM25 

### 1,354 195 1,548
The 2007 level of PM2.5 

### emissions from nonpoint sources, excluding fire, was 1,354 tons. This quantity accounted for over 75 percent oftotal PM25 

### emissions in Catoosa and Walker counties. The top three nonpoint source classifications for PM2.5 

### emissions were dust from unpaved roads, industrial wood-fired boilers, and residential open burning ofhousehold waste (see Table 3-4).
Table 3-4. Largest Nonpoint PM2.5 

### Emissions by Source Classification



## sec Description 2007PMz.s (tons) 2296000000 Unpaved Roads /All Unpaved Roads /Total: 665 Fugitives 2102008000 Stationmy Fuel Comb /Industrial /Wood /Total: 165 All Boiler Types 2610030000 Open Burning/Residential /Household Waste 140

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3.1.1.3 OnroadMobile Sources U.S. EPA's MOVES2010a mobile source emissions model was mn in rate look-up mode, and datasets were interpolated between 2002 and 2009 to generate 2007 on-road mobile source emissions of S02, NOx. and 

### PM25 since 2007 modelmns were not available. The 2007 onroad mobile source emissions for Catoosa and Walker counties are presented in Table 3-5.
Table 3-5. OnroadMobile Source Emissions for 2007 (tons, annual) Pollutant · Onroad Emissions 

## so, 20 NOx 4442 

### PM25 134 Best available local data for MOVES inputs such as vehicle population, vehicle miles traveled (VMT) by source types, road type distribution, speed distributions, ramp fractions, hourly VMT fractions and age distribution were used. The Chattanooga Metropolitan Planning Area (MPO) travel model includes all of Catoosa County and the portion ofWalker County within the MPO planning area. The Travel Demand Model is used to estimate VMT and congested flow speeds for the subregions included in the travel model. Offmodel, Highway Performance Monitoring System (HPMS) based modeling techniques were used to calculate emissions for the "donut" pmtion ofWalker County that falls outside the MPO planning and travel modeling area. Age distribution was based on MOVES national defaults. Source type population inputs were based on 2002 vehicle registration data with MOVES national default vehicle type ratios. Meteorological information was obtained from EPA's National Mobile Inventmy Model for 2007. For a detailed discussion on how the on-road mobile emission inventmy was developed, see Appendix C-3.
3.1.1.4 NonroadMobile Sources The nonroad sector is comprised ofnonroad engines included in EPA's NONROAD model, such as recreational marine and land-based vehicles, farm, construction and industrial machinery, and lawn and garden equipment. This sector also includes engines not modeled in NONROAD, specifically aircraft, commercial marine vessels, and locomotives. There are no commercial marine vessel emissions sources in Catoosa and Walker counties. 2007 nonroad mobile emissions are presented in Table 3-6. Emissions from NONROAD model source categories in 2007 were obtained from the SEMAP final nonroad mobile sources emissions inventory. These emissions were calculated using EPA's latest National Mobile Inventory Model, NMIM2008, which incorporates EPA's latest NONROAD model (NONROAD2008) and reflects all ofEPA's final nomoad standards to date. The county/monthly gasoline profile assignments in the County/Year/Month table and the gasoline fuel profiles in the Gasoline table ofthe 2007 NMIM county-level database (NCD) were updated with data provided by
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the state ofGeorgia. For more information regarding the SEMAP nonroad inventory, please refer to Appendices C and C-2. 2007 Emissions from aircraft and locomotives were obtained from the SEMAP final nonroad mobile source emissions inventory. For more information regarding the SEMAP marine, aircraft, and locomotives inventory, please refer to Appendices C and C-4.



### Table 3-6. NonroadMobile Source Emissions for 2007 (tons, annual) Pollutant Nonroad 

## - Aircraft Locomotive Total (tons) except _air and 

### Nonroad rail 

### so2 26 0.2 2 27 NOx 

### 450 1 182 633 PM2.s 43 3 5 51 3.1.1.5 Summmy of2007Emissions 1nventmy 

### The total 2007 Catoosa and Walker County emissions ofS02 , NO" 

### and PM25 are presented for each source sector in Table 3-7. The majority of S02 emissions, by far, are fi·om point sources. The majority of NO, 

### emissions are fi·om onroad mobile sources. The majority of PM25 emissions are from nonpoint sources. 

### Table 3-7. Attainment-year (2007) Emissions Inventory (tons, annual) Pollutant Point Point. ·. Point Nonpoint Onroad Nonrmid Total

(tons) Total 

### EGU ... Non- Mobile Mobile



## . EGU

. .· 

### so2 280 0 280 77 

### 20 27 404 NOx 

### 48 0 48 359 4,442 633 5,482 PM2.s 0 0 0 1,548 134 51 1,733

3.1.2 Projected Emissions Inventories As discussed previously, Georgia EPD is providing a demonstration ofmaintenance through the year 2025 (the maintenance year). Emissions projections to suppmt maintenance through 2025 have been prepared for the years 2017 and 2025. In 

