# REDESIGNATION REQUEST

AND

MAINTENANCE DEMONSTRATION

Jackson County, Alabama

Chattanooga

Annual PM 2.5 

## Nonattainment Area

Prepared by:



## Alabama Department of Environmental Management

Air Division

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

i 

## Executive Summary

This document contains Alabama's demonstration under the federal Clean Air Act (CAA) Amendments of 1990 that the Jackson County portion of the Chattanooga Annual PM 2.5 

### Nonattainment Area (NAA) should be redesignated from nonattainment to attainment with respect to the National Ambient Air Quality Standard (NAAQS) for annual fine part icle pollution. This area consists of Hamilton County in Tennessee, Catoosa and Walker Counties in Georgia, and the portion of Jackson County in Alabama that is described as U.S. Census 2000 block group identifier 01 –071-9503– 1. There are no PM 2.5 

### monito rs located in the Jackson County, Alabama, portion of the nonattainment area; however, the air quality monitoring data for 2001

- 2003 from monitors located in the Georgia and Tennessee portions of the nonattainment area indicated that the annual average PM 2 .5 

### concentrations (design values)
exceeded the 15.0 m icr ograms per cubic meter 

### ( μg/m 3 

### ) NAAQS. The U.S. Environmental Protection Agency ( EPA ) included the above

- mentioned portion of Jackson County, Alabama, in the Chattanooga nonattainment area because they concluded that the Tennessee Valley Authority ( TVA ) Widows Creek Fossil Plant located in the county contributes to the
nonattainment situati on in the Chattanooga NAA.

This redesignation request is based on three years of ambient monitoring data, 2007 to 2009, at
all four PM 2.5 

### monitors in the Chattanooga NAA showing no violation of the annual PM 2.5 

### standard, the implementation of permanent and enforceable reductions in PM 2.5 

### and precursor emissions, compliance with Section 110 and Part D requirements of the C AA , and the Chattanooga Maintenance Plan with projections demonstrating that the 2007 emission levels in
this nonattainment area will no t be exceeded through at least the year 2025.

The Alabama Department of Environmental Management (ADEM), the Chattanooga

- Hamilton County Air Pollution Control Bureau, the Tennessee Division of Air Pollution Control and the Georgia Air Protection Branch co llaborated to develop a PM 2.5 

### NAAQS State Implementation Plan (SIP) for each jurisdiction.

On May 31, 2011, EPA promulgated its determination (76 FR 31239) that the Chattanooga nonattainment area had attained the 1997 annual average PM 2.5 

### 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 μg/m 3 

### . This final rule became effective on June 30, 2011. Upon EPA’s determination that the a rea had, in fact, attained the standard, Alabama, Georgia and Chattanooga began work on redesignation requests for their respective portions of the nonattainment area. As part of this work, coordination and consultation took place between
the three agencie s concerning emissions, monitoring data and the expectations of maintenance for the entire area. The emissions and monitoring data gathered as a result of this consultation is reflected in this request.

This document contains the redesignation request for the Jackson County, Alabama, portion of the nonattainment area, which demonstrates maintenance of the annual PM 2.5 

### NAAQS, promulgated in 1997, in the Chattanooga NAA thru 2025. The State of Georgia’s redesignation request and maintenance plan is located i n Appendix A, and the Chattanooga

- Hamilton County Air Pollution Control Bureau’s draft redesignation request and maintenance plan is located in Appendix E.

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

ii 

## TABLE OF CONTENTS

1.0 Introduction .................................................................................................................................. 1-1

1.1 Purpose ..................................................................................................................................... 1-1

1.2 Historic Background ................................................................................................................ 1-1

1.3 Form ation of PM 2.5 ................................................................................................................... 1-3

1.4 Criteria for Redesignation ........................................................................................................ 1-4

2.0 Attainment Demonstration ........................................................................................................... 2-1

2.1 Demonstration that the NAAQS Has Been Attained ............................................................... 2-1

2.1.1 PM 2.5 Monitoring Network .................................................................................................. 2-1

2.2 Permanent and Enforceable Reductions in Emissions ............................................................. 2-4

3.0 Fully Approved SIP, Section 110 and Part D Requirements ........................................................ 3-1

3.1 Section 110 Implementation Plans ........................................................................................... 3-1

3.2 Part D Plan Requirements for Nonattainment Areas ............................................................... 3-1

3.2.1 Nonattainment Areas in General .......................................................................................... 3-1

3.2.1.1 Section 172(c) – ........................................................................................................... 3-1

3.2.1.2 Section 176(c) – ........................................................................................................... 3-1

3.2.1.2.1 Nitrogen Oxides (NO X ) ........................................................................................... 3-2

3.2.1.2.1.1 Analysis of motor vehicle NO X emissions in the Jackson County portion of the Chattanooga nonattainment area. ......................................................................................... 3-2

3.2.1.2.1.2 The current state of the air quality in Jackson County. ..................................... 3-3

3.2.1.2.1.3 The absence of SIP motor vehicle controls for the area. .................................. 3-4

3.2.1.2.1.4 Historical trends and future projections of the growth of motor vehicle
emissions. .......................................................................................................................... 3-4

3.2.1.2.2 Direct PM 2.5 ............................................................................................................. 3-4

3.2.1.2.2.1 Analysis of motor vehicle PM 2.5 emissions in the Jackson County portion of the Chattanooga nonattainment area .......................................................................................... 3-4

3.2.1.2.2.2 The current state of the air quality in Jackson County. ..................................... 3-6

3.2.1.2.2.3 T he absence of SIP motor vehicle controls for the area. .................................. 3-6

3.2.1.2.2.4 Historical trends and future projections of the growth of motor vehicle
emissions. .......................................................................................................................... 3-6

4.0 Maintenance Plan ........................................................................................................................ 4-1

4.1 Maintenance Demonstration .................................................................................................... 4-1

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

iii 4.2 Attainment Inventory ............................................................................................................... 4-1

4.2.1 Point Sources ....................................................................................................................... 4-2

4.2.2 Nonpoint Sources ................................................................................................................. 4-2

4.2.3 On -road Mobile Sources ...................................................................................................... 4-4

4.2.4 Nonroad Mobile Sources ..................................................................................................... 4-5

4.3 Projected Emissions Inventory ................................................................................................ 4-5

4.3.1 Point Sources ....................................................................................................................... 4-6

4.3.2 Nonpoint Sources ................................................................................................................. 4-6

4.3.3 Onroad Mobile Sources ....................................................................................................... 4-6

4.3.4 Nonroad Mobile Sources ..................................................................................................... 4-7

4.4 Maintenance Plan Inventory .................................................................................................... 4-9

4.5 Plan to Maintain Air Quality .................................................................................................. 4- 11

4.5.1 Verification of Continued Attainment ................................................................................ 4-12

4.5.2 Contingency Plan ............................................................................................................... 4-12

5.0 Conc lusion ................................................................................................................................... 5-1

TABLES

Table 2.1.1-1 Annual and Three

- year Average Ambient PM 2.5 Concentrations ................................. 2-2

Table 3.2.1.2.1.1-1 2007, 2017, 2025 NO X (TPY) Emissions in the Nonattainment portion of Jackson County by Source Type.................................................................................................................... 3-3

Table 3.2.1.2.1.1-2 2007, 2017, 2025 NO X (TPY) On -road Mobile Source Emissions in the

Nonattainment Portion of Jackson County Compared to Total On-road Mobile Source E missions in the entire Chattanooga NAA ................................................................................................................. 3-3

Table 3.2.1.2.1.4-1 Historical and Future Projections of NO X emissions from On -Road Mob ile Sources in Jackson County ........................................................................................................................... 3-4

Table 3.2.1.2.2.1-1 2007, 2017, 2025 Direct PM 2.5 (TPY) Emissions in the Nonattainment Portion of Jackson County by Source Type ...................................................................................................... 3-5

Table 3.2.1.2.2.1-2 2007, 2017, 2025 Direct PM 2 .5 (TPY) On

- road Mobile Source Emissions in the Nonattainment Portion of Jackson County Compared to Total On-road Mobile Source Emissions in the Entire Chattanooga NAA ................................................................................................................ 3-5

