CHATTANOOGA-HAMIL TON COUNTY 

~~-~--AIR POLLUTION CONTROL BUREAU 

To: 

From: 

Date: 

SUBJECT: 

All Board M~)11gers 

Bob Colby lV 

June 26, 2014 

PM 2.

5 (FINE PARTICLES) REDESIGNATION REQUEST 

RESPONSE TO COMMENTS 

The Bureau has received comments from the United States Environmental 

Protection Agency (Region 4) on the Redesignation Request and Maintenance Plan 

for the Tennessee Portion of the Chattanooga, Tennessee-Georgia PM2.

5 

Nonattainment Area. Those comments were received by e-mail on June 25, 

2014 and are attached to this memorandum. 

Comment 1. Operations at Caraustar Mill Group, Inc. (Aka Chattanooga 

Paperboard) ceased on July 22, 2008, and no emissions are being used 

for boilers for years after 2008. We recommend the text on page 22 also 

discuss the status of permits for this facility . 

.. 

Bureau Response: As requested, text was added to the last paragraph on Page 

20 of the document to indicate that the operating permit for Caraustar Mill Group, Inc. 

(doing business as Chattanooga Paperboard) was withdrawn after all operations at 

the plant ceased. 

Comment 2. Appendix F - Please include emissions from PM2.

5 point sources 

in Appendix F. 

Bureau Response: Appendix F contains only S02 and NOx emissions, and it 

appeared that PM2.

5 emissions had been inadvertently excluded from it. However, as 

is indicated in the first paragraph on Page 10 of the document, the emissions of S02 

and NOx from Hamilton County point sources for various years that are given in 

Appendix Fare used in Tables 2-3 and 2-4 on Page 10 for comparison to respective 

annual emissions of S02 and NOx from power plants in nearby counties, No such 

comparison to PM2.

5 emissions is made or warranted. Attainment year emissions of 

all three of these pollutants from Hamilton County point sources are provided in 

Appendix G, however, and are presented in Table 3-1 on Page 20. Therefore, 

Appendix F correctly includes only S02 and NOx emissions and no change is needed 

as a result of this comment. 

6125 Preservation Drive Chattanooga, Tennessee 37416-3740 Tel. (423) 643-5970 Fax (423) 643-5972 
PM 2.

5 (FINE PARTICLES) REDESIGNATION REQUEST RESPONSE TO 

COMMENTS (CONTINUED) 

Comment 3. Recommend placement of titles and units for the data presented 

in Appendix H and a written description as to how the data in the tables were 

used in the development of emissions inventories. 

Bureau Response: As requested, titles, data units, and a calculation methodology 

were added to each of the five spreadsheets in Appendix H used for the calculation 

of point source emissions. Furlhermore, although not requested, titles, data units, 

and a calculation methodology were also added to each of the five similar 

spreadsheets in Appendix K used for the calculation of area source emissions. 

Comment 4. Appendix J - Additional textual narratives are recommended for 

Appendix J for aircraft. Also, for marine vessels, please explain how port 

emissions differ from underway emissions and how data is 

updated/projected/developed from 2005 to 2007 as used in the State 

Implementation Plan Narrative. 

Bureau Response: As requested, text was added to the last paragraph on Page 18 

of the document to explain that emissions data in Appendix J for aircraft, marine, and 

railroad sources were determined by the U.S. EPA. Also as requested, text was 

added to this paragraph to indicate types and sources of data that were used by the 

U.S. EPA as the basis for emissions from marine vessels in order to show the 

difference between the "pori" and "underway" emission categories. Furlhermore, 

although not requested, text was also added to this paragraph to indicate types and 

sources of data that were used as the basis for emissions from both aircraft and 

railroad sources. 

We have included a copy of the revised document incorporating the changes 

outlined in theses responses to comments. 

Attachment 

6125 Preservation Drive Chattanooga, Tennessee 37416-3740 Tel. (423) 643-5970 Fax (423) 643-5972 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 4 

Bob Colby, Director 

Chattanooga-Hamilton County 

Air Pollution Control Bureau 

6125 Preservation Drive, Suite 140 

Chattanooga, Tennessee 37416. 

Dear Mr. Colby: 

ATLANTA FEDERAL CENTER 

61 FORSYTH STREET 

ATLANTA, GEORGIA 30303-8960 

June 25, 2014 

JUN 3 0 

Thank you for your May 23, 2014, email, concerning a prehearing package regarding the redesignation 

request for the Chattanooga .1997 annual fine particulate matter (PM2.s) nonattainment area. This 

preheating package requested written comments by the close of business on June 26, 2014. We have 

completed a preliminary review of the submittal and offer the comments provided in the enclosed 

document. 

We look forward to continuing to work with you and your staff. If you have any questions, please 

contact Ms. Lynorae Benjamin, Chief, Regulatory Development Section at ( 404) 562-9040, or have your 

staff contact Mr. Sean Lakeman at ( 404) 562-9043. 

Enclosure 

Sincerely, 

R. Scott Davis 

Chief 

Air Planning Branch 

Internet Address (URL) • http://www.epa.gov 

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) 
Tennessee Portion of the Chattanooga 1997 Annual PM2.s Nonattainment Area 

Redesignation Request 

General Comments: 

1. Operations at Caraustar Mill Group, Inc., (aka Chattanooga Paperboard) ceased on July 22, 2008, 

and no emissions are being used for boilers for years after 2008. We recommend the text on 

page 22 also discuss the status of permits for this facility. 

2. Appendix F - Please include emissions from PMz.s point sources in Appendix F. 

3. Recommend placement of titles and units for the data presented in Appendix H and a written 

description as to how the data in the tables were used in the development of emissions 

inventories. 

4. Appendix J -Additional textual narratives are recommended for Appendix J for aircraft. Also, 

for marine vessels, please explain how port emissions differ from underway emissions and how 

data is updated/projected/developed from 2005 to 2007 as used in the State Implementation Plan 

Narrative.