## DRAFT

Pre

- Hearing Draft

Redesignation Request and

Maintenance Demonstration

For

The Tennessee Portion of the Chattanooga Tennessee

- Georgia

Annual PM 2.5 Nonattainment Area

Prepared by:

Chattanooga

- Hamilton County Air Pollution C ontrol Bureau

6125 Preservation Drive Chattanooga, Tennessee 37416

- 3638

January 16 , 2013Preface: This document contains the technical support for the Chattanooga

- Hamilton County Air Pollution Control Bureau’s request that Hamilton County T ennessee be redesignated to attainment for the annual fine particulate matter national ambient standard pursuant to §§ 107(d)(3)(D) and (E) of the Clean Air Act, as amended.DRAFT



### Table of Contents

EXECUTIVE SUMMARY

................................ ................................ ................................ 1

1.0 INTRODUCTION

................................ ................................ ................................ ........ 3 1.1 Maintenance Plan Requirements

................................ ................................ .............. 3

1.2 Request for Redesignation

................................ ................................ ........................ 4

1.3 Description of Fine Particulate

................................ ................................ ................. 4

1.4 Clean Air Act Redesignation Criteria

................................ ................................ ....... 5

Air Quality

................................ ................................ ................................ .......................... 6

2.1 Monitor Locations

................................ ................................ ................................ ..... 6

3.0 PERMANENT AND ENFORCEABLE EMISSIONS REDUCTIONS

...................... 8

3.1 Power Plants

................................ ................................ ................................ ............. 8

4.0 EMISSION REDUCTIONS FROM GEORGIA

................................ .......................... 9 5.0 CONCLUSION AND REQUEST FOR REDESIGNATION

................................ .... 11

5.1 1990 Clean Air Act Amendment

................................ ................................ ........... 11

5.2 Air Quality History

................................ ................................ ................................ . 11

5.3 Clean Air Act Redesignation Criteria

...................... Error! Bookmark not defined.

6.0 Air Quality

................................ ................................ ................................ .................. 12 6.1 Air Quality (1999

- 2009)

................................ ................................ ......................... 12

6.2 Recent Design Values (2007

- 2009, 2008

- 2010 and 2009

- 2011)

........................... 12

8.0 Ma intenance Plan

................................ ................................ ................................ ........ 14 8.1 Hamilton County Maintenance Plan

................................ ................................ ....... 14

8.2 Existing Emissions Controls

................................ ................................ ................... 15

8.3 Federal Motor Vehicle Standards

................................ ................................ ........... 15

8.3.1 Tier 2 Passenger Vehicle Standards

................................ ................................ . 15 8.3.2 Heavy Duty Gasoline and Diesel Highway Vehicle Standards

....................... 15 8.3.3 Large Non

- road Diesel Engines Rule

................................ .............................. 16

8.3.4 Non

- road Spark

- Ignition Engi nes and Recreational Engines Standard

........... 16

8.4 TRANSPORT RULES

................................ ................................ ........................... 16

8.5 ADDITIONAL PROGRAMS SUPPORTING MAINTENANCE

......................... 179.0 Emissions Inventories and Maintenance Demonstration

................................ ............ 17

9.1.2 Emission Inventories

................................ ................................ ............................ 17

9.1.3 Safety Margin

................................ ................................ ................................ ... 19 10.0 Plan to Maintain Air Quality

................................ ................................ ..................... 20

List of Tables

Table 2

- 1 Annual PM 2.5 Design Values for al l monitors................................12

Table 4

- 1 2012 SO 2 Reductions from Bowen and Hammond Power Plants..........14

Table 4

- 2 2002 and 2009 SO 2 Reductions from Bowen and Hammond Plants......14

Table 4

- 3 Annual Sulfate Concentration at the Chattanooga Speciation Monitor...15

T able 6

- 1 FRM Monitors in the Tennessee

- North Georgia PM 2.5 Nonattainment Area Annual Mean PM 2.5 Concentrations .................. 17

Table 9

- 1 NO

x Inventory by Year.............................................................

. 22

Table 9

- 2 SO 2 Inventory by Year..............................................................

. 22

Tab le 9

- 3 PM 2.5 Inventory by Year.........................................................

. 23

Table 10

- 4 Safety Margin.....................................................................

. 23List of Figures

Figure 2

- 1 Locations of Federal Reference Monitors..............................

......... ...11

## EXECUTIVE SUMMARY

On January 5, 2005, the United States Environmental Protection Agency (EPA) published the fine particulate matter (PM 2.5 ) nonattainment designation for the Chattanooga, Tennessee

Georgia area. This area consists of Hamilton County in Tennessee, Catoosa and Walker Counties in Georgia, and the portion of Jackson County in Alabama that is described as U.S. Census 2000 block group identifier 01

– 071

- 9503

– 1. The Alabama portion of the nonattainment

area contains a coal

- fired power plant and a paper plant. Large c oal

- fired power plants are

located in Georgia between the nonatt ainment area and Atlanta.

The Chattanooga

- Hamilton County Air Pollution Control Bureau, the Tennessee Division of Air Pollution Control, the Georgia Air Protection Branch, and the Alabama Department of

Environmen tal Managemen t have developed PM 2.5 National Ambient Air Quality Standard ( NAAQS ) State Implementation Plan s (SIP) for each jurisdiction.

Reductions in PM 2.5 precursors and direct PM 2.5 resulted in monitor readings that demonstrate

attainment.

Monitored PM 2.5 Wei ghted Mean Values (μg/m 3 ) For Determination of Design Value

Federal Reference Monitor 2009 2010 2011

Siskin Drive/UTC (470654002) 10.5 11.7 11.1

Tombras Avenue (470650031) 1 0.5 1 2.0 11.1

Soddy

- Daisy High School (470651011) 9.5 1 3.3 10.3

Rossville, Ge orgia (132950002) 1 0.7 8.7 10.8 *

*Did not meet completeness criteria.

