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- UNITED STATES ENVIRONMEN TAL PROTECTION AGENCY

REGION 6 MULTIMEDIA PLANNING AND PERMITTING DIVISION 1445 ROSS AVENUE, SUITE 1200 DALLAS, TX 75202-2733

DATE: October 21, 2009

SUBJECT: Technical Review of the Re designation Request / Revision s to the Arkansas SIP for Crittenden County

FROM: Jeffrey Riley Air Planning Section, 6 PD-L

TO: Files

THROUGH: Guy Donaldson, Chief Air Planning Section, 6 PD-L

Background

EPA is proposing to approv e the State of Arkansas’ February 24, 2009 request to redesignate the Arkansas portion of the bi-s tate Memphis Tennessee-Arkans as (Memphis TN-AR) 1997 8-hour ozone nonattainment area to attainment for the 8-hour ozone National Ambient Air Quality Standard (NAAQS), as well as the accompanyi ng State Implementation Plan (SIP) revision containing an 8-hour ozone maintenance plan for the Arkansas portion of the bi-state Memphis TN-AR Area. This proposed approval of Arka nsas’ redesignation reque st and supporting 8-hour ozone maintenance plan is based on EPA’s determ ination that Arkansas has demonstrated that Crittenden County has met the criteria for redesigna tion to attainment specified in the Clean Air Act (CAA), including the determination that the entire Memphis TN-AR ozone nonattainment area has attained the 1997 8-hour ozone standard.

This document is intended to provide furthe r demonstration of air quality improvements in Crittenden County than what is presen ted in the proposed approval.

Analysis of the State’s Submittal

 Monitored Data Attainment of the 8-hour ozone NAAQS is based on the design value a for a given area. Design values for each site for each three-year pe riod ending in 2002 through 2008 are listed in and graphically displayed in Figure 1. Monitoring data for 2008 for both ADEQ and the

a The 8-hour ozone design value for a given site is the three-year average of the annual fourth highest 8-hour

ozone concentration at that site. The design value for a given area is the maximum over all sites in the area.- 2

- Memphis/Shelby County Health Depa rtment has undergone quality a ssurance, been certified and submitted to the EPA AQS database. ADEQ included certified ozone monitoring data reports for the Marion monitor, as well as copies of asso ciated certification letters in the submittal. Of the four monitors represented in Table 1 and Fi gure 1, the Marion monitor is the only one located in Crittenden County. The Hernando monitor, located in DeSoto County, Mississippi, was included in several data figures provided by ADEQ, because of its inclusion in the Memphis Metropolitan Statistical Area. However, DeSoto County is not part of the Memphis 8-hour ozone nonattainment area, and EPA’s approval of the redesignation reque st does not consider DeSoto County data – it was included by ADEQ to further demonstrate improvements in air quality.

Table 1. 8-Hour Ozone Design Values (ppb) fo r 2000 through 2008 forO zone Monitoring Sites in the Memphis Area.

Design Value Period Site 2000-2002 2001-2003 2002-2004 2003- 2005 2004-2006 2005-2007 2006-2008
Frayser 87 84 80 79 79 82 82
Orgill 90 89 84 81 80 81 80

Marion 94 92 87 86 87 89 82

Hernando 86 81 83 80 83 85 81

Figure 1. 8-Hour Ozone Design Values (ppb) fo r 2000 through 2008 for Ozone Monitoring Sites in the Memphis Area

8-Hour Ozone Design Values

55 65 75 85 95 105

2000-2002 2001-2003 2002-2004 2003-2005 2004-2006 2005-2007 2006-2008ppb

Frayser Orgill Marion Hernando

Between 2000 and 2007, the Marion monitor measured some of th e highest 1- and 8-hour average ozone concentrations in the Memphis MSA and this is reflected in the desi gn values. However, for the most recent three-year design value period, the design values fo r all four sites are similar and the highest value (82 ppb) represents both the Frayser and Marion sites.- 3

- The 8-hour design values for all four monitors are characterized by a downward trend between 2002 and 2005, followed by both increases and decr eases between 2005 and 2008. The Crittenden County maintenance plan addresses the prior 8-hour ozone NAAQS which requires a design value of less than 85 ppb. Thus for the 2006-2008 peri od, all sites, and thus the Memphis area, are in attainment of the prior 8-hour ozone NAAQS.

This tendency toward lower ozone is also reflect ed in the number of exce edance days. Figure 2 shows the number of exceedances of the 85 ppb 8-hour NAAQS for each ye ar from 2000 to 2008, based on the maximum 8-hour ozone concentratio n over all monitoring sites in the area. Figure 2 demonstrates that from 2006 through 2 008, a consistent downward trend in the number of 8-hour ozone exceedance days has occurred.

