ATTACHMENT B: Public Hearing Notice
Tennessee Press Service, Inc. 

ROP D~vision 

435 Montbrook Lane 

T Knoxville,M 37919-2704 &&/ i3 n 12: j: PRESS SERVICE Voice (865) 584-5761 Fax (865) 558-8687 

I 

Monday, May 31,2010 10:56 AM 

In voice 

Malcolm Butler 

Agency TN Division of Air Pollution Control 

9th Floor, L&C Annex 

401 Church Street 

Nashville, TN 372431 531 

PO Number 

Order SD10-1782 

Client TAPCDIRon Cullberson 

Newspaper 

Caption Run Date Ad Size Rate Rate Name Color Disc. Total 

Knoxville News Sentinel 

Notice Of Public 05/28/2010 4 x 4.5 $39.06 National $8.00 0.0000% $71 1 .08 

Hearing - Revised Classified 

Total Advertising $71 1.08 

Discounts 

Tax: USA 

Total Invoice $71 1.08 

Payments $0.00 

Adjustments 

Balance Due 

We appreciate your business! TERMS: Due Net 30 Days 

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435 Montbrook Lane 

Knoxville, TN 37919 

Voice (865) 584-5761 Fax (865) 558-8687 or (865) 584-651 3'(~cct~) 

AFFIDA VIT 

C Ron Culberson 

Administrative Services 

Division of Air Pollution Control 

Tennessee Department of Environment & Conservation 

gth Floor, L&C Annex 

401 Church Street 

Nashville, TN 37243-1 531 

Gentlemen: 

The enclosed itemized statement is for publication of TDAPC Public Notice in the list of 

newspapers on the date (s) stated therein as authorized by your office. 

As requested, full page tearsheets are submitted herewith on our invoice SD10-1782 as further 

proof of publication. 

I, Kathy Hensley, Accounting Services Representative for Tennessee Press Service, Inc., do 

hereby certify that the attached is true and correct. 

This Thirty First day of May 2010 
News Sentinel 

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Notice of Public Hearing - Revised 

Tennessee Department of Environment and Conservation 

Division of Air Pollution Control 

The Technical Secretary of the Tennessee Air Pollution Control Board will hold =public hearing to 

receive oral and written comments concerning proposed amendments to the State Jmplementation 

Plan (SIP). The proposed amendments are to incorporate the proposed Knoxville area Eight-Horn 

Ozone Redesignation Request and Maintenance Plan. The comments received at this hearing will 

be distributed to the members of the Tennessee Air Pollution Control Board for their review in 

regard to the proposed amendments. The hearing will be conducted in the manner prescribed by the 

Uniform Administrative Procedures Act, Tennessee Code Annotated, Section 4-5-201 et. &q. and 

will take place in the Knoxville Environmental Field Office, 3711 Middlebrook Pike, Knoxville, 

TN 37921, at 2:00 PM Eastern Daylight Tie on Monday, June 28,2010. Anyone desiring to 

make oral comments at this public hearing is requested to prepare awritten copy of their comments 

to be submitted to the hearing officer at the public hearing. Written comments not submitted at 

the public hearing will be included in the hearing record only if received by the close of business 

on Monday, June 28,2010, at the following address: Technical Secretary, Tennessee Air Pollution 

Control Board, 9th Flm, L & C Annex, 401 Church Street, Nashville, TN 37243-1531. Any 

individuals with disabilities who wish to participate in these proceedings or to review these filings should contact the Tennessee Department of Environment and Conservation to discuss any 

auxiliary aids or services needed to facilitate such,participation. Such initial conkkt may be in 

pmon, by writing, telephone, or other means, and should be made no less than ten (10) days prior 

to Monday, June 28,2010, or the date such party intends to review such filings, to dlow time to 

pmvide such aid or service. Contact the Tennessee Department of Enviromnent and Conservation 

ADA Cdordinator, 12th Floor L&C Tower, 401 Church Street, Nashville TN 37243, (615) 532- 

0207. Hearing impaired callers may use the Tennessee Relay Service (1-800-848-0298). Copies of 

the.redesignation request are available for review at the following locations: 

Air Pollution Control Division Air Pollution Control Division Knox County Depamnent of 

9th Floor, L & C Annex Knoxville Environmentai Field Office Air Quality Management 401 Church Sueet 371 1 Middlebrook Pike 140 Dameron Avenue, Suite 242 Nashville, 'IN 37243-1531 Knoxville, TN 37921 Knoxville, TN 37917 

If you have any questions about the origination of these documents, you may contact Mr. Travis 

Blake or Mr. Quincy Styke, at(615) 532-0554. For information about reviewing these documents, 

please contact Mr. Travis Blake or Mr. Quincy Styke, 9th Floor, L & C Annex, 401 Church Street, 

Nashville, TN 37243-1531, telephone (615) 532-0554. 