### addition, emissions have been calculated by interpolation for the years 2014 and 2020. Emissions for these additional years provide additional reference points for periodic assessment of maintenance of the standard. Maintenance period emissions controls, projection methods, and projected inventories are discussed in the remainder of this subsection.
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3.1.2.1 Methods andProjectedInventories Projected emissions inventories are calculated by applying applicable control and growth factors to the 2007 emissions of individual sources or source categories. The control and growth factors may apply for some or all of the years 2008 (year following attainment inventmy) through 2025 (out· year). The bases used to determine these factors are summarized in Table 3-8.
Table 3-8. Bases ofControl and Growth Factors for 2017 and 2025 Inventories

Point- non-EGU Nonpoint Nonpoint- fire Onroad Mobile

NomoadMobile Nonroad Mobile 

### -marine, aircraft, and rail Regulatory review

- no additional controls defined at this time EGAS growth factors by SCC and county for 2017 and 2025. Regulatmy review

- no additional EGAS growth factors by SCC for 2017 controls defined at this time and 2025. No additional controls anticipated MOVES rate look-up mode (PM25, NO" S02) for 2025. All known Federal controls.

NMIM2008 No growth anticipated MOVES rate look-up mode (PM25 , NO" S02) for 2025. Vehicle population growth from human population projections. Vehicle miles traveled (VMT) growth from Georgia DOT. NMIM2008 SEMAP (Pechan) control factors SEMAP (Pechan) growth factors by SCC by 

## sec for 2017 and 2025 for 2017 and 2025

The pollutants whose emissions are projected are S02, NO" and direct PM2.5• As with the attainment inventmy, emissions from the following sectors are projected: • Point sources (non-EGU). • Nonpoint sources (including fire) • Onroad mobile sources. and • Nonroad mobile sources (including marine vessels, aircraft, and rail). The projected inventories are presented in the following subsections. The methods used to develop the emissions projections are presented in more detail inAppendix C.

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3.1.2.2 PointSources There are no EGU facilities in Catoosa or Walker counties. Projected non-EGU point source emissions are shown in Table 3-9 (county totals). The emissions for 2017 and 2025 were estimated using SCC-specific and county-specific growth factors generated with EPA's Economic Growth Analysis System version 5.0 (EGAS 5.0). Appendix C-6 contains the SCC-specific growth factors for Catoosa and Walker counties. The projections show small increases in emissions for S02 and NOx. No additional future controls can be defined for non-EGU point sources at this time. Emissions levels for 2014 and 2020 were calculated by linear interpolation.



### Table 3-9. Projected Point Source Emissions (tons) Pollutant 2007 2014 2017 2020 2025

. (attainment) EGU



## so, 0 0 0 0 0 NO, 0 0 0 0 0 PM2.5 0 0 0 0 0 Non-EGU



## so, 280 285 287 290 295 NOx 48 49 49 50 52 PM2.5 0 0 0 0 0 TotalPoint



## so, 280 285 287 290 295 NOx 48 49 49 50 52 PM2.5 0 0 0 0 0



### 3.1.2.3 Nonpoint Sources Nonpoint source emissions, excluding fire, in future years 2017 and 2025 were estimated using SCCand county-specific growth factors generated with EGAS 5.0. Appendix C-6 contains the 

## secspecific growth factors for Catoosa and Walker counties. No additional future controls can be defined for these sources atthis time. Projections ofnonpoint source emissions are presented in Table 3-10. Emissions from fire in future years 2017 and 2025 were assumed to be the same as 2007 emissions. The projections show a small increase in emissions ofS02 as well as moderate increases in emissions ofNO, and PM2.5 .

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Table 3-10. Projected Nonpoint Source Emissions (tons) Pollutant 2007 

### 2014 2017 2020
. 

### (attainment) Nonpoint**(excludin~**

### lire)



## so, 68 72 74 75 NOx 303 342 358 374 PM25 

### 1,354 1,535 1,612 1,684 

### Fire



## so, 9 9 9 9 NOx 55 55 55 55 PM2.5 

### 195 195 195 195 

### TotalNonvoint



## so, 77 

### 81 82 84 NOx 359 397 414 430 PM25 

### 1,548 1,729 1,807 1,878 2025

.



### 78 401 1,804
9 55 195

87 456 1,998 The top three nonpoint source classifications for 2025 PM25 

### emissions are dust from unpaved roads, industrial wood-fired boilers, and residential open buming of household waste (see Table 3-11). Projected PM2.5 

### emissions from these three source classifications make up over 60 percent oftotal projected PM2.5 

### emissions. Table 3-11. 

### Largest Nonpoint PM2.5 

### Emissions by Source Classification, Year 2025



## sec Description 2025PM 2.5 

### (tons) 2296000000 Unpaved Roads I AU 

### Unpaved Roads /Total: 885 Fugitives 2102008000 Stationmy Fuel Comb /Industrial /Wood /Total: 223 AU 

### Boiler Types 2610030000 Open Burning/Residential /Household Waste 186

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3.1.2.4 OnroadMobile Sources 

### U.S. EPA's MOVES2010a mobile source emissions model was run in rate look-up mode to generate 2025 onroad mobile somce emissions of S02, 