Figure 2. Number of 8-Hour Ozone Exceedance Days p er Year for 2000 through 20 08 for the Memphis Area

No. of 8-Hour Ozone Exceedance Days

0 5 10 15 20 25

2000 2001 2002 2003 2004 2005 2006 2007 2008No. of Days

As demonstrated in the preceding examples, moni toring data for the area has shown a continued downward trend in design values and 8-hour ozone exceedance days from 2006-2008. Preliminary data for the 2009 8-hour ozone season indicates a highest value of 76 ppb for the Marion monitor, and a highest value for the area (for both the Hernando and Frayser monitors) at 78 ppb, indicating a continued downward trend.

 Modeled Data

The Crittenden County maintenance plan establishe s a period of maintenance for the relevant NAAQS (8-hour ozone) for at least 10 years after the area is rede signated, as per the requirements of Section 175A of the Clean Air Act. The base year for this maintenance period was established as 2006, and emissions values for the four source types (point, non-point, nonroad, on-road) were developed utilizing the EP A-approved methods brie fly described below:

 Point Source

Facility-level emission estimates were base d on the 2005 point source data submitted to EPA for the NEI 2005 by State of Arkansas.

 Non-Point Source- 4

- County-level emission estimates for non-point source were based on the EPA NEI Version 2 data. The non-point data include two parts: actual 2005 wildfire emissions and emissions for other categories. According to EPA, the emi ssions included in the second part are the 2002 emissions in the NEI Version 4 (these were not updated).

 Non-Road Source

County-level emission estimates fo r the majority of non-road s ource categories were developed using EPA’s NONROAD2005 model (EPA, 2005) with June maximum, minimum and average temperatures (calculated from the 1970-2000 30-year historical aver ages) for State of Arkansas. Aircraft, commercial marine ve ssel, and locomotive sources are not in cluded in the NONROAD model, and the emissions for the categories were taken from the EPA 2 005 NEI Version 2 data.

 On-road Source

The county-level emission estimates for the on-ro ad mobile source emissions were developed using MOBILE6.2.03 with 2006 county-level daily vehicle miles traveled (VMT), speed and registration information provide d by the Arkansas Department of Transportation (ADOT), and 30-year historical average temperatures and humidity data for the month of June.

ADEQ established the end of the maintenan ce period as 2021, and in the submittal, ADEQ provided discussion and documentation of the methodology for projecting the 2006 base year emissions inventory for Crittenden County to the future years (2009, 2012, 2015, 2017, 2018 and 2021), as required by EPA. Projections fo r 2009, 2017 and 2021 were conducted as described below. The projections for years 2012, 2015 and 2018 were derived from simple interpolation between these years.

Methodology

 Point and Non-Point Sources

The development of future year emissions es timates for point and non-point sources includes the application of growth and c ontrol factors to the base-year emissions. The growth factors used in this assessment are the Regional Econo mic Models, Inc. (REMI) 6.0 factors contained in EPA’s Economic Growth and Analysis Sy stem (EGAS), Version 5.0 (EGAS 5.0) (Abt, 2006). These growth factors were applied to the various industrial sectors and source categories to reflect expected future growth (o r decline) in industrial activity and resulting emissions. The emission estimates for wildfires were kept at the base-year (2006) level.

For fuel combustion sources, ener gy adjustment factors, which we re developed from the U.S. Department of Energy (DOE) publication Annual Entergy Outlook 1999 (DOE, 1998), were applied to the base year emissions to account for expected increases in fuel combustion and process efficiency for the future years. Add itional controls were applied for residential wood combustion and Stage II VOC for gasoline service stations.

 Non-Road Sources

The future-year emission estimates for the majority of source categories from non-road sources are based on EPA’s NONROAD2005 model, which includes estimates for growth based on expected future economic conditions and other factors, as we ll as any national- 5

- controls that apply to thes e sources in the future year s. In applying the NONROAD2005 model, June maximum, minimum, a nd average temperatures were used.

To estimate the future-year emissions for aircraft, commercial marine vessels and locomotives, the EGAS 5.0 REMI 6.0 growth factor s were applied to the base-year emissions. In March 2008, EPA finalized more stringent em issions standard for locomotives and marine compression-ignition engines (EPA, 2008). Base d on the information provided in the EPA regulatory announcement for the final rule, the NO x emissions reductions were estimated as 5.6%, 22% and 36% for 2009, 2017 and 2021 from 2005 emissions levels, respectively. These reductions were incorporated into the future-y ear emission estimates for commercial marine vessels and locomotive engines for Crittenden County.

