April 2011 

REDESIGNATION REQUEST 

AND 

MAINTENANCE DEMONSTRATION

Birmingham 

Annual PM2.5 Nonattainment Area

Prepared by: 

Alabama Department of Environmental Management 

Air Division 
Birmingham Annual PM2.5 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 PM2.5 ......................................................................................................... 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 PM2.5 Monitoring Network .................................................................................................... 2-1

2.1.3 Ambient PM2.5 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 PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

iv 

 TABLES 

Table 2.1.2-1 Summary of the Annual PM2.5 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 PM2.5 Attainment Area Maintenance Plan PM2.5 Emissions 

(Tons per Year)............................................................................................................................... 4-7

Table 4.3-2 Birmingham Annual PM2.5 Attainment Area Maintenance Plan NOX Emissions 

(Tons per Year)............................................................................................................................... 4-8

Table 4.3-3 Birmingham Annual PM2.5 Attainment Area Maintenance Plan SO2 Emissions (Tons 

per Year) ......................................................................................................................................... 4-9

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

Table 4.3.3-1 Projected Reductions ................................................................................................ 4-15

Table 4.3.3-2 SO2 Emissions Reductions ....................................................................................... 4-16

Table 4.3.3-3 NOX 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 PM2.5 in Relation to the North 

Birmingham PM2.5 Monitor .......................................................................................................... 2-4

Figure 2.2-2 Locations of Local Sources Being Controlled for PM2.5 in Relation to the Wylam 

PM2.5 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 PM2.5 24hr > 25μg/m3 vs. # of Days >= 90oF 2003-2010....................................... 2-8

Figure 2.2.1-3 PM2.5 24hr > 25μg/m3 vs. # of Days with Rain >=0.05” 2003-2010 ...................... 2-9

Figure 2.2.1-4 PM2.5 24hr>15μg/m3 vs. # of Days with Rain >=0.05” 2000-2009...................... 2-10

Figure 2.2.1-5 Number of Days > 25μg/m3 vs. April-Sept Rainfall Totals ................................. 2-11

Figure 4.3.1-1 Locations of Power Plants in Relation to the Birmingham Annual PM2.5

Nonattainment Area .................................................................................................................... 4-12

APPENDICES 

PM2.5 Monitor Locations ....................................................................................................................... A 

AIRS AQS Report ................................................................................................................................. B 

Birmingham Particulate Matter Study ............................................................................................... C 

Mobile Source Precursor Discussion .................................................................................................... D 

Emissions Documentation and Projections ......................................................................................... E 

MOVES Modeling to Demonstrate Maintenance ................................................................................ F 

Point Source Closure Documentation .................................................................................................. G 
v 

Executive Summary 

This document contains Alabama's demonstration under the federal Clean Air Act 

Amendments of 1990 that the Birmingham annual PM2.5 Nonattainment Area (NAA) 

should be redesignated from nonattainment to attainment with respect to the National 

Ambient Air Quality Standard (NAAQS) for 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 PM2.5 monitors in the Birmingham NAA showing no violation of the annual PM2.5 

standard, the implementation of permanent and enforceable reductions in PM2.5 and

precursor emissions, compliance with Section 110 and Part D requirements of the 

Clean Air Act, and the Birmingham Maintenance Plan with projections demonstrating 

that the 2009 emission levels in this area will not be exceeded through at least the year 

2024. 

Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

1-1 

1.0 Introduction 

1.1 Purpose 

This document contains the technical support necessary for the Alabama Department 

of Environmental Management's (ADEM) request that the Birmingham annual PM2.5 

NAA be redesignated as an area attaining the annual PM2.5 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 PM2.5 standard. The official 

designations and classifications were printed in the Federal Register on January 5, 

2005, (70 FR 944). This designation became effective on April 5, 2005. 

1.3 Formation of PM2.5 

PM2.5, also known as particle pollution or fine 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. These 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 PM2.5 in Birmingham is similar to that of similar sites across 

the Southeast. PM2.5 measurements are separated into several components: 

ammonium sulfate ((NH4)2SO4), ammonium nitrate (NH4NO3), 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. NH4NO3 and (NH4)2SO4 are 

secondary pollutants formed in the atmosphere from primary emissions of sulfur 

dioxide (SO2), nitrogen oxides (NOX) and ammonia (NH3). OC is a mixture of primary 

carbon, predominantly from fuel combustion and biomass burning, and secondary 

carbon, predominantly from biogenic emissions. EC and crustal components (fine soil 

& metals) are primary pollutants emitted directly into the atmosphere. 

OC and (NH4)2SO4 are the dominant contributors to PM2.5 mass in the Birmingham 

area. SO2 emissions, primarily from utility and industrial point sources, are the 

primary contributors to SO4. SO4 mass is highest in the summer months, in part due to 

higher SO2 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 PM2.5 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 relate 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 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. 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 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 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 PM2.5 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 quality 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 PM2.5 is demonstrated when the three year 

average of the annual arithmetic mean PM2.5 concentrations is less than or equal to 15 

μg/m3. The resulting concentration represents an annual PM2.5 design value. A 

violation of the annual PM2.5 NAAQS occurs when the design value exceeds 15 μg/m3 at 

any monitor. 

The most recent three years of annual PM2.5 monitoring data (2008-2010) for the 

Birmingham NAA demonstrate compliance with the NAAQS for annual PM2.5, as will 

be illustrated in the next section. 

2.1.2 PM2.5 Monitoring Network 

There are presently ten PM2.5 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 PM2.5 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 PM2.5 concentrations for each year for each monitor and the 3-year average. 
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

2-2 

 

Table 2.1.2-1 Summary of the Annual PM2.5 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 PM2.5 Monitoring Data 

All of the PM2.5 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 PM2.5 concentrations at these monitors for these years is included in 

Appendix B. 
Birmingham Annual PM2.5 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 PM2.5 and PM2.5 precursor emission 

reductions. The improvement in air quality that has resulted in attainment of the 

annual PM2.5 NAAQS can be reasonably attributed to these emissions reductions. These 

programs were established to provide reductions 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 Standards 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 NOX SIP Call 

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

10. Local NOX controls on some NAA cement plants required by the 8-Hour Ozone 

Contingency Plan 

11. Local PM controls at Birmingham facilities associated with the Birmingham 

Annual PM2.5 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 PM2.5 concentrations at the North Birmingham 

(NBHM) and Wylam (WYL) monitors. A comparison of the PM2.5 mass across the 

Birmingham NAA provides a basis to estimate a regional background contribution, a 

general urban contribution and an incremental 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/m3, an urban contribution of roughly 2 μg/m3, and a 

local contribution for NBHM of 2-3 μg/m3 and for WYL of ~2 μg/m3. Therefore, 

decreases in emissions of direct PM2.5 constituents, such as those detailed in the table 

below, have and will directly impact PM2.5 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 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 request may need to be revised to be consistent with the 

Agency’s new final action.
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

Figure 2.2-1 Locations of Local Sources Being Controlled for PM2.5 in Relation to the 

North Birmingham PM2.5 Monitor 

Figure 2.2-2 Locations of Local Sources Being Controlled for PM2.5 in Relation to the 

Wylam PM2.5 Monitor 

2-4 
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

2-5 

Table 2.2-1 Summary of RACT Controls 

Facility Source RACT Controls

PM2.5

RACT 

Reduct 

(TPY)

RACT 

Date

W.J. Bullock2 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 MW3

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. Pipe4

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 NOX and SO2 controls at utilities around the Birmingham area have 

provided reductions of ~3,526 tpy of NOX and ~84,786 tpy of SO2 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 PM2.5 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 round operation beginning in 2008. SCRs 

were added as a result of the NOXSIP Call. Year-round operation of all SCRs 

was planned in anticipation of the annual NOX 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 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 PM2.5 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 PM2.5 concentrations and meteorology, 

a focus on the meteorological variables associated with the bulk of the elevated 

concentrations was needed. The warm weather months of the year (April - September) 

were where this meteorological analysis primarily focused. Figure 2.2.1-1 below helps 

inform this decision. As can be seen, the greatest number of high PM2.5 days over the 

three year period across Alabama and the Southeast 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 PM2.5 during this time period. It is also 

worth noting that a count of days with PM2.5 concentrations greater than 15 ug/m3 also 

shows that the second and third quarters typically have the highest PM2.5

concentrations. 
Birmingham Annual PM2.5 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 PM2.5 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 likely contributing at least in part to lower 

PM2.5 concentrations. 

As stated above, PM2.5 concentrations are usually higher on days with high 

temperatures, especially during the summer months. 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 

PM2.5 concentration was greater than 25μg/m3. Both the number of days with high 

temperatures greater than or equal to 90oF and the number of days with PM2.5

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 PM2.5 concentration greater than 

25μg/m3 decreased. This indicates that lower emissions may have led to lower PM2.5

concentrations. A sharper decline in PM2.5 concentrations can be seen between 2008-

2009, along with a decrease in the number of days with a high at or above 90oF. Both 

weather conditions and emission reductions likely 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 PM2.5 exceeding 25μg/m3 only 

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

2-7 
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

likely played a key role in reducing annual PM2.5 concentrations to levels below the 

NAAQS. 

Figure 2.2.1-2 PM2.5 24hr > 25μg/m3 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 PM2.5 concentration was greater 

than 25μg/m3 from 2003-2010. In general, PM2.5 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 PM2.5

concentrations showed a general decrease. This indicates that lower emissions may 

have led to lower PM2.5 concentrations. 

2-8 
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

Figure 2.2.1-3 PM2.5 24hr > 25μg/m3 vs. # of Days with Rain >=0.05” 2003-2010 

A sharper decline in PM2.5 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 

PM2.5 greater than 25μg/m3 only increased slightly. This further demonstrates that 

emission reductions have played a key role in meeting the annual PM2.5 NAAQS. To 

better separate the weather’s influence from the influence of emissions reductions on 

PM2.5, trend lines were added to Figure 2.2.1-4 below. As shown, the trend line for 

rainfall has little slope, while the PM2.5 trend line slopes steadily downward. This 

demonstrates that while rainfall clearly has an impact on PM2.5, the decline in 

concentrations can be attributed to both a decrease in emissions and weather. 

2-9 
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

Figure 2.2.1-4 PM2.5 24hr>15μg/m3 vs. # of Days with Rain >=0.05” 2000-2009 

To further illustrate an emission reduction signal, Figure 2.2.1-5 shows that during the 

typically higher PM2.5 months of April-September, from 2005-2007 the number of high 

PM2.5 days continued to decrease even though the April-September precipitation 

amounts decreased. A sharper decrease in high PM2.5 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 PM2.5 days only 

increased slightly and was well below the level it was in 2006. This indicates that 

emission reductions have likely contributed significantly to the sharper decline in high 

PM2.5 days over the past 3 years and in return have lowered annual PM2.5

concentrations to a level below the NAAQS. 

2-10 
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

Figure 2.2.1-5 Number of Days > 25μg/m3 vs. April-Sept Rainfall Totals 

With respect to the meteorology associated with the 2008 – 2010 time period, the 

following should be noted: 

• The graphs above include trend lines which 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 monitored concentrations decreased from the 

previous years. This would be contrary to what would be expected and is a 

strong indication that emissions reductions likely played a role in the lower 

monitor values. 

 Similarly, beginning in mid- 2008 to 2009, milder and wetter conditions 

occurred than were previously experienced, 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 relative 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 PM2.5, 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 

PM2.5 levels in the Birmingham area. 

2-11 
Birmingham Annual PM2.5 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 PM2.5 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 applicable requirements under Section 110 and Part 

D. 

3.1 Section 110 Implementation Plans 

Alabama’s CAIR5 SIP was fully approved by EPA on October 1, 2007 (72 FR 55659), 

and became effective on October 31, 2007. The annual PM2.5 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 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. On July 25, 2008, ADEM submitted a letter to EPA 

certifying that Alabama’s existing SIP meets all Section 110(a)(2) provisions of the 

Clean Air Act that address the requirements 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 PM2.5 Nonattainment Area”. 

This plan demonstrates attainment of the annual PM2.5 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 PM2.5. Thus, ADEM has met the requirement of Section 172(c). 

Section 176(c) - The concept of transportation conformity 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 transportation 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 Plan (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 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 request may need to be revised to be consistent with the 

Agency’s new final action.
Birmingham Annual PM2.5 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 purposes 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 PM2.5 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 NOX and primary PM2.5 for the year 2024. 
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

4-1 

4.0 Maintenance 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 verification of continued attainment, and the 

contingency plan. 

4.2 Attainment Inventory 

4.2.1 Overview 

Monitored attainment of the annual PM2.5 standard was achieved for the 2008-2010 

three-year period. The most recent comprehensive 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 that inventory is not yet available. 

According to the September 4, 1992, EPA guidance document entitled, "Procedures for 

Processing Requests to Redesignate Areas to Attainment", the base attainment 

inventory should be consistent with EPA'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 

PM2.5 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 emission 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 stationary sources that emit greater than 100 tons 

per year (TPY) of a criteria pollutant. The source emissions are calculated from data 
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

4-2 

 

collected annually from the sources. VISTAS/ASIP6 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 point source data for Jefferson County is 

obtained from the Jefferson County Department 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 inventories. 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 unit/facility allowable limits to prevent 

overgrowth. Utilities with installed controls were kept steady rather than applying 

growth factors. 

The downward trend in point source PM2.5 emissions is due to both the implementation 

of RACT controls on local Birmingham sources and the closing of three facilities: Sloss 

Industries Corporation – Mineral Wool, W.J. Bullock Incorporated, and U.S. Pipe and 

Foundry Company, LLC – North Birmingham7. Point source SO2 emissions are 

projected to drop significantly from 2009 to 2012 due to installed controls on utilities as 

a result of CAIR8. These controls are listed in Table 4.3.3-1. For conservatism due to 

the uncertain status of CAIR9, no additional reductions in SO2 or NOx emissions from 

utilities were assumed to occur beyond 2012. 

Appendix D provides information on how emissions 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 discussed 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 PM2.5. For further information concerning these 

facility closures, please see Appendix F.

8 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 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 request may need to be revised to be consistent with the 

Agency’s new final action.

9 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 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 request may need to be revised to be consistent with the 

Agency’s new final action.
Birmingham Annual PM2.5 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 information 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 PM2.5 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 PM2.5 redesignation request for Jefferson and Shelby Counties 

and a portion of Walker County. A total 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 NOX, PM2.5 and SO2. For those pollutants where the 

emissions calculation is based on prior calculation 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/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 Speed Distribution, Fuel Supply, Meteorology 

and Ramp Fraction. Source Type Population, Vehicle Type VMT and Road Type 

Distribution were derived from either an additional 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 from the SIP at this 

time. The maintenance plan is not considering the reductions gained from using the 

SIP RVP limit in the future year projections because the State may consider rescinding 
Birmingham Annual PM2.5 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 grew 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 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 

methodology and data used were agreed upon 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 analysis 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 NOX and primary PM2.5. In the 

Birmingham, Alabama, annual PM2.5 SIP submitted in May 2009, ADEM determined 

that SO2 emitted by the mobile source sector is insignificant. EPA in its Federal 

Register notice for PM2.5 does not address the mobile sector in its listing of significant 

sources of SO2 emissions. Since the mobile source SO2 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 PM2.5 NAAQS. Maintenance of the annual PM2.5 NAAQS is 

demonstrated by showing that future emissions of direct PM2.5, SO2 and NOX will not 

exceed the level of the attainment inventory. Direct PM2.5, SO2 and NOX emissions 

from on-road mobile sources were projected for the year 2024 using the methodology 

discussed in Section 4.2.4.2. Direct PM2.5, SO2 and NOX 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 

PM2.5, SO2 and NOX are projected to decrease from the attainment year (2009) through 
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

4-5 

the year 2024. Specifically, PM2.5 emissions are projected to decrease by 151.95 

tons/year and NOX emissions are projected to decrease by 16,095.79 tons/year. These 

projected decreases in emissions from the attainment 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 PM2.5 and 15,982 

tons/year for NOX. This MVEB will be in effect for any required analysis years for the 

year 2024 and beyond. The MVEB for PM2.5 will be the projected 2024 emissions for 

on-road mobile sources in addition to approximately 70 percent of the safety margin for 

PM2.5. The MVEB for NOX will be the projected 2024 emissions for on-road mobile 

sources in addition to approximately 45 percent of the safety margin for NOX. 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 PM2.5 Emissions for 2024 (335.7 TPY) + approximately 70% of PM2.5

Safety Margin (106.37 TPY) = 2024 PM2.5 MVEB (442.07 TPY) 

On-Road Mobile NOX Emissions for 2024 (8,738.39 TPY) + approximately 45% of NOX

Safety Margin (7,243.11 TPY) = 2024 NOX MVEB (15,981.50 TPY) 

Additionally, revisions were made to the MVEB established in the June 2010, 24-hour 

PM2.5 maintenance plan. The original MVEB was set at 0.79 tons/day for PM2.5 and 

60.48 tons/day for NOx. The revised MVEB is set at 1.21 tons/day for PM2.5 and 48.41 

tons/day for NOX. Fifty percent of the safety margin was used for both NOx and PM2.5. 

These budgets will apply for any required analysis years for the year 2024 and later. 

Supporting information for the budget can be found in the 24-hour PM2.5 redesignation 

request and maintenance plan. 

4.2.5 Non-road Mobile Sources 

Non-road mobile sources are mobile sources that do not travel on local roads, state 

highways and interstates. Non-road mobile source emissions result from the use of fuel 

in a diverse collection of vehicles and equipment: 

 agricultural equipment, such as tractors; 

 aircraft, such as jets and prop planes; 

 airport ground-support equipment, such as terminal tractors; 

 commercial equipment, such as generators, 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 PM2.5 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 for railroad, commercial marine vessel, and 

airport activity emissions. Emission growth factors were derived from EGAS for 

railroad, commercial marine vessel, and airport 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 Tables 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. Subsequently, 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 PM2.5 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 PM2.5, NOX and SO2 for 

each year in the maintenance plan. 
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

4-7 

Table 4.3-1 Birmingham Annual PM2.5 Attainment Area Maintenance Plan PM2.5

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 

(PM2.5 Safety Margin*) -795.05 -746.91 -577.79 -379.47 -151.95 

*After assigning 106.37 TPY of the PM2.5 safety margin to the MVEB, the revised 2024 

PM2.5 safety margin will be 45.58 TPY. 
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

4-8 

Table 4.3-2 Birmingham Annual PM2.5 Attainment Area Maintenance Plan NOX

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 16,289.47 12,214.57 10,521.46 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 15,271.6 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 19,980.14 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 

(NOX 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 NOX safety margin to the MVEB, the revised 2024 NOX

safety margin will be 8,852.68 TPY. 
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

4-9 

Table 4.3-3 Birmingham Annual PM2.5 Attainment Area Maintenance Plan SO2

Emissions (Tons per Year) 

County Source 

Category 2009 2012 2015 2018 2021 2024 

Jefferson 

Point 68,696.65 11,924.55 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 

(SO2 Safety Margin) 

-

105,866.56 

-

105,634.89 

-

105,364.01 

-

105,093.27 

-

104,684.36 
Birmingham Annual PM2.5 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 PM2.5 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 

Clean Air Act. 

The following regulatory programs will remain in place in the Birmingham 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 Performance 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 NOX 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 retrofit projects have been initiated in the 

nonattainment area. These projects utilize diesel emission control equipment as 

well as locomotive idle reduction equipment 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 NOX Burners (LNB) 

on Units 7 & 8 at TVA’s Widows Creek Plant 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 NOXSIP Call. As a result of the addition of SCR to 

Unit 5, the existing FGD on Unit 5 required a re-build, which, in turn, increased 

its SO2 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 NOXSIP 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 the Agency to remedy the rule’s flaws in accordance 

with the Court’s July 11, 2008, opinion 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 request may need to be revised to be consistent with 

the Agency’s new final action.
Birmingham Annual PM2.5 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 NOXSIP 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 round 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 NOXSIP Call. Year-round operation of all SCRs was planned in 

anticipation of the annual NOx 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 Gaston Plant in 2006 was added 

as a result of the NOXSIP Call and in anticipation of CAIR. 

• Installation of Low NOX Burner Technology for Cell Burners (LNCB) with overfire air (OFA) on Unit 1 at Alabama Power’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 NOXSIP Call. 
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

Figure 4.3.1-1 Locations of Power Plants in Relation to the Birmingham Annual PM2.5

Nonattainment Area 

4-12 
Birmingham Annual PM2.5 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 Pipe11

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 Pipe12 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 PM2.5 monitors that are operating in the annual PM2.5 

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. 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 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 PM2.5 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 production on March 31, 2010.
Birmingham Annual PM2.5 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 these 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 PM2.5 NAAQS will begin the process to 

implement these contingency measures. Also, in the event that the annual average 

PM2.5 concentrations in a year at any individual monitor in the nonattainment area 

records a reading of 15 μg/m3 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 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 determining the need for additional control 

measures in the event of a future year violation of the annual PM2.5 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 direct PM2.5 and/or SO2. 

In May of 2009, ADEM submitted to EPA the “Attainment Demonstration for the 

Birmingham, Alabama Annual PM2.5 Nonattainment Area”. This plan demonstrates 

attainment of the annual PM2.5 NAAQS beginning in 2012 based on implementation of 

a combination of federal measures including CAIR13, other regional controls, mobile 

source controls and local controls on industrial sources of direct PM2.5. As shown in the 

Table 4.3.3-1 below, this plan is based on reductions in direct PM2.5, NOX and SO2

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 the Agency to remedy the rule’s flaws in accordance 

with the Court’s July 11, 2008, opinion 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 request may need to be revised to be consistent with 

the Agency’s new final action. 
Birmingham Annual PM2.5 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. Bullock14 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 PM2.5 NAAQS also contained 

contingency measures to be undertaken if the area fails to attain the annual PM2.5 

NAAQS by the 2012 attainment date. The contingency measures will also rely on 

emissions 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 Units”), requires permitted NOX and SO2 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 additional reductions in emissions of SO2 and NOX

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

reductions for SO2 and NOX. 

 

14 W.J. Bullock ceased all operations as of October 2009.
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

4-16 

Table 4.3.3-2 SO2 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 April 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 PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

4-17 

Table 4.3.3-3 NOX 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 April 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 programs will result in continued reductions in 

emissions of direct PM2.5, SO2 and NOX through the year 2015. In the event of a future 

violation of the annual PM2.5 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 reductions in emissions of direct PM2.5 and/or SO2. Even 

though there is some uncertainty as to the status of CAIR, ADEM will evaluate the 

status of CAIR15 and all regulatory programs at the time of a future year violation of 

the annual PM2.5 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 the Agency to remedy the rule’s flaws in accordance 

with the Court’s July 11, 2008, opinion in the case of North Carolina v. EPA, 531 F. 3d 896, 901 (D.C. Cir. 
Birmingham Annual PM2.5 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 PM2.5 annual SIP will be evaluated for additional control of direct 

PM2.5 emissions. Also, the possibility of expanding the current voluntary diesel retrofit 

program operating in the Birmingham area will be explored. 

A timeline for the development of NOX, PM2.5 and/or SO2 regulations or permit 

conditions follows. This schedule initiates with certification of ambient air quality 

monitoring data indicating a violation of the annual PM2.5 NAAQS: 

Table 4.3.3-4 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 

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 request may need to be revised to be consistent with 

the Agency’s new final action.
Birmingham Annual PM2.5 Nonattainment Area 

Request for Redesignation to Attainment 

5-1 

5.0 Conclusion 

The most recent three years of quality-assured PM2.5 monitoring data for the 

Birmingham area demonstrate compliance with the NAAQS for annual PM2.5. Since 

the late 1970's, there have been many major programs enacted in the Birmingham area 

that have led to significant actual, enforceable emissions reductions, which have led to 

improvements in the air quality in Birmingham. This redesignation request and 

maintenance demonstration has been prepared to meet the requirements of the 1990 

Clean Air Act Amendments.