T

abl e 3.2.1.2.2.4-1 Historical and Future Projections of PM 2.5 emissions from On

- Road Mobile Sources in Jackson County ........................................................................................................................... 3-6

Table 4.2.1-1 2007 Point Emissions (TPY) ........................................................................................ 4-2

Table 4.2.2-1 Jackson County NAA Nonpoint Source Emissions for 2007 (TPY) ............................. 4-3

Table 4.2.4-1 2007 Nonroad Mobile Source Emissions (tons) ........................................................... 4-5

Table 4.3.4-1 Projected Nonroad Mobile Source Emissions (tons per year) ..................................... 4-8

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

iv Table 4.4-1 Jackson County, AL portion of the Chattanooga Annual PM 2.5 Attainment Area Maintenance Plan Emissions (Tons per Year) ...................................................................................................... 4-9

Table 4.4-2 Maintenance Inventory for the Chattanooga NAA (TPY) ............................................. 4-10

Table 4.5.2- 1 Schedule for Permit Revisions or Rule Revisions for Contingency Measures ........... 4-13

FIGURES

Figure 1.2-1 The Jackson County, AL portion of the Chattanooga Annual PM 2.5 NAA ..................... 1-2

Figure 2.1.1-1 Locations of PM 2.5 Monitors in the Chattanooga NAA .............................................. 2-3

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

v APPENDICES

GA Maintenance Plan and Redesignation Request ............................................................................... A

Insignificance Determination for Transportation Conformity Under PM 2.5 NAAQS for Jackson County,

AL ........................................................................................................................................................... B

Emissions Inventory Documentation ..................................................................................................... C

Development of the Point Source Emissions Inventory for 2007 in the SESARM Region (Version 1.10a), January 18, 2012 ................................................................................................................ C-1

Area and Nonroad 2007 Base Year Inventories, Revised Final Report, Jan 2012 ......................... C-2

Onroad and Nonroad Emissions Modeling Da ta ........................................................................... C-3

Growth Factors, Control Factors, and Emission Summaries for Emission Inventory (includes memorandum from K. Thesing) ...................................................................................................... C-4

MACTEC, August 2009. Point Source, On

- road, and Fire Base Year, Future Year, and Control Strategy Emissions Inventories Draft Quality Assurance Project Plan .......................................... C-5

E.H. Pechan and Associates, July 29, 2009. Quality Assurance Project Plan for Non

- road and Area
Source Base Year and Future Year Emissions Inventories .............................................................. C-6

The Federal Facilities Compliance Agreement Between EPA and the Te nnessee Valley Authority, Docket

No. CAA -04-2010-1760 ......................................................................................................................... D

Chattanooga, TN DRAFT Maintenance Plan and Redesignation Request – Narrative Only ................ E

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

vi 

## List of Acronyms

Acronym Meaning Acronym Meaning

ADEM Alabama Department of Environmental Management FR Federal Register

AERR Annual Emissions Reporting Requirements FRM Federal Reference M onitor

AIRS Aerometric Information Retrieval System ICI Industrial and
Co mmercial/Institutional

ALDOT Alabama Department of Transportation LRTP Long Range Transportation Plan

AQS Air Quality Sub system MOVES Motor V ehic le Em issions Si mu lator

CAA Clean Air Act NAA Nonattainment Area

CAIR Clean Air Interstate Rule NAAQS National Ambient Air Quali ty Standard

CERR Consolidated Emissions Reporting
Rule NEI National Emissions Inven tory

CFR Code of Federal Regulations NESHAP National Emissions Standards for
Hazardous Air Pollutants

CMV Commercial Marine Vessels NMIM National Mo b ile Invento ry Model

EGAS Econom ic Growth Ana ly sis Sy stem NSR New Source Review

EGU Electric G en e rating Unit NO x Nitrogen Ox id es

EIA Energy Information Administration PM Particulate Matter

EPA U.S. Environm ental Protection Agency PM 2.5 Fine Particulate Matter

FGD Flue Gas Desulfurization P PM parts per m il lion

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

vii Ac ro nym Meaning Ac ro nym Meaning

PSD Prevention of Significant Deterioration SIP S tate Im plementation Plan

RACM Reasonably Av ailable Control Measur es SO 2 Sulfur Diox id e

RACT Reasonably Av ailable Control Technology TIP Transportation Improvement Plan

RFP Reasonable Fu rther Progr e ss TPY tons per y ear

RVP Reid Vapor Pressure TVA Tennessee Valley Authority

SAFETEA

LU Safe, Accountable, Flexible, Efficient Transportation Equity Act

– A Legacy
for Users ULSD Ultra

- Low Sulfur Diesel

SCC Source Class i fication Code VIS T AS Visibility Improvement

– State
and Tribal Association of the
Southeast

SCR Selective Ca t al y tic Reduct ion VMT V ehicle Miles T raveled

SEMAP Southeastern Modeling Anal y sis Plan

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

1-1 

## 1.0 Introduction

1.1 Purpose

This document contains the technical support necessary for the ADEM request that the Jackson County , Alabama

, portion of the Chattanooga annual PM 2.5 

### NAA be redesignated as an area attaining the annual PM 2.5 

### NAAQS pursuant to §§107(d)(3)(D) and (E) of the C AA , as amended.

1.2 Historic Background

On January 5, 2005, the EPA designated a portion of Jackson County, Alabama, as a part of the Chattanooga NAA for the annual PM 2.5 

### standard. The official designations and classifications were printed in the Federal Reg ister on January 5, 2005 (70FR944)

, and were amended on April 5, 2005 (70FR19844). Figure 1.2-1 shows the boundaries of the Jackson County portion of the

NAA

. On May 31, 2011, EPA promulgated its determination (76 FR 31239) that the Chattanooga
NAA had attained the 1997 annual average PM 2.5 

### 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 μg/m3. This final rule became effective on June 3 0,
2011.

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

1-2 Figure 1.2-1 The Jackson County, AL portion of the Chattanooga Annual PM 2.5 N AA

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

1-3 

### 1.3 Formation of PM 2.5 

### Fine particulate matter, also known as fine particles and PM 2.5 

### , refers to airborne particles less than or equal to 2.5 micrometers (μm) in diameter. Fine particles are treated as though they are a single pollutant, but they come from many different sources and are composed of many different compounds. PM 2.5 

### exposure adversely affects human health, especially respiratory and cardiovascular systems. Individuals particularly sensitive to PM 2.5 

### exposure include children, people with heart and lung disease, and older adults.

PM 2.5 

### can be liquid, solid, or can have a solid core surrounded by liquid. PM 2.5 

### can include material produced by combustion, photochemical reactions, and can contain salt from sea spray and soil like particles. Particles are distinguished based on the method of formation. Primary particles are particles directly emitted into t he atmosphere and retain the same chemical composition as when they were released. Secondary particles are those formed through chemical reactions involving atmospheric oxygen, water vapor, hydroxyl radical s , nitrates, sulfur dioxide (SO 2 

### ), nitrogen oxides (NO X 

### ), and organic gases from natural and anthropogenic

sources. PM 2.5 

### can therefore be composed of varying amounts of different species, including:

• Sulfates

• Nitrates (usually found in the form of ammonium nitrate)

• Ammonium

• Hydrogen ion

• Particle bound water

• Elemental carbon

• Organic compounds

o Primary organic species (from cooking and combustion)

o Secondary organic compounds

• Crustal material (includes calcium, aluminum, silicon, magnesium, and iron)

• Sea salt (generally only found at coastal monitorin g sites)

• Transitional metals

• Potassium (generally from wood burning or cooking)

The most significant sources of PM 2.5 

### and its precursors are coal

- fired utilities, industrial boilers, and other combustion sources. These emissions are often transported over large
distances. Other sources of PM 2.5 

### emissions include mobile sources, area sources, biogenic sources, fires, windblown dust, and oceans.

A variety of meteorological and geographic factors influence the concentration levels of fine particles, includin g both the regional and local distribution of urbanized areas, primary and precursor emissions sources, and natural features such as oceans and forests. Since PM 2.5 

### concentrations can exceed the NAAQS at any time of the year, the EPA mandates the year

rou nd monitoring of the pollutant throughout the country (40 CFR 58, App. D).