 On-road Sources

The Arkansas Highway and Transportation Department provided different VMT yearly growth factors for two ten-year periods (2007-2017 and 2017-2027) by road type based on 2007 levels. The projection factors for each of the future years were calculated by applying the growth factors to 2007 VMT to obt ain the VMT estimates for 2009, 2017 and 2021.

The county-level emission estimates for the on-road mobile source emissions were developed using MOBILE6.2.03 with future year county-level da ily VMT, state provided speed and registration information, and 30-year hi storical average temperatures and humidity data.

As shown in Figure 3 below, substantial and c onsistent reductions in nitrogen oxide (NOx) emissions are projected to occur between th e years 2006 and 2021. Small increases in point source emissions are offset by much larger pr ojected reductions in non-road and on-road emissions. These reductions are anticipated in la rge part due to fleet turnover (Federal Motor Vehicle Control Program [40 CFR Part 86], Heavy Duty Diesel Rule/2007 Highway Rule [66 FR 5001, Amended 71 FR 51481]), and Tier 2 fuel and vehicle emission standards (65 FR 6697). A similar trend is reflected in volatile organi c compound (VOC) emissions through these years, although not to the scale seen in NOx emissions.- 6

- Figure 3. Emissions Totals for NOx, and VOC for the Base Year (2006) and Future Years (2009, 2017, and 2021) for Crittenden County

Crittenden County NOx Emissions for 2006, 2009, 2012, 2015, 2017, 2018 and 2021

0 5 10 15 20

Point Area Non-road On-road Total(tons/day)

2006 2009 2012 2015 2017 2018 2021

Crittenden County VOC Emissions for 2006, 2009, 2012, 2015, 2017, 2018 and 2021

0 5 10 15 20 25 30 35

Point Area Non-road On-road Total(tons/day)

2006 2009 2012 2015 2017 2018 2021

Plan to Maintain Air Quality

Section 175A of the Clean Air Act defines the general framework of a maintenance plan. The maintenance plan must provide for maintenance of the relevant NAAQS for at least 10 years after- 7

- the area is redesignated. Because section 107(d)(3)(D) grants the Administrator up to 18 months from receipt of a complete subm ittal to process a redesignation request, ADEQ has developed this maintenance plan for the time from March 1, 2009 through November 30, 2021, a period of twelve years and nine months. The plan to maintain air quality contains a commitment to continue applicable existing programs, and in the ev ent unforeseen developments overwhelm the effectiveness of the mandated effort to mainta in the 1997 8-hour ozone NAAQS, to implement the programs and measures necessary to promptly corr ect any violation of the NAAQS that occur after redesignation of the area.

Supporting Analyses
The maintenance plan is designed to prevent de terioration of ozone ai r quality in Crittenden County through 2021. The following analyses provi de corroborative evidence that the observed 8-hour ozone concentrations are representative of typical meteor ological conditions and that future maintenance of the 85 ppb 8-hour ozone NAAQS is expected.

Considering the form of the design value metric , 8-hour ozone design valu es can be influenced by meteorology. Year-to-year variations in me teorology and especially unusually persistent meteorological conditions during one or more of the years comprising a design-value cycle can lead to variations in the design values that are not necessarily reflective of emissions or air quality changes. Thus it is important to account for th e effects of meteorology in examining design value trends. Figure shows actual and meteorologica lly adjusted design values for the Marion monitoring site. The meteorologically adjusted desi gn values were obtained using a series of data analyses beginning with Classification and Regre ssion Tree (CART) analysis. CART was applied for the period 2000-2008. Each day was placed into a classification bin that corresponds to a certain range of 8-hour ozone concentration and a specific set of meteorological conditions. The category of a bin reflects the c oncentration or se verity associated with the bin’s meteorological conditions, and the number of days in a bin represents the frequency with which those conditions occur. Using this information, each individual y ear was normalized such that the different sets of meteorological conditions are represented no more or less th an they are on average over all years in the period. The meteorol ogically adjusted design values were then calculated using the “data” for each normalized year.- 8

- Figure 4. Actual and Meteorologically Adjusted 8-Hour Ozone Design Values (ppb) for 2000 through 2008 for the Marion, AR Monitoring Site

8-hr Ozone DV: Marion

65 75 85 95 105

2000-2002 2001-2003 2002-2004 2003-2005 2004-2006 2005-2007 2006-2008ppb

Actual Adjusted

As expected, the adjusted design values exhib it less variation among years than the observationbased values. For most periods, the meteorologically adjusted de sign values are lower than the observation-based values. Both the actual and meteorologically adjusted design values show a downward trend. Although slightly higher than observed, the me teorologically adjusted design value for 2006-2008 also indicates attainment.

