2011 Emissions Inventory

and

Stationary Point Source Emission Inventory Statements

for

Shelby County Tennessee

Required by the

2008 Ozone National Ambient Air Quality Standard

for

Marginal Nonattainment Areas

Prepared by the

Shelby County Health Department

Pollution Control Section

Air Planning Branch

814 Jefferson Avenue

Memphis, Tennessee 38105

July 17, 2014
i

TABLE OF CONTENTS

Introduction ......................................................................................... 1

Point Source Emission Inventory ............................................................. 1

Point Source Emission Statements ............................................................. 1

NonPoint Sources ............................................................................... 2

NonRoad Sources ................................................................................ 2

NonRoad Equipment ...................................................................... 2

Commercial Marine Vessels (CMV)............................................................ 2

Locomotives ............................................................................... 2

Aircraft and GSE ................................................................................ 2

OnRoad Sources ................................................................................ 3

Biogenic Sources ................................................................................ 6

Summary .......................................................................................... 6

ATTACHMENTS

Attachment 01 - Shelby County 2011 Point Source Emission Inventory Summary and Questionnaires

Attachment 02 - Shelby County 2011 Point Source Emission Statements

Attachment 03 - Shelby County Local Reporting Requirements

Attachment 04 - Shelby County 2011 NonPoint Emissions Inputs and Estimates

Attachment 05 - Shelby County 2011 NonRoad Equipment (NONROAD2008a) Emissions Inputs and 

Estimates

Attachment 06 - Shelby County 2011 NonRoad Commercial Marine Vessel (CMV) Emissions Inputs

and Estimates

Attachment 07 - Shelby County 2011 NonRoad Locomotive Emissions Inputs and Estimates

Attachment 08 - Shelby County 2011 NonRoad Aircraft and Ground Service Equipment (GSE) 

(Emissions and Dispersion Modeling System, Version5.1) Emissions Estimates

Attachment 09 - Shelby County 2011 OnRoad (MOVES2010b) Emissions Inputs and Estimates

Attachment 10 - Shelby County 2011 Biogenic (BEIS3.14) Emissions Inputs and Estimates

Attachment 11 - Shelby County Quality Assurance Project Plan (QAPP)

Attachment 12 - Shelby County 2011 Area Source Emissions Inventory Calculation Methodology

Attachment 13 - Shelby County 2011 Emissions Inventory Summary
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1

INTRODUCTION

The 2008 Ozone (O3) National Ambient Air Quality Standard (NAAQS) of 0.075 parts per million (ppm) 

was finalized effective May 27, 2008 (Federal Register, March 27, 2008). As a result, the Memphis TNMS-AR Metropolitan Statistical Area (MSA) was designated as a marginal non-attainment area of the 

2008 O3 NAAQS, effective July 20, 2012 (Federal Register, May 21, 2012). The Tennessee portion of 

the MSA consists of Shelby County. The EPA proposed state implementation plan (SIP) requirements in 

the Federal Register on June 6, 2013. The proposed rule requires that marginal non-attainment areas 

submit an O3 precursor (volatile organic compounds (VOC) and nitrogen oxides (NOX)) emission 

inventory and stationary point source emission inventory statements by July 20, 2014. According to draft 

emissions inventory guidance for implementation of the O3 NAAQS developed by the EPA and dated 

April 11, 2014, formal attainment SIPs are not required for marginal nonattainment areas (see page 42 of 

that document). This document was received by the Shelby County Health Department-Pollution Control 

Section (SCHD-PCS), on May 13, 2014.

Hard copies of some large files in various source categories are provided in the documents submitted 

showing only the first and last pages of those files. However, all files in their entirety are provided in 

electronic form on CD‟s and in email transmissions.

