# Supplement to the Redesignation Demonstration and Maintenance Plan
for the Hickory (Catawba County) and Greensboro/Winston-Salem/High Point (Davidson and Guilford Counties)
Fine Particulate Matter Nonattainment Areas

Prepared by North Carolina Department of Environment and Natural Resources Division of Air Quality

December 22, 2010(This page intentionally left blank)Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 1 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 

### INTRODUCTION
This document is intended to supplement th e Redesignation Demonstration and Maintenance Plan for the Hickory (Catawba County) and Greensboro/Winston-Salem/High Point (Davidson and Guilford Counties) Fine Part iculate Matter Nonattainment Ar eas that was submitted to the United States Environmental Protection Ag ency (USEPA) on December 18, 2009. This document revises the on-road mobile source emi ssions and the motor vehicle emission budgets (MVEBs) using the new USEPA mobile model Motor Vehicle Emission Simulator (MOVES). In March 2010, the USEPA announced in the Federa l Register (FR) that the new MOVES model was required for State Implementation Plan purpo ses and would be requir ed for transportation conformity purposes starting March 2012 (40 FR 9411). The North Carolina Division of Air Quality (NCDAQ) committed to the transportation partners to revise the MVEBs once the new mobile model was released.



### REVISED SECTIONS

Attached are the revised sections to the Redesi gnation Demonstration an d Maintenance Plan for the Hickory and Greensboro/Wins ton-Salem/High Point Fine Part iculate Matter Nonattainment Areas. To appropriately revise the original package, replace the pages as outlined below:

Narrative Replacements

Replace December 18, 2009 page 3-6 with the att ached December 22, 2010 page 3-6. (Note that Errata December 22, 2010 page 3-7 has been included for ease of substitution.)

Replace December 18, 2009 pages 3-13 through 3-17 with the attached December 22, 2010 pages 3-12 through 3-17. (Note that Errata D ecember 22, 2010 page 3-12 has been included for ease of substitution.)

Replace December 18, 2009 pages 4-8 through 4- 11 with the attached December 22, 2010 pages 4-8 through 4-11.

Appendix C Replacements

Replace all of December 18, 2009 Appendix C.3 “O n-Road Mobile Source Emission Inventory Documentation” with the attached December 22, 2010 Appendix C.3 “On-Road Mobile Source Emission Inventory Documentation”.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 2 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Appendix E Replacements

Replace December 18, 2009 Appendix E “Public Notice Report, Comments Received and Responses” page i with the attached Decembe r 22, 2010 Appendix E page i. (Note that December 18, 2009 Appendix E page ii has been included for ease of substitution.)

Add December 22, 2010 Appendix E pages 15 through 23 to end of December 18, 2009 Appendix E.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-6 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 3-1 OBDII Phase-in Effective Dates County Date Catawba July 1, 2003 Davidson July 1, 2003 Guildford July 1, 2002
These emission reductions are state enforceable. The expected NO x benefits for the maintenance years are listed in Table 3-2 below.

Table 3-2 I/M NO x Benefits by County NO x I/M Benefit (Tons/year) 2008 2011 2014 2017 2021 Catawba County 171 136 132 122 111 Davidson County 180 166 139 129 114 Guilford County 541 505 403 358 318

NO x SIP Call Rule/CAIR In response to the USEPA’s NO x SIP call, North Carolina adopted rules to control the emissions of NO x from large stationary combustion sources. These rules cover (1) fossil fuel-fired stationary boilers, combustion turbines, and comb ined cycle systems serv ing a generator with a nameplate capacity greater than 25 MW and selli ng any amount of electricity, (2) fossil fuelfired stationary boilers, combustion turbines, and combined cycle systems having a maximum design heat input greater than 250 million Britis h thermal units per hour, and (3) reciprocating stationary internal combustion en gines rated at equal to or great er than 2400 brake horsepower (3000 brake horsepower for diesel engines and 4400 brake horsepow er for dual fuel engines). As part of the NO x SIP Call, the USEPA rules established a NO x budget for sources in North Carolina and other states. North Carolina has a Phase II budget (i.e., em ission allowance) of 165,022 tons NO x per ozone season.