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

1-4 

### 1.4 Criteria for Redesignation

Section 107(d) of the federal C AA , as amended in 1990, states that an area can be redesignated to attainment if the following conditions are met:

1. The EPA has determined that the NAAQS have been attained.

2. The applicable implementation plan has been fully approved by EPA under Section 110(k).

3. The EPA has determined that the improvement in air quality is due to permanent and
enforceable reductions in emission s.

4. The state has met all applicable requirements for the area under Section 110 and Part D.

5. The EPA has fully approved a maintenance plan, including a contingency plan, for the
area under Section 175A.

The first and third of these requirements relate direc tly to air quality and the reasons for its improvement. These requirements are discussed together in Section 2 of this document.

The second and fourth requirements relate to the implementation plan. All requirements under §110 and Part D of the Act have been met. These requirements are discussed in Section 3.

The maintenance plan has two required components under Section 175A . First, the state must
submit a revision to the SIP , which provides for maintenance of the NAAQS in the area for at least ten yea rs after the redesignation. EPA has up to 18 months after submittal of the redesignation request to approve or disapprove it. Therefore, EPA is required to make its decision by mid -2014 since this document is being submitted in early 2013 . Thus, the Sta te must demonstrate that the Chattanooga NAA will maintain the standard through at least 202 5 [2015 + 10 = 202 5 ]. The end year of our plan is 2025. Also, the plan revision must incorporate a contingency plan outlining commitments by the state to promptly correct any future violations. The maintenance demonstration and contingency plan are discussed in Section 4.

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

2-1 

## 2.0 Attainment Demonstration

2.1 Demonstration that the NAAQS Has Been Attained

Compliance with the NAAQS for annual PM 2.5 

### is demonstrated when the three year average of
the annual arithmetic mean PM 2.5 

### concentrations is less than or equal to 15 μg/m 3 

### . The resulting concentration represents an annual PM 2.5 

### design value. A violation of the annual PM 2.5 

### NAAQS occurs when the design value exceeds 15 μg/m 3 

### at any monitor.

The three year period of annual PM 2.5 

### monitoring data for 2007- 2009 for the Chattanooga NAA demonstrate compliance with the NAAQS for annual PM 2.5, 

### as will be illustrated in the next
section.

On May 31, 2011, EPA promulgated its determination (76 FR 31239) that the Chattanooga

NAA had attained the 1997 annual average PM 2.5 

### 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 μg/m 3 

### . This final rule became effective on June 30, 2011.

2.1.1 PM 2.5 Monitoring Network



### Four PM 2.5 

### federal reference monitors (FRM) are located in the nonattainment area. Three monitors are located in Hamilton County

, Tennessee

, and one monitor is located in Walker County, Georgia. FRM s collect samples that are used to determine if an area is in attainment
with the PM 2.5 

### NAAQS. The FRM located at Soddy

- Daisy High School is the most rural site of the three Hamilton County FRMs and has always shown attainment. The other three monitors
showed exceedances of the annual standard for the 2001

- 2003 averaging period, which is the period the EPA used in the designation of the NAA

. Table 2.1.1 -1 shows the annual average

PM 2.5 

### concentrat ions and the associated 3

- year average that demonstrate attainment of the
standard in the Ch attanooga nonattainment area. The 2007

– 2009 three

- year design value is 12.7 μg/m 3 

### , which is below the standard of 15.0 μg/m 3



### . The table includes annual averages from 2003 through 2010, demonstrating the downward trend in the measured ambient PM 2.5 

### level in the nonattainment area. The 2008

- 2010 three

- year design value (Monitor ID 470654002) is 11.6 μg/m 3 

### . This provides continued evidence that the area is meeting the
standard. Monitor locations are shown in Figure 2.1.1 -1. All of the PM 2.5 

### ambient monitoring data that was collected during 2007, 2008, and 2009 was collected in accordance with 40 CFR
58 and has been stored in EPA's Aerometric Information Retrieval System (AIRS) Air Quality System (AQS ).

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

2-2 Table 2.1.1-1 Annual and Three

- year Average Ambient PM 2.5 Concentrations

Year Monitor

13-295-0002 (μ g/m3) Monito r
47-065-0031 (μg/m3) Monitor

47-065-1011 (μg/m3) Monitor

47-065-4002 (μg/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

2011 † 10.8* 11.1 10.3 11.1

2007- 20 09 12.3* 12.6 11.7 12.7

2008- 20 10 10.7 11.6 11.4 11.6

2009-2011 10.1* 11.2 11.0 11.1



### * V alues subject to data substitution ( 76 FR 15895)

† Data obtained from AQS

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

2-3 Figure 2.1.1-1 Locations of PM 2.5 Monitors in the Chattanooga NAA

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

2-4 

### 2.2 Permanent and Enforceable Reductions in Emissions

Since 2000, there have been several major federal programs enacted that have led to significant actual, enforceable PM 2.5 

### and PM 2.5 

### precursor emission reductions. These programs were established to provide reductions in emissions from the mobile source and industrial sectors. These programs are listed below.

1. Tier II Motor Vehicle Emissions Standards

2. Federal Onroad Diesel Engine Standards

3. Federal Nonroad Diesel Engine Standards

4. Federal Marine Engine Requirements

5. Federal Locomotive Requirements

6. The New Source Performance Standards under Section 111 (42 U.S.C 7411)

7. The National Emission Standards for Hazardous Air Pollutants under Section 112 (42 U.S.C. 7412)

8. The NO X 

### SIP Call

9. The Clean Air Interstate Rule

10. After December 1, 2014, all on

- road, non

- road, locomotive and marine diesel fuel produced and imported will be Ultra

- Low Sulfur Diesel (ULSD -15 p pm).

11. Installation of Selective Catalytic Reduction ( SCR ) on Unit 7 (2003) and Unit 8 (2004) at
TVA Widows Creek. SCRs were added as a result of the NO

x 

### SIP Call. The Flue

- gas desulfurization ( FGD ) on Unit 8 was upgraded in efficiency in 2004. Year round operation of the SCRs and FGDs was planned in anticipation of the Clean Air Interstate Rule ( CAIR ) rule, and subsequent replacement rule

.

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

3-1 

## 3.0 Fully Approved SIP, Section 110 a nd Part D Requirements

3.1 Section 110 Implementation Plans

On October 5, 2012, EPA finalized approv al of a SIP revision (77 FR 60904 ) submitted by

ADEM on October 7, 2009, for the purpose of demonstrating attainment of the 1997 PM 2.5 

### NAAQS in the Alabama portion of the tri

- state Chattanooga PM 2.5 

### NAA

. The Chattanooga Area is comprised of Catoosa and Walker Counties in Georgia; Hamilton County in Tennessee; and a portion of Jackson County in Alabama. The Alabama SIP revision pertains only to the Alabama portion of the Chattanooga Area. EPA finalized approv al of Alabama’s October 7, 2009, SIP revision regarding reasonably available control technology (RACT) and reasonably available control measures (RACM); reasonable further progress (RFP); contingency measures; and, for transportation conformity purposes, an insignificance determination for PM 2.5 

### and NO

x 

### for the mobile source contribution to ambient PM 2.5 

### levels for the Alabama portion of the Chattanooga Area. This action is being taken in accordance with the CAA and the ‘‘Clean Air Fine Particle Implementation Rule,’’ issued by EPA on April 25, 2007. EPA also approved the base year emissions inventory for the 2009 attainment SIP for the Alabama portion of the Chattanooga NAA on February 8, 2012 (77 FR 6469).

