## 2011 Emissions Inventory

a nd Stationary Point Source Emission Inventory Statements

for Shelby County Tennessee

Required by the 2008 Ozone National Ambient Air Quality Standard

for Marginal Non a ttainment Areas

Prepared by the Shelby County Health Department

Pollution Control Section Air Planning Branch

814 Jefferson Avenue Memphis, Tennessee 38105

Ju ly 17 , 2014i TABLE OF CONTENTS

I ntroduction

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

Point Source Emission Inventory

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

Point Source Emission Statements

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

NonPoint Sources

... .......... ....................................... ............... ............ 2

Non R oad Sources

............ ... ....................................... .......... ................ 2

Non R oad Equipment

... ... ................................................... .......... ... 2

Commercial Marine Vessels (CMV)

............................................................ 2

Locomotives

.................................................................. ... ...... .... 2

Aircraft and GSE

............................................................ ..... . .............. 2

OnR oad 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 Non R oad E quipment (NONROAD2008a) Emissions Input s and

Estimates

Attachment 06

- Shelby County 2011 NonRoad Commercial Marine Vessel (CMV) Emissions Input s

and Estimates

Attachment 07

- Shelby County 2011 NonRoad Locomotive Emissions Input s 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 Co unty 2011 On R oad (MOVES2010 b ) Emi ssions Input s and Estimates

Attachment 10

- Shelby County 2011 Biogenic ( BEIS 3.14 ) Emissions Input s 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 Summaryi1

INTRODUCTION

The 2008 Ozone (O 3 ) 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 TN

MS

- AR Metropolitan Statistical Area (MSA) was des i gnated as a marginal non

- attainment are a of the

2008 O 3 NAAQS, effective July 20, 2012 (F ederal Register, May 21, 20 12 ). 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 propos ed rule requi res that marginal non

- attainment areas

submit an O 3 precursor (volatile organic compounds (VOC) and nitrogen oxides (NO X )) emission inventory and stationary point source emission inventory statements by July 20, 2014. According to draft

emissions inventory guidance for implementation of the O 3 NAAQS developed by the EPA and dated April 11, 2014, f

ormal attainment SIP s are not required for marginal nonattainment areas (see page 42 of that document)

. This document was received by the Shelby County H ealth Department

- Pollution Control

Section (SCHD

- PCS) , o n May 1 3 , 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 EMISSIO N 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 repre sent Shelby County emissions in response to the 2008

O 3 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

Em ission 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 2011 1 , other emission source categories are also beli e ved to be well represented by 2011 emission activity. M aj or stationary sources wit h actual emission s 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 s elected 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 in to the overall inventory.

POINT SOURCE EMISSIO N STATEMENTS

Point s ource certified emission statements found in Attachment 02 are required in each of the Shelby County municipalities and in unincorporated Shelby County

. R equirements to make these

certifications are found in Attachment 0 3 . 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 93 5,088.2

NONPOINT SOURCES

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

b urning be included in the emission inventory. „ L and c learing to construct ‟ is a form of prescribed burning sp ecific to Shelby C ounty and is considered as a representation of the p rescribed b urning

me n tioned in the guidance. It is included as part of the NonPoint Source C ategory

. 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. Emiss ions 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 „polluta nt burden‟ should likely be „shared ‟ throughout the MSA in some way that is more representative

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

also because o f the reason for the burden

.

NONROAD EQUIPMENT

NonRoad equipment emissions are generated by the NONROAD2008 a model . Other nonroad categories follow. These emissions were generated for a typical ozone season day. Inputs and

estimates for this sub

- categor y are found in Attachment 05.

COMMERCIAL MARINE VE SSELS (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 b ut 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 200 6 were grown to obtain estimates for 2011

. Inputs and

estimates for this sub

- category are found in Attachment 0 7

.

AIR CRAFT 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. Estimat es were developed by EPA3

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 temp eratures 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 consul tation 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, Tenn essee. 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 appl ied 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 defa ult VMT to the local VMT to arrive at an estimate of local source

ty pe 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 conver ter to change

MOBILE6

- formatted information to MOVES format.4

Vehicle Type VMT and VMT Fractions: T his information, data was pulled from available travel demand models or from regional HPMS data.

HPMS Vehicle Class VMT

– The HPMS vehicle class VMT was det ermined 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 w ere 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 informati on 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 664913.785

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 wa s 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

progr am) was used for analysis year 20 11

.

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 i n 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 int erpolated 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 adj ustments 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 percen t 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 o f 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 tr aveled (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

.

T he 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 SCHD

PCS compliance factor is defined by the following eq uation: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%

Sam ple 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 Calcul ation 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 Ozo ne 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 1 

### Total 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 7 

### 5.39 0.82 0.3

Aircraft *** , 8 

### 8.68 12.76 2.11

Total NonRoad 29.24 172.7 15.09

OnRoad 9 

### Total 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 Attachme nts 01 and 04 through 10 found in the emission inventory document for detailed Category inputs and outputs