This document contains the Chattanooga

- Hamilton County ’s demonstration under the F ederal Clean Air Act Amendments of 1990 that the Tennessee portion of the Chattanooga, Tennessee

Geor gia PM 2.5 Nonattainment Area should be re designated from nonattainment to attainment with respect to the 1997 National Ambient Air Quality Standard (NAAQS) for annual PM 2.5 particulate. The nonattainment area consists of Hamilton County in Tennessee, Walke r and Catoosa Counties in Georgia

, as well as the portion of Jackson County in Alabama that is described as U.S. 2000 block group identifier 01

- 071

- 9503

- 1.This area is request ing to be redesignated to attainment for PM 2.5

. Attainment is based on the

des ign values for 2007

- 2009, for 2008

- 2010 , and for 2009

- 2011

. On May 31, 2011, the Environmental Protection Agency published “Approval and Promulgation of Implementation Plans and Designations of Areas for Air Quality Planning Purposes; Alabama, Georgia, and

Tennessee : Chattanooga; Determination of Attaining Data for the 1997 Annual Fine Particulate

Standard”. The Chattanooga Area has attained the 1997 annual average PM 2.5

. EPA has

determined that the Tennessee

- Georgia , fine particulate ( PM 2.5 ) nonattainment area has attained the 1997 annual average PM 2.5 National Ambient Air Standard. This determination of attainment is based upon quality

- assured and certified ambient air monitoring data for the 200 7

- 2009 period showing that the a rea has monitored attainment of the 1997 annual PM 2.5 NAAQS

.

## 1.0 INTRODUCTION

1.1 Maintenance Plan Requirements

The United State s EPA, the State of Tennessee, t he State of Georgia, the State of Alabama

, and the Chattanooga

- Hamilton County Air Pollution Control Bureau implemented permanent and

enforceable reductions in emissions of fine particulate matter, sulfur dioxide, and nitrogen oxides. Sulfur dioxide and nitrogen oxides are precursors for PM 2.5 particulate matter. T he se emissions reducti ons demonstrate the PM 2.5 monitors s how atta inment with the annual PM 2.5 standard

. This document contains the technical support for the Hamilton County Tennessee portion of the Chattanooga nonattainment area to be redesignated as an area attaining the 1997

annual fine particulate matter (PM 2 .5 ) standard pursuant to Sections 107(d)(3)(D) and (E) of the Clean Air Act (CAA) as amended. This redesignation request was prepared in accordance with US EPA Guidance issued in 1992 ( Memorandum dated September 4 1992 from John Calcagni )

. The United State s EPA, Hamilton County Tennessee, the State of Georgia, the State of Tennessee, and the State of Alabama have implemented permanent and enforceable reductions in fine particulate matter, sulfur dioxide (SO 2 ), and nitrogen oxide (NO

x ). SO 2 and NO

x are

precu rsors for fine particulate matter. Actions by the Chattanooga

- Hamilton County Air Pollution Control Bureau, The Tennessee Department of Environmental Quality, the Georgia Air Protection Branch, and federal actions have resulted in cleaner air in the PM 2.5 nonattainment area. The future benefits from these programs are expected to result in continued maintenance of

the 1997 annual PM 2.5 NAAQS.

The redesignation applies to Hamilton County Tennessee

.

Local measures includ e the implementation of rules tha t apply to industrial sources. The state of Tennessee implemented an annual motor vehicle inspection and maintenance program. Georgia implemented Georgia Rule 391

- 3

- 1

- .02(2)(SSS) which reduced emissions from power plants.

Several actions at the f ederal lev el contributed to the reductions in PM 2.5. The federal effort involved reducing the sulfur content of diesel fuel and gasoline, reducing NO

x from on

- road and

non

- road mobile sources, and reducing power plant emissions.

The stationary emissions inve ntory was developed for the 2007 baseline year. The area source

emission s inventory was also developed for 2007. Future emission inventories were developed

for years 2010, 2013, 2016, 2019, 2022 and a f inal emission inventory for 2025 . The future

em issions wer e less than the 2007 emissions in all cases.

This demonstrates that the PM 2.5 nonattainment area is expected to continue to maintain the 1997

annual PM 2.5 NAAQS through 2025 since in no future year emissions are expected to be greater than they were in t h e baseline year. The area is in compliance with Section 110 and Part D requirements of the Clean Air Act. INVISTA is subject to a Federal Consent Decree . To comply with this requirement, INVISTA has removed their coal fired boilers and now uses n atural g asThe backup fuel is now No 2 oil. These changes will reduce 157.015 tons/y ear of NO

x . SO 2 reductions will 502.803tons per year. These reductions are used for the contingency provisions.



### 1.2 Request for Redesignation

Based on the information above and criteria established in Section 107(d)(3)(E) of the CAA, Tennessee is requesting that the USEPA redesi gnate the Tennessee p ortion of the Chattanooga,

Tennessee

- Georgia PM 2.5 fine particulate nonattainment area to attainment. The monitoring data

shows that the region has attained the annual fine particulate matter standard, and the maintenance demonstration shows that future emission inventories are expected to be lower than the attainment year through the implementation of the various controls discussed in this

document.



### 1.3 Description of Fine Particulate

Fine particulate matter, also known as PM 2.5 , refers to airborne particles less than or equal to 2.5

micro grams per cubic meters (μgm) in diameter. Fine particles are treated as though they are a single pollutant, but they come from many different sources and are composed of many different compounds and elements. PM 2.5 exposure adversely affects human health, especially respiratory and cardiovascular systems. Individuals particularly sensitive to PM 2.5 e xposure include children, people with heart and lung disease, and older adults.