The general elements required in a SIP are listed in §110(a). These elements include procedures for air quality monitoring and modeling; criteria for establishing stationary source controls, monitoring and reporting; implementation of permitting programs under Part C (Prevention of Significant Deterioration or PSD) and Part D (New Source Review or NSR); and provisions for public involvement. Alabama has a fully approved SIP under the authority of §110.

3.2 Part D Plan Requirements for Nonattainment Areas

3.2.1 Nonattainment Areas in General

3.2.1.1 Section 172(c) –



### In October of 2009, ADEM submitted to EPA the a ttainment d emonstration for the Jackson County , Alabama, portion of the Chattanooga annual PM 2.5 

### NAA

. This plan demonstrates
attainment of the annual PM 2.5 

### NAAQS beginning in 20 10 based on implementation of a
combination of federal measures

, other regional controls, and local controls and unit shutdowns
associated with NAA utilities. Thus, ADEM has met the requirement of Section 172(c). EPA also approved the base year emissions inventory for the 2009 attainment SIP for the Alabama portion of the Chattanooga NAA on February 8, 2012 (77 FR 6469).

3.2.1.2 Section 176(c) –



### The concept of transportation conformity was introduced in the C AA of 1977, but the requirements became substantially more rigorous in the Amendments of 1990. The CAA and the Safe, Accountable, Flexible, Efficient Transportation Equity Act

– A Legacy for Users (SAFETEA

- LU) define the framework fo r effective integration of transportation and air quality planning.

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

3-2 

### Transportation conformity is a process by which it is determined that on

- road mobile (highway) source emissions evaluated from the Transportation Improvement Program (TIP) and/or Long Rang e Transportation Plan (LRTP) will not adversely impact air quality in a determined area of nonattainment. Federal funding and approval are given to transportation activities that are consistent with air quality goals.

As part of the Jackson County attainment demonstration submitted in 2009, ADEM included a report entitled “Insignificance Determination for Transportation Conformity Under PM 2.5 

### NAAQS for Jackson County, AL”. The report, which was approved by EPA in a June 18, 2010, Federal Register notice (75 FR 34735), shows that emissions of NOx and direct fine particles ( PM 2.5 

### ) from mobile sources in the small portion of Jackson County designated by EPA as nonattainment for the annual fine particle NAAQS, are an insignificant contributor to
nonattainment of the PM 2.5 

### NAAQS. Therefore, the Jackson County portion of the Chattanooga annual PM 2.5 

### nonattainment area is not subject to transportation conformity. The analysis performed in the 2009 Insignificance Determination is presented below:

According to 40 CFR 93.109( f ), there are several factors that are used to support a finding of insignificance for these transportation

- related PM 2.5 

### precursor pollutants. The first factor is the percentage of motor vehicle emissions in the conte xt of the total SIP inventory. The second factor is the current state of the air quality in the area. The third factor is the absence of SIP motor vehicle emission control measures. Lastly, historical trends and future projections of the growth of motor vehicle emissions are reviewed. These factors are discussed in detail in the sections to follow. Each section supports the insignificance of NO X 

### and direct PM 2.5 

### emissions from mobile sources in the Jackson County portion of the nonattainment area under the transportation conformity rule for the PM 2.5 

### NAAQS.

3.2.1.2.1 Nitrogen Oxides (NO X )

3.2.1.2.1.1 Analysis of motor vehicle NO X emissions in the Jackson County portion of the Chattanooga

nonattainment area.



### Only a small portion of Jackson County, Alabama, was included in the Chattanooga PM 2.5 

### nonattainment area. The small portion of the county designated nonattainment contains a
limited number of roads. In order to determine the on

- road emissions of NO X 

### from motor vehicles in that portion of Jackson County, the document tit led “Chattanooga Nonattainment

Area Year 203 5 Conformity Determination Report for Particulate Matter (PM 2.5 

### )” was used to determine how emissions were calculated for Jackson County and the same methodology was applied in this analysis. In order to estimat e on

- road mobile source emissions for the nonattainment portion of Jackson County, a ratio of the size of the nonattainment portion of Jackson County in square miles to the size of the entire county in square miles was calculated. The nonattainment portion of Jackson County was determined to be only about one percent of the total area of the entire county. The same ratio was applied to obtain area and non

- road mobile source emissions for the nonattainment portion of the county. The following table
shows the small percentage of NO X 

### emissions from on

- road mobile sources as compared to

NO X 

### emissions from all other sources in the Jackson County portion of the nonattainment area.
Emission data were obtained from the SEMAP 2007 base year emissions inventory.

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

3-3 T

able 3.2.1.2.1.1-1 2007, 2017, 2025 NO X (TPY) Emissions in the Nonattainment portion of Jackson County by Source Type

Source Category 2007 (attainment) % of
total 2017 % of
total 2025 % of
total

Point 18,591.83 99.668 3,468.44 98.962 3,607.05 99.27

Area 1.58 0.008 1.55 0.044 1.57 0.043

Non

road 37.32 0.2 25.86 0.737 18.95 0.522

Mobile 23 0.123 9 0.257 6 0.165

Total 18,653.73 100 3,504.83 100 3,633.57 100



### As the above table demonstrates, NO X 

### emissions from on

- road mobile sources in the nonattainment portion of Jackson County are 0. 123 % of the total NO X 

### emissions from all source categories in the same area for 2007, 0.257% for 2017, and 0.165% for 2025.

In the table below, a comparison is made of the mobile source NO X 

### emissions from the nonattainment portion of Jackson County to total mobile source NO X 

### emissions for the entire Chattanooga nonattainment area.

Table 3.2.1.2.1.1-2 200 7, 2017, 2025 NO X (TPY) On

- road Mobile Source Emissions in the Nonattainment Portion of Jackson County Compared to Total On- road Mobile Source Emissions in the entire Chattanooga NAA

Area 2007
Emissions

(TPY) Percentage
of Total 2017
Emissions

(TPY) Percentag
e of Total 2025
Emissions

(TPY) Percentage
of Total

Jackson County

NAA Portion 23 .18% 9 .11 % 6 .16%

Chattanooga
NAA 12,773 8,105 3,827



### As the table above demonstrates, NO X 

### emissions from on

- road mobile sources in the Jackson County portion of the nonattainment area are .18 % of the total NO X 

### emissions from on -road mobile sources in the entire Chattanooga nonattainment area for 2007, .11 % for 2017, and .16 %
for 2025.

3.2.1.2.1.2 The c urrent state of the air quality in Jackson County.



### As stated earlier in this document, the small portion of Jackson County, Alabama, was included in the Chattanooga PM 2.5 

### nonattainment area due to the fact that a power plant is located in that
area and it was thought by EPA to contribute to the PM 2.5 

### problem in Chattanooga. There are

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

3-4 

### no PM 2.5 

### monitors located in Jackson County. Monitors in Alabama near Jackson County have
monitored values below the annual PM 2.5 

### NAAQS. Other counties surrounding the county are either in attainment or unclassifiable.

3.2.1.2.1.3 The absence of SIP motor vehicle controls for the area.



### There are no SIP motor vehicle controls for Jackson County.

3.2.1.2.1.4 Historical trends and future projections of the growth of motor vehicle emissions.



### The “C hattanooga Non

- Attainment Area Year 203 5 Conformity Determination Report for Particulate Matter (PM 2.5 

### )” was used to obtain past and future projections of the growth in NO X 

### emissions from on

- road mobile sources. As demonstrated in the table below, future emissions
of NO X 

### are expected to decrease.

Table 3.2.1.2.1.4 -1 Historical and Future Projections of NO X emissions from On

- Road Mobile Sources in Jackson County

Year Emissions (TPY)

2002 21.31

2009 12.87

2015 7.17

2025 4.11

2035 3.71

3.2.1.2.2 Direct PM 2.5

3.2.1.2.2.1 Analysis of motor vehicle PM 2.5 emissions in the Jackson County portion of the Chattanooga nonattainment area



### Only a small portion of Jackson County, Alabama, was included in the Chattanooga PM 2.5 

### nonattainment area. The portion designated as nonattainment contains a limited number of
roads. In order to determine the on

- road emissions of PM 2.5 

### from motor vehicles in that portion of Jackson County, the document titled “Chattanooga Non

- Attainment A rea Year 203 5 Conformity Determination Report for Particulate Matter (PM 2.5 

### )” was used to determine how emissions were calculated for Jackson County and the same methodology was applied in this analysis. In order to estimate on

- road mobile source emission s for the nonattainment portion of Jackson County, a ratio of the size of the nonattainment portion of Jackson County in square miles to the size of the entire county in square miles was cal culate d. The nonattainment portion of Jackson County was determined to be only about one percent of the total area of Jackson County. Th e same ratio was applied to obtain area and non

- road mobile source emissions for the nonattainment portion of the county. The following table shows the small percentage of

PM 2.5 

### emiss ions from on

- road mobile sources as compared to PM 2.5 

### emissions from all other

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

3-5 

### sources in the nonattainment portion of Jackson County. Emission data were obtained from the SEMAP 2007 base year inventory.