### NOx. and PM2.5. 

### Intermediate year emissions were generated by interpolating between 2007 and 2025. VMT and congested flow speeds were estimated by the travel demand model for areas within the MPO. VMT estimates derived fi·om the travel demand model were adjusted based on Federal Highway Administration HPMS traffic count data fi·om Georgia. Outside the MPO, VMT was estimated using GA HPMS traffic count data. The vehicle age distribution was based on MOVES national defaults. Source type population inputs were based on 2002 vehicle registration data with MOVES national default vehicle type ratios. Temperature and humidity inputs were assumed to be the same as year 2007. The projected onroad mobile source emissions levels are presented in Table 3-12. Onroad emissions of all three pollutants trend downward during the maintenance period. The trend in S02 

### is of less importance since onroad mobile sources emit very little S02• 

### For a detailed discussion on how the onroad mobile emission inventmy was developed, see Appendix C-3. 

### Table 3-12. Projected Onroad Mobile Source Emissions (tons) Pollutant 2007 

### 2014 2017 2020 2025

(tons) (attainment) 

## so, 20 17 15 14 II 

### NOx 4,442 3,112 2,542 1,972 1,022 PM2.5 

### 134 96 80 63 36 3.1.2.5 NonroadMobile Sources 

### Projections ofnonroad emissions in 2017 and 2025, excluding air and rail sources, were calculated using NMIM2008 with the same meteorological inputs as for 2007. Defaults in NMIM 2008 were used for other inputs. Growth factors for all aircraft engine and airpmt-related SCCs were based on landing and take-off operation (ITO) projections available from the Federal Aviation Administration's Tenninal Area Forecasts (FAA, 2010). Growth rates for military aircraft were held constant at 2007 levels. No control factors were applied to aircraft emissions. Growth factors for freight rail sector emissions were based on fuel consumption forecasts. For passenger and commuter rail, growth factors were developed from national forecasts ofintercity rail diesel consumption and commuter rail diesel consumption. Control factors were based on U.S. EPA's locomotive engine regulatmy impact analysis and associated emission factor guidance. The nonroad mobile source emissions projections are presented in Table 3-13. Total emissions ofall three pollutants trend downward during the maintenance period. As with omoad sources, the downward trend in S02 

### is of less impmtance since nonroad sources emit ve1y little S02. 

### For a

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detailed discussion on how the nonroad mobile emissions projections were developed, see Appendix C. 

### Table 3-13. Projected Nonroad Mobile Source Emissions (tons) Pollutant 2007 

### 2014 2017 2020 2025 (tons) 

### (attainment) Nonroad*



## so, 26 8 0.6 0.6 0.6 NO, 

### 450 296 230 204 160 PM 25 

### 43 31 26 23 17 Aircraft



## so, 0.2 0.2 0.2 0.2 0.2 NOx 

### 1 1 1 I I 

### PM25 

### 3 3 3 3 3 Locomotive



## so, 1.6 0.5 0.1 0.1 0.1 NOx 

### 182 153 141 132 116 PM,.s 

### 5 4 3 3 2 Tot. Nonroad



## so, 27 8.8 0.8 0.8 0.9 NO, 

### 633 450 372 336 277 PM,.s 

### 51 38 32 28 22 

## *excludmg mrcraft and locomotive emiSSions
3.1.3 EmissionsProjections SummaryandDemonstration ofMaintenanceofAttainment
The consolidated emissions projections for all Catoosa and Walker County sources are presented in Table 

### 3-14. Emissions of 

### S02 and NOx drop from 

### 2007 to 

### 2025. This is a reflection of the implementation ofthe majority ofstate and federal controls during the first halfofthe maintenance period. Overall, emissions of 

### S02 and NOx are projected to decline by 

### 2.5 percent and 

### 67 percent, respectively, over the course ofthe maintenance period. Emissions of 

### PM 25 rise from 

### 2007 through 

### 2025. This is a reflection of an increase in nonpoint source emissions (primarily road dust and industrial wood boilers) which is pmtially offset by reductions in the omoad and nonroad sectors. The overall rise in 

### PM 25 is 

### 18.6 percent ofattainment year emissions. Therefore, fmther evaluation is needed to judge whether the increase ·in 

### PM 25 emissions, in combination with the decreases in 

### S02 and NOx emissions, is likely to provide for maintenance ofthe standard.



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Table 3-14. Projected Emissions- Total ofAll Sectors (tons) Pollutant 2007 2014 2017 2020 2025 % change, (tons) 

### (attainment) 2007-2025 

## so, 404 391 385 389 394 -2.5 NOx 5,482 4,009 3,377 2,788 1,806 -67.1 PM25 1,733 1,863 1,918 1,970 2,056 +18.6

Each of the three pollutants is characterized by a different relationship between emissions and air quality. Therefore, simply summing the emissions ofthe pollutants does not provide a meaningful indicator ofthe combined air quality impact ofthese emission changes. A more appropriate indicator is the percentage change in emissions for each emitted pollutant, weighted according to the air quality impact for each. For this purpose, Georgia EPD examined speciation data available from the EPA Air Explorer Web site for 2007- 2009 for the Chattanooga monitor (site 47-065-4002). The 3-year average ofthis data suggests that ambient PM25 in Chattanooga consists of approximately 48.1 percent sulfate, 2.4 percent nitrate, 40.6 percent organic particulate (which consists of directly-emitted primary organic matter and atmospherically fanned secondmy organic aerosol), 5.0 percent misceJlaneous inorganic particulate (sometimes labeled "crustal particles"), and 3.9 percent other types ofparticulate matter. Therefore, using a conservative assumption that all of the organic particulate is primary organic matter, direct PM2