POINT SOURCE EMISSION INVENTORY

Prior to receipt of the guidance noted above, calendar year 2011 was chosen by the SCHD-PCS Air 

Planning Branch as the base year inventory to represent Shelby County emissions in response to the 2008 

O3 NAAQS requirements. 2011 is the “first three-year cycle inventory” as defined in the Code of Federal 

Regulations (CFR), 40CFR51.30(b)(1), and has been submitted for Shelby County into the National 

Emission Inventory (NEI) following Air Emissions Reporting Rule Requirements (AERR) (Federal 

Register, December 17, 2008). Shelby County point source emission inventory questionnaire‟s with

associated technical data can be found in Attachment 01. Although the Marginal air quality design value 

for Shelby County is based upon 2008-2010 air quality data, the 2011 Point Source inventory is 

considered a near replication of emissions that occurred during each of those three years. As the 

population for Shelby County has remained essentially static during this time at 927,644 people in 2010 

and 935,388 (a 0.1% increase) in 20111, other emission source categories are also believed to be well 

represented by 2011 emission activity. Major stationary sources with actual emissions of at least 100 tons

per year of NOx or VOC are included in the inventory. CO actual emissions of greater than 100 tons per 

year were not used as part of the selection process. CO emissions from those sources selected due to the 

NOx and VOC criteria were included in the inventory. Having included CO emissions in the point source 

category, CO emissions in other source categories were also input into the overall inventory.

POINT SOURCE EMISSION STATEMENTS

Point source certified emission statements found in Attachment 02 are required in each of the 

Shelby County municipalities and in unincorporated Shelby County. Requirements to make these 

certifications are found in Attachment 03. Certified emission statements are made by the point 

sources upon payment of emission fees and other assessments on a year by year basis. 

Certifications are also made with the submittal of the Emission Inventory Questionnaire‟s found 

in Attachment 01.

 

1

Per the United States Census Bureau, Shelby County population for calendar years 2008 through 2011 were 

919,137; 920, 232; 927,644; and 935,088.
2

NONPOINT SOURCES

The April 11, 2014 EPA emission inventory guidance specifically requests that emissions from prescribed 

burning be included in the emission inventory. „Land clearing to construct‟ is a form of prescribed 

burning specific to Shelby County and is considered as a representation of the prescribed burning 

mentioned in the guidance. It is included as part of the NonPoint Source Category. That guidance also 

mentioned that high electricity demand (HEDD) days be addressed. This category has not been 

specifically developed for Shelby County as the TVA- Allen Fossil Plant (TVA) is included in the point 

source inventory and essentially is run at maximum capacity throughout the summer and year. Additional 

electrical demand is provided by the power grid such that additonal emissions are not generated locally. 

Combustion turbines located at TVA are operational but are not used for peaking demand due to the 

inherent cost of distillate fuel and the high emissions associated with their operation. Emissions in this 

category have been verified against the point source category such that there is no double counting of 

emissions as can best be determined. Inputs and estimates for this category are found in Attachment 04.

NONROAD SOURCES

The transportation infrastructure in Shelby County (International Port of Memphis, the five Class I and 

one passenger railroads, and the International Airport (MEM)), provides for the transport of supplies,

products, and passengers into and out of Shelby County and the MSA/region. Consequently, the 

„pollutant burden‟ should likely be „shared‟ throughout the MSA in some way that is more representative,

based on not just the location of the burden, i.e. the Port, the railroads and switchyards, and the MEM, but 

also because of the reason for the burden.

NONROAD EQUIPMENT

NonRoad equipment emissions are generated by the NONROAD2008a model. Other nonroad 

categories follow. These emissions were generated for a typical ozone season day. Inputs and 

estimates for this sub-category are found in Attachment 05.

COMMERCIAL MARINE VESSELS (CMV)

CMV emission estimates are generated by the PCS-Air Planning Branch and incorporated data 

from the United States Corps of Engineers Waterborne Commerce Tables for the Port of 

Memphis, Tennessee. It should be noted that total emissions for CMV are accounted for in this 

inventory but that approximately fifty percent (50%) should be assigned to Crittenden County, 

Arkansas, along with other considerations. Inputs and estimates for this sub-category are found 

in Attachment 06.