This same method was used to estimate the mete orologically adjusted num ber of exceedance days for the Memphis area, as shown in Figure 5:

Figure 5. Number of Actual and Meteorologically Adjusted 8-Hour Ozone Exceedance Days for 2000 throug h 2008 for the Memphis Area

No. of Exceedance Days (85 ppb): All Sites

0 10 20 30 40

2000 2001 2002 2003 2004 2005 2006 2007 2008No. of Days

Actual Adjusted

In 2006, the State of Arkansas established Cr ittenden County as a Zone Targeted for Economic Development (EDZ) and petitione d the EPA to approve emissi ons growth a llowances and permitting regulations that would ap ply to the EDZ. Arka nsas was required to demonstrate that the level of growth in ozone precursor emissions that was established for the EDZ would not; cause or- 9

- contribute to violations, or interfere with mainte nance, of the 1997 8-hour ozone standard. These regulations are codified in Arkansas Pollution Control and Ecology Commis sion Regulation No. 31 - Nonattainment New Source Review Requiremen ts as Regulation 31.305 - Zones Targeted for Economic Develo pment. These regulations describe specific provisions for permitting new emissions sources in such zones. In order to assure continued maintenance of the 1997 8-hour ozone standard, ADEQ will continue to administer these provisi ons. Regulation 31 .305 describes available quantities of VOC and NOx emissions that may be allocated to new f acilities within the EDZ without interfering with attainment, or maintenance, of the eight-hour ozone standard.

Figure 6 displays the results from two diffe rent modeling studies (the ATMOS and EDZ modeling analyses. In both cases , the baseline (or cu rrent) year is 2002. ATMOS examined four projection years (2007, 2009, 2012, and 2017) and th e EDZ modeling examin ed two projection years (2007 and 2009). The emissions for the EDZ modeling are slightly more up to date than those used for ATMOS. In the figure, the 2002 value is the average design value for the three three-year periods ending in 2002, 2003 and 2004. This is the EPA recommended basis for the modeled attainment test (EPA, 2005). The re maining estimated design values (EDVs) were calculated using the modeling results and the EPA modeled attainment test. The results presented in Figure 6 show that the modeling resu lts are consistent with the reduction in design value observed between 2002 and 2008. The results indicate attainment of the 85 ppb 8-hour ozone NAAQS by 2007/2009 and continued maintena nce of the standard through 2017 for the Marion site and the entire Memphis area.

Figure 6. Observation-Based (Weighted-Average) and Model-Based Estimated Design Values (EDVs) for the Memphis Area Ozone Monitoring Sites for the ATMOS and EDZ Simulations

Frayser

83.7

77 77 75 78 83.7

78 79

60 65 70 75 80 85 90 95

2002 2007 2009 2012 2017ppb

ATMOS EDZ Orgill

87.7

77 78
74 80 87.7

77 79

60 65 70 75 80 85 90 95

2002 2007 2009 2012 2017ppb

ATMOS EDZ

Marion

91

83 83 81 84 91

83 84

60 65 70 75 80 85 90 95

2002 2007 2009 2012 2017ppb

ATMOS EDZ Hernando

83.3

77
73 76 75 77 76 83.3

60 65 70 75 80 85 90 95

2002 2007 2009 2012 2017ppb

ATMOS EDZ- 1 0

- Emissions Reduction Programs

Permanent and Enforceable Emission Reductions (2000-2008) Ozone precursor emissions reductions of oxides of nitrogen (NOx), volatile organic compounds (VOC), and carbon monoxide (CO) have occurred in Crittenden County during the period 2000 – 2008. The majority of these reduc tions have been realized fro m Federal and State measures, primarily related to mobile sources. Table 2 below provides a summary of these measures, with estimated benefits, as well as several volunt ary emission reductions enacted for Crittenden County.

Point Source Reductions Emission reductions from point sources in Critte nden County have occurred during, or since, the 2006 base-year. These permanent reductions in point source emissions were the result of two changes in permitted facility operations.

Proform Company, LLC, a source previously perm itted to emit 0.1 tons per day VOC, closed in 2006 and the air permit has been voided.

On December 15, 2008 CIBA Corporation was recl assified from a major source to a minor source when it modified operations in order to comp ly with an applicable MACT standard. This modification resulted in reductions of 1.6 tpy NOx, 448 tpy VOC and 0.2 tpy CO.

Area Source Reductions In 2004, ADEQ adopted a regulation requiring Stage I Vapor Recovery systems to be installed and operated at gas stations in Crittenden County. This requirement applies to approximately 70 facilities in the County.

Additional area source VOC emissions reductions we re likely realized during this period due to federal controls on architectural coatings, ro adway paints, auto body refinishing, manufacturing, and other commercial and consