### April 2011



## REDESIGNATION REQUEST
AND
MAINTENANCE DEMONSTRATION

Birmingham
Annual PM 2.5 

## Nonattainment Area

Prepared by:

Alabama Department of En vironmental Management
Air Division

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

1-2 

### (This page has intentionally been left blank)

### TABLE OF CONTENTS 

### Executive Summary ............................................................................................................. v
1.0 Introduction ............................................................................................................ 1-1

1.1 Purpose

............................................................................................................................. 1-1

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

1.3 Formation of PM 2.5 

### ......................................................................................................... 1-1

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


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

2.1 Demonstration that the NAAQS Has Been Attained ............................................ 2-1 2.1.1 Overview

.............................................................................................................................. ..... 2-1 2.1.2 PM 2.5 Monitoring Network .................................................................................................... 2-1 2.1.3 Ambient PM 2.5 Monitoring Data .......................................................................................... 2-2


### 2.2 Permanent and Enforceable Reductions in Emissions .......................................... 2-3 2.2.1 Meteorological Analysis ......................................................................................................... 2-6


### 3.0 Fully Approved SIP, Section 110 and Part D Requirements ....................... 3-2

3.1 Section 110 Implementation Plans ............................................................................ 3-2

3.2 Part D Plan Requirements for Nonattainment Areas ........................................... 3-2 3.2.1 Nonattainment Areas in General ........................................................................................ 3-2


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

4.1 Overview .......................................................................................................................... 4-1

4.2 Attainment Inventory ................................................................................................... 4-1 4.2.1 Overview

.............................................................................................................................. ..... 4-1 4.2.2 Point Sources ........................................................................................................................... 4- 1 4.2.3 Area Sources ............................................................................................................................ 4 -2 4.2.4 On-road Mobile Sources ......................................................................................................... 4-3 4.2.4.1 Mobile Source Attainment Budget ..................................................................................... 4-3 4.2.4.2 Projected Mobile Source Emissions Methodology ............................................................. 4-3 4.2.4.3 Mobile Source Maintenance Budget .................................................................................. 4-4 4.2.5 Non-road Mobile Sources ...................................................................................................... 4-5


### 4.3 Maintenance Demonstration ....................................................................................... 4-6 4.3.1 Plan to Maintain Air Quality ............................................................................................. 4-10 4.3.2 Verification of Continued Attainment .............................................................................. 4-13 4.3.3 Contingency Plan .................................................................................................................. 4-13


### 5.0 Conclusion ............................................................................................................... 5-1

iii

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

iv TABLES Table 2.1.2-1 Summary of the Annual PM 2.5

Concentrations and the 3-Year Averages ............... 2-2 Table 2.2-1 Summary of RACT Controls ......................................................................................... 2-5 Table 2.2-2 Summary of Utility Controls ........................................................................................ 2-6 Table 4.3-1 Birmingham Annual PM 2.5

Attainment Area Maintenance Plan PM 2.5

Emissions (Tons per Year)

............................................................................................................................... 4-7 Table 4.3-2 Birmingham Annual PM 2.5

Attainment Area Maintenance Plan NO X

Emissions (Tons per Year)

............................................................................................................................... 4-8 Table 4.3-3 Birmingham Annual PM 2.5

Attainment Area Maintenance Plan SO 2 Emissions (Tons per Year)

.............................................................................................................................. ........... 4-9 Table 4.3.1-1 RACT Controls In stalled Prior to or During 2010 ................................................ 4-13 Table 4.3.3-1 Projected Reductions ................................................................................................ 4-15 Table 4.3.3-2 SO 2 Emissions Reductions ....................................................................................... 4-16 Table 4.3.3-3 NO X

Emissions Reductions ...................................................................................... 4-17 Table 4.3.3-4 Schedule for Permit Revisions or Rule Revisions for Contingency Measures ....... 4-18



### FIGURES Figure 2.2-1 Locations of Local Sources Being Controlled for PM 2.5

in Relation to the North Birmingham PM 2.5

Monitor .......................................................................................................... 2-4 Figure 2.2-2 Locations of Local Sources Being Controlled for PM 2.5

in Relation to the Wylam PM 2.5 Monitor

.............................................................................................................................. ... 2-4 Figure 2.2.1-1 Number of Days > 25μg/m3 by Quarter for 2008 – 2010 ....................................... 2-7 Figure 2.2.1-2 PM 2.5

24hr > 25μg/m 3 vs. # of Days >= 90oF 2003-2010 ....................................... 2-8 Figure 2.2.1-3 PM 2.5

24hr > 25μg/m 3 vs. # of Days with Rain >=0.05” 2003-2010 ...................... 2-9 Figure 2.2.1-4 PM 2.5

24hr>15μg/m3 vs. # of Days with Rain >=0.05” 2000-2009 ...................... 2-10 Figure 2.2.1-5 Number of Days > 25μg/m 3 vs. April-Sept Rainfall Totals ................................. 2-11 Figure 4.3.1-1 Locations of Po wer Plants in Relation to the Birmingham Annual PM 2.5 Nonattainment Area .................................................................................................................... 4-12


### APPENDICES

PM 2.5

Monitor Locations ............................................................................................................ ........... A AIRS AQS Report ............................................................................................................... .................. B Birmingham Particul ate Matter Study ........................................................................................... .... C
Mobile Source P recursor Discu ssion ............................................................................................ ........ D

Emissions Documentatio n and Projections ....................................................................................... .. E MOVES Modeling to Demons trate Maintenance ................................................................................ F
Point Source Closu re Documentation ............................................................................................ ...... G

### v 

## Executive Summary

This document contains Alabama's demons tration under the federal Clean Air Act Amendments of 1990 that the Birmingham annual PM 2.5 

### Nonattainment Area (NAA) should be redesignated from nonattainment to attainment with respect to the National Ambient Air Quality Standard (NAAQS) fo r annual fine particle pollution. The Birmingham NAA consists of two full counties, Jefferson and Shelby Counties, and one partial county, Walker County. This request is based on three years of ambient monitoring data, 2008 to 2010, at all ten PM 2.5 

### monitors in the Birmingham 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 Clean Air Act, and the Birmingham Mainte nance Plan with projections demonstrating that the 2009 emission levels in this area w ill not be exceeded through at least the year 2024.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

1-1 

## 1.0 Introduction

1.1 Purpose

This document contains the technical su pport necessary for the Alabama Department of Environmental Management's (ADEM) request that the Birmingham 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 Clean Air Act, as amended.



### 1.2 Historic Background On January 5, 2005, the EPA designated Jefferson and Shelby Counties and a portion of Walker County as nonattainment for the annual PM 2.5 

### standard. The official designations and classifications were prin ted in the Federal Register on January 5, 2005, (70 FR 944). This designation became effective on April 5, 2005.



### 1.3 Formation of PM 2.5


### PM 2.5 

### , also known as particle pollution or fi ne particulate, is a complex mixture of extremely small particles and liquid droplets . Particle pollution is made up of a number of components, including nitrates and sulfates, organic chemicals, metals, and soil or dust particles. Fine particles, such as those found in smoke and haze, are 2.5 micrometers in diameter and smaller. Thes e particles can be directly emitted from sources such as forest fires, or they can form when gases emitted from power plants, industries and automobiles react in the air. The chemical makeup of PM 2.5 

### in Birmingham is similar to that of similar sites across the Southeast. PM 2.5 

### measurements are separated into several components: ammonium sulfate ((NH 4 

### ) 2 

### SO 4 

### ), ammonium nitrate (NH 4 

### NO 3 

### ), organic carbon mass (OC), elemental carbon (EC) and crustal materials, as well as a factor to correct for particles on the filter, characterized as passive mass. NH 4 

### NO 3 

### and (NH 4 

### ) 2 

### SO 4 

### are secondary pollutants formed in the atmosp here from primary emissions of sulfur dioxide (SO 2 

### ), nitrogen oxides (NO X 

### ) and ammonia (NH 3 

### ). OC is a mixture of primary carbon, predominantly from fuel combus tion and biomass burning, and secondary carbon, predominantly from biogenic emissi ons. EC and crustal components (fine soil & metals) are primary pollutants emitted directly into the atmosphere. OC and (NH 4 

### ) 2 

### SO 4 

### are the dominant contributors to PM 2.5 

### mass in the Birmingham area. SO 2 

### emissions, primarily from utility and industrial point sources, are the primary contributors to SO 4 

### . SO 4 

### mass is highest in the summer months, in part due to higher SO 2 

### emissions in the summer months and in part due to more active secondary photochemical formation under the higher temperatures, relative humidity, and oxidant loading of the summer months.



### 1.4 Criteria for Redesignation Section 107(d) of the federal Clean Air Act, 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.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

1-2 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 emissions.

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 re late directly 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 rela te to the implemen tation 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. First, the state must submit a revision to the state implementation plan (SIP), which provides for maintenance of the NAAQS in the area for at least ten years af ter the redesignation. EPA has up to 18 months after submittal of the redesignatio n request to approve or disapprove it. Therefore, EPA is required to make its deci sion by 2012 since this document is being submitted in mid-2011. Thus, the State must demonstrate that Birmingham will maintain the standard through at least 2022 [2012 + 10 = 2022]. Our plan goes out to 2024. 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.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

2-1 

## 2.0 Attainment Demonstration

This section will focus on the first and third criteria discussed earlier in Section 1.3. Criterion 1. The EPA has determined that the NAAQS has been attained. Criterion 3. The improvement in air qua lity is due to permanent and enforceable reductions.



### 2.1 Demonstration that the NAAQS Has Been Attained

2.1.1 Overview 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
μ g/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 μ g/m 3 

### at any monitor. The most recent three years of annual PM 2.5 

### monitoring data (2008-2010) for the Birmingham NAA demonstrate comp liance with the NAAQS for annual PM 2.5, 

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

2.1.2 PM 2.5 

### Monitoring Network There are presently ten PM 2.5 

### monitoring stations in the Birmingham NAA installed in accordance with 40 CFR 58, which provide adequate coverage of the entire nonattainment area and have been representative of the area of highest concentrations (see Appendix A, Map of the PM 2.5 

### Monitoring Sites). All monitors remained at their original locations during the period 2008-2010. Table 2.1.2-1 is a summary of the annual PM 2.5 

### concentrations for each year for each monitor and the 3-year average.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

2-2 Table 2.1.2-1 Summary of the Annual PM 2.5 Concentrations and the 3-Year Averages



### Monitor County 2008 2009 2010 3-Year Average

Corner Jefferson 11.5 9.7 10.7 10.6

Hoover Jefferson 12.1 10.3 11.8 11.4

Leeds Jefferson 13.2 10.3 12.1 11.9
McAdory Jefferson 12.2 10.4 11.8 11.5

Pinson Jefferson 11.9 9.9 10.9 10.9

Providence Jefferson 10.8 9.6 10.1 10.2
N. Birmingham Jefferson 15.5 11.7 13.8 13.7
Wylam Jefferson 14.4 11.3 12.4 12.7
Walker County Walker 11.7 10.1 11.3 11.0

Pelham Shelby 11.6 9.8 11.3 10.9

2.1.3 Ambient PM 2.5 

### Monitoring Data
All of the PM 2.5 

### ambient monitoring data that was collected during 2008, 2009, and 2010 was collected in accordance with 40 CFR 58 and has been stored in EPA's Aerometric Information Retrieval System (AIRS) Air Quality System (AQS). This process was completed in February 2011. A copy of an AIRS printout showing the maximum PM 2.5 

### concentrations at these monitors for these years is included in Appendix B.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

2-3 

### 2.2 Permanent and Enforceable Reductions in Emissions Since 2000, there have been several major federal and local programs enacted that have led to significant actual, enforceable PM 2.5 

### and PM 2.5 

### precursor emission reductions. The improvement in air quality that has resulted in attainment of the annual PM 2.5 

### NAAQS can be reasonably attributed to these emissions reductions. These programs were established to provide reducti ons in emissions from the mobile source and industrial sectors. These programs are listed below:

1. Federal Tier II Motor Vehicle Emissions Standards

2. Federal On-road Diesel Engine Standards

3. Federal Non-road Diesel Engine Standards

4. Federal Marine Engine Requirements

5. Federal Locomotive Requirements

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

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

8. The Federal NO X 

### SIP Call

9. The Federal Clean Air Interstate Rule (CAIR) 1



### 10. Local NO X 

### controls on some NAA cement plants required by the 8-Hour Ozone Contingency Plan

11. Local PM controls at Birmingham fac ilities associated with the Birmingham Annual PM 2.5 

### SIP have provided reductions of ~62 tpy as of the end of 2009 (See Table 2.2-1 below) An extensive analysis of monitoring data in the Birmingham area was conducted as part of the local area analysis (the Envair Study, see Appendix C), which investigated source contributions to elevated PM 2.5 

### concentrations at the North Birmingham (NBHM) and Wylam (WYL) monitors. A comparison of the PM 2.5 

### mass across the Birmingham NAA provides a basis to estima te a regional background contribution, a general urban contribution and an increment al contribution from local sources in the immediate vicinity of the NBHM and WYL sites. These monitors collectively suggest a regional contribution of 12-14 μg/m 3 

### , an urban contribution of roughly 2 μg/m 3 

### , and a local contribution for NBHM of 2-3 μg/m 3 

### and for WYL of ~2 μg/m 3 

### . Therefore, decreases in emissions of direct PM 2.5 

### constituents, such as those detailed in the table below, have and will directly impact PM 2.5 

### concentrations.

1 On December 23, 2008, the United States Court of Appeals for the District of Columbia Circuit remanded CAIR to EPA, without vacatur, directing the Agency to remedy the rule’s flaws in accordance with the Court’s July 11, 2008, opinion in th e case of North Carolina v. EPA, 531 F. 3d 896, 901 (D.C. Cir. 2008). When EPA responds to the Court’s re mand, the request may need to be re vised to be consistent with the Agency’s new final action.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

Figure 2.2-1 Locations of Local Sources Being Controlled for PM 2.5 in Relation to the North Birmingham PM 2.5 Monitor

Figure 2.2-2 Locations of Local Sources Being Controlled for PM 2.5 in Relation to the Wylam PM 2.5 Monitor



### 2-4

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

2-5 Table 2.2-1 Summary of RACT Controls

Facility Source RACT Controls PM 2.5 RACT Reduct (TPY) RACT Date

W.J. Bullock 2 Crucible furnaces Install baghouse 3.891 4Q2009 Facility totals 3.891 McWane Pipe Charge handling area Wet suppression 0.385 2008 Facility totals 0.385 Sloss MW 3 and Sloss Coke Coal piles Wet suppression 0.398 4Q2008

Facility totals 0.398

ACIPCO Charge make-up Wet suppression 11.91 4Q2008 Roads & process areas Paving 3.58 2007/2008

Cupola melting furnace New cupola/BH & spray suppression 5.84 2007/2008 Sand & cement storage silos Baghouse 0.09 2008 Facility totals 21.42

Nucor Steel Meltshop fugitives Route to BH, other physical improvements 28.1 4Q2008 Facility totals 28.1

U.S. Pipe 4 Cupola charge makeup Wet suppression 1.818 4Q2008 Sand/cement silos Install bin vents 5.93 4Q2008 Facility totals 7.748 TOTAL 61.942



### 12. Local NO X 

### and SO 2 

### controls at utilities around the Birmingham area have provided reductions of ~3,526 tpy of NO X 

### and ~84,786 tpy of SO 2 

### as of the end of 2010 (See Table 2.2-2).

2 W.J. Bullock ceased all operations as of October 2009, resulting in a 0.1263 ton reduction.

3 Sloss Mineral Wool announced its closure in December 2009, resulting in a 130 ton reduction.

4 U.S. Pipe ceased production on March 31, 2010, resulting in a 46 ton reduction.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

2-6 Table 2.2-2 Summary of Utility Controls

Facility Date Control Installed Projected Reductions (TPY)
NOX SO2 NOX SO2 APCo Miller Unit 3 2008 1,726 APCo Miller Unit 4 2008 1,800 APCo Gorgas Unit 8 Dec-2007 5,387 APCo Gorgas Unit 9 Dec-2007 4,493 APCo Gorgas Unit 10 Dec-2007 23,889 APCo Gaston Unit 5 Jan. 2010 51,017 Total Reductions 3,526 84,786

• 

### Installation of FGD on Units 8 – 10 at Alabama Power’s Gorgas Plant in 2007. The FGD was added in anticipation of CAIR.