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NOTICE 

The ldopted. foregoing Unless w~thin Resolution twentv has (70) rlnvc been 
ATTACHMENT C: Public Comments and 

Responses
1

Response to Comments

Knoxville Ozone Redesignation Request

I. EPA Comments & Responses

Item # Comment Response

Note: Page numbers indicated in EPA’s comments are based on the original draft, while page numbers in the response are based on the revised version. 

1 In Section 2, page 10 (last paragraph) please change the “2009” reference to “2010.” Corrected on page 10 of the revised narrative.

2 In Section 4, page 32 (below Table 4-1) please revise the following language to say 

volatile organic compounds (VOC) emissions for the five counties are projected to 

increase to 9.53 tons/day in “2024” not in “2020.” 

Corrected on page 38 of the revised narrative.

3 In Section 5, page 41 (second paragraph), please change the language “violation at the 

ruling monitor” to “violation at any monitor.” 

Page 48 of the revised narrative was amended to indicate that contingency 

measures will be triggered by a design value violation at any monitor.

4 In Section 5, page 41-42, the Knoxville Maintenance Plan only commits to 

implementing contingency measures 18 to 24 months after a violation of the national 

ambient air quality standards (NAAQS). It does not commit to whether this is 18 to 

24 months from the violation or from the data being quality assured. Please provide 

clarification to ensure that Tennessee will implement contingency measures within 

the 24-month timeframe guideline.

A footnote was added to page 49 of the revised narrative to clarify the date of 

the triggering event, as follows: 

“If quality assured/quality controlled data indicates a violating design 

value for the 8-hour ozone NAAQS, then the triggering event will be 

the date of the design value violation, and not the final QA/QC date. 

However, if initial monitoring data indicates a possible design value 

violation but later QA/QC indicates that a NAAQS violation did not 

occur, then a triggering event will not have occurred, and 

contingency measures will not need to be implemented.”

Contingency measures would be implemented 18 to 24 months after date of the 

triggering event.

5 The September 4, 1992, Memorandum entitled “Procedures for Processing Requests 

to Redesignate Areas to Attainment”, also referred to as the Calcagni memo states 

that the maintenance plan should clearly identify the measures to be adopted. The 

Knoxville Maintenance Plan states that “In the event that additional controls are 

necessary, and not due to an exceptional event, malfunction, or noncompliance with a 

source permit condition or rule requirement, the State and the DAQM will determine 

the additional emission control measures needed to assure future attainment of the 

ozone NAAQS.” It is not apparent in the maintenance plan what actions DAQM will 

take in the circumstances underlined above. Please provide an explanation of how 

DAQM will address these types of scenarios.

The redesignation request was revised to state that “If additional controls are 

necessary, Tennessee and the Knox County DAQM will implement the 

appropriate contingency measures needed to assure future attainment of the 

ozone NAAQS.” 
2

Item # Comment Response

6 Please specify in the Motor Vehicle Emissions Budgets discussion that the 2024 

budgets listed in Table 4-11 encompass the entire Knoxville, Tennessee maintenance 

area.

Page 43 of the revised narrative was amended as follows (last sentence before 

Table 4-11): 

“The Motor Vehicle Emissions Budgets including safety margins for 

the Greater Knoxville 1997 8-hour Ozone Nonattainment Area 

(Anderson, Blount, Jefferson, Knox, Loudon and Sevier 

Counties and the portion of Cocke County that falls within the 

boundaries of the Great Smoky Mountains National Park) are 

contained in Table 4-11.”

7 Please add county names to the point source data tables in Attachment A. We also 

recommend that the emissions totals by facility, county and for the entire 

nonattainment area are added to the tables. Addressing this comment will facilitate a 

comparison of the data in the attachment with Table 4-1 in the SIP Narrative.

County names, emissions totals, and summary tables were added to the point 

source inventory.

8 Please provide the year of the data in Appendix B of Attachment A. Corrected in Attachment A.

9 It is unclear how the nonroad material in Appendix C should be interpreted since it is 

similar to language from the EPA Emissions Inventory System site. Please clarify the 

nonroad material in Appendix C as well as explain if all the source categories are in 

the Knoxville area.

The “Nonpoint Sectors for 2008 NEI” listed in Appendix C contains the list of 

source categories used to develop the area source emission inventory. 