LOCOMOTIVES

Locomotive emission estimates are generated by the PCS-Air Planning Branch and incorporated 

data provided by five Class I Railroads, 1 small railroad, and 1 passenger railroad, and associated 

switchyards serving the MSA/region, with the exception Canadian National and Norfolk Southern 

Railroads, whose emissions for 2006 were grown to obtain estimates for 2011. Inputs and 

estimates for this sub-category are found in Attachment 07.

AIRCRAFT AND GSE

The EPA now includes airport (aircraft and GSE) emissions in the point source category of the 

National Emissions Inventory (NEI). Nevertheless, because of it‟s association with mobile 

sources it is being included in the nonroad emission category. Estimates were developed by EPA 
3

using the Emissions and Dispersion Modeling System, Version5.1 (EDMS5.1). Estimates for this 

sub-category are found in Attachment 08.

ONROAD SOURCES

MOVES inputs were developed in accordance with guidance provided in EPA document 420b12028, 

titled “Using MOVES to prepare EIs for SIP and Conformity”. Discussions on these inputs are presented 

below.

Meteorology data used for this analysis was based on local information obtained from NOAA data at the 

Memphis International Airport (MIA) and was adapted for MOVES using the EPA conversion tool.

Temperature – The minimum and maximum daily temperature estimates of 73F and 97F, respectively, 

were derived from temperatures recorded over a three year period on the ten highest ozone exceedance 

days. These values have been relied upon in previous state implementation plans and were determined to 

be appropriate for use in the ozone season through the interagency consultation group (IAC) process.

Reid Vapor Pressure (RVP) – 7.8 pounds per square inch (psi) was used as 40 CFR 80.270, titled 

“Controls and Prohibitions on Gasoline Volatility”, indicates it is the ozone season regulatory maximum 

RVP for Shelby County, Tennessee. This value has been relied upon in previous state implementation 

plans and was determined to be appropriate for use in ozone season through the interagency consultation 

group (IAC) process.

Humidity – In a pre-analysis consensus IAC discussion and as recorded in a May 17, 2013 memorandum, 

TDEC provided three-year average data from the MIA for the month of July, including hourly 

temperatures and relative humidity (see the table below). The consensus assumed the meteorological 

MIA data could be applied throughout the entire modeled area of Shelby County.

Hourly Temperature and Relative Humidity Values

monthID hourID temperature relHumidity hourID temperature relHumidity

7 1 78.2 78.1 13 94.1 56.0

7 2 76.8 79.9 14 96.1 54.1

7 3 75.7 81.8 15 96.8 52.7

7 4 74.9 82.9 16 97.0 52.5

7 5 74.3 84.3 17 96.5 52.8

7 6 73.6 85.4 18 95.1 54.1

7 7 73.0 84.9 19 92.7 57.2

7 8 73.5 79.7 20 89.6 62.3

7 9 76.5 73.3 21 86.5 67.3

7 10 81.3 67.7 22 83.8 71.1

7 11 86.2 62.7 23 81.9 74.4

7 12 90.4 59.1 24 80.0 76.4

Source Type Population: MOVES default was used as a starting point for all source types. The MOVES 

Technical Guidance offers guidance on how to leverage default population and VMT data alongside local 

VMT data to arrive at an estimate of the local population. This guidance suggests comparing the ratio of 

default source type population to default VMT to the local VMT to arrive at an estimate of local source 

type population.

Age Distribution: Used Shelby County, TN-specific data obtained from the UTK paper “Tennessee 

Traffic Data for Estimating Air Pollution Emissions in 2002” and an EPA converter to change 

MOBILE6-formatted information to MOVES format.
4

Vehicle Type VMT and VMT Fractions: This information, data was pulled from available travel demand 

models or from regional HPMS data.

HPMS Vehicle Class VMT – The HPMS vehicle class VMT was determined using the pre-processor 

developed within the travel demand model. The travel demand model classifies vehicles into 

automobiles, single unit trucks, and combination unit trucks. The three vehicle classes in the model were 

divided into the six HPMS vehicle class types through the pre-processor. Since the travel demand model 

produces daily weekday volumes, the EPA conversion tool was used to convert these daily VMT numbers 

to annual values.

Daily VMT Fraction – The University of Tennessee developed county-specific daily VMT fractions, 

which were applied in this analysis. This information was provided in a format appropriate for use in 

MOVES.