Table 3.2.1.2.2.1-1 200 7, 2017, 2025 Direct PM 2.5 (TPY) Emissions in the Nonattainment Portion of Jackson County by Source Type

Source Category 2007 (attainment) % of
total 2017 % of
total 2025 % of
total

Point 755.49 96.194 534.89 94.79 534.89 94.682

Area 27.11 3.452 28.08 4.976 29.17 5.164

Non

road 2.05 0.261 1.01 0.179 0.63 0.112

Mobile 0.73 0.093 0.31 0.055 0.24 0.042

Total 785.38 100 564.29 100 564.93 100



### As the above table demonstrates, direct PM 2.5 

### emissions from on

- road mobile sources in the nonattainment portion of Jackson County are less than 1% of the total direct PM 2.5 

### emissions from all source categories in the same area.

In the table below, a comparison is made of the mobile source direct PM 2.5 

### emissions from the nonattainment portion of Jackson County to total mobile source PM 2.5 

### emissions for the entire Chattanooga nonattainment area.

Table 3.2.1.2.2.1-2 200 7, 2017, 2025 Direct PM 2.5 (TPY) On

- road Mobile Source Emissions in the Nonattainment Portion of Jackson County Compared to Total On- road Mobile Source Emissions in the Entire Chattanooga NAA

Area 2007
Emissions

(TPY) Percentage of

Total 2017
Emissions

(TPY) Percentage
of Total 2025
Emissions

(TPY) Percentage
of Total

Jackson County NAA
Portion 0.73 0.2% 0.31 0.2% 0.24 0.2%

Chattanooga
NAA 390 197 134



### As the table above demonstrates, direct PM 2.5 

### emissions from on

- road mobile sources in the Jackson County portion of the nonattainment area are 0.2 % of the total direct PM 2.5 

### emissions
from on -road mobiles sources in the entire Chattanooga NAA for 2007, 2017, and 2025.

### Jackson County Annual PM 2.5 

### Nonattainment Area

Req uest for Redesignation to Attainment

3-6 3.2.1.2.2.2 The current state of the air quality in Jackson County.



### The small portion of Jackson County, Alabama, was included in the Chattanooga PM 2.5 

### nonattainment area due to the fact that a power plant is located in that area and it was thought by EPA to contribute to the PM 2.5 

### problem in Cha ttanooga. There are no PM 2.5 

### monitors located in Jackson County. Monitors in Alabama near Jackson County have monitored values
below the annual PM 2.5 

### NAAQS. Other counties surrounding the county are either in
attainment or unclassifiable.

3.2.1.2.2.3 The absence of SIP motor vehicle controls for the area.



### There are no SIP motor vehicle controls for Jackson County.

3.2.1.2.2.4 Historical trends and future projections of the growth of motor vehicle emissions.



### The “Chattanooga Non

- Attainment Area Year 203 5 Conformity Determination Report for Particulate Matter (PM 2.5 

### )” was used to obtain past and future projections of the growth in
direct PM 2.5 

### emissions from on-road mobile sources. As demonstrated in the table below, future
emissions of direct PM 2.5 

### are expected to decrease.

Table 3.2.1.2.2.4-1 Historical and Future Projections of PM 2.5 emissions from On

- Road Mobile Sources in Jackson County

Year Emissions (TPY)

2002 0.413

2009 0.241

2015 0.155

2025 0.130

2035 0.136



### Each of the factors set forth in 40 CFR 93.109(k) were reviewed for the transportation

- related

PM 2.5 

### precursor pollutants NO X 

### , SO X 

### , and direct PM 2.5 

### . These reviews support the conclusion
that mobile source emissions of NO X 

### , SO X 

### , and direct PM 2.5 

### in the Jackson County portion of the Chattanooga annual PM 2.5 

### nonattainment area are insignificant under the transportation conformity rule for the annual PM 2.5 

### NAAQS.

Th e report is included in this request as Appendix B.

### Jackson County Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-1 

## 4.0 Maintenance Plan

Section 175A of the C AA Amendments of 1990 defines the general framework of a maintenance plan. The core provisions include the attainment inventory, the maintenance demonstration, the verification of continued attainment, and the contingency plan.

4.1 Maintenance Demonstration

The required maintenance plan must become a part of the SIP and provide for maintenance of the air quality in the affected area for at least 10 years after designation. Specifically, the

C AA requirement is that a maintenance plan that is at least 10 years in length (i.e., after EPA’s expected approval) be submitted with the redesignation request. Subsequently, 8 years after redesignation and submittal of the initial maintenance plan, the Stat e is required to submit an additional maintenance plan that shows maintenance for the remainder of the 20 year period. Alabama has chosen 2025 as the end year of the initial maintenance plan for the Chattanooga NAA.

The general approach used for the maint enance plan to demonstrate that attainment of the
annual PM 2.5 

### standard will continue to be maintained is based upon restricting the future anthropogenic emissions to a level that is representative of attainment of the standard. If these future emissions are no greater than the actual emissions during a year in which attainment of the standard was monitored, then it can be assumed that attainment of the standard will also be achieved in future years.

The following sections discuss the attainment year inventory, the projected inventories, and
verification of continued attainment. Table 4 .4-1 shows a calculated safety margin for

PM 2.5 

### , NO X 

### and SO 2 

### for each year in the maintenance plan.

4.2 Attainment Inventory

2007 was selected as the year for the attainment year emissions inventory. 2007 is one of the 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 

### , SO 2 

### , and NO

x 

### . The following emissions sectors are included in the inventory:

• Point sources (EGU and non- EGU).

• Nonpoint sources (including fire),

• Onroad mobile sources, and

• Nonroad mobile sources (including marine vessels, aircraft, and rail).

The 2007 inventory, with the exception of on

- road mobile emissions, was prepared for
Alabama by the contractors for the Southeastern Modeling, Analysis, and Planning (SEMAP) project. SEMAP is funded by the same ten states that participated in the Visibili ty Improvement – State and Tribal Association of the Southeast (VISTAS) project. Under the SEMAP project, emissions estimates are reported by county and source classification code (SCC). The SEMAP emissions inventories were developed using data from a number of sources, including state and local agencies and EPA’s National Emissions Inventory (NEI).

### Jackson County Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-2 

### ADEM developed the 2007 inventory of on

- road mobile emissions. Please see Table 4. 4-1 for a summary of the base year inventory.

4.2.1 Point Sources



### Point sources captured in the inventory include stationary sources whose actual emissions equal or exceed 100 tons per year of SO 2 

### , NO
x 

### , or particulate matter. Emissions from point
sources have been calculated for EGU and non

- EGU sources.

There are only two point sources in the Jackson County portion of the NAA : TVA Widows
Creek Plant and Rock -Tenn Mill Company, LLC – Stevenson Mill.

Table 4.2.1-1 2007 Point Emissions (TPY)

Facility Unit NOx PM2.5 SO2

Rock -Tenn Mill Company,
LLC - Stevenson Mill Neutral Sulfite Semi

Chemical Recovery System 147.17 0.14 0.67

No. 1 Power Boiler 99.85 34.08 45.78

No. 2 Power Boiler 51.45 9.44 32.98

No. 1 Wood Waste Boiler 251.68 42.53 1.01

No. 2 Wood Waste Boiler 436.68 5.15 6.54

986.83 91.34 86.98

TVA Widows Creek Unit 1 1,646.00 20.00 3,550.00

Unit 2 1,706.00 7.04 3,673.00

Unit 3 1,750.00 111.00 3,766.00

Unit 4 2,028.00 18.40 4,363.00

Unit 5 1,316.00 20.40 2,834.00

Unit 6 1,818.00 2.21 3,911.00

Unit 7 3,694.00 63.10 6,519.00

Unit 8 3,647.00 422.00 4,101.00
17,605.00 664.15 32,717.00 Facility/Point Emissions Total 18,591.83 755.49 32,803.98



### Emissions estimates for point sources in 2007 were obtained from SEMAP point source inventory v1.10. For more information regarding the SEMAP point inventory, please refer to Appendix C-1.

4.2.2 Nonpoint Sources



### Nonpoint sources can be defined as those sources and activities that are too small or too numerous to be handled individually in a point source inventory. Nonpoint sources captured in the inventory include stationary sources whose emissions levels of SO 2 

### , NO
x 

### , and particulate matter are each less than 100 tons per year. Emissions from nonpoint sources in 2007 were obtained from the SEMAP final nonpoint source inventory v ersion 1.1. A default 2007 nonpoint source inventory was created that includes all of the sour ce categories covered by the 2008 nonpoint source NEI.

### Jackson County Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-3 

### For all source categories

, except industrial and commercial/institutional (ICI) fuel combustion, emissions data from 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 inventory were removed from the nonpoint inventory.

For ICI fuel combustion, the 2008 nonpoint source NEI developed emissions activity
estimates rather than emission estimates. Because of the potential importance of these source categories and the availability of methodological improvements, Tran S ystems 1


### utilized an emissions estimation method for ICI fuel combustion that incorporates a few
refinements to the NEI method. These emissions were supplemented with carry

- forward categories from Alabama’s 2005 Consolidat ed Emissions R eporting Rule ( CERR ) submission grown using EPA’s Economic Growth Analysis System 5.0 (EGAS). For more information regarding the SEMAP nonpoint inventory, please refer to Appendix C-2.

Emissions fr om fires in 2007 were obtained from the SEMAP final “actual” fire emissions
inventor y. This inven tory was developed using 2007 bu rned area data su bm itted b y Alabama, as well as updated fuel consumption and emissions factors. The 2007 nonpoint source emissions for Jackson County are presented in Table 4.2.2-1.

Table 4.2.2-1 Jackson County NAA Nonpoint Source Emissions for 2007 (TPY)

Pollutant Nonpoint (excluding fire) Fire Total Nonpoint

SO 2 0.1455 0.108 3 0.2538

NO

x 1.0722 0.51 07 1.5829

PM 2.5 25.363 1.75 08 27.1138



### The 2007 level of PM 2 .5 

### emissions from nonpoint sources, excl uding fire, was 25.363

tons. This quantity accounted for about 3 percent of total PM 2.5 

### emissions in Jackson County.

As area sources are largely a function of population, the ratio of the population of the single census block to the entire county’s population was applied to the county

- wide area source emissions, as seen below:

Census Block Population/County Population * County

- wide Area Source Emissions = Partial County Area Source Emissions

1 TranSystems is supporting SESARM in the SEMAP project that is funded by the same ten states originally involved in the VISTAS project. The SEMAP project addresses the next phase of ozone, fine particle, and regional haze assessment obligations of the SESARM member states. The SEMAP project is designed to produce technical analyses to aid the participating agencies in developing SIPs required by the CAA.

In June 2010, TranSystems developed a set of “final” 2007 area and nonroad source base year inventory
emission estimates.

### Jackson County Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-4 

### 1,469 / 53,227 * 38.85 TPY NO
x 

### = 1.0722 TPY NO
x 

### . For fire emissions calculations, the ratio of the area of the single census block to the entire county’s area was applied to the county- wide fire emissions, as seen below:

Census Block Area/County Area * County

- wide Fire Emissions = Partial County Fire
Emissions

12.88 sq. miles/1127 sq. miles * 44.6891 TPY NO

x 

### = 0.5107 TPY NO

x 

### .

Population data used in calculations was taken from the 2010 Census.

4.2.3 On -road Mobile Sources



### The U.S. EPA’s MOVES2010b mobile source emissions model was run in inventory mode to generate 2007 mobile source emissions for SO 2 

### , NO X 

### and PM 2.5 

### for Jackson County, Alabama. Local vehicle miles traveled (VMT) data for Jackson County was developed by the Alabama Department of Transportation (ALDOT) for 2007 . T he VMT data was used to make appropriate calculations in the development of the MOVES2010b input files.

The runspecs for all years modeled were developed using the same format. All were set to the county scale with all months, days and hours being modeled. The aggregation level was set to hour with the appropriate state and county being selected in the geographic bounds
section.

All relevant gasoline and diesel vehicles were chosen as well as all road types. The pollutants of concern were NO X 

### , PM 2.5 

### and SO 2 

### . For those pollutants where the emissions calculation is based on prior calculati on of another pollutant, the appropriate base pollutants were also selected. “Tons” was selected as the emissions unit, and the emissions detail was aggregated to “year” in order to retrieve data in tons per year. Input data was then imported through the County Data Manager (CDM).

MOVES2010b default data was exported, reviewed and re

- imported for the following CDM inputs: Age Distribution, Average Speed Distribution, Fuel Supply, Meteorology and Ramp Fraction. Source Type Population, Vehicle Type

, VMT

, and Road Type Distribution were derived from either manual calculation or by using one of the converters provided by EPA. For Fuel Formulation, the Reid vapor pressure ( RVP ) was adjusted to 9.0 for May

September with the default RVP being used for all other months.

The process of data collection and emissions modeling was conducted in accordance with the Technical Guidance on the Use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity. The onroad mobile source emissions for the portion of Jackson County in the nonattainment area were derived by taking 1% of the total for all of Jackson County for each of the pollutants (SO 2 

### , NO
x 

### and

PM 2.5 

### ). 1% is based on the ratio of the size of the nonattainment portion of Jackson County in square miles to the size of the entire county in square miles. The 2007 onroad mobile source emissions totals for the portion of Jackson County in the nonattainment area are
listed in Table 4.4-1 (Please also see Appendix C -3).

### Jackson County Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-5 4.2.4 Nonroad Mobile Sources



### The nonroad sector is comprised of nonroad 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 (CMV) , and locomotives. There are no aircraft emissions sources in the portion of Jackson County that is included in the nonattainment area. Nonroad mobile emissions for 2007 for the portion of Jackson County in the nonattainment area are presented in detail in Table 4.2.4 -1 and summarized in
Table 4. 4-1.

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 Inve ntory Model, NMIM2008, which incorporates EPA’s latest NONROAD model (NONROAD2008) and reflects all of EPA’s final nonroad standards to date. For more information regarding the SEMAP nonroad inventory, please refer to Appendi ces C-2 , C

- 3 and C -4. Emission s from commercial marine
vessels and locomotives for 2007 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 -2, C-3 and C4

Nonroad sources encompass sources that are a function of population as well as sources that are more location specific. To develop more conservative nonroad estimates for the partial county, a population ratio was applied. The equation is below:

Census Block Population/County Population * County

- wide Emissions = Partial County
Emissions

Table 4.2.4-1 2007 Nonroad Mobile Source Emissions (tons)

Pollutant

(tons) Nonroad* CMV Locomotives Total
Non road

SO 2 .55 .08 .28 .91

NO

x 11.40 1.08 24.84 37.32

PM 2.5 1.19 .03 .83 2.05

*Excludes CMV and Locomotives.



### 4.3 Projected Emissions Inventory

Projected emissions inventories are calculated by applying applicable control and growth factors to the 2007 emissions of individual sources or source categories. The pollutants whose emissions are projected are SO2, NOx, and direct PM2.5. As with the attainment inventory, emissions from the following sectors are projected:

• Point sources (non- EGU).