Besides amending existing NO x rules and adopting new NO x rules specifically to address the USEPA NO x SIP Call, the North Carolina rules also re quire new sources to control emissions of NO x . The objective of this requiremen t is (1) to aid in meeting the NO x budget for North Carolina for minor sources and (2) to aid in a ttaining and maintaining the ambient air quality standard for ozone in North Carolina. North Carolina’s NO x SIP Call rule was predicted to reduce summertime NO x emissions from power plants a nd other industries by 68% by 2006. In October 2000, the North Carolina Environmen tal Management Commission (EMC) adopted rules requiring the reductions.Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-7 Errata to the Redesignation Demonstratio n and Maintenance Plan December 22, 2010 In 2009, the NO x SIP Call program was replaced with th e CAIR, a cap-and-trade program that will achieve reductions of emissions of SO 2 and NO x in the eastern United States. NO x sources that were regulated under the NO x SIP Call are now regulated under the CAIR program. North Carolina adopted the CAIR rule s in 2006 (amended in 2008). North Carolina’s CAIR rules set annual SO 2 allowances as well as bo th ozone season and annual NO x allowances for coal-fired electric generating units and ot her large combustion sources. Th ese regulations are due to a Federal program and thus are both State and Federally enforceable.

Due to the Court challenges of CAIR in 2008, the USEPA will be making changes to this program soon. However, the existing CAIR rules will remain in place until the USEPA promulgates changes to the program.

Clean Smokestacks Act
In June 2002, the North Carolina General Assemb ly enacted the NCCSA, which requires coalfired power plants in Nort h Carolina to reduce annual NO x emissions by 77% by 2009. These power plants must also reduce annual SO 2 emissions by 49% by 2009 and 73% by 2013. It is significant to note that this law sets a cap on NO x and SO 2 emissions for the State which the North Carolina public utilities cannot meet by purch asing credits from sour ces outside of North Carolina. With requiring year-round NO x controls and not allowing the purchase of NO x credits to meet the caps, the NCCSA reduces NO x emissions beyond the requirements of the NO x SIP Call Rule. One of the first state laws of its ki nd in the nation, this legislation provides a model for other states in controlling multiple air pollutants from older coal-fired power plants. These emissions reductions are state enforceable.

Prevention of Significant Deterioration All new major sources of SO 2 and NO x will be evaluated under the prevention of significant deterioration program and are required to use best available control technology. These emissions reductions are state enforceable.

Open Burning The North Carolina open burning regulation proh ibits the burning of man-made materials statewide. In June 2004, the EMC approved re visions to the open burning regulation banning open burning of yard waste and land clearing debris on forecasted Code Orange or higher "air quality action days," for those counties that th e NCDAQ or local air programs forecast ozone or fine particulate matter. The following counties in the Hickory area are subject to this rule : Alexander , Catawba , southeastern Burke and southeastern Caldwell. The following counties inHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-12 Errata to Redesigna tion Demonstration and Mainte nance Plan December 22, 2010 Table 3-5 Point Source SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 6,189 6,187 6,186 6,184 6,183

Davidson 286 289 292 295 299 Guilford 449 451 453 455 458 Triad Total 735 740 745 750 757

Table 3-6. Point Source PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 6,976 6,975 6,975 6,973 6,971

Davidson 179 178 177 176 175 Guilford 62 62 62 63 63 Triad Total 241 240 239 239 238

Area sources are those stationary sources whose emissions are relatively small but due to the large number of these sources, the collective emi ssions could be significan t (i.e., dry cleaners, service stations, etc.). For area sources, emissions are estimated by multiplying an emission factor by some known indicator of collective activity such as production, number of employees, or population. These types of em issions are estimated on the count y level. For the projected year's inventory, area source emissions are changed by population growth, projected production growth, or when applicable, by E-GAS 5.0 growth factors. For detailed discussion on how the area source emission inventory wa s developed, see Appendix C.2. A summary of the area source emissions are presented in Tables 3-7 to 3-9.