Monthly VMT Fraction – The University of Tennessee developed county-specific monthly VMT 

fractions, which were applied in this analysis. This information was provided in a format appropriate for 

use in MOVES.

Hourly VMT Fraction – The hourly VMT fraction was determined using the pre-processor developed 

within the travel demand model. To produce the information needed for the MOVES input file, the three 

vehicle classes in the model were expanded to the 13 MOVES vehicle source types. In addition, the four 

time of day periods in the model were expanded to represent each hour of the day. The default mix of 

off-network hourly distribution percentages was used for all vehicle classes.

The following table displays the Shelby County annual VMT produced by the MOVES VMT converter 

by source type and by year.

Shelby County Annual VMT by Source Type and by Year

Source Type Source 

Type ID

Source Type 

VMT

2011

Motorcycle 11 14960.02

Passenger Car 21 430119.28

Passenger Truck 31 137966.55

Light Commercial Truck 32 46092.29

Intercity Bus 41 592.73

Transit Bus 42 306.64

School Bus 43 4015.84

Refuse Truck 51 237.92

Single Unit Shorthaul Truck 52 17040.8

Single Unit Longhaul Truck 53 2247.58

Motor Home 54 3956.38

Combination Short-haul Truck 61 3326.07

Combination Long-haul Truck 62 4051.69

Total 664913.78
5

Average Speed Distribution: The average speed distribution was determined using the pre-processor 

developed within the travel demand model. The vehicle classes in the model were expanded to the 13 

MOVES vehicle source types, and the hourly distribution was expanded from the four time periods in the 

model to each hour of the day.

Road Type Distribution: The road type distribution was determined using the pre-processor developed 

within the travel demand model. The vehicle classes in the model were expanded to the 13 MOVES 

vehicle source types

Ramp Fraction: The ramp fractions were determined using the pre-processor developed within the travel 

demand model.

Fuel Supply and Fuel Formulation: MOVES default data for Shelby County (obtained from the MOVES 

program) was used for analysis year 2011.

Fueltype and Technologies/Alternative Fuel Vehicle Types: If no information is entered for AVFT, 

MOVES assumes a default mix of alternative fuels. The MOVES default mix assumes a small percentage 

of compressed natural gas (CNG) transit buses. Since there are no CNG buses in the transit fleet for 

Shelby County, the default value for this file was modified to reflect only diesel and gasoline fuel types.

Inspection and Maintenance (I/M) Programs: The compliance factors in these files were adjusted to 

reflect not only participation within the City of Memphis, but also Shelby County as a whole. As stated 

in the EPA MOVES Technical guidance, this methodology can be used to avoid conducting two sets of 

runs that are then interpolated outside of MOVES.

The IM Compliance Factor used in this analysis was determined in accordance with section 3.10.6 of the 

MOVES Technical Users Guide, which states that this factor “accounts for I/M program compliance 

rates, waiver rates, and adjustments needed to account for the fraction of vehicles within a source type 

that are covered by the I/M program”. For Shelby County the Compliance Factor is defined by the 

following equation:

Compliance Factor = percent compliance rate times (100 percent minus the percent waiver rate) times 

(regulatory class coverage adjustment percentage)

where,

1. percent compliance rate is the percentage of vehicles in the fleet covered by the I/M program 

that complete the I/M program and receive either a certificate of compliance or a waiver.

2. percent waiver rate is the percentage of vehicles that fail an initial I/M test and do not pass a 

retest, but do receive a certificate of compliance.

3. regulatory class coverage adjustmen percentage is percentage of vehicle miles traveled (VMT) 

by the various regulatory weight classes within a source type. Default adjustments are provided 

in Table A.3, pages 46-47, EPA-420-B-10-023, April 2010.