• Nonpoint sour ces (including fire).

### Jackson County Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-6 

### • Onroad mobile sources. and

• Nonroad mobile sources (including marine vessels, aircraft, and rail).

The projected inventories are presented in the following subsections and a summary can be
found in Table 4. 4-1 . The methods used to develop the emissions projections are presented
in more detail in Appendix C-4.

4.3.1 Point Sources



### To establish 2017 and 2025 projected point emissions, the following issues were taken into

account:

• A federal facilities compliance agreement between EPA and the Tennessee Valley Authority, Docket No. CAA -04-2010- 1760 (Compliance Agreement) requires TVA
Widows Creek to retire Units 1 -6 by July 31, 2015 (Please see Appendix D)

.

• Power Boilers 1 and 2 at th e Stevenson Mill are switching from Grade 6 Residual Oil to Natural Gas. The new permit limits are reflected in their Title V.

Growth rates for Widows Creek Units 1

- 6 were set to zero to reflect the retirement of those units. For Units 7 and 8, an averag e rate of growth was calculated based on emissions from

2000- 2010 as reflected in the Clean Air Markets Division Database. EGAS 5.0 factors were applied to all units at the Stevenson Mill; however, new base estimates were calculated for the two power boil ers to reflect the switch in fuels. These estimates are based on similar
units within the S tate. Please see Appendix C-4 for the projection calculations.

4.3.2 Nonpoint Sources



### Nonpoint source emissions, excluding fire, in future years 2017 and 2025 were estim ated using SCC
- and county

- specific growth factors generated with EGAS 5.0 . Appendix C -4
contains the SCC
- specific growth factors for Jackson County

. Just as for the base year, the emissions were apportioned to the census block group by applying the ratio of block group population to county population. No additional future controls can be defined for these
sources at this time. Emissions from fire in future years 2017 and 2025 were assumed to be
the same as 2007 emissions.

4.3.3 Onroad Mobile Sources



### The U.S. EPA’s MOVES2010b mobile source emissions model was run in inventory mode to generate 2017 and 2025 mobile source emissions for SO 2 

### , NO
x 

### and PM 2.5 

### for Jackson County, Alabama. Local VMT data for Jackson County was developed by the ALDOT for

2017 and 2025. The VMT data was used to make appropriate calculations in t he development of the MOVES2010b input files.

The same methodologies described in Sectio n 4.2.3 for runspec and input file development were used for 2017 and 2025. The process of data collection and emissions modeling was
conducted in accordance with the Technical Guidance on the Use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and Transportation Conformity. The same methodologies described in section 4.2.3 to calculate partial county emissions were also used for 2017 and 2025. The projected onroad mobile source emissions

### Jackson County Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-7 

### totals for the portion of Jackson County in the nonattainment area are listed in Table 4. 4-1 (Please see Appendix C -3).

4.3.4 Nonroad Mobile Sources



### Projections of nonroad emissions in 2017 and 2025, excluding commerc ial marine vessels and rail sources, were calculated using NMIM2008. Defaults in NMIM2008 were used for inputs.

Category 1 & 2 growth and control factors were applied to the “ diesel underway ” category ( SCC2280002200). Growth factors for CMV emissions w ere calculated based on fuel consumption forecasts published by the Energy Information Administration (EIA). Table 67 of EIA’s Annual Energy Outlook, 2010 provides national

- level forecasts by domestic and international shipping sectors for years out to 2035 (EIA, 2010 ). Control factors were developed based on emission reductions calculated from national base case and control case inventories developed for the years 2002 through 2040. Growth and control factors were
received from Tran S ystems/Pechan. The development of these growth and control factors is discussed in Appendix C-4.

For Class I and Class II/III line haul and diesel switchyard operations, growth factors were calculated based on freight rail sector fuel consumption forecasts, as published by the EIA. Similar to CMVs, diesel locomotive engines are subject to revised Fed eral Tier 0, Tier 1 and Tier 2 standards, as well as Tier 3 and 4 standards. Control factors were developed for
diesel

- powered locomotive engine emissions based on EPA’s locomotive engine regulatory impact analysis and associated emission factor guidance. Growth and control factors were
received from Tran S ystems/Pechan. The development of these growth and control factors is discussed in Appendix C-4.

The nonroad mobile source emissions projections for the portion of Jackson County in the
nonattainment area are presented in detail in Table 4.3.4 -1 and summarized in Table 4. 4-1. Total emissions of all three pollutants trend downward during the maintenance period. For more information regarding the nonroad inventory please see Appendices C -2, C-3 and C-4.

Nonroad sources encompass sources that are a function of population as well as sources that are more location specific. To develop more conservative nonroad estimates for the partial county, a population ratio was applied. The equation is below:

Cen sus Block Population/County Population * County

- wide Emissions = Partial County
Emissions

### Jackson County Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-8 Table 4.3.4-1 Projected Nonroad Mobile Source Emissions (tons per year)

Source Type Pollutant 2007 2017 2025

Nonroad* SO 2 0.55 0.02 0.02

NO

x 11.4 8.16 6.42

PM 2.5 1.19 0.6 0.37

CMV SO 2 0.08 0.08 0.08

NO

x 1.08 0.9 0.66

PM 2.5 0.03 0.02 0.02

Locomotive SO 2 0.28 0.05 0.05

NO

x 24.8 16.8 11.9

PM 2.5 0.83 0.39 0.24

Total Nonroad SO 2 0.91 0.15 0.15

NO

x 37.3 25.9 19

PM 2.5 2.05 1.01 0.63

*Excludes CMV and Locomotives.

### Jackson County Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-9 

### 4.4 Maintenance Plan Inventory

Table 4.4-1 Jackson County, AL portion of the Chattanooga Annual PM 2.5 Attainment Area Maintenance Plan Emissions (Tons per Year)

Source Category Pollutant 2007 (attainment) % of
total 2017 % of
total 2025 % of total

Point SO 2 32,803.98 99.996 10,515.63 99.996 10,517.47 99.996

NO X 18,591.83 99.668 3,468.44 98.962 3,607.05 99.270

PM 2.5 755.49 96.194 534.89 94.790 534.89 94.682

Area SO 2 0.25 0.001 0.25 0.002 0.24 0.002

NO X 1.58 0.008 1.55 0.044 1.57 0.043

PM 2.5 27.11 3.452 28.08 4.976 29.17 5.164

Non -road SO 2 0.91 0.003 0.15 0.001 0.15 0.001

NO X 37.32 0.200 25.86 0.737 18.95 0.522

PM 2.5 2.05 0.261 1.01 0.179 0.63 0.112

Mobile SO 2 0.19 0.001 0.07 0.001 0.07 0.001

NO X 23.00 0.123 9.00 0.257 6.00 0.165

PM 2.5 0.73 0.093 0.31 0.055 0.24 0.042

Total SO 2 32,805.33 100.00 10,516.10 100.000 10,517.93 100.000

NO X 18,653.73 100.00 3,504.83 100.000 3,633.57 100.000

PM 2.5 785.38 100.00 564.29 100.000 564.93 100.000

Maintenance Plan Decrease from 2007 SO 2 22,287.40

NO X 15,020.16

PM 2.5 220.45

### Jackson County Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4- 10 Table 4.4-2 Maintenance Inventory for the Chattanooga NAA (TPY)

Source Category 

### NOx SO2 PM2.5

2007 2017 2025 2007 2017 2025 2007 2017 2025

Point Chattanooga,

TN 2,437 2,651 3,155 919 798 866 160 169 206
Georgia 48 49 52 280 287 295 0 0 0

Alabama 18,592 3,468 3,607 32,804 10,516 10,517 755 535 535

Point Total 21,077 6,168 6,814 34,003 11,601 11,678 915 704 741
Nonpoint/Area Chattanooga,

TN 3,415 4,090 4,881 333 383 441 875 1,001 1,122
Georgia 359 414 456 77 82 87 1,548 1,807 1,998