10 Please provide a list of nitrogen oxides (NOx) and VOCs emissions in the 

nonattainment area (by counties) for the nonroad and area sources for the 2007 

attainment year in Appendix C of Attachment A including the source description 

name. The totals from this data will be used to compare with the totals in Tables 4-5 

and 4-6 of the SIP narrative.

Attachment A was revised to provide additional breakdown of area and mobile 

source emissions.

11 Please clarify in the SIP narrative that the 1997 8-hour ozone NAAQS is the focus of 

the redesignation request.

Corrected on page 1 of the revised narrative.

12 Table 2-1 of the SIP narrative shows a large increase in the 4th highest design value 

in 2007 followed by a steady decrease in 2008-2009. If emission decreases contribute 

to the decreases prior to 2007, please clarify the cause of the increase in 2007, other 

than meteorology.

Pages 27-30 of the narrative discuss the 2007 ozone season. We note in the 

narrative that increased ozone levels in 2007 resulted in part from the unusually

warm and dry summer in 2007 (specifically, see Table 2-8, which indicates that 

increased ozone concentrations occurred not only in the Knoxville area, but 

throughout the southeast). We also note that wildfires in Georgia and Florida 

during the summer of 2007 may have contributed to increased ozone 

concentrations. 
3

Item # Comment Response

13 The SIP narrative only discusses the effects of temperature and ozone exceedances. It 

is assumed that your ozone forecasting program uses more meteorological parameters 

in determining if exceedances are possible. Regarding the temperature data 

presented, it appears that 2008 and 2009 was not particularly conducive to the 

formation of ozone. If precipitation and temperature were considered, 2009 was not a 

particularly good year for ozone exceedances.(e.g.. 

http://www.ncdc.noaa.gov/sotc/index.php?report=national&year=2006&month=ann). 

Precipitation and wind speed are also important to the formation of ozone. Please 

consider revising the meteorological discussion to include precipitation and wind 

speed parameters.

An updated discussion of the effect of various meteorological variables on 

ambient ozone concentrations was added to Section 2 of the redesignation 

request. Several new graphs were added to the revised section, and two 

redundant graphs (comparison of temperature and ozone exceedances with 2002 

and 2004 baselines) were deleted.

14 Since the 2008 emissions inventory was due for submission to EPA by June 1, 2010, 

please add the 2008 ozone season data to the emissions trends data in Table 2-7 in the 

SIP narrative. Also clarify if the data in Table 2-7 represents all emissions source 

categories. Please consider including the ozone season NOx and VOC emission data 

to the SIP narrative as opposed to annual NOx and VOC emissions trends.

The 2008 inventory was not included in Table 2-7 because Tennessee is 

working through various error messages that were received upon submittal of 

the 2008 NEI. These issues are unlikely to be resolved prior to submittal of the 

redesignation request. The footnote in Table 2-7 was amended to state that 

each emission total represents all source categories.

VOC and NOX emissions are presented as tons per year in Table 2-7 and Figure 

2-10 of the draft redesignation request. We used tons per year because we were 

looking at longer-term trend of declining emissions from 1996, and tons per 

year data were more readily available. While we agree that ozone season 

emissions would be a useful metric, we believe that the data as presented are 

adequate to illustrate changes in emissions and ozone concentrations (the 

revised document includes more data to highlight the relationship between 

emissions and ambient ozone). Ozone season data for 2007 (as tons per typical 

summer day) are presented in the emission inventory section of the 

redesignation request. 

15 Please provide detail discussion on the emission reductions from federal and state 

controls that contributed to ozone NAAQS attainment. 

Permanent and Enforceable Reductions are discussed in Section 3.0 of the 

narrative.

16 Please provide detail discussion on the development of the 2007 emissions inventory, 

future emissions for area and nonroad sources in the SIP narrative. Additionally, 

please consider including the NOx and VOC emission inventory data tables (similar 

to Tables 4-5 and 4-6) for nonroad sources. Also, consider including a table with 

combined totals of all emission source categories and all years before the biogenics 

discussion. This should summarize all of the data presented in the point, area, 

nonroad, and onroad tables.

Additional discussion of inventory development was added to Section 4.0 and 

Attachment A. Nonroad emission inventory data are included in Tables 4-12, 

4-13, 4-14, and 4-15. A summary table of emissions for all categories is 

included in the MVEB discussion as Table 4-10.

II. Comments received during the June 28, 2010, public hearing: There were no comments received during the public hearing on June 28, 2010.

III. Other Comments received during the public comment period: There were no other comments received during the public comment period.
ATTACHMENT D: Air Pollution Control 

Board Order