PM 2.5 can be liquid, solid, or a solid core surrounded by liquid. PM 2.5 can include material produced by combustion, photochemical reactions, and salt from sea spray and soil like particles. Particles are distinguished based on the method of formation. Primary particles are directly emitted into the atmosphere and retain the same chemical composition as when they were released. Secondary particles are those formed through chem ical reactions involving atmospheric oxygen, water vapor, hydroxyl radical, nitrates, sulfur dioxide (SO 2 ), oxides of nitrogen (NO

x ), and organic gases from natural and anthropogenic sources. PM 2.5 can be composed of varying amounts of different species in cluding:

• Sulfate

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

• Ammonium

• Hydrogen ion

• Particle bound water

• Elemental Carbon

• Organic compounds

• Primary organic species (from cooking and combustion)

• Secondary organic compounds

• Crustal Material (inc ludes calcium, aluminum, silicon, magnesium, and iron

• Sea Salt (generally only at costal monitoring sites)

• Transitional metals• Potassium (generally from wood burning or cooking)

The most significant sources of PM 2.5 and its precursors are coal

- fired power plants, industrial boilers, and other combustion sources. These emissions are often transported over long distances.

Other sources of PM 2.5 emissions include on

- road and non

- road mobile sources, area sources, fires, windblown dust, and biogenic, i.e., nat urally occurring emissions such as organics from

trees.

A variety of meteorological and geographic factors influence the concent ration levels of fine particles. R egional and local distribution of PM 2.5 comes from urbanized areas as primary and

precursor e missions sources. PM 2.5 concentrations can also be high and exceed the national ambient air quality standards (NAAQS) for fine particulate at any time of the year. Therefore year around monitoring is required.

In 1997, t he USEPA promulgated the annual an d daily NAAQS for PM 2.5 . The annual standard was set at 15 micrograms per cubic meter and the daily standard was set at 65 micrograms per cubic meter. However, the daily standard has been revised to 35 micrograms per cubic meters. The Chattanooga area is i n attainment with the revised daily standard and has never been in non attainment of the daily standard.

A violation of the annual PM 2.5 standard occurs when the annual average PM 2.5 concentration, averaged over a three consecutive year period, is equal or greater than 15.1 micrograms per cubic

meter. The annual PM 2.5 design value for a nonattainment area is the highest design value for any

monitor in that area.



### 1.4 Clean Air Act Redesignation Criteria

Since the 1977 amendments of the Clean Air Act (CA A), areas that had not attained the ambient standard for a particular pollutant were formally designated as nonattainment for that pollutant. This formal designation concept was retained in the 1990 Amendments (CAAA). With the implementation of the PM 2.5 s tandard, areas could be designated under Section 172 of the CAAA (Subpart 1) and have five years from designation to attain the standard. The effective date of the nonattainment designation for this was April 5, 2005 and was based on air quality monitoring for the years 2001, 2002, and 2003.

Section 107(d)(3)(E) of the CAA, as amended, states that an area can be redesignated to attainment if the following conditions are met:

The US EPA has determined that the NAAQS have been attained. For fine particulat e matter, the area must show that the average of the annual average values from three consecutive calendar years of quality

- assured air quality monitoring data must be 15 micrograms per cubic meter or

lower.The applicable implementation plan has been ful ly approved by the USEPA under section 110(k).

The US EPA has determined that the improvement in air quality is due to permanent and enforceable reductions in emissions. To demonstrate this, the reduction (from the year used to determine the designation a nd classification) achieved from Federal, State, and local measures.

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

The US EPA has fully approved a maintenance plan, including a contingency plan, for the areas

u nder Section 175A.

The following will provide the technical data necessary to show that the Chattanooga area has attained and is expected to maintain the annual fine particulate matter standard. This area meets the requirements for redesignation as descr ibed.



## Air Quality

2.1 Monitor Locations

Four PM 2.5 federal reference monitors are located in the nonattainment area. Three monitors are located in Hamilton County Tennessee and one monitor is located in Walker County Georgia.

Federal reference monitors (FRM) collect samples that are used to determine if an area is in

attainment with the PM 2.5 NAAQS. A list of the monitors and associated design values are

shown in Table 1

- 1. The FRM located at Soddy

- Daisy High School is the most rural site of the

three Ha milton County FRMs and has always shown attainment. The other three monitors

showed exce edences of the annual standard for the 2001

- 2003 averaging period, which is the period the EPA used in the designation of the nonattainment area. Monitor locations ar e show inFigure 2 -1.

Figure 2 -1 Monitor Locations 

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..... -o.- ."'llf'll rtc-.Design values for all monitors are shown below in Table 2

- 1.

Table 2

- 1

. Design Values for All Monitors for all years ( EPA Concurred Exceptional Events Excluded )

Monitor 2002

- 2004* 2003

- 2005 2004

- 2006 2005

- 2007 2006

- 2008 2007

- 2009 2008

- 2010 2009

- 2011

Siskin

Drive/UTC (470654002) 14.7 15.0 15.1 15.3 14.3 12.7 11.6 11.1

Tombras

Avenue/ East Ridge (470650031) 15.7 16.1 15.5 15.3 14.0 12.6 11.6 11.2

Soddy

- Daisy

H igh School (470651011) 13.8 13.8 13.5 13.8 13.0 11.7 11.4 11.0

Walker County, G A (132950002) 15.5 15.5 15.2 15.8 15.2 13.0 10.7 *10.1

*Averaging period used by the EPA in the nonattainment area designation

Design values show attainment with the annual standard for 2007 through 2009, 2008 through 2010, and 2009 through 2011.



## 3.0 PERMANENT AND ENFORCEABLE EMISSIONS REDUCTIONS

In order to meet the standard, permanent and enforceable reductions of precursors for PM 2.5 and

of direct PM 2.5 wer e required. The major precursors of PM 2.5 in this area are sulfur dioxide, organic carbon, and nitrogen oxide s

.

Hamilton County industrial sources base year was 2007. All stationa ry sources are shown below:



### 3.1 Power Plants

Area wide power plants are major sources of PM 2.5 , Nitrates, and Sulfates. Emissions from Georgia Power plants are subject to Georgia Rule 391

- 3

- 1.02(2)(sss) which require reductions of

SO 2 and NO

x as well as direct PM 2.5 . The closest Tennessee coal

- fired power plants are the Widows Creek plant and the Kingston Steam plant. These plants are required to control both

Sulfate and Nitrate PM 2.5

.Industrial sources in the Hamilton County portion of the nonattainment area are subject to at

least RACT level controls for direct PM 2.5 and PM 2.5 precurso rs. Many of the industrial sources are subject to requirements of BACT. Industrial sources are regulated by existing local rules, Tennessee rules, and federal rules.

Automobiles and light trucks registered in Hamilton County are subject to the State of Tennessee Automobile Inspection and Maintenance Program. This rule requires annual vehicle inspections. The Inspection and Maintenance Program insures that high

- emitting vehicles are promptly repaired so that they meet the emissions standards for the speci fic vehicle. Annual On

- Board Diagnostic (OBD) testing is required for model years 2006 and newer. Older vehicles are subject to a tail pipe test. Open burning is also restricted by Rule 6 of the Chattanooga Air Pollution Control Ordinance. No open burning is allowed between May 1 and September 30.

The following Federal actions contribute to the improvement in air quality.

Tier 2 vehicle standards: In addition to NO

x controls, the Tier 2 rule also reduced the sulfur content of gasoline to thirty parts per million (30 ppm) starting in January 2006. Most gasoline sold in Tennessee prior to January of 2006 had a sulfur content of about 300 ppm.

Heavy

- duty diesel and gasoline vehicle standards: The second phase of standards and testing procedures, which began in 2007, will reduce particulate matter from heavy

- duty highway engines and will reduce highway diesel fuel sulfur content to 15ppm to avoid damage to emission control devices. This program is expected to reduce particulate emissions by 90%.

Non

- road spa rk

- ignition engine and recreational engine standards: Tier 1 of this standard was implemented in 2004 and Tier 2 started in 2007, and will reduce particulate matter emissions.

Large nonroad diesel engine standards: This standard was promulgated in 2004 a nd is being phased in between 2008 and 2014. This rule will also reduce sulfur content in nonroad diesel fuel. When fully implemented, this rule will also reduce NO

x and direct PM 2.5 emissions by over

90%.

As on road and non

- road vehicles are replaced, em issions from motor vehicles will continue to decrease since newer vehicles are subject to more stringent standards than older vehicles.

The combination of local, state, and federal actions resulted in the monitors demonstrating attainment today and in th e future.



## 4.0 EMISSION REDUC TIONS FROM GEORGIA

Table 4

- 1 shows the Georgia counties 2012 SO 2 e missions for this Area. The Georgia SIP showed the following quantities of SO 2 emissions from power plants located between Hamilton County and Atlanta . Georg ia Rule 391

- 3

- 1

- .02(2)(sss) required reductions of SO 2 from the

Bowen and Hammond coal

- fired power plants as shown in Table 4

- 1.Table 4

- 1 2002 and 2009 SO 2 Reductions from Bowen and Hammond Power Plants in Georgia

Power Plants 2002

S O 2 tpy 2009

SO 2 tp y 2002

- 2009

SO 2 tpy
Reductions

Bowen 153,848.8 83,349.3 70,499.7

Hammond 30,376.2 1,857.9 28,518.3

Total 184,225.0 85,207.2 99,017.8

The Hammond plant is located 55 miles from the Chattanooga speciation monitor which is

located at 35.050 degrees nort h and 85.2929 degrees west. The Bowen plant is located 67 miles from the speciation monitor. The speciation monitor is collocated with the Federal Reference

Monitor at the Siskin Drive/UTC site.

Effective December, 2008, reductions of SO 2 were required b y Georgia Rule SSS. Both the Hammond and Bowen plants were required to significantly reduce SO 2. Reductions in SO 2 resulted in reductions of Sulfates. The speciation monitor located at the University of Tennessee at Chattanooga at 35.050 degrees n orth and 85.2929 degrees w est shows a decrease in sulfates at the University of Tennessee at Chattanooga after the sulfur reductions occurred at the power plant.

The Widows Creek Power Plant is located in Jackson County Alabama. The power plant is 28.26

located mi les from the s p eciation monitor. Emissions of SO 2 and NO

x are as follows:

Table 4

- 2 Emissions from Widows Creek

2007 2017 2025

SO 2 32,803 10,515 10,515

NO

x 18,591 3,468 3,607

PM 2.5 755.49 534.89 534.89Table 4

- 3 Annual Sulfate Concent ration at the Chattanooga Speciation Monitor

Year μgram/m 3

2006 4.997

2007 5.532

2008 4.266

2009 2.816

2010 2.570

The speciation monitor shows a decrease in c oncentration of sulfate for 2009 and 2010, compared with 2006 and 2007 as a component of P M 2.5 . All of the FRM monitors also show

reductions of PM 2.5.



## 5.0 CONCLUSION AND REQUEST FOR REDESIGNATION

Based on the information presented in this document and in criteria established in Section 107(d)(3)(E) of the Clean Air Act, Tennessee is requestin g that USEPA redesignate Hamilton County to attainment. The monitors show that this area has attained the standard and the maintenance demonstration shows that the future inventories are expected to be lower than the attainment year inventory through the i mplementation of the various national, regional, and local

efforts.

In 1997, the US EPA promulgated the primary and secondary NAAQS for PM 2.5 . The annual standard was set at 15 micrograms per cubic meter and the daily standard was set at 65 micrograms per cubic meter. However, the daily standard was revised to 35 μgrams per cubic meters. The Chattanooga area is in attainment with the revised daily standard and has never been in nonattainment of the daily standard.

A violation of the annual PM 2.5 standard occurs when the annual average PM 2.5 concentration averaged over a three consecutive year period is equal or greater than 15.1 micrograms per cubic

meter. The annual PM 2.5 design value for a nonattainment area is the highest design value for any

monitor in that area.



### 5.1 1990 Clean Air Act Amendment

Since the 1977 amendments of the Clean Air Act (CAA), areas that had not attained the ambient standard, for a particular pollutant were formally designated as nonattainment for that pollutant.

This formal d esignation concept was retained in the 1990 CAA Amendments (CAAA). With the implementation of the PM 2.5 standard, areas could be designated under Section 172 of the CAAA (subpart 1) and have five years from designation to attain the standard. The effective date of the nonattainment designation for this was April 5, 2005 and was based on air quality monitoring for the years 2001, 2002, and 20035.2 Air Quality History

On January 5, 2005, EPA published the annual PM 2.5 nonattainment designation for the

Chatt anooga

- Tennessee

- Georgia area. The area consists of Hamilton County in Tennessee, Catoosa and Walker Counties in Georgia, and the portion of Jackson County in Alabama that is described as U.S. Census 2000 block group identifier 01

- 071

- 9503

- 1. Although Jack son County is not contiguous to the rest of the nonattainment area, a coal

- fired power plant located in this census tract is a major contributor to the PM 2.5 problem.



## 6.0 Air Quality

6.1 Air Quality (1999

- 2009)

There are 4 Federal Reference Monitors i n the nonattainment area. Locations of the monitors in

the nonattainment area are shown in Figure 2

- 1 . The speciation monitor is 67 miles from the

Bowen coal

- fired power plant and 55 miles from the Hammond coal

- fired power plant. The speciation monitor is located at the Siskin Drive/UTC site.



### 6.2 Recent Design Values (2007

- 2009 , 2008

- 2010 and 2009

- 2011 )

As shown in Table 2

- 1, the most recent three year design values of PM 2.5 monitoring data (2007

- 2009) as well as (2008

- 2010) demonstrate attainment with the annual fine particulate standard at

all of the monitors in this nonattainment area.

Permanent and Enforceable Emissions Reductions Local, State, and Federal measures have been enacted that provide for permanent and

enforceable emissions reductions to ensure that the PM 2.5 will continue to meet the standard at all

monitors in the area.

The federal measures that have been implemented include:

• Tier 2 vehicle standards : In addition to NO

x controls, the Tier 2 rule also reduced the sulfur content of ga soline to 30 parts per million (ppm) starting in January of 2009. Prior to the implementation of the low sulfur gasoline, the sulfur content of gasoline was 340 ppm in this

area.

• Heavy

- duty gasoline and heavy diesel highway vehicles standards : The sec ond phase of standards and testing procedures, which will reduce particulate matter from heavy

- duty highway engines, and will also reduce highway diesel fuel sulfur content to 15 ppm since sulfur damagesthe emissions control devices. The total program is expected to achieve a 90% reduction in particle from diesel vehicles.

• Non

- road spark

- ignition engines and recreational engine standards : Tier 1 of the standard was implemented in 2004 and Tier 2 started in 2007, and will continue to reduce particulat e matter
emissions.

• Large non

- road diesel engine standards : Promulgated in 2004, this rule is being phased in

between 2008 and 2014. The rule will also reduce sulfur content in non

- road diesel fuel. When fully implemented, this rule will reduce NO

x and direct PM 2.5 emissions by over 90%.

Georgia Power Plant Reductions

• The Georgia Rules for Air Quality Control Chapter 391

- 3

- 1 Rule(sss) “Multipollutant Control of Electric Steam Generating Units” required the following reductions of NO

x and SO 2 . By

D ecember 2008 emission controls were required to be installed and operational at the Bowen Plant in Bartow County and the Hammond Plant near Rome Georgia. Emissions of SO 2 were required to be reduced by 92,104 tons per year. An additional reduction of 19,32 8 tons of SO 2 reductions were achieved during the last 7 months of 2010. Further reductions of SO 2 and NO

x will continue through 2015 from Georgia power plants.

Tennessee Valley Authority

• The Kingston Steam Plant has been equipped with SO 2 scrubbers . This scrubber installation was operational in 2009 but was not modeled. Additional scrubbers were installed on 9 units in

2010.

Boiler Changes July 28, 2009 Federal Consent Order for INVISTA

• A Federal Consent order of July 28, 2009 required INVISTA to reduce emissions of SO 2 by 783 tons per year and 167 tons per year of NO

x. The reduction was implemented in a 2009 Consent Decree and has been incorporated in a Title 5 Air Permit issued April 19, 2010.

• To meet the requirements of the consent agree ment, INVISTA elected to replace the coal fired boilers with natural gas fired boilers. These emissions reductions were not modeled because the emissions were not recognized prior to the modeling. These allowable emissions were as

follows:

2007 SO 2 Emi ssions 566.81 TPY

2007 NO

x Emissions 316.67 TPY

2014 SO 2 Allowable Emissions 75.889 TPY

2014 NO

x Allowable Emissions 151.757 TPYThe 2009 emissions inventory was adjusted to reflect the consent decree requirements to reduce

SO 2 and NO

x totals above.