Alabama 2 2 2 0.25 0.25 0.24 27 28 29 Nonpoint/Area
Total 3,776 4,506 5,339 410 465 528 2,450 2,836 3,149

Nonroad Chattanooga,

TN 1,792 1,003 675 99 14 16 154 101 64
Georgia 633 372 277 27 8 9 51 32 22

Alabama 37 26 19 1 0.15 0.15 2 1 0.63

Nonroad Total 2,462 1,401 971 127 22 25 207 134 87

Onroad Chattanooga,

TN * 8,308 5,554 2,799 59 43 28 255 117 98
Georgia 4,442 2,542 1,022 20 15 11 134 80 36

Alabama 23 9 6 0.19 0.07 0.07 0.73 0.31 0.24

Onroad Total 12,773 8,105 3,827 79 58 39 390 197 134

Total Chattanooga,

TN 15,952 13,298 11,510 1,410 1,238 1,351 1,444 1,388 1,490
Georgia 5,482 3,377 1,807 404 392 402 1,733 1,919 2,056

Alabama 18,654 3,505 3,634 32,805 10,516 10,518 785 564 565

Total 40,088 20,180 16,951 34,619 12,146 12,271 3,962 3,871 4,111

*Emissions for the Chattanooga, TN area are draft. Further, the maintenance demonstration for the Chattanooga, TN
counties used 2016 as a mid

- year rather than 2017. Therefore, the emissions estimates for TN in the 2017 column are actually 2016 va lues.

### Jackson County Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4- 11 

### 4.5 Plan to Maintain Air Quality

ADEM has implemented programs that will remain enforceable and are hereby submitted as the plan to ensure that maintenance of the annual PM 2.5 

### standard will continue. Sources are prohibited from reducing emission controls ('anti

- backsliding') following the redesignation of the area unless such a change is first approved by the EPA as a revision to the Alabama SIP that is consistent with Section 110(l) of the C AA

. The following regulatory programs will remain in pla ce in the Chattanooga NAA:

• Federal Tier II Motor Vehicle Emissions Standards

• Federal On -road Diesel Engine Standards

• Federal Non -road Diesel Engine Standards

• Federal Marine Engine Requirements

• Federal Locomotive Requirements

• The Federal New Source Performa nce Standards under Section 111 (42 U.S.C. 7411)

• The Federal National Emissions Standards for Hazardous Air Pollutants (NESHAP) under Section 112 (42 U.S.C 7412)

• The Federal NO X 

### SIP Call

• The Clean Air Interstate Rule 2



### • Georgia Rules for Air Quality Control Chapter 391 -3- 1 Rule (sss) “Multipollutant Control of Electric Steam Generating Units”

• The federal facilities compliance agreement between EPA and the Tennessee Valley Authority, Docket No. CAA -04-2010-1760 requiring TVA Widows Creek to retire
Units 1 -6. The compliance dates for this action are staggered as follows:

o 2 units by July 31, 2013;

o 2 units by July 31, 2014;

o 2 units by July 31, 2015.

The overall expected reductions are 15,111 tons per year of NO X 

### and 28,192 tons per year of SO 2



### . The consent decr ee further required year

- round operation of the SCRs
on Units 7 and 8 (See Appendix D)

.

• Rock

- Tenn Mill Company, LLC

– Stevenson Mill is switching from Grade 6 Residual Oil to Natural Gas in the power boilers (units Z001 and X008). The new permit limits are reflected in their Title V.

2 The Cro ss-S tate Air Pollution Rule was vacated by the United States Court of Appeals for the District of Columbia Circuit on August 21, 2012. The Clean Air Interstate Rule was reinstated until a permanent transport rule is put into place; however, EPA’s modeling for the Transport Rule demonstrates the Chattanooga Area would be able to obtain the 1997 Annual PM2.5 standard even in the absence of the Transport Rule.

### Jackson County Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4- 12 4.5.1 Verification of Continued Attainment



### Verification of continued attainment is monitored through the State of Georgia, the Chattanooga- Hamilton County Air Pollution Control Bureau, and the Tennessee Division of
Air Pollution C ontrol ’s operation of the ambient fine particulate matter monitor network and the maintenance of updating the area's emissions inventory.

The current four ambient PM 2.5 

### monitors that are operating in the annual PM 2.5 

### nonattainment area will continue to operate unless a change(s) is approved by EPA. No plans are underway to discontinue operation, relocate, or otherwise affect the integrity of the ambient monitoring network in place. Any change would only be made if it is consistent
with 40 CFR Part 58.

The Air Emissions Reporting Requirements (AERR) was promulgated by EPA on
December 5, 2008. For the purposes of verifying continued attainment based upon the emissions inventory, the three main components of the inventory, point, area and mobile, will be updated on different schedules. The major point sources of air pollution will continue to submit data on their emissions on an annual basis. This has been required under

40 CFR 51, Subpart Q for many years. For the area source and mobile source portions of the inventory, these emissions will continue to be quantified on a three- year cycle.

4.5.2 Contingency Plan



### Section 175A(d) of the C AA Amendments requires the inclusion of contingency provisions that would be implemented by the State to correct any future violation of the NAAQS in areas that had been redesignated as an attainment area. Alabama commits to adopt, within
18 months of certification of a violation of the annual PM 2.5 

### standard, one or more control measure(s) (contingency measures) as needed to re

- attain the standard. The State of Alabama will use actual ambient monitoring data as the indicator or trigger to determine when these contingency measures, if deemed necessary, would be implemented. In accordance with

40 CFR 58, ambient fine particulate matter monitoring data that indicates a future violation
of the annual PM 2.5 

### NAAQS will begin the process to implement these contingency measures. Also, in the event that the annual average PM 2.5 

### concentrations in a y ear at any individual monitor in the nonattainment area records a reading of 15 μg/m 3 

### or higher, the State will evaluate existing control measures to determine whether any further emission reduction measures should be implemented at that time. If periodic emission inventory updates reveal excessive or unanticipated emissions growth greater than 3 0%, the State will evaluate existing control measures to determine whether any further emission reduction measures should be implemented at that time.

Several factors will be considered in determining the need for additional control measures in the event of a future year violation of the annual PM 2.5 

### standard. Depending on when such future year violation occurs, additional local and regional emissions reductions may still be on the way from various regulatory programs. If a future year violation occurs, ADEM will consider the air quality impact of these various regulatory programs in determining the need
for additional local reductions in emissions of d irect PM 2.5 

### and/or SO 2



### . If deemed necessary, c ontingency measure(s) will be selected from the following types of measures or from any other measure s deemed appropriate and effective at the time the
selection is made:

### Jackson County Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4- 13 

### • Reasonably Available Control Measures (RACM) for sources of SO 2 

### and PM 2.5 

### ;

• Reasonably Available Control Technology (RACT) for point sources of SO 2 

### and

PM 2.5 

### ;

• Expansion of RACM/RACT to area(s) of transport within the State; and

• Additional SO 2 

### and/or PM 2.5 

### reduction measures yet to 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.

A time line for the development of NO X 

### , PM 2.5 

### and/or SO 2 

### regulations or permit conditions follows. This schedule initiates with certification of ambient air quality monitoring data indicating a violation of the annual PM 2.5 

### NAAQS:

Table 4.5.2-1 Schedule for Permit Revisions or Rule Revisions for Contingency Measures

1. Identify and quantify the emissions reductions expected to result in the future from existing and future state and federal regulatory

programs. 3 months

2. Use the best available air quality modeling to evaluate the air quality improvement expected to result in Jackson County from the programs and emissions reductions identified in step 1 above. 6 months

3. Draft any needed permit conditions or SIP regulations. 3 months

4. Complete rulemaking or permit revision process and submit to

EPA. 6 months

Completion no later than: 18 months

### Jackson County Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

5-1 

## 5.0 Conclusion

The most recent three years of quality

- assured PM 2.5 

### monitoring data for the Chattanooga NAA demonstrate compliance with the NAAQS for annual PM 2.5 

### . This redesignation request and maintenance demonstration has been prepared to meet the requirements of the
1990 C AA Amendments.