_ 5 species make up 45.6 percent (sum of40.6 and 5.0) ofthe total ambient PM25 . Georgia EPD used a conservative approach that assumes that the :filii ambient concentration of organic particulate matter plus miscellaneous inorganic particulate matter will vmy in accordance with changes in total nonattainment area emissions ofdirect PM25 . This analysis thus assumes that the direct PM25 component of ambient PM2

_ 5 will increase by the 18.6 percent projected increase in direct PM25 emissions. This approach was used by U.S. EPA in its evaluation and approval ofthe annual PM25 redesignation request for the Evansville, Indiana, nonattainment area (see 76 FR 29695 and 76 FR 59527). In the Chattanooga analysis, the baseline concentration is conservatively assumed to be 15.0 f1g/m3• Direct PM2

_ 5 is estimated to contribute 45.6 percent, or 6.84 ftg/m3
, of the 15.0 ftg/m3

. Georgia EPD's assessment assumes that the projected increase in direct PM2

_ 5 emissions will cause a corresponding 18.6 percent increase in ambient concentrations of PM2.5, which would suggest an increase in the ambient concentration ofthe direct PM2

_ 5 component by 1.27 f1g/m3• However, Georgia EPD believes that this potential increase will be fully offset by a greater decrease in sulfate and nitrate concentrations. The precise decrease in sulfate and nitrate concentrations is a complicated result of emissions reductions notjust in Chattanooga, but also in many other parts of the Eastern United States. Modeling conducted by EPA for the Cross State Air Pollution Rule (CSAPR) estimated that future Chattanooga concentrations with the final CSAPR in place would be 3.7 f1g/m3 below the standard (2014 Remedy Average case*). In addition, the emissions reductions that have already occurred have brought measured Chattanooga concentrations to 11.6 ftg/m3 (as shown in Table 2-2). Therefore, the 1.27 f1g/m3 increase in the components associated with direct PM2

_ 5 would not be expected to yield concentrations above the standard. That is, GA EPD believes 36 of47

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that maintenance ofthe annual PM2.5 standard is demonstrated despite the small projected increase in direct PM 2.5 emissions. 

## * Air Quality Modeling Final Transport Rule Technical Support Document, docket item EPA-HQOAR-2009-0491-4140.
3.1.4 Emissions Decreases An emissions smplus represents the degree ofimprovement (reduction) in 2025 emissions compared to the attainment year (2007) emissions. The surpluses are shown in Table 3-15 for each pollutant. A positive surplus reflects an emissions decrease from the attainment year to 2025. The negative surplus for PM2.5 reflects a projected increase in emissions. A portion of the NO, surplus will be allotted to the Motor Vehicle Emissions Budget as a safely margin (see Section 4).
Table 3-15. Emissions Decrease

Pollutant Surplus . Emissions*

. 2007 to2025 (tons) 

## so, 10 NOx 

## ** 3,676 PMz.s 

## ** -323 

## * Surplus= (2007 emissions level)- (2025 emissions level) **These quantities do not reflect allotment to MotorVehicle Emissions Budget

3.1.5 Verification ofContinued Attainment Items 5.c and 5.d of the September 4, 1992, EPA guidance memo outline requirements for verification of continued attainment. Verification ofcontinued attainment is accomplished through operation of the ambient PM2.s monitoring network and through periodic updates of the area's emissions inventory. The location and operation ofEPD's FRM monitor in Georgia's portion ofthe Chattanooga area are described in Section 2.1 ofthis plan. During the maintenance period EPD will continue to operate a federal reference monitor in Walker County per the requirements of40 CFR Part 58. The Consolidated Emissions Repmting Rule (CERR) was promulgated by EPA on June I0, 2002. The CERR was replaced by the Annual Emissions Repmting Requirements (AERR) rule on December 17, 2008. The most recent triennial inventory for Georgia was compiled for 2008. The larger point sources of air pollution will continue to submit data on their emissions on an annual basis as required by the AERR. Emissions from the rest ofthe point sources, the nonpoint source pmtion, and the omoad and nonroad mobile sources continue to be quantified on a tlu·ee-year cycle. The inventory will be updated and maintained on a tlu·ee-year cycle. As required by the AERR, the next overall emissions inventory will be compiled for 20II.

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### 3.2 Contingency Provisions Section 175A(d) of the Clean Air Act requires that the maintenance plan include provisions for contingency measures that would promptly be implemented to correct a violation of the standard, should this**occm~** after redesignation of an area as an attainment area. The measures may include rules or other measures that are not yet effective, but EPD agrees to adopt and implement, as expeditiously as practicable, when required by this plan. The minimum requirement for contingency provisions is the implementation ofall measures that were contained in the SIP for the area (i.e., the nonattainment plan) before the redesignation. In addition, EPA guidance (John Calcagni memo dated September 4, 1992) specifies the following pertaining to contingency provisions in the maintenance plan:
• identification of additional measures that would be considered for implementation should a violation occur; • identification oftriggers for the implementation ofadditional contingency measures; and • a schedule and procedure for adoption and implementation ofadditional measures (with time limit). 3.2.1 Contingency Measure Triggers Section 175A(d) of the Clean Air Act Amendments requires that the maintenance plan include provisions for contingency measures that would promptly be implemented by the state to correct any violation ofthe annual PM25 NAAQS after redesignation ofan area as an attainment area. A list of potential contingency measures that could be considered for future implementation in such an event should also be included in the maintenance plan. EPD has developed a contingency plan for the Georgia pmiion of the Chattanooga PM 2.5 maintenance area. Contingency measures are intended to provide further emission reductions in the event that violations of the NAAQS occur after redesignation to attainment. Consistent with this plan, EPD agrees to adopt and implement, as expeditiously as practicable, the necessmy con·ective actions in the event that violations of the standard occur within the maintenance area after redesignation to attainment. Contingency measures as described below would be adopted and implemented within 24 months ofa contingency trigger unless EPD has demonstrated that technical or economic feasibility warrm1ted a period longer than 24 months. EPD will use actual ambient monitoring and emissions inventory data as the indicators to determine whether contingency measures would be implemented. ln accordance with 40 CFR Pmi 58, ambient monitoring data that indicates a violation of the annual 

### PM 25 NAAQS will begin the process to implementthese contingency measures according to the protocols identified below. The contingency plan provides for corrective responses should the NAAQS be violated, or ifemissions inthe Georgia pmtion ofthe Chattanooga maintenance area increase significantly above current levels. Tier I. A Tier 1 trigger is activated when any one of the following conditions occurs:
• the previous calendaryear's annual average PM25 concentration exceeds the standard by 1.5 ug/m3 or more; • the mmual average 

### PM 25 concentration in each ofthe previous two consecutive calendar years exceeds the standard by 0.5 ug/m3 or more;

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• the total maintenance area S02 emrssrons in the most recent NEI exceeds the corresponding attainment-year inventmyby more than 30.0 percent; and • the total maintenance area PM2.s emissions in the most recent NEI exceeds the corresponding attainment-year inventory by more than 30.0 percent. EPD will conduct an evaluation as expeditiously as practicable to determine ifthe trend is likely to continue. If it is determined that additional emission reductions are necessary, EPD will adopt and implement any required measures in accordance with section 3.2.2. The PM2.5 trigger concentrations described above apply to the PM2.5 federal reference monitors in the maintenance area. EPD will evaluate a Tier I condition, ifit occurs, as expeditiously as practicable to determine the cause(s) ofthe ambient PM2.5 or emissions inventory increase and to determine ifa Tier IIcondition (see below) is likely to occur. Tier II. A Tier II trigger is activated when any violation ofthe annual PM2.s NAAQS at any FRM ambient monitoring station in the Chattanooga maintenance area is recorded, based on qualityassured monitoring data. In this event, EPD will conduct 

### a comprehensive study to determine the cause(s) ofthe ambient PM,.s increase and to determine ifthe increase is likely to continue and will implement any required measures as expeditiously as practicable, taking into consideration the ease ofimplementation and the technical and economic feasibility ofselected measures. 3.2.2 Schedule andProcedureforAdoption andImplementation ofContingencyMeasures EPD will, in the event of I) a Tier II trigger condition or 2) 

### a Tier I condition in which EPD has determined that a Tier II condition is likely to occur, conduct a comprehensive study to determine whether or not contingency measures are required for the maintenance ofthe PM 2.s standard. Since Catoosa and Walker counties may be influenced by emissions from outside the maintenance area, the study will attempt to detennine whether the trigger condition is due to local emissions, emissions from elsewhere, or a combination ofthe previous. The comprehensive analysis, based on qualityassured ambient data, will examine:

• the severity ofthe trigger condition; • the meteorological conditions (in the case of an ambient concentration trigger) associated with the trigger condition; • potential contributing local emissions sources; • potential contributing emissions resulting from regional or long-range transpmi; • the geographic applicability ofpossible contingency measures; • emission trends, including implementation timelines of potential control measures; • timelines of"on-the-books" (adopted) measures that are notyet fully implemented [e.g., Georgia Rule (sss) and Rule (mm) S02 controls]; and • current and recently identified control teclmologies. The comprehensive study will be completed and submitted to EPA as expeditiously as practical but no later than nine months after the Tier I or Tier II trigger is activated. IfEPD determines, through the comprehensive study, that contingency measures are required for maintenance of the standard, the appropriate corrective measures wi11 be adopted and implemented within 18 to 24 months after the Tier I or II trigger occurs. These control measures which will continue to produce substantial reductions in fine particulate matter and its precursors in excess of what is relied upon in this maintenance plan, include the Georgia Multipollutant Rule, which is described in section 2.3.2.1 of 39 of47

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### NonattainmentArea RedesignationRequestandMaintenance Plan

this maintenance plan, as well as diesel engine retrofit, replacement, and repowering programs and truck stop electrification programs which are currentlybeing implemented by Georgia EPD. Ifthe study determines that additional measures are required, rules will be adopted no later than 18 months following the date on which the Tier I or Tier II trigger is activated. Selection ofmeasures will take into consideration the ease ofimplementation as well as technical and economic feasibility. If it is determined that adoption and implementation of a rule will take longer than 24 months following the trigger date, EPD will submit for EPA's approval a revised schedule for the development and adoption ofcontingency measures. 3.2.3 ContingencyMeasures Ifthe analysis required above determines emissions from the local area are contributing to the trigger condition, EPD will evaluate those measures as specified in Section 172 of the CAA for control options as well as other available measures. Ifa new measure/control is already promulgated and scheduled to be implemented at the federal or state level, and that measure/control is determined to be adequate, additional local controls may be unnecessary. Under Section 175A(d), the minimum requirement for contingency measures is the implementation of all measures that were contained in the SIP before the redesignation. Currently all such measures are in effect for the Chattanooga NAA; however, an evaluation ofthose measures, such as RACT, can be performed to determine ifthose measures are adequate or up-to-date. In addition to those identified in section 3.2.2, contingency measure(s) will be selected from the following types ofmeasures or from any other measure deemed appropriate and effective at the time the selection is made:
• ReasonablyAvailable Control Measures (RACM) for sources ofS02 and PM2.5 ; • ReasonablyAvailable Control Technology (RACT) for point sources ofS02 and PM2.5 ; • Expansion ofRACM/RACTto area(s) oftransport within the State; • Mobile source measures; and • Additional S02 and/or PM25 reduction measures yetto be identified. Any resulting contingency measure(s) will be based upon cost effectiveness, emission reduction potential, economic and social considerations, ease and timing of implementation, and other appropriate factors. Adoption of additional control measures is subject to necessmy administrative and legal processes. EPD will solicit input from interested and affected persons (stakeholders) in the area prior to selecting appropriate contingency measures. No contingency measure will be implemented without providing the opportunity for full public patticipation. This process will include issuance ofnotices, m1 opportunity for public hearing, and other measures required by Georgia law.

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### 4.0 Motor Vehicle Emissions Budget The transpmtation confonnity rule (40CFR93.100

- 40CFR93.129) ensures that projects and plans funded by the Federal HighwayAdministration and the Federal Transit Administration conform to air quality SIPs and maintenance plans. h1 

### the case ofa NAAQS maintenance plan, the rule requires a motor vehicle emissions budget (MVEB) to be established for the last year ofthe plan's maintenance period. The rule, at 40CFR93.124(a), describes a motor vehicle emissions budget as "
...the implementation plan's estimate offuture [motor vehicle

## Jemissions." Such budgets establish caps on motor vehicle emissions; projected emissions from transpmtation plans and programs must be equal to or less than these caps for a positive conformity dete1mination to be made. Transpmtation conformity determinations are required for non-exempt, federally-funded highway and transit projects before they are funded and approved and for transpottation plans and transportation improvement programs. The budget presented in this section applies to the Georgia pmtion ofthe Chattanooga NAA only. 

### 4.1 Pollutants For Catoosa and Walker counties, MVEBs will be set for direct PM2.s 

### and NOx only. 40 CFR Patts 93 .119(f)(7) through (1

### 0) identifY the PM 2.5 

### pollutants which must be analyzed for transpmtation conformity purposes. These patts ofthe rule are listed below: §119(j)(7)- PM 2.5 in PM 25 areas; §119(j)(8)

- Reentrainedroaddust in P M2.5 areas only 

### if the EPA [EnvironmentalProtectionAgency} Regional Administrator or the director ofthe State air agency has made afinding that emissions from reentrained roaddust ·within the area are a significant contributor to the PM2.s nonattainment problem andhas so notifiedthe MPO andDOT[Department of Transportation}; §119(j)(9)- NO, [nitrogen oxides] in PM 25 areas, unless the EPA RegionalAdministrator and the director of the State air agency have made afinding that emissions ofNO,fi'O/n within the area are not a significant contributor to the PM 25 nonattainmentproblem and has so notified the MPO and DOT; and §119(j)(10)- VOC, S0 2 and/or ammonia in PM 2 .5 areas 

### ifthe EPA Regional Administrator or the director of the State air agency has made afinding that any of suchprecursor emissionsfi'om within the area are a significant contributor to the PM 25 nonattainmentproblem and has so notified the MPOandDOT 

### Primaty, or direct, PM2.5 

### emissions must be considered for all transportation conformity regional emissions analyses. For Chattanooga, NOx must also be considered since EPA has not approved Georgia EPD's finding that NOx is not a significant contributor to the PM 25 

### nonattainment problem in Chattanooga. None ofthe other pollutants identified (reentrained road dust, VOC, and ammonia) above have been determined by EPA or Georgia EPD to be significant contributors to PM nonattainment in Chattanooga. S02 

### from coal combustion is significant but levels ofS02 

### emissions from mobile sources m·e vmy low and, therefore, not significant for transpmtation conformity purposes. 41 of47

### Georgia Portion of the Chattanooga PM2.sNonattainmentArea Redesignation RequestandMaintenance Plan
4.2 Methodology In preparation ofthis Chattanooga PM2.5 

### Maintenance Plan, EPD worked closely with the Georgia Department of Transpottation (GDOT) and the Chattanooga-Hamilton County-Nmth Georgia Transpmtation Planning Organization (TPO) to develop the estimates ofmobile source emissions for the Georgia portion of the Chattanooga nonattainment area. The Chattanooga-Hamilton CountyNmth Georgia Transpmtation Planning Organization is the metropolitan planning organization (MPO) for the Chattanooga urbanized area. Mobile source inventories for 2025 were developed using the latest available planning assumptions, the most recent travel demand model, EPA's latest motor vehicle emission factor model, and, in the case of Georgia counties in the MPO, vehicle population and age distributions developed from registration data obtained from R.L. Polk & 

### Company. The methodology used to calculate the highway mobile source emissions on which the 2025 MVEBs are based is discussed below. Emissions fi·om motor vehicles were estimated as a sum ofproducts ofvehicle activity measures and vehicle emissions factors. Vehicle activity measures (e.g. vehicle miles traveled, or VMT) were determined from a county-specific travel demand model and/or HPMS traffic count data. Vehicle emissions factors were determined from a motor vehicle emissions model. See Appendix C-3 for more details on the development of the travel demand model and the determination of emissions factors. The MOVES201 Oa motor vehicle emission model was used to calculate 2025 emission factors with all currently known 2025 mobile source control rules in place. The MOVES model was run in rate look-up mode. The emission factors reflect all federal controls, e.g., the Federal Motor Vehicle Control Program including Tier 1 and (beginning with 2006 models) Tier 2 tailpipe standards; and the National Low Emission Vehicle program. MOVES20IOa produces three sets ofemission factors per run: • rate per distance; • rate per vehicle; and • rate per profile. Of these three types of emission factors, the first is multiplied by VMT and the second two by vehicle population. Note that rate-per-profile emissions (i.e., vapor venting) are not applicable to PM2.5 

### modeling. The Chattanooga TPO travel demand model is developed and maintained by Cambridge Systematics, Inc., and model output for the Georgia portion ofthe MPO is managed by GDOT. Inputs to the model are socioeconomic data and the highway network that consists ofroadway segments (links) and intersections (nodes). Outputs include vehicle activity, number oftrips, vehicle population, and other data. The use of a county-specific travel demand model for transpmtation conformity calculations is consistent with the transportation conformity rule at 40CFR93.122(b) and (d), which requires a network-based travel model emissions estimation methodology if the use of such procedures has been the previous practice ofthe MPO. The use ofsuch a methodology has been the previous practice ofthe Chattanooga TPO. Off-model techniques based on HPMS data were used to calculate emissions for the portion ofWalker County that falls outside the Chattanooga MPO area but is still inside the non-attainment area (referred to as a "donut" area).
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### Georgia Portion of the Chattanooga PM 2.5

### NonattainmentArea Redesignation RequestandMaintenance Plan
Section 93.105(b) of the Transpmtation Conformity Rule and Sections I06(g) and I06(h) of Georgia's transpmtation conformity SIP require interagency consultation for SIP development. Accordingly, a detailed listing of the procedures and planning assumptions used for the regional emissions analysis suppmting development of the MVEB was presented to the Chattanooga interagency consultation committee for review in November of 2011. The assumptions used to develop Chattanooga's conforming Long Range Transpmtation Plan and Transpmtation Improvement Program were also used to develop the network and emissions for this maintenance planMVEB. 

### 4.3 MotorVehicle Emissions Budgets and Safety Margins The projected 2025 on-road motor vehicle emissions for direct PM2_, 

### and NO, are 36 and I,022 tons, respectively. A budget for S02 

### is not required. On-road emissions ofS02 

### are considered to be 

### "de

### minimis" (70FR 24283), and, therefore, no budget is necessaty. The on-road mobile emissions, emissions budgets, and safety margins are preseuted in Table 4-1. A safety margin is necessaty to accommodate the variabilities or worst-case scenarios that can occur due to future planning assumptions. The worst-case daily motor vehicle emtsstons projection for PM2

_ 5 

### is 22.8 percent above the projected 2025 on-road emissions. In a worst-case scenario, the needed annual safety margin for the MVEB would be 8.2 tons resulting in an overall MVEB of44.2 tons per year. The worst-case daily motor vehicle emissions projection for NOx is 35.7 percent above the projected 2025 on-road emissions. In a worst-case scenario, the needed annual safety margin for the MVEB would be 364.6 tons resulting in an overall MVEB of 1,386.5 tons peryear.
Table 4-1. 2025 MotorVehicle Emissions, Emissions Budgets, and Safety Margins Pollutant Projected 2025 Safety Margin Safety Margin MVEB* with Safety On-Road Allottee! to MVEB Allotted to Margin (tons) Emissions (%) 

### MVEB(tons) (tons) PM 25 

### 36.0 22.8 8.2 44.2 NO, 1,021.8 35.7 364.6 1,386.5 *MVEB for the Georgia pmtion ofthe Chattanooga NAA.

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### NonattainmentArea Redesignation RequestandMaintenance Plan


### 5.0 Conclusion Section 107(d) of the CAA states that an area can be redesignated to attainment if the following conditions are met: 1. The EPA has determined that the NAAQS has been attained. 2. The applicable implementation plan has been fully approved by EPA under Section IIO(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 PartD. 5. The EPA has fully approved a maintenance plan, including a contingency plan, for the area as required by CAA Section 175A.


### Table 

### 5-1. Summary ofProjected S02 

### Emissions -Total ofAll Sectors (tons) 

### 2007 attainment 2014 2017 2020 2025 Source (tons) (tons) (tons) (tons) (tons)
Point

- total 

### 280 285 287 290 295 Area- total 77 

### 81 82 84 87 Non-road- total 

### 27 8.8 0.8 0.8 0.9 Onroad 

### 20 17 15 14 II Total 

### 404 391 385 389 394

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Table 5-2. 

### Summary ofProjected NO, Emissions- Total ofAll Sectors (tons)

. 2007 

### attainment 

### 2014 2017 2020 2025 Source (tons) (tons) (tons) (tons) (tons)

. Point

- total 48 49 49 50 52 Nonpoint- total 359 397 414 430 456 Non-road -total 633 450 372 336 277 Onroad 4,442 3,112 2,542 1,972 1,022 Onroad Safety 364.6 Margin Total 5,482 4,009 3,377 2,788 2,171



### Table 5-3. 

### Summary ofProjected PM2.5 

### Emissions -TotalofAll Sectors (tons)
2007 

### attainment 

### 2014 2017 2020 2025 Source (tons) (tons) (tons) (tons) (tons)

. Point- total 0 0 0 0 0 Nonpoint- total 1,548 1,729 1,807 1,878 1,998 Non-road- total 51 38 32 28 22 Onroad 134 96 80 63 36 Onroad Safety 8.2 Margin Total 1,733 1,863 1,918 1,970 2,064

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### NonattainmentArea Redesignation RequestandMaintenance Plan
The supporting documentation to show that the above conditions have been met for the Georgia portion ofthe Chattanooga nonattainment area is contained in this document. Based on the 2007- 2009 monitored design value for the Chattanooga nonattainment area, EPA has published in the Federal Register its final rule that the nonattainment area has attained the 1997 annual average PM25 NationalAmbient Air Quality Standard (NAAQS). The maintenance demonstration in this document shows that, based on comparison ofprojected emissions to attainment year emissions, emissions are expected to stay at or below levels commensurate with attaining air quality through the year 2025 as illustrated by Tables 5-l, 5-2 and 5-3 above. Analysis was presented to demonstrate thatthe standard will be maintained despite a projected increase in direct 

### PM 25 emissions. This document also contains provisions for contingency measures should emissions levels or ambient concentrations rise unexpectedly. EPA's concurrence that the improvement in Chattanooga's air quality is due to permanent m1d enforceable reductions in emissions and EPA's approval ofthis document will satisfy Items 3 and 5 above. Therefore, Georgia EPD requests that the Georgia pmtion ofthe Chattanooga nonattainment area, Catoosa and Walker counties, be redesignated from nonattaimnent to attainment with respect to the !997 ammal NAAQS for fine particulate matter. In addition, 2025 MVEBs have been presented for omoad mobile emissions ofdirect PM25 and NOx. These emissions budgets are required by EPA's transportation conformity rule as tools for ensuring conformance ofhighway and transit plans with air quality SIPs and maintenance plans.

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## 6.0 References
State ofGeorgia, Rules forAir Quality Control, Chapter 391-3-1, Effective September 13,2011. US Energy InformationAdministration, Annual Energy Outlook 20I0, April 20I0. USEPA, Air Quality Modeling Final [Cross-state Air Pollution] Rule Technical Supp01t Document, June 2011, Docket lD No. EPA-HQ-OAR-2009-0491-4140. USEPA, "Approval, and Promulgation ofAir Quality Implementation Plans; Indiana; Redesignation ofthe Evansville Area to Attainment ofthe Fine Particulate Matter Standard"; proposed rule, 76 FR 29695. USEPA, "Clean Data Policy for the Fine Patticle National AmbientAir Quality Standards," Memorandum from Stephen Page, December 14, 2004. USEPA, "Determination ofAttaining Data for the 1997A1111ual Fine Pmticulate Standard; Alabama, Georgia, and Tennessee: Chattanooga, Final Rule"; 76 FR 31239- 31241. USEPA, "Federal Implementation Plans: Interstate Transport ofFine Particulate Matter and Ozone and Correction ofSIPApprovals" [a.k.a. "Cross-StateAir Pollution Rule"]; final rule, 76 FR48208. USEPA, National Emissions Inventory: inventory years 2005, 2007, and 2008. USEPA, "Procedures for Processing Requests to Redesignate Areas to Attainment," Memorandum from John Calcagni, September 4, 1992.

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# Georgia's Redesignation Request and Maintenance Plan for the Chattanooga NonattainmentArea for the 1997 PM2.s NAAQS For Catoosa and Walker Counties August 31, 2012

Prepared by: 

# Georgia Department ofNatural Resources Environmental Protection Division AirProtection Branch