• 

### Installation of SCR on Units 3 & 4 at Alabama Power’s Miller Plant in 2003 with a Consent Decree requiring year ro und operation beginning in 2008. SCRs were added as a result of the NO X 

### SIP Call. Year-round operation of all SCRs was planned in anticipation of the annual NO X 

### CAIR rule. The consent decree further required year-round operation of the SCRs on Units 3 and 4. The consent decree requirements have been inco rporated into the facility’s Title V permit and are enforceable.

• 

### Installation of FGD on Unit 5 of Alabama Power’s Gaston Plant in January 2010.

2.2.1 Meteorological Analysis

The purpose of this section is to complement Section 2.2, which states that the improvement in air quality that has resulted in attainment of the annual PM 2.5 

### NAAQS can be reasonably attributed to permanent and enforceable emissions reductions. The analyses presented in this section will show that there is both an emissions reduction and meteorological signal in the air quality and meteorological data. In evaluating the relationship between elevated PM 2.5 

### concentrations and meteorology, a focus on the meteorological variables associated with the bulk of the elevated concentrations was needed. The warm weathe r months of the year (April - September) were where this meteorological analysis prim arily focused. Figure 2.2.1-1 below helps inform this decision. As can be seen, the greatest number of high PM 2.5 

### days over the three year period across Alabama and the Sout heast in general are found in the second and third quarters (spring-summer). Therefore, this analysis is intended to evaluate the relationship between weather and elevated PM 2.5 

### during this time period. It is also worth noting that a count of days with PM 2.5 

### concentrations greater than 15 ug/m 3 

### also shows that the second and third quarters typically have the highest PM 2.5 

### concentrations.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

Figure 2.2.1-1 Number of Days > 25μg/m3 by Quarter for 2008 – 2010



### The analysis below shows the relationship between high PM 2.5 

### concentrations and weather conditions. The two meteorological variables that show the best relationship are temperature and precipitation. This analysis also shows that, after analyzing the different variables, lower emissions are like ly contributing at least in part to lower PM 2.5 

### concentrations. As stated above, PM 2.5 

### concentrations are usually higher on days with high temperatures, especially during the summer mo nths. In Figure 2.2.1-2, this pattern can be seen in the years 2003-2005 when looking at the total number of days with a high temperature equal to or above 90oF and the total number of days in which the PM 2.5 

### concentration was greater than 25μg/m 3 

### . Both the number of days with high temperatures greater than or equal to 90oF and the number of days with PM 2.5 

### concentrations greater than 25ug/m3 showed an increase during this period. However, from 2005-2006, the number of days with a high temperature equal to or above 90oF increased sharply, while the number of days with a PM 2.5 

### concentration greater than 25μg/m 3 

### decreased. This indicates that lower emissions may have led to lower PM 2.5 

### concentrations. A sharper decline in PM 2.5 

### concentrations can be seen between 2008- 2009, along with a decrease in the number of da ys with a high at or above 90oF. Both weather conditions and emission reductions like ly led to this sharper decline. Then in 2010, the number of days with a high temperature above 90oF increased dramatically to the highest level in 8 years while the number of days PM 2.5 

### exceeding 25μg/m 3 

### only increased slightly from 2009. This further demonstrates that emission reductions have

2-7

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment
likely played a key role in reducing annual PM 2.5 

### concentrations to levels below the NAAQS.

Figure 2.2.1-2 PM 2.5 24hr > 25μg/m 3 vs. # of Days >= 90oF 2003-2010



### The same general pattern can be seen when looking at precipitation amounts. Figure 2.2.1-3 shows the number of days with rainfall amounts greater than or equal to 0.05 inches compared to the number of days in which the PM 2.5 

### concentration was greater than 25μg/m 3 

### from 2003-2010. In general, PM 2.5 

### concentrations are higher when rainfall amounts are lower. However, looking at Figure 2.2.1-3, 2006-2008, both the number of days with rainfall amounts greater than or equal to 0.05 inches and PM 2.5 

### concentrations showed a general decrease. This indicates that lower emissions may have led to lower PM 2.5 

### concentrations.

2-8

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

Figure 2.2.1-3 PM 2.5 24hr > 25μg/m 3 vs. # of Days with Rain >=0.05” 2003-2010



### A sharper decline in PM 2.5 

### concentration can be seen from 2008-2009 when the number of days with precipitation greater than or equal to 0.05 inches increased. Both weather conditions and emission reductions likely led to this sharper decline. Then in 2010, the number of days with rainfall decreased considerably while the number of days with PM 2.5 

### greater than 25μg/m 3 

### only increased slightly. This further demonstrates that emission reductions have played a key role in meeting the annual PM 2.5 

### NAAQS. To better separate the weather’s influence from the influence of emissions reductions on PM 2.5 

### , trend lines were added to Figure 2.2.1- 4 below. As shown, the trend line for rainfall has little slope, while the PM 2.5 

### trend line slopes steadily downward. This demonstrates that while rainfall clearly has an impact on PM 2.5 

### , the decline in concentrations can be attributed to both a decrease in emissions and weather.

2-9

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

Figure 2.2.1-4 PM 2.5 24hr>15μg/m3 vs. # of Days with Rain >=0.05” 2000-2009



### To further illustrate an emission reduction si gnal, Figure 2.2.1-5 shows that during the typically higher PM 2.5 

### months of April-September, from 2005-2007 the number of high PM 2.5 

### days continued to decrease even thou gh the April-September precipitation amounts decreased. A sharper decrease in high PM 2.5 

### days can be seen from 2008- 2009, when precipitation amounts increased. By 2010, rainfall decreased dramatically to the level similar to what it was in 2006; however, the number of high PM 2.5 

### days only increased slightly and was well below the le vel it was in 2006. This indicates that emission reductions have likely contributed sign ificantly to the sharper decline in high PM 2.5 

### days over the past 3 years and in return have lowered annual PM 2.5 

### concentrations to a level below the NAAQS.

2-10

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

Figure 2.2.1-5 Number of Days > 25μg/m 3 vs. April-Sept Rainfall Totals



### With respect to the meteorology associat ed with the 2008 – 2010 time period, the following should be noted:

• The graphs above include trend lines wh ich provide valuable information about emissions reductions that have occurred over the last few years.

 First, 2007 was an extremely hot and dry year. Most of the state experienced severe drought conditions, yet the moni tored concentrations decreased from the previous years. This would be contra ry to what would be expected and is a strong indication that emissions reducti ons likely played a role in the lower monitor values.

 Similarly, beginning in mid- 2008 to 2009, milder and wetter conditions occurred than were previously experience d, and while monitor values decreased, the trend line relative to the monitor values show an even larger signal than would be expected (i.e. especially rela tive to the wetter years of 2003-2004). Again, this a strong indication of an emissions signal.

 In 2010, warmer and drier conditions returned to the area and despite the more favorable conditions for PM 2.5 

### , concentrations remained low and only increased slightly from what they were during the wet and mild 2009 season. This further indicates that emission reductions have played a key role in reducing annual PM 2.5 

### levels in the Birmingham area.

2-11

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment
Meteorology will always play a role in attainment demonstrations and redesignation requests. The responsibility of the state or local agency is to reasonably demonstrate that regardless of that role, an area is achieving improved air quality through permanent and enforceable emissions reductions. The State of Alabama believes that this request documents these reductions.

