# CHATTANOOGA-HAMILTON 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 PM 2.5 

### 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 lastparagraph on Page 20 ofthe document to indicate that the operating permit for CaraustarMill Group, Inc. (doing business as Chattanooga Paperboard) was withdrawn afterall operations at the plant ceased.



### Comment 2. Appendix F

- Please include emissions from PM 2.5 

### point sources in Appendix F.
Bureau Response: Appendix F contains only

### S02 and NOx emissions, and it appeared that PM 2.5 emissions hadbeen inadvertently excluded from it. However, as is indicated in the firstparagraph on Page 10 ofthe document, the emissions of

### S02 and NOx from Hamilton Countypoint sources for various years that are given in Appendix Fare used in Tables 2-3 and2-4 on Page 10 for comparison to respective annual emissions of

### S02 and NOx from powerplants in nearby counties, No such comparison to PM 2.5 emissions is made or warranted. Attainmentyear emissions of all three ofthese pollutants from Hamilton Countypoint sources are provided in Appendix 

### G, however, andare presentedin Table 3-1 on Page 20. Therefore, Appendix F correctly includes only

### S02 and NOx emissions and no change is needed as 

### a result ofthis 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 oftitles 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 ofthe 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 ofthe five similar spreadsheets in Appendix K used for the calculation ofarea 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 lastparagraph on Page 18 ofthe document to explain that emissions data in AppendixJ foraircraft, marine, and railroad sources were determined by the U.S. EPA. Also as requested, text was added to this paragraph to indicate types andsources ofdata that were usedby the U.S. EPA as the basis for emissions from marine vessels in orderto 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 ofdata 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) 643-5972UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4

Bob Colby, Director Chattanooga-Hamilton County Air Pollution Control Bureau 6125 Preservation Drive, Suite 140 Chattanooga, Tennessee 37416.
DearMr. Colby: ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA, GEORGIA 30303-8960
June 25, 2014 

### JUN 30

Thankyou for yourMay 23, 2014, email, concerning a prehearingpackageregarding the redesignation request for the Chattanooga.1997 annual fine particulate matter (PM2.s) nonattainment area. This preheatingpackagerequested written comments bythe close ofbusiness on June 26, 2014. Wehave completed a preliminaryreview ofthe submittal and offer the comments provided inthe enclosed document.
We look forward to continuing to work with you and your staff. Ifyou have any questions, please contact Ms. Lynorae Benjamin, Chief, Regulatory Development Section at (404) 562-9040, orhave your staffcontact 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 ofthe Chattanooga 1997 AnnualPM2.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 ofpermits for this facility.
2. Appendix F - Please include emissions from 

### PMz.s point sources in Appendix F.
3. Recommend placement oftitles and units for the data presented inAppendix H and a written description as to howthe data in the tables wereused in the development ofemissions inventories.
4. Appendix J -Additional textual narratives are recommended for Appendix J for aircraft. Also, for marine vessels, please explainhowport emissions differ from underway emissions and how data is updated/projected/developed from 2005 to 2007 as used in the State Implementation Plan Narrative.