## 8.0 Maintenance Plan

8.1 Hamilton County Maintenance Plan

Hamilton County Tennessee’s plan for maintaining compliance with the ambient air quality standard for fine particulate consists of three components. The Chattanooga Air Pollution

Control ordinance established local air pollution control rules, and local adoption of existing federal requirements. Both Tennessee and Georgia have adopted rules in surrounding jurisdictions that are not in Hamilton County which will provide reductions of pollutants that will contribute to attainment in both the Tennessee and the Georgia portion of the nonattainment area. A maintenance plan and a contingency plan are also in place to insure that attainment is maintained. Federal and State rules that are implemented in Te nnessee and Georgia that are already in effect, as well as the future benefits of the federal engine programs, low sulfur gasoline, and low sulfur diesel fuel insure that attainment is maintained.

The Tennessee Department of Environment and Conservation, the Chattanooga

- Hamilton County Air Pollution Control Bureau, and the Georgia EPD have implemented enforceable requirements as well as contingency measures to ensure that maintenance with the standard will continue. Each jurisdiction that has contributed to attainment has developed enforceable rules that will ensure that the standard continues to be met. Sources are prohibited from increasing emissions (anti

- backsliding) following the redesignation of the area unless such a change is first approved by USEP A as a revision of the appropriate SIP that is consistent with Section 110(l) of

the Clean Air Act.

For the maintenance demonstration, the base year of 2009 was chosen since it falls within the attaining design value period of 2007

- 2009 and emission inve ntory data was developed for these years. The interim years that were chosen were 2010, 2013, 2016, 2019, 2022 , and 2025 since

the USEPA recommends three

- year increments. The final year of the m aintenance demonstration

is 2025 , since the Clean Air Act requ ires maintenance for at least ten years after redesignation.

The maintenance demonstration consists of a comparison between the 2007 baseline emissions inventory and the projected emissions i nventories (for 2010, 2013, 2016

, 2019, 2022, 2025 ),

which consid er economic and population growth as well as expected controls. The comparison shows that the total emissions in each of the interim years and the final year will be lower than the base year and therefore demonstrates maintenance of the annual PM 2.5 standa rd. The reductions in emissions are due to the emissions control programs discussed.

### 8.2 Existing Emissions Controls

The main element of the maintenance plan is the existing emission control program. This program implements the controls necessary to ma intain the ambient air quality standards. The purpose of the control program is to maintain the ambient air quality standards from being violated. Each component of the control program is essential to maintain the air quality

standards.

The control progr am consists of federal, state, and local measures. The federal measures include cleaner fuels, on and off road programs, and controls on power plants. State measures include the Tennessee Inspection and Maintenance program, and the CAIR rule. Georgia Air P ollution Controls including Georgia Rule SSS which requires reductions of NO

x and SO 2 . Local measures include open burning restrictions, gasoline station requirements for Stage 1 Vapor Recovery, VOC limiting rules, NO

x limiting rules, and SO 2 limits. All o f these programs have been implemented.



### 8.3 Federal Motor Vehicle Standards

**8.3.1 Tier 2 Passenger Vehicle Standards**

Federal Tier 2 vehicle standards require all passenger vehicles in a manufacture’s fleet, including light

- duty trucks and sport utility v ehicles (SUVs) to meet an average standard of 0.07 grams per

NO

x . Implementation began in 2004, with full compliance required by 2007. Tier 2 Standards also apply to passenger vehicles over 8,500 pounds gross vehicle weight that are not covered by

Tier 1 r ules. For these vehicles, the standards were phased in beginning in 2008 with full compliance required by 2009. Sulfur in gasoline has also been reduced from approximately 350 ppm to 30 ppm starting in January 2006. Lower sulfur gasoline is necessary to ac hieve the Tier 2

vehicle emission standards.



### 8.3.2 Heavy Duty Gasoline and Diesel Highway Vehicle Standards

Implementation of USEPA standards designed to reduce NO

x and VOC emissions from heavy

duty gasoline and diesel vehicles began in 2004. The second phase of the standards and testing procedures began to take effect in 2007 and reduces particulate from heavy duty highway engines. Diesel fuel with a sulfur content of 15 ppm will be required for these vehicles. Use of the new low sulfur diesel fuel comp ared to emissions from engines using diesel fuel with higher

sulfur levels will achieve a 90% reduction in PM emissions and a 95% reduction in NO

x emissions.

### 8.3.3 Large Non

**- road Diesel Engines Rule** 

In May 2004, the USEPA promulgated new rules for large non

- road diesel engines, such as those used in construction, agricultural, and industrial equipment, to be phased in between 2008 and

2014. The non

- road diesel rules also reduce the allowable sulfur in non

- road diesel fuel by more

than 99%. Prior to the f uel standard change, nonroad diesel fuel averaged about 3400 ppm sulfur. The rule limited nonroad diesel fuel sulfur content to 500 ppm by 2006 and requires the sulfur content to be limited to 15 ppm by 2010. The combined engine and fuel rules are expected to
reduce NO

x and PM emissions from large nonroad diesel engines by more than 90% compared to current nonroad engines using higher

- content sulfur diesel.



### 8.3.4 Non

**- road Spark** 

**- Ignition Engines and Recreational Engines Standard** 

The non

- road spark

- ignition and recreational engine standards, effective in July 2003, regulates

NO

x , hydrocarbons and CO for groups of previously unregulated nonroad engines. These standards apply to all new engines sold in the United States and imported after these standards began and applies to large spark

- ignition engines (forklifts and ground service equipment) recreational vehicles (off

- highway motorcycles and all terrain vehicles) and recreational marine diesel engines. The regulation varies based upon the type of engine or ve hicle.