2-12

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

3-2 

## 3.0 Fully Approved SIP, Section 110 and Part D Requirements
Criterion 2: The applicable implementation plan has been fully approved by the EPA under Section 110(k). Criterion 4: The State has met all applic able requirements under Section 110 and Part D.



### 3.1 Section 110 Implementation Plans

Alabama’s CAIR 5 

### SIP was fully approved by EPA on October 1, 2007 (72 FR 55659), and became effective on October 31, 2007. The annual PM 2.5 

### attainment demonstration was submitted by ADEM to EPA in May 2009. Thus, Criterion 2 has been met. The general elements required in a SIP are listed in §110(a). These elements include procedures for air quality monitoring and mo deling; criteria for establishing stationary source controls, monitoring and reporting; implementation of permitting programs under Part C (Prevention of Significant Dete rioration 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. On July 25, 2008, ADEM submitted a letter to EPA certifying that Alabama’s existing SIP meet s all Section 110(a)(2) provisions of the Clean Air Act that address the requireme nts for the 1997 annual particulate matter NAAQS. This, in addition to the discussion in Section 3.2, meets Criterion 4.



### 3.2 Part D Plan Requirements for Nonattainment Areas

3.2 .1 Nonattainment Areas in General Section 172(c) – In May of 2009, ADEM submitted to EPA the “Attainment Demonstration for the Birmingham, Alabama, Annual PM 2.5 

### Nonattainment Area”. This plan demonstrates attainment of the annual PM 2.5 

### NAAQS beginning in 2012 based on implementation of a combination of federal measures including CAIR, other regional controls, mobile source controls and local controls on industrial sources of direct PM 2.5 

### . Thus, ADEM has met the requirement of Section 172(c). Section 176(c) - The concept of transportation conf ormity was introduced in the Clean Air Act 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 for effective integration of trans portation and air quality planning. 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 Range Transportation Pl an (LRTP) will not adversely impact air

5 On December 23, 2008, the United States Court of Appeals for the District of Columbia Circuit remanded CAIR to EPA, without vacatur, directing the Agency to remedy the rule’s flaws in accordance with the Court’s July 11, 2008, opinion in th e case of North Carolina v. EPA, 531 F. 3d 896, 901 (D.C. Cir. 2008). When EPA responds to the Court’s re mand, the request may need to be re vised to be consistent with the Agency’s new final action.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

3-3 quality in a determined area of nonattainment. Federal funding and approval are given to transportation activities that are consistent with air quality goals. The State has developed a SIP for the purpos es of addressing conformity. This SIP delineates the interagency consultative process between the Metropolitan Planning Organization (MPO), the Environmental Protection Agency (EPA), the Federal Highway Administration (FHWA), the Federal Transit Authority (FTA), State and local transportation and air quality agencies, as well as, the public participation process for stakeholders and citizens in the Birmingham NAA. The Alabama Conformity SIP under the PM 2.5 

### NAAQS was approved on March 26, 2009 (74 FR 13170), with an effective date of May 26, 2009.
This SIP revision will establish a MVEB for NO X 

### and primary PM 2.5 

### for the year 2024.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-1 

## 4.0 M aintenance Plan

4.1 Overview Criterion 5. The EPA has fully approved a maintenance plan, including a contingency plan, for the area under §175A. Section 175A of the Clean Air Act Amendments of 1990 defines the general framework of a maintenance plan. The core provisions include the attainment inventory, the maintenance demonstration, the verificati on of continued attainment, and the contingency plan.



### 4.2 Attainment Inventory

4.2 .1 Overview
Monitored attainment of the annual PM 2.5 

### standard was achieved for the 2008-2010 three-year period. The most recent comp rehensive periodic (triennial) emissions inventory for the Birmingham NAA was compiled for 2005 pursuant to §182(a)(3)(A). According to federal requirements, the next triennial inventory for 2008 was submitted in June 2010, however, version 1 of t hat inventory is not yet available. According to the September 4, 1992, EPA gu idance document entitled, "Procedures for Processing Requests to Redesignate Area s to Attainment", the base attainment inventory should be consistent with EP A's most recent guidance on emission inventories and should represent the emissions during the time period associated with the monitoring data showing attainment. For purposes of demonstrating maintenance of the standard, 2010 is the attainment year, representing the monitoring period of 2008 - 2010 The inventory years were generally chosen as 2009, with interim years set as 2012, 2015, 2018, 2021 and 2024, which is the end of the first 10-year maintenance period. VISTAS/ASIP developed emissions inventories for regional haze, 8-hr ozone and annual PM 2.5 

### attainment demonstrations for the years 2010, 2012 and 2018. These inventories were used to develop point, area and off-model non-road inventories for 2015, 2021 and 2024. Version 3 of the 2002 NEI and the development of the 2008 NEI were applied to determine reasonableness in the area source inventory. Non-road mobile and on-road mobile source emissions were calculated for 2009-2024 based on EPA-approved models. Necessary calculations for the projections were made using Microsoft Excel © 

### software. The following section describes how growth factors for each emi ssion category were obtained and used. The documentation for emissions inventory development and growth is included in Appendix D.

4.2.2 Point Sources Major point sources are defined as stationar y sources that emit greater than 100 tons per year (TPY) of a criteria pollutant. The source emissions are calculated from data

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-2 collected annually from the sources. VISTAS/ASIP 6 

### used actual annual 2002 emissions data for point sources to calculate point source emissions for 2009, 2012 and 2018. All point source emissions information, with the exception of Jefferson County, is stored in ADEM's Microsoft Access© database. The po int source data for Jefferson County is obtained from the Jefferson County Departme nt of Health’s Air Program. Actual 2008 point source data was used to establish any shutdowns or new sources that were not accounted for in the VISTAS/ASIP inventor ies. Actual 2009 data was used where available. The emissions were grown for 2012 (where actual 2009 emissions were available), 2015, 2018 (where actual 2009 emissions were available), 2021 and 2024 using EGAS 5.0 and compared against un it/facility allowable limits to prevent overgrowth. Utilities with installed controls were kept steady rather than applying growth factors. The downward trend in point source PM 2.5 

### emissions is due to both the implementation of RACT controls on local Birmingham source s and the closing of three facilities: Sloss Industries Corporation – Mineral Wool, W.J. Bullock Incorporated, and U.S. Pipe and Foundry Company, LLC – North Birmingham 7 

### . Point source SO 2 

### emissions are projected to drop significantly from 2009 to 20 12 due to installed controls on utilities as a result of CAIR 8 

### . These controls are listed in Table 4.3.3-1. For conservatism due to the uncertain status of CAIR 9 

### , no additional reductions in SO 2 

### or NO x 

### emissions from utilities were assumed to occur beyond 2012. Appendix D provides information on how emi ssions were projected for point sources. Each county total is listed in summary Tables 4.3-1 through 4.3-3 under point sources.

4.2.3 Area Sources
Area 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. Cutoff levels are those levels below the point source level di scussed above. For area source emission projections, emission growth factors were derived from EGAS, BEA factors and EPA

6 The BAPS inventory was used in conjunction with the VISTAS/ASIP inventory for the Jefferson County point source base and future year inventories.

7 The closings resulted in a reduction of ~177 tons of PM 2.5 . For further information concerning these facility closures, please see Appendix F.

8 On December 23, 2008, the United States Court of A ppeals for the District of Columbia Circuit remanded CAIR to EPA, without vacatur, directing the Agency to remedy the rule’s flaws in accordance with the Court’s July 11, 2008, opinion in th e case of North Carolina v. EPA, 531 F. 3d 896, 901 (D.C. Cir. 2008). When EPA responds to the Court’s re mand, the request may need to be re vised to be consistent with the Agency’s new final action.

9 On December 23, 2008, the United States Court of A ppeals for the District of Columbia Circuit remanded CAIR to EPA, without vacatur, directing the Agency to remedy the rule’s flaws in accordance with the Court’s July 11, 2008, opinion in th e case of North Carolina v. EPA, 531 F. 3d 896, 901 (D.C. Cir. 2008). When EPA responds to the Court’s re mand, the request may need to be re vised to be consistent with the Agency’s new final action.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-3 projections. The application of these growth factors for each projection was then used for area sources. Appendix D provides info rmation on how emissions were projected for area sources. Each county total is listed in summary Tables 4.3-1 through 4.3-3 under

area sources.

4.2.4 On-road Mobile Sources

4.2.4 .1 Mobile Source Attainment Budget On-road mobile sources are vehicles that travel on local roads, state highways and interstates. Currently, no motor vehicle emissions budget (MVEB) has been approved for annual PM 2.5 

### for this area. Conformity is presently determined by a “No Greater Than Baseline” test. However, pursuant to 40 CFR 93.118(b)(2)(i) of the conformity regulations, a new MVEB is proposed for the year 2024. The 2024 MVEB is to be used for required analysis years of 2024 and beyond . The “No Greater Than Baseline” test will remain in effect and will be used for any required analysis years prior to 2024. A discussion follows in Section 4.2.4.3.

4.2.4.2 Projected Mobile Source Emissions Methodology
The MOVES2010a mobile source emissions model was utilized to estimate emissions for Alabama’s annual PM 2.5 

### redesignation request for Jefferson and Shelby Counties and a portion of Walker County. A tota l of nine runspecs were established representing 2009, 2015 and 2024. Each county had one runspec per year. Data for 2012, 2018 and 2021 was not modeled; however, emissions for these years were interpolated. All runspecs were set to the county scale and inventory was chosen as the calculation type. In the time span section, the aggregation level was set to hour, along with the selection of all months, all days and all hours. In the geographic bounds section, the state and appropriate county were selected for each run. 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 calc ulation 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 or der to retrieve data in tons/year. Input data was then imported through the County Data Manager (CDM). MOVES2010a default data was exported, reviewed and re-imported for the following CDM inputs: Age Distribution, Average Spee d Distribution, Fuel Supply, Meteorology and Ramp Fraction. Source Type Popula tion, Vehicle Type VMT and Road Type Distribution were derived from either an a dditional MOVES run, manual calculation or by using one of the converters provided by EPA. For Fuel Formulation, RVP adjustments were made for May-September, with the default RVP being used for all other months. The Reid Vapor Pressure (RVP) for gasoline sold in Jefferson and Shelby Counties will assume an RVP of 7.8 during the summer months of June, July, August and September in all future year inventory projections for the years 2012, 2015, 2018, 2021 and 2024, in the maintenance demonstration. The SIP requires a lower RVP as a control during summer months, and it is not being removed fr om the SIP at this time. The maintenance plan is not considering the reductions gained from using the SIP RVP limit in the future year projection s because the State may consider rescinding

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-4 the SIP RVP limit at a later date. The maximum federal limit for summertime RVP in specified ozone nonattainment/maintenance areas is 7.8 psi. The vehicle miles traveled (VMT) used in MOVES was determined by the network modeling process conducted by the Regional Planning Commission of Greater Birmingham (RPCGB) and Alabama Department of Transportation (ALDOT). TranPlan , the transportation model currently utilized by RPCGB and ALDOT, is a travel demand model used to forecast travel demands along a defined transportation network. In developing the TranPlan model run, RPCGB used the latest planning assumptions available. 2000 Census data were used for population, employment and journey to work estimates. The RPCGB gr ew 2005 data that had been obtained from ALDOT to provide 2009, 2015, 2017 and 2025 VMT data. The 2024 VMT data was then interpolated from the data provided by the RPCGB. This VMT data was used to make the appropriate calculations. The process of data collection and emissi ons 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 methodology and data used were agreed up on through interagency consultation. The VMT from the TranPlan output files and the MOVES documentation are found in Appendix E. The Birmingham area mobile source emissions totals are listed in summary Tables 4.3- 1 through 4.3-3 under mobile sources.

4.2.4.3 Mobile Source Maintenance Budget In accordance with the Transportation Conformity Rule, this maintenance plan establishes a MVEB for the last year of the maintenance plan (2024). This MVEB will be in effect for required analys is years for the year 2024 and beyond. As stated in Section 4.2.4.1, the current method for determining conformity is the “No Greater Than Baseline” test. This maintenance plan will establish a 2024 MVEB for NO X 

### and primary PM 2.5 

### . In the Birmingham, Alabama, annual PM 2.5 

### SIP submitted in May 2009, ADEM determined that SO 2 

### emitted by the mobile source sector is insignificant. EPA in its Federal Register notice for PM 2.5 

### does not address the mobile sector in its listing of significant sources of SO 2 

### emissions. Since the mobile source SO 2 

### contribution is insignificant, ADEM is not establishing MVEBs for this precursor. A discussion of precursor significance is located in Appendix C. This maintenance plan establishes an attainment inventory for the year 2009. This attainment inventory identifies the level of emissions in the area which is sufficient to attain the annual PM 2.5 

### NAAQS. Maintenance of the annual PM 2.5 

### NAAQS is demonstrated by showing that future emissions of direct PM 2.5 

### , SO 2 

### and NO X 

### will not exceed the level of the attainment inventory. Direct PM 2.5 

### , SO 2 

### and NO X 

### emissions from on-road mobile sources were proje cted for the year 2024 using the methodology discussed in Section 4.2.4.2. Direct PM 2.5 

### , SO 2 

### and NO X 

### emissions were also projected for the year 2024 for point, area and non-road mobile sources as described in Sections 4.2.2, 4.2.3, and 4.2.5, respectively. These projections are shown in Tables 4.3-1 through 4.3-3. As can be seen in Tables 4.3-1 through 4.3-3, total emissions of direct PM 2.5 

### , SO 2 

### and NO X 

### are projected to decrease from the attainment year (2009) through

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-5 the year 2024. Specifically, PM 2.5 

### emissions are projected to decrease by 151.95 tons/year and NO X 

### emissions are projected to decrease by 16,095.79 tons/year. These projected decreases in emissions from the a ttainment year through 2024 are termed the “safety margin”. In establishing a MVEB for the last year of the maintenance plan (2024 in this case), all or a portion of the safety margin may be allocated to the on-road MVEB. An interagency consultation meeting was held on February 25, 2011, to discuss this issue. As a result of the interagency consultation meeting on February 25, 2011, this maintenance plan establishes the MVEB at 442 tons/year for PM 2.5 

### and 15,982 tons/year for NO X 

### . This MVEB will be in effect for any required analysis years for the year 2024 and beyond. The MVEB for PM 2.5 

### will be the projected 2024 emissions for on-road mobile sources in addition to approx imately 70 percent of the safety margin for PM 2.5 

### . The MVEB for NO X 

### will be the projected 2024 emissions for on-road mobile sources in addition to approximately 45 percent of the safety margin for NO X 

### . The Birmingham area emissions and safety margins are listed in Tables 4.3-1 and 4.3-3. The calculations below show how the MVEB was determined for the year 2024 and beyond.
On-Road Mobile PM 2.5 

### Emissions for 2024 (335.7 TPY) + approximately 70% of PM 2.5 

### Safety Margin (106.37 TPY) = 2024 PM 2.5 

### MVEB (442.07 TPY)
On-Road Mobile NO X 

### Emissions for 2024 (8,738.39 TPY) + approximately 45% of NO X 

### Safety Margin (7,243.11 TPY) = 2024 NO X 

### MVEB (15,981.50 TPY) Additionally, revisions were made to th e MVEB established in the June 2010, 24-hour PM 2.5 

### maintenance plan. The original MVEB was set at 0.79 tons/day for PM 2.5 

### and 60.48 tons/day for NO x 

### . The revised MVEB is set at 1.21 tons/day for PM 2.5 

### and 48.41 tons/day for NO X 

### . Fifty percent of the safety margin was used for both NO x 

### and PM 2.5



### . These budgets will apply for any required anal ysis years for the year 2024 and later. Supporting information for the budget can be found in the 24-hour PM 2.5 

### redesignation request and maintenance plan.

4.2.5 No n-road Mobile Sources
Non-road mobile sources are mobile sources that do not travel on local roads, state highways and interstates. Non-road mobile so urce emissions result from the use of fuel in a diverse collection of vehicles and equipment:

 agri cultural equipment, such as tractors;

 aircraft, such as jets and prop planes;

 airport ground-support equipment, such as terminal tractors;

 commercial equipment, such as gene rators, air compressors, and pressure washers;

 construction and mining equipment, such as graders and back hoes;

 industrial equipment, such as forklifts and sweepers;

 lawn and garden equipment, such as lawn mowers and leaf and snow blowers;

 logging equipment, such as chain saws and shredders;

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-6  marine vessels, such as power boats and oil tankers;

 railroad equipment, such as train engines; and

 recreational vehicles and watercrafts, such as all-terrain vehicles, off-road motorcycles, and boats. For non-road emission projections, EPA's NONROAD2008a Model was used. Normal average high, average low, and average daily temperatures were obtained from the National Weather Service for the Birmingham area. As discussed in Section 4.2.4.2, the gasoline Reid Vapor Pressure (RVP), for use in the NONROAD model, will assume an RVP of 7.8 psi in all future year inventory projections for the years 2012, 2015,2018, 2021 and 2024 in this maintenance demonstration. At this time, the current nonroad model does not calculate emissions fo r railroad, commercial marine vessel, and airport activity emissions. Emission growth factors were de rived from EGAS for railroad, commercial marine vessel, and airpo rt activity emissions. These factors were applied to the 2009, 2012 and 2018 VISTAS/ASIP inventories for railroad, commercial marine vessel, and airport activity emissions and subsequently grown for 2015, 2021, and 2024. The 2010 non-road and future year estimates can be found in Appendix D. Each county total is listed in summary Ta bles 4.3-1 through 4.3-3 under non-road

sources.



### 4 .3 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 Clean Air Act 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. Subse quently, 8 years after redesignation and submittal of the initial maintenance plan, the State is required to submit an additional maintenance plan that shows maintenance for the remainder of the 20 year period. Alabama has chosen 2024 as the end year of the initial maintenance plan for the Birmingham NAA. The general approach used for the maintenance 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. Tables 4.3-1 through 4.3-3 show a calculated safety margin for PM 2.5 

### , NO X 

### and SO 2 

### for each year in the maintenance plan.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-7 Table 4.3-1 Birmingham Annual PM 2.5 Attainment Area Maintenance Plan PM 2.5 Emissions (Tons per Year)

County Source Category 2009 2012 2015 2018 2021 2024

Jefferson Point 2,890.8 2,503. 90 2,649.90 2,817.80 3,000.30 3,201.05

Area 3,186.45 3,120. 75 3,164.55 3,212.00 3,255.80 3,303.25

Non-road 386.90 357.70 310.25 262.80 237.25 222.65

Mobile 667.34 541.28 415. 24 369.37 323.50 277.61

Total 7,131.49 6,523.63 6,539. 94 6,661.97 6,816.85 7,004.56

Shelby Point 1,040.25 890.6 938.05 989.15 1,018.35 1,051.2

Area 1,153.4 1,160.7 1,182. 6 1,208.15 1,230.05 1,255.6

Non-road 193.45 182.5 167.9 153.3 146 142.35

Mobile 146.14 117.28 88.45 77.68 66.91 56.12

Total 2,533.24 2,351.08 2,377. 00 2,428.28 2,461.31 2,505.27

Walker (partial county) Point 164.25 164.25 164. 25 164.25 164.25 164.25

Area 167.9 167.9 167. 9 171.55 175.2 178.85

Non-road 7.3 3.65 3. 65 3.65 3.65 3.65

Mobile 6.32 4.94 3. 55 3.01 2.47 1.97

Total 345.77 340.74 339. 35 342.46 345.57 348.72

Total for the Bham NAA Point 4,095.3 3,558.75 3,755. 85 3,971.2 4,186.55 4,416.5

Area 4,507.75 4,445.7 4,515. 05 4,588.05 4,664.7 4,737.7

Non-road 584 543.85 481.8 419.75 383.25 365.00

Mobile 819.80 663.50 507. 24 450.06 392.88 335.70

Total 10,006.85 9,211.80 9,259. 94 9,429.06 9,627.38 9,854.90

Maintenance Plan Decrease from 2009 (PM 2.5 Safety Margin*) -795.05 -746.91 -577. 79 -379.47 -151.95

*After assigning 106.37 TPY of the PM 2.5 safety margin to the MVEB, the revised 2024 PM 2.5 safety margin wi ll be 45.58 TPY.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-8 Table 4.3-2 Birmingham Annual PM 2.5 Attainment Area Maintenance Plan NO X Emissions (Tons per Year)

County Source Category 2009 2012 2015 2018 2021 2024

Jefferson Point 14,698.55 14,483. 2 14,789.8 15,114.65 15,479.65 15,866.55

Area 3,325.15 3,379.9 3,434. 65 3,485.75 3,540.5 3,595.25

Non-road 7,504.4 6,770.75 6, 000.6 5,369.15 5, 321.7 5,398.35

Mobile 20,364.40 16,28 9.47 12,214.57 10,52 1.46 8,828.35 7,135.25

Total 45,892.50 40,923.32 36,439. 62 34,491.01 33,170.20 31,995.40

Shelby Point 14,997.85 15,27 1.6 15,549.0 15,826. 4 16,184.1 16,541.8

Area 719.05 730.0 740. 95 748.25 759.2 770.15

Non-road 2,303.15 2,058.6 1, 795.8 1,598.7 1, 554.9 1,554.9

Mobile 4,428.17 3,532.52 2,636. 85 2,268.42 1,899.99 1,531.57

Total 22,448.22 21,592.72 20,722. 60 20,441.77 20,398.19 20,398.42

Walker (partial county) Point 5,434.85 5,434.85 5,434. 85 5,434.85 5,434.85 5,434.85

Area 54.75 58.4 58.4 58.4 58.4 58.4

Non-road 160.6 149.65 138.7 208.05 131.4 135.05

Mobile 198.56 158.15 117. 72 102.33 86.94 71.57

Total 5,848.76 5,801.05 5,749. 67 5,803.63 5,711.59 5,699.87

Total for the Bham NAA Point 35,131.25 35,189. 65 35,773.65 36,375.9 37,102.25 37,846.85

Area 4,102.6 4,168.3 4,230. 35 4,296.05 4,358.1 4,423.8

Non-road 9,968.15 8,679.0 7, 935.1 7,172.25 7, 004.35 7,088.3

Mobile 24,991.13 19,98 0.14 14,969.14 12,892. 21 10,815.28 8,738.39

Total 74,193.13 68,017.09 62,908. 24 60,736.41 59,279.98 58,097.34

Maintenance Plan Decrease from 2009 (NO X Safety Margin*) -6,176.04 -11,284.89 -13,456.72 -14, 913.15 -16,095.79

*After assigning 7,243.11 TPY of the NO X safety margin to the MVEB, the revised 2024 NO X safety margin will be 8,852.68 TPY.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-9 Table 4.3-3 Birmingham Annual PM 2.5 Attainment Area Maintenance Plan SO 2 Emissions (Tons per Year)

County Source Category 2009 2012 2015 2018 2021 2024

Jefferson Point 68,696.65 11,92 4.55 12,015.8 12,125. 3 12,285.9 12,464.75

Area 233.6 240.9 244. 55 251.85 259.15 266.45

Non-road 124.1 47.45 43.8 43.8 47.45 47.45

Mobile 121.67 99.47 77.30 77.75 78.20 78.61

Total 69,176.02 12,312.37 12,381. 45 12,498.70 12,670.70 12,857.26

Shelby Point 106,039.8 57,071. 4 57,235.65 57,403.55 57,618.9 57,834.25

Area 47.45 47.45 51.1 51.1 51.1 54.75

Non-road 54.75 25.55 21.9 21.9 21.9 25.55

Mobile 26.38 21.31 16. 25 16.31 16.37 16.42

Total 106,168.38 57,165.71 57,324. 90 57,492.86 57,708.27 57,930.97

Walker (partial county) Point 5,358.2 5,358.2 5,358. 2 5,358.2 5,358.2 5,358.2

Area 109.5 109.5 113. 15 113.15 113.15 113.15

Non-road 2.92 1.46 1. 46 1.825 1.46 1.46

Mobile 1.03 .79 .54 .56 .58 .59

Total 5,471.65 5,469.95 5,473. 35 5,473.74 5,473.39 5,473.40

Total for the Bham NAA Point 180,094.65 74,354.15 74,609.65 74,887.05 75,131.96 75,525.8

Area 386.9 397.85 405. 15 416.1 423.4 434.35

Non-road 182.5 73.0 69.35 69.35 69.35 73.00

Mobile 149.08 121.57 94.09 94.62 95.15 95.62

Total 18,0813.13 74,946.57 75,178. 24 75,467.12 75,719.86 76,128.77

Maintenance Plan Decrease from 2009 (SO 2 Safety Margin) - 105,866.56 - 105,634.89 - 105,364.01 - 105,093.27 - 104,684.36

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-10 4.3 .1 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 redu cing emission controls ('anti-backsliding') following the redesignation of the area unles s 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 Clean Air Act. The following regulatory programs will remain in place in the Birmingham NAA:

• Fede ral 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 Performance St andards under Section 111 (42 U.S.C. 7411)

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

• The Federal NO X 

### SIP Call

• The Federal Clean Air Interstate Rule (CAIR) 10



### • The Local Jefferson and Shelby County Burn Ban

• Local voluntary on and off-road diesel retro fit projects have been initiated in the nonattainment area. These projects utilize diesel emission control equipment as well as locomotive idle reduction equipm ent to lessen the particulate emissions from these engines. The reductions are not officially quantified and credit was not taken for these reductions.

• Installation of Selective Catalytic Reduction (SCR) and Low NO X 

### Burners (LNB) on Units 7 & 8 at TVA’s Widows Creek Pl ant in 2003/2004. Also, Unit 8’s Flue Gas Desulfurization (FGD) was upgraded in efficiency in 2004. LNB and SCR were added as a result of the NO X 

### SIP Call. As a result of the addition of SCR to Unit 5, the existing FGD on Unit 5 requi red a re-build, which, in turn, increased its SO 2 

### removal efficiency.

• Installation of LNB on Units 1-4 at TVA’s Colbert Plant in 2006 and SCR on Unit 5 in 2004. LNB and SCR were added as a result of the NO X 

### SIP Call.

10 On December 23, 2008, the United States Court of Appeals for the District of Columbia Circuit remanded CAIR to EPA, without vacatur, directing th e Agency to remedy the rule’s flaws in accordance with the Court’s July 11, 2008, opinio n in the case of North Carolina v. EPA, 531 F. 3d 896, 901 (D.C. Cir. 2008). When EPA responds to the Court’s remand, the requ est may need to be revised to be consistent with the Agency’s new final action.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-11 • Installation of LNB on Units 6 & 7 at Alabama Power’s Gorgas Plant in 2003 and SCR on Unit 10 in 2002. Also, the installation of FGD on Units 8 – 10 in 2007. LNB and SCR were added as a result of the NO X 

### SIP Call. The FGD was added in anticipation of CAIR.

• Installation of SCR on Units 3 & 4 at Alabama Power’s Miller Plant in 2003 with a Consent Decree requiring year ro und operation beginning in 2008. Also, the installation of SCR on Units 1 & 2 in 2005. All 4 SCRs were added as a result of the NO X 

### SIP Call. Year-round operation of all SCRs was planned in anticipation of the annual NO x 

### CAIR rule. The consent decree further required year-round operation of the SCRs on Units 3 and 4. The consent decree requirements have been incorporated into the facility’s Title V permit and are enforceable.



### • Installation of SCR on Unit 5 at Alabama Power’s Gast on Plant in 2006 was added as a result of the NO X 

### SIP Call and in anticipation of CAIR.

• Installation of Low NO X 

### Burner Technology for Cell Burners (LNCB) with overfire air (OFA) on Unit 1 at Alabama Po wer’s Greene County in 2003. Also, the installation of OFA on the LNB on Unit 2 in 2004. LNCB and OFA were added as a result of the NO X 

### SIP Call.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

Figure 4.3.1-1 Locations of Power Plants in Relation to the Birmingham Annual PM 2.5 Nonattainment Area



### 4-12

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-13 Table 4.3.1-1 RACT Controls Installed Prior to or During 2010 

### Facility Source RACT Controls
McWane Pipe 11 Charge handling area Wet suppression Sloss Coke Coal piles Wet suppression

ACIPCO Charge make-up Wet suppression Roads & process areas paving Cupola melting furnace new cupola/BH & spray suppression Sand & cement storage silos Baghouse Nucor Steel Meltshop fugitives route to BH, other physical improvements

US Pipe 12 Cupola charge makeup Wet suppression Sand/cement silos install bin vents



### 4 .3.2 Verification of Continued Attainment Verification of continued attainment is monitored through operation of the ambient fine particulate matter monitor network and the maintenance of updating the area's emissions inventory.
The current ten 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 oper ation, 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 Requirement s (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 emi ssions will continue to be quantified on a three-year cycle. As required by the AERR, the next overall emissions inventory will be compiled for the calendar year 2011.

4.3.3 Contingency Plan Section 175A(d) of the Clean Air Act Amendmen ts 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.

11 McWane Pipe idled its operations as of May 2010.

12 U.S. Pipe ceased prod uction on March 31, 2010.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-14 The State of Alabama will use actual ambient monitoring data as the indicator or trigger to determine when th ese contingency measures 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 year at any individ ual monitor in the nonattainment area records a reading of 15 μ g/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 emi ssion inventory updates reveal excessive or unanticipated emissions growth greater th an 10%, 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 dete rmining 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 violat ion 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 n eed for additional local reductions in emissions of direct PM 2.5 

### and/or SO 2



### . In May of 2009, ADEM submitted to EPA the “Attainment Demonstration for the Birmingham, Alabama Annual PM 2.5 

### Nonattainment Area”. This plan demonstrates attainment of the annual PM 2.5 

### NAAQS beginning in 2012 based on implementation of a combination of federal measures including CAIR 13 

### , other regional controls, mobile source controls and local controls on industrial sources of direct PM 2.5 

### . As shown in the Table 4.3.3-1 below, this plan is based on reductions in direct PM 2.5 

### , NO X 

### and SO 2 

### emissions that will occur through the year 2012.

13 On December 23, 2008, the United States Court of Appeals for the District of Columbia Circuit remanded CAIR to EPA, without vacatur, directing th e Agency to remedy the rule’s flaws in accordance with the Court’s July 11, 2008, opinio n in the case of North Carolina v. EPA, 531 F. 3d 896, 901 (D.C. Cir. 2008). When EPA responds to the Court’s remand, the requ est may need to be revised to be consistent with the Agency’s new final action.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-15 Table 4.3.3-1 Projected Reductions