The components of the compliance factor were developed with the guidance outlined above, and then, the 

result was multiplied by the percentage of vehicles covered by the I/M program (I/M split). The SCHDPCS compliance factor is defined by the following equation:
6

SCHD-PCS Compliance Factor = IM Split x (Compliance Rate x (1 - Wavier Rate) x Regulatory Class 

Coverage Adjustment)

For example:

Sample Calculation for sourcetype 11:

SCHD Compliance Factor = 0.6149 x (0.9336 x (1 – 0.0001) x 1.00) = 0.5740 or 57.40%

Sample Calculation for sourcetype 21:

SCHD Compliance Factor = 0.6149 x (0.9336 x (1 – 0.0001) x 1.00) = 0.5740 or 57.40%

Sample Calculation for sourcetype 31:

SCHD Compliance Factor = 0.6149 x (0.9336 x (1 – 0.0001) x 1.00) = 0.5740 or 57.40%

Sample Calculation for sourcetype 32:

SCHD Compliance Factor = 0.6149 x (0.9336 x (1 – 0.0001) x 1.00) = 0.5740 or 57.40%

Sample Calculation for sourcetype 42:

SCHD Compliance Factor = 0.6149 x (0.9336 x (1 – 0.0001) x 0.50) = 0.2870 or 28.70%

Sample Calculation for sourcetype 43:

SCHD Compliance Factor = 0.6149 x (0.9336 x (1 – 0.0001) x 0.50) = 0.2870 or 28.70%

Sample Calculation for sourcetype 51:

SCHD Compliance Factor = 0.6149 x (0.9336 x (1 – 0.0001) x 0.50) = 0.2870 or 28.70%

Sample Calculation for sourcetype 52:

SCHD Compliance Factor = 0.6149 x (0.9336 x (1 – 0.0001) x 0.49) = 0.2812 or 28.12%

Sample Calculation for sourcetype 53:

SCHD Compliance Factor = 0.6149 x (0.9336 x (1 – 0.0001) x 0.48) = 0.2755 or 27.55%

Sample Calculation for sourcetype 54:

SCHD Compliance Factor = 0.6149 x (0.9336 x (1 – 0.0001) x 0.50) = 0.2870 or 28.70%

Sample Calculation for sourcetype 61:

SCHD Compliance Factor = 0.6149 x (0.9336 x (1 – 0.0001) x 0.48) = 0.2755 or 27.55%

Inputs and estimates for this sub-category are found in Attachment 09.

BIOGENIC SOURCES

Biogenic emissions were generated by the EPA using the most current model, BEIS5.14. Estimates for 

this sub-category are found in Attachment 10.

SUMMARY

The 2011 emission inventory necessitated by the 2008 Ozone NAAQS for the precursors of ozone, NOx 

and VOC, in marginal nobnattainment areas are shown in the following table. CO is also included in that 

table although it is not believed to be a presursor of ozone. The emissions represent ozone season days.
7

SHELBY COUNTY TENNESSEE 2011 EMISSION INVENTORY SUMMARY

Category Sub-Category

Ozone Season (OS)

Emissions

(tons per day)

NOx CO VOC

Point 1Total Point 18.3 14.43 9.49

NonPoint 4

Prescribed Burning *0.12 5.09 2.78

Other NonPoint 4.41 7.07 45.34

Total NonPoint 4.53 12.15 46.88

NonRoad

NonRoad Equipment - Total ** , 5 11.44 158.42 12.61

Commercial Marine Vessels (CMV) 

6 3.72 0.7 0.08

Locomotives 75.39 0.82 0.3

Aircraft *** , 8 8.68 12.76 2.11

Total NonRoad 29.24 172.7 15.09

OnRoad 9Total OnRoad 37.9 167.93 16.11

Biogenic **** , 10 Total Biogenic 1.35 9.61 80.01

Total All Categories 91.32 376.82 167.58

 * - Land Clearing to construct (Prescribed Burning) is included in this category

 ** - NonRoad Equipment emissions generated by the NONROAD2008 model

 *** - Aircraft emissions generated by the EPA using the Emissions Dispersion Modeling System (EDMS)

 **** - Biogenic emissions generated by the EPA using the most current BEIS model

Footnotes 1 and 4 through 10 - See Attachments 01 and 04 through 10 found in the emission inventory document for detailed Category inputs and outputs