Emissions from large spark

- ignition engines contribute to ozone formation and ambient CO and PM levels in urban areas. Tier 1 of this standard was implemented in 2004 and Tier 2 started in 2007. Like the large spark

- ignition engines, recreational vehicles contribute to ozone formation

and ambient CO and PM levels. For the off

- highway motorcycles and all

- terrain

- vehicles, the exhaust emissions standard was phased in. Fifty percent of model year 2006 engines had to meet the standard. All engines from model year 2007 and newer must meet the standard. Recreational marine diesel engines over 37 kilowatts are used in yachts, cruisers, and other types of pleasure craft. Recreational marine engines contribute to ozone formation and PM levels, especially in marinas. Depending on the size of the size of the engine, the standard began phasing

- in in 2006.

When all of the nonroad spark

- ignition and recreational engine standards are fully implemented, an overall 72% reduction in HC, 80% reduction in NO

x , and a 5 6%reduction in CO emissions are expected by 2020. These controls will help reduce ambient concentration of ozone, CO, and

PM 2.5



### 8.4 TRANSPORT RULES

In October 1998, the USEPA made a finding of significant contribution of NO

x emissions from

Tennessee and other South Eastern States and published a rule that set ozone season (May to September) NO

x budgets to reduce regional ozone transport. Reductions of NO x, which is a PM 2.5 precursor, were 59,414 tons per ozone season in Tennessee between 2003 and 2005.

### 8.5 ADDITIONAL PROGRAMS SUPPORTING MAINTENANCE

The Chattanooga Air Pollution Control Ordinance prohibits open burning between May 1 and September 30 and when air quality is forecast ed to be Code Orange or higher. Pollution Solution is a public outreach and education program of the Hamilton County Air Pollution Control Bureau. The goal of the program is to reduce air pollution by voluntary actions. The program is activated when the Air Quality Index is predicted to be greater than 100. On air quality alert d ays, information is sent to more than 80 individuals, government employees, daycares, gyms, hospitals, health care facilities, schools and police and fire departments. Information is communicated to 6 TV stations, 21 radio stations and 4 print publications . In addition, 15 billboards are located throughout the county to make people aware of high levels of

ozone and PM 2.5

Through the Chamber of Commerce, and the Chattanooga Manufacturing Association employers also are notified of high pollution levels.



## 9.0 Emissions Inventories and Maintenance Demonstration

To demonstrate continued maintenance the projected emissions inventory is compared to the baseline emissions inventory. The approach used for this demonstration is the comparison of

emission s inventorie s for the years 2007 and 2025

.

For the maintenance demo nstration, the base year of 2007 was chosen and emissions inventory data was developed for this year. The maintenance demonstrati on is made by comparing the

2007 emissions inventory to the 2025 proje cted emissions inventory. If the projected emissions remain at or below baseline emissions, then the amb ient air quality standard will not be violated in the future. In addition to comparing the final year of the plan, all of the interim y ears are compared to the 2007 baseline to demonstrate that these years are also expected to show continued maintenance of the fine particulate matter standard.

Section 175A(d) of the Clean Air Act requires contingency provisions. The contingency provisions are available to provide 157 tons per year and for 503 tons per year.

The emissions inventories are comprised of four major types of sources: point, area, on

- road mobile, and nonroad mobile. The projected emissions inventories have been estimated using projected rates of growth in population, traffic, economic activity, expected control programs, and other parameters. Naturally occurring, or biogenic, emissions are not included in the emissions inventory comparison, as these emissions are out of the agency span of contr ol.

9.1 Emission Inventories and Motor Vehicle Emissions Budget

The baseline year i s 2007 . Three year e missions were developed for 2007(baseline), 2010, 2013, 2016, 2019, 2022, and 2025

.Stationary source emissions were grown using EGAS 5.0 factors. E GAS factors were also used

for area sources. Nonroad emissions were derived from running the nonroad model.

There are four different man

- made emission inventory classifications: (1) stationary point, (2) area, (3) on road mobile and (4) nonroad mobile sources.

Stationary Po int sources are those sources that require an air permit to operate. In general, these

sources have a s ignificant potential to emit NO x, PM 2.5 , and SO 2 from a single facility. The

source emissions are tabulated f rom data collected b y direct measurement of emissions or mass balance calculation utilizing emission factors from the USEPA’s AP

- 42 or other calculation

methods. S everal emission sources are often located at a n industrial facility. Emissions data is collected for each point source at a facility and the data is entered into an in

- house database

system.

Area Source s are facilities that are smaller sources such as dry cleaners, automobile repair facilities, small machine shops etc. The facility usually totals the facilities

.

Nonroad road sources are construction equipment, railroads, boats, lawn equipment

, etc. Most nonroad equ ipment emissions are calculated from the non

- road model. EPA Nonroad2008 is the

current EPA nonroad model. The model is EPA

- 420

- F

- 09

- F

- 09

- 021 dated 2009

.

MOVES 2010b is the current version of MOVES EPA model dated March 2012. The MPO provided inputs to the MOVES model.

The following show s emissions from Point Sources, Area Sources, Nonroad Sources, and

Onroad sources for NO

x , and PM 2.5. The SO 2 is less than 60 tons per year in any year. Also SO 2 continues to decrease each year. By 2025

, SO 2 shows only 20 tons per year

.

Table 9

- 1 Projected NO X (tons/year)

2007 2010 2013 2016 2019 2022 2025

Point 2,437 2,484 2,576 2,651 2,812 2,982 3,155

Ar ea 3,415 3,638 3,835 4,090 4,349 4,609 4,881

Nonroad 1,792 1,563 1,264 1,003 834 731 675

Onroad 8,308 7,390 6,472 5,554 4,635 3,717 2,799

Total 15,952 15,075 14,147 13,297 12,629 12,039 11,509Table 9

- 2 Projected SO 2 (tons/year)

2007 2010 2013 2016 2019 2022 2025

Point 919 798 808 798 819 842 866

Area 333 347 363 383 401 421 441

Nonroad 99 26 15 14 15 15 16

Onroad 59 54 49 43 38 33 28

Total 1,410 1,224 1,235 1,238 1,273 1,311 1,350

Table 9

- 3 Projected PM 2.5 (tons/year)

2007 2010 2013 2016 2 019 2022 2025

Point 160 156 158 169 181 193 206

Area 875 917 956 1,001 1,043 1,084 1,122

Nonroad 154 142 124 101 82 70 64

Onroad 255 229 203 117 151 124 98

Total 1,444 1,443 1,440 1,448 1,456 1,472 1,490

Safety Margin

A safety margin is the differ ence between the attainment level of emissions from all categories (i.e., point, area, onroad mobile, nonroad) and the projected level of emissions from all source categories. The safety margin s are as show n in Table 9

- 4.

Table 9

- 4 Safety Margin (tons/ye ar)

Year NO X SO 2 PM 2.5 2007 15,952 1,410 1,444

2010 15,075 1,224 1,443

2013 14,147 1,235 1,440

2016 13,297 1,238 1,448

2019 12,629 1,273 1,457

2022 12,039 1,311 1,472

2025 11,509 1,350 1,490

Differences from

2007 to 2025 (Safety Margin) 4,443 60 46The projected NO X emissions reduction is 4,443 tons from 2007 to 2002 . In addition, overall

SO 2 emissions are projected to decrease by 60 tons for this period, and the slight projected

increase in PM 2.5 emissions over this period is 46 tons.

10

- 1 M otor Vehicle Emissions Budget

Pursuant to the EPA transportation conformity rule at 40 CFR Part 93, specific emission budgets are hereby defined for the on

- road mobile source portion of the emissions inventory. These budgets are to be used by the transpo rtation authorities to assure that transportation plans, programs, and projects are consistent with, and conform to, the maintenance of acceptable air quality in the Hamilton County mai ntenance plan is 2025. Motor Vehicle Emissions Budg ets (MVEB) for 2007 and 2025 will be set for PM 2.5 and NO

x by the Air Pollution Board

.

Table 10

- 1

Total Motor Vehicle Emissions In tons per year

2007 2025

NOx 8308 2 799

PM 2.5 255 98

The MVEB reflect s the total on

- road emissi ons for the MVEB years 2007 and 2025

, plu s an allocation from the availabl e NO

x and PM 2.5

. The Air Pollution Control Board will determine Mobile Vehicle Emissions budgets. A portion of the safety margin may be allocated for transportation emissions

.

The MVEB are consist with the plan for maintai ning total emissions from all source categories

at or below the 2007 NO

x and PM 2.5 emissions levels through the year 2025. For future conformity determinations, transportation authorities should rely on the above MVEB unless the maintenance plan is revise d

.

10

- 2 Contingency Measures

The con tingency requirement is met by replacing t he coal boilers with natural gas boilers that will use No. 2 fuel oil as a backup

. The new boilers are projected to reduce the NO X and SO 2 emissions by 157 .0 tons per year and 502.8 tons p er year. The new boilers are projected to emit

3 7

. 0 tons per year of NO X and 27. 2 tons per year of SO 2

. These are surplus and available to use for use as the contingency measure.

10

- 3 Plan to Maintain Air Quality

The Chattanooga

- Hamilto n County Air Pollution Control Bureau , the state of Alabama, the state of Georgia, and the state of Tennessee have implemented programs that will remain enforceable and are submitted as the plan to ensure that maintenance of the annual PM 2.5 standard willcontinue. Sources are prohibited from reducing emission controls (“anti

- backsliding”) following the redesign a tion of the area unless such a change is first approved by the EPA as a revision to the Hamilton County SIP , the state of Alabama SIP, the state of Georgia SIP, and the state of

Tennessee that is consistent with Section 110(l) of the CAA.

The following regulatory programs will remain in place in the Chattanooga Non

- attainment

Area:

Chattanooga Air Pollution Air Pollution Control Ordinance

Hami lton County Air Pollution Control Regulation

Collegedale Air Pollution Control Ordinance

East Ridge Air Pollution Control Ordinance

Lakesite Air Pollution Control Ordince

Lookout Mountain Air Pollution Control Ordinance

Red Bank Air Pollution C ontrol Ordinance

Ridgeside Air Pollution Control Ordinance

Signal Mountain Air Pollution Control Ordinance

Soddy

- Daisy Air Pollution Control Ordinance

Walden Air Pollution Control Ordinance

Federal Tier II Motor Vehicle Emissions Standards

Fe deral On

- road Diesels Engine 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 Fe deral NO

x SIP CallGeorgia Rules for Air Quality Control Chapter 391

- 3

- 1 Rule (sss) “ Multipollutant Control of Electric Steam Generating Units”

The federal fa cilities compliance agreement be tween EPA and the Tennessee Valley Authority,

Docket No. CAA

- 04

- 2010

- 1760 requiring TVA Widows Creek to retire Units 1

- 6. The compliance dates for this action are staggered as follows:

2 units by July 31, 2013; 2 units by July 31, 2014; 2 units by July 31, 2015.

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

x and 28,192 tons per year of

SO 2 . The consent decree further required year

- round operation of the SCRs on Units 7 and 8.