Date Control Installed Projected Reductions (TPY) Facility PM2.5 NOX SO2 PM2.5 NOX SO2 W.J. Bullock 14 Dec-2009 3.9 McWane Pipe 2009 14.7 Sloss Coke 2009 0.4 ACIPCO 2007/2008 21.4 Nucor Steel 2008/2009 28.1 APCo Miller Unit 1 2005 5,664 APCo Miller Unit 2 2005 5,464 APCo Miller Unit 3 2003/2008 6,446 APCo Miller Unit 4 2003/2008 7,238 APCo Gaston Unit 5 2006 Jan-2010 10,483 51,017 APCo Gorgas Unit 8 Dec-2007 5,387 APCo Gorgas Unit 9 Dec-2007 4,493 APCo Gorgas Unit 10 2002 Dec-2007 5,077 23,889 TVA Colbert Unit 5 2004 3,467 22,732 TVA Widows Creek Unit 7 2003 3,463 TVA Widows Creek Unit 8 2004 2004 (upgrade) 5,689 3,741 GA Bowen Unit 1 2008 2009 3,613 36,951 GA Bowen Unit 2 2008 Jun-2009 4,213 37,210 GA Bowen Unit 3 2008 Jan-2009 9,630 40,431 GA Bowen Unit 4 2008 Jan-2009 9,401 40,100 GA Wansley Unit 1 2008 Jan-2009 8,531 36,851 GA Wansley Unit 2 2008 Jan-2010 7,458 35,240 GA Hammond Unit 1 Jan-2009 3,675 GA Hammond Unit 2 Jan-2009 3,832 GA Hammond Unit 3 Jan-2009 4,005 GA Hammond Unit 4 Jan-2009 Jan-2009 2,101 17,007 Total Reductions from Base Year (AL only) 69 52,991 111,259 Total Reductions from Base Year (includes GA EGUs) 69 97,938 366,561



### The Attainment Demonstration for the Annual PM 2.5 

### NAAQS also contained contingency measures to be undertaken if the area fails to attain the annual PM 2.5 

### NAAQS by the 2012 attainment date. The co ntingency measures will also rely onemissions reductions that will occur as a result of CAIR and the Georgia multipollutant rule. The Georgia multi-pollutant rule (Georgia Department of Natural Resources’ Air Quality Rule 391-3-1-.02(2 )(sss), “Multipollutant Control for Electric Utility Steam Generating Unit s”), requires permitted NO X 

### and SO 2 

### controls at several western Georgia utilities. All controls relied on as contingency measures in the plan are based on controls that are scheduled to be installed in the year 2011 or later. These programs are expected to result in ad ditional reductions in emissions of SO 2 

### and NO X 

### through the year 2015. The Tables 4.3.3-2 and 4.3.3-3 below depict these emissions reductions for SO 2 

### and NO X



### .

14 W.J. Bullock ceased all operations as of October 2009.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-16 Table 4.3.3-2 SO 2 Emissions Reductions

Facility Unit Control Installation Date** Emissions (t/y)

2010 PostControl Δ

TVA Plant Colbert 1 FGD 2015* 7121.58 356.08 6765.50
TVA Plant Colbert 2 FGD 2015* 7088.45 354.42 6734.03
TVA Plant Colbert 3 FGD 2015* 7106.34 355.32 6751.02
TVA Plant Colbert 4 FGD 2015* 7079.83 353.99 6725.84
TVA Plant Colbert 5 FGD 2015* 4597.90 229.90 4368.00
APCo Miller 1 FGD 2011 105071.1 1284.1 9223
APCo Miller 2 FGD 2011 9765.44 1283.44 8482
APCo Miller 3 FGD December 31, 2011 10970.6 1256.6 9714
APCo Miller 4 FGD December 31, 2011 12889.8 1235.8 11654 GPC McDonough 1 FGD Apri l 2012 11134.1 20.1 11114.0 GPC McDonough 2 FGD January 2012 11468.9 20.7 11448.0
GPC Plant Scherer 3 FGD January 2012 27735.1 1387 26348.1
GPC Plant Scherer 4 FGD December 31, 2012 26616.20 1330.80 25285.40
GPC Plant Branch 3 FGD December 31, 2013 20105.10 1005.30 19099.80
GPC Plant Scherer 2 FGD December 31, 2013 26074.60 1303.70 24770.90
GPC Plant Branch 4 FGD June 1, 2014 19663.00 983.20 18679.80
GPC Plant Branch 1 FGD December 31, 2014 10732.90 536.60 10196.30
GPC Plant Branch 2 FGD December 31, 2014 12993.80 649.70 12344.10
GPC Plant Scherer 1 FGD December 31, 2014 26264.50 1313.20 24951.30

GPC Plant Yates 6 FGD June 1, 2015 14207.20 6334.00 (2015)
710.40 (Post-2015) 7873.20 (2015)
13496.80 (Post-2015)

GPC Plant Yates 7 FGD June 1, 2015 14348.40 6397.00 (2015)
717.40 (Post-2015) 7951.40 (2015)
13631.00 (Post-2015)

*Projected start-up date **The installation date listed for Georgia sources is required by Georgia rules.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-17 Table 4.3.3-3 NO X Emissions Reductions

Facility Unit Control Installation Date** Emissions (t/y)

2010 PostControl Δ

TVA Plant Colbert 1 SCR 2015* 3126.37 468.96 2657.41
TVA Plant Colbert 2 SCR 2015* 3111.82 466.77 2645.05
TVA Plant Colbert 3 SCR 2015* 3119.68 467.95 2651.73
TVA Plant Colbert 4 SCR 2015* 3108.04 466.21 2641.83 GPC McDonough 1 SCR Apri l 2012 2127.20 306.30 1820.90 GPC McDonough 2 SCR January 2012 2191.20 315.50 1875.70
GPC Plant Scherer 3 SCR January 2012 5024.50 2410.50 2614.00
GPC Plant Scherer 4 SCR December 31, 2012 4821.76 2410.90 2410.86
GPC Plant Scherer 2 SCR December 31, 2013 4723.64 2361.80 2361.84
GPC Plant Branch 4 SCR June 1, 2014 6899.85 1207.50 5692.35
GPC Plant Branch 1 SCR December 31, 2014 5130.36 897.80 4232.56
GPC Plant Branch 2 SCR December 31, 2014 4475.81 783.30 3692.51
GPC Plant Scherer 1 SCR December 31, 2014 4758.04 2379.00 2379.04

GPC Plant Yates 6 SCR June 1, 2015 3009.54 1561.20 (2015)
526.70 (Post-2015) 1448.34 (2015)
2482.84 (Post-2015)

GPC Plant Yates 7 SCR June 1, 2015 3039.45 1576.70 (2015)
531.90 (Post-2015) 1462.75 (2015)
2507.55 (Post-2015)

*Projected start-up date **The installation date listed for Georgia sources is required by Georgia rules.



### As shown above, several regulatory progra ms will result in continued reductions in emissions of direct PM 2.5 

### , SO 2 

### and NO X 

### through the year 2015. In the event of a future violation of the annual PM 2.5 

### standard, ADEM will consider the air quality impact of all of these regulatory programs and any other new programs at the time in determining the need for additional local redu ctions in emissions of direct PM 2.5 

### and/or SO 2 

### . Even though there is some uncertainty as to the status of CAIR, ADEM will evaluate the status of CAIR 15 

### and all regulatory programs at the ti me of a future year violation of the annual PM 2.5 

### NAAQS.

15 On December 23, 2008, the United States Court of Appeals for the District of Columbia Circuit remanded CAIR to EPA, without vacatur, directing th e Agency to remedy the rule’s flaws in accordance with the Court’s July 11, 2008, opinio n in the case of North Carolina v. EPA, 531 F. 3d 896, 901 (D.C. Cir.

### Birmingham Annual PM 2.5 

### Nonattainment Area Request for Redesignation to Attainment

4-18 In the event that further reductions are needed, the list of culpable sources that was developed in the PM 2.5 

### annual SIP will be evaluated for additional control of direct PM 2.5 

### emissions. Also, the possibility of exp anding the current voluntary diesel retrofit program operating in the Birmin gham area will be explored. A timeline for the development of NO X 

### , PM 2.5 

### and/or SO 2 

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

### NAAQS:

Table 4.3.3-4 Schedule for Permit Revisi ons or Rule Revisions for Contingency Measures



### 1. Ide ntify 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 Birmingham 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

2008). When EPA responds to the Court’s remand, the requ est may need to be revised to be consistent with the Agency’s new final action.

### Birmingham 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 Birmingham area demonstrate comp liance with the NAAQS for annual PM 2.5 

### . Since the late 1970's, there have been many major programs enacted in the Birmingham area that have led to significant actual, enforce able emissions reductions, which have led to improvements in the air quality in Birmin gham. This redesignation request and maintenance demonstration has been prepared to meet the requirements of the 1990 Clean Air Act Amendments.