Table 3-7. Area Source NO x Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 662 614 566 520 454

Davidson 583 551 516 486 438 Guilford 1,243 1,210 1,177 1,146 1,099 Triad Total 1,826 1,816 1,693 1,632 1,537Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-13 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 3-8. Area Source SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 2,263 2,037 1,808 1,580 1,277

Davidson 983 838 692 548 353 Guilford 4,129 3,905 3,683 3,460 3,164 Triad Total 5,112 4,743 4,375 4,008 3,517

Table 3-9. Area Source PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 682 658 629 606 559

Davidson 1,071 1,028 979 937 857 Guilford 697 663 623 590 524 Triad Total 1,768 1,691 1,602 1,527 1,381

For mobile sources, the USEPA’s Motor Vehicle Emission Simulator (MOVES) mobile model is run to generate emissions. The MOVES model includes the road class vehicle miles traveled (VMT) as an input file and can directly output the estimated emi ssions. For the projected years’ inventories, the on-road mobile sources emissi ons are calculated by running the MOVES mobile model for the future year with the projected VMT to generate emissions that take into consideration expected Federal ta ilpipe standards, fleet turnover and new fuels. For detailed discussion on how the on-road mobile emission inventory was developed, see Appendix C.3. A summary of the on-road mobile source emissions are presente d in Tables 3-10 to 3-12.

Table 3-10. On-road Mobile Source NO x Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 4,982 4,005 3,240 2,591 2,054

Davidson 5,267 4,095 3,227 2,536 1,974 Guilford 14,499 11,157 8,882 7,143 5,796 Triad Total 19,766 15,252 12,109 9,679 7,770Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-14 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 3-11. On-road Mobile Source SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 35 20 18 19 20

Davidson 36 19 17 18 18 Guilford 111 62 55 59 63 Triad Total 147 81 72 77 81

Table 3-12. On-road Mobile Source PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 166 127 107 89 73

Davidson 169 121 97 77 60 Guilford 465 330 272 221 183 Triad Total 634 451 369 298 243

Nonroad mobile sources are equipment that can move but do not use the roadways, i.e., lawn mowers, construction equipment, railroad locomotiv es, aircraft, etc. The emissions from this category are calculated using the USEPA’s N ONROAD2008a nonroad mobile model, with the exception of the railroad locomotives and aircraft engine. The railroad locomotive and aircraft engine emissions are estimated by taking activit y data, such as landi ngs and takeoffs, and multiply by an emission factor. These emissions ar e also estimated at the county level. For the projected years’ inventories, the emissions are estimated using the USEPA’s NONROAD2008a nonroad mobile model, E-GAS 5.0 growth factor s or projected landing and takeoff data for aircraft. For detailed discussion on how the nonroad mobile emission inventory was developed, see Appendix C.4. A summary of the nonroad mobile source emissions are presented in Tables 3-13 to 3-15.

Table 3-13. Nonroad Mobile Source NO x Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 1,173 922 700 551 453

Davidson 1,831 1,632 1,467 1,275 1,115 Guilford 3,864 3,371 2,816 2,350 1,980 Triad Total 5,695 5,003 4,283 3,625 3,095Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-15 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 3-14. Nonroad Mobile Source SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 18 6 4 3 4

Davidson 25 17 2 2 2 Guilford 96 51 42 42 43 Triad Total 121 68 44 44 45

Table 3-15. Nonroad Mobile Source PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 70 67 57 46 38

Davidson 71 67 58 46 40 Guilford 264 252 220 186 157 Triad Total 335 319 278 232 197

3.3.3 Summary of Emissions

The sum total of these man-made emissions for the PM 2.5 nonattainment areas is tabulated in Tables 3-16 though 3-18.

Table 3-16. Total Man-Made NO x Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 20,127 16,090 15,054 14,210 13,509

Davidson 8,522 7,143 6,102 5,217 4,488 Guilford 19,837 15,969 13,107 10,872 9,112 Triad Total 28,359 23,112 19,209 16,089 13,600

Table 3-17. Total Man-Made SO 2 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 8,505 8,250 8,016 7,786 7,484

Davidson 1,330 1,163 1,003 863 672 Guilford 4,785 4,469 4,233 4,016 3,728 Triad Total 6,115 5,632 5,236 4,879 4,400Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-16 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 3-18. Total Man-Made PM 2.5 Emissions (tons per year) County 2008 2011 2014 2017 2021 Catawba 7,894 7,827 7,768 7,714 7,641

Davidson 1,490 1,394 1,311 1,236 1,132 Guilford 1,488 1,307 1,177 1,060 927 Triad Total 2,978 2,701 2,488 2,296 2,059

3.3.4 Maintenance Demonstration
As discussed above, maintenance is demonstrat ed when the future years total man-made emissions are less than the 2008 baseline emissi ons. The following tables summarized the SO 2 , NO x , and primary PM 2.5 emissions for both the Hickory a nd Triad nonattainment areas. The difference between the base year and the final ye ar of the plan illustrates that the continued maintenance of the annual fine par ticulate matter NAAQS is expected.

Table 3-19 Maintenance Demonstration for Hickory PM 2.5 Nonattainment Area

Year NO x (tons per year) SO 2 (tons per year) PM 2.5 (tons per year) 2008 20,127 8,505 7,894 2011 16,090 8,250 7,827 2014 15,054 8,016 7,768 2017 14,210 7,786 7,714 2021 13,509 7,484 7,641 Difference from 2008 to 2021 -6,618 -1,021 - 253

Table 3-20 Maintenance Demonstration for Triad PM 2.5 Nonattainment Area

Year NO x (tons per year) SO 2 (tons per year) PM 2.5 (tons per year) 2008 28,359 6,115 2,978 2011 23,112 5,632 2,701 2014 19,209 5,236 2,488 2017 16,089 4,879 2,296 2021 13,600 4,400 2,059 Difference from 2008 to 2021 -14,759 -1,715 - 919Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 3-17 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 The difference between the attainment level of emissions (2008) from all man-made sources and the projected level of emissions from all ma n-made sources in the nonattainment areas are considered the “safety margin”. The safety marg in for each projected year is listed below in Table 3-21 and 3-22.

Table 3-21 Safety Margin for Hickory PM 2.5 Nonattainment Area

Year NO x (tons per year) SO 2 (tons per year) PM 2.5 (tons per year) 2011 -4,037 -255 -67 2014 -5,073 -489 -126 2017 -5,917 -719 -180 2021 -6,618 -1,021 -253

Table 3-22 Safety Margin for Triad PM 2.5 Nonattainment Area

Year NO x (tons per year) SO 2 (tons per year) PM 2.5 (tons per year) 2011 -5,247 -483 -277 2014 -9,150 -879 -490 2017 -12,270 -1,236 -682 2021 -14,759 -1,715 -919

For both nonattainment areas, th ere are significant safety margins from 2011 to 2021. In addition to the above safety margins within the PM 2.5 nonattainment areas, SO 2 emissions from nearby coal-fired power plants will be significantly reduced due to the NCCSA. This effectively gives the PM 2.5 nonattainment areas an even larger safety margin for SO 2 . Table 2-5 shows the SO 2 reductions at nearby coal-fir ed power plants. These reduc tions will benefit both the Triad and Hickory nonattainment areas and will provide large safety margins through 2021.

3.4 CONTINGENCY PLAN

3.4.1 Overview
The two main elements of the North Carolina contingency plan are tracking and triggering mechanisms to determine when contingency meas ures are needed and a process of developing and adopting appropriate control measures. Ther e will be three potential triggers for the contingency plan. The primary trigger of the contingency plan will be a violation of the annual PM 2.5 NAAQS at any of the monitors in either PM 2.5 nonattainment area. Th e secondary triggerHickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-8 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 copy of the letter can be found in Appendix B. In the letter, the NCDAQ expressed its preference for setting county level budgets and the reasons why the NCDAQ believed county level budgets were appropriate.

The NCDAQ received comments from the Gr eensboro Urban Area Metropolitan Planning Organization (GUAMPO) regarding the geographic extent of th e MVEBs. The GUAMPO was in favor of having county level MVEBs. A co py of the letter received can be found in Appendix B. Therefore, the NCDAQ decided to move forward with setting county-by-county MVEBs.

Additionally, there was discussion through the inte ragency consultation process on the years to set MVEBs for the Hickory and Triad PM 2.5 maintenance plans. According to Section 93.118 of the transportation conformity rule, a maintenance pl an must establish MVEBs for the last year of the maintenance plan (in this case, 2021). Thro ugh the interagency consultation process, it was decided that MVEBs would be set for the year 2011 for both the Hickory and Triad PM 2.5 nonattainment areas.

Although the emissions up to this point have been expressed in terms of tons per year, the MVEBs will be set in terms of kilograms (kg) per y ear. In past conformity exercises, there have been some issues with conversion to tons, as well as concerns with how the MVEBs were rounded to the hundredth place. Setting MVEBs in kilograms will avoid thes e issues in future conformity determinations. Additionally, setting the MVEBs in kilograms was agreed to as part of the interagency c onsultation process.

The table below shows the countie s with their on-road mobile PM 2.5 and NO x emissions expressed in kilograms per year and the corr esponding tons per year values for 2011 and 2021.

Table 4-1. On-Road Mobile Source PM 2.5 Emissions
County Kilograms/year Tons/year 2011 2021 2011 2021 Davidson 109,769 54,431 121 60 Guilford 299,371 166,015 330 183 Triad Total 409,140 220,446 451 243Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-9 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 4-2. On-Road Mobile Source NO x Emissions
County Kilograms/year Tons/year 2011 2021 2011 2021 Catawba 3,633,274 1,863,357 4,005 2,054

Davidson 3,714,921 1,790,782 4,095 1,974 Guilford 10,121,459 5,258,042 11,157 5,796 Triad Total 13,836,380 7,048,824 15,252 7,770

The NCDAQ will set MVEB, for tr ansportation conformity purposes, as county budgets within the Hickory and Triad maintenance areas for 2011 and 2021. Tables 4-3 through 4-5 below list out the MVEBs in kilograms per year, for transportation conformity purposes, by county for the years 2011 and 2021. Upon the USEPA’s affirmativ e adequacy finding for these county level sub-area MVEBs, these MVEBs will become the applicable MVEBs for each county.

Table 4-3 Catawba County MVEB 2011 2021

NO x Emissions (kg/year) Base Emissions 3,633,274 1,863,357 Safety Margin Allocated to MVEB 363,327 372,671 NO x Conformity MVEB 3,996,601 2,236,028

Table 4-4 Davidson County MVEB 2011 2021

NO x Emissions (kg/year) Base Emissions 3,714,921 1,790,782 Safety Margin Allocated to MVEB 371,492 358,156 NO x Conformity MVEB 4,086,413 2,148,938

PM 2.5 Emissions (kg/year) Base Emissions 109,769 54,431 Safety Margin Allocated to MVEB 43,544 98,882
PM 2.5 Conformity MVEB 153,313 153,313Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-10 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 4-5 Guilford County MVEB 2011 2021

NO x Emissions (kg/year) Base Emissions 10,121,459 5,258,042 Safety Margin Allocated to MVEB 1,012,146 1,051,608 NO x Conformity MVEB 11,133,605 6,309,650

PM 2.5 Emissions (kg/year) Base Emissions 299,371 166,015 Safety Margin Allocated to MVEB 122,470 255,826
PM 2.5 Conformity MVEB 421,841 421,841

4.5 NEW SAFETY MARGINS
For the Hickory nonattainment area, a to tal of 363,327 kg/year (400 tons/year) and 372,671 kg/year (411 tons/year) of the 2011 and 2021 NO x safety margins, respectively, were added to the NO X MVEBs.

For the Triad nonattainment area, a to tal of 1,383,638 kg/year (1,525 tons/year) and 1,409,764 kg/year (1,554 tons/year) of the 2011 and 2021 NO x safety margins, respectively, were added to the Triad NO X MVEBs. For PM 2.5 , a total of 166,014 kg/year (183 tons/year) and 354,708 kg/year (391 tons/year) of the 2011 and 2021 PM 2.5 safety margins, respectively, were added to the Triad PM 2.5 MVEBs.

Table 4-6 New Safety Margins for the Hickory PM 2.5 nonattainment area
Year NO x (tons/year) PM 2.5 (tons/year) 2011 -3,637 -67 2014 -5,073 -126 2017 -5,917 -180 2021 -6,207 -253Hickory and Greensboro/Winston-Salem/High Point Annual PM 2.5 4-11 Supplement to Redesignation Demonstratio n and Maintenance Plan December 22, 2010 Table 4-7 New Safety Margins for the Triad PM 2.5 nonattainment area
Year NO x (tons/year) PM 2.5 (tons/year) 2011 -3,722 -94 2014 -9,150 -490 2017 -12,270 -682 2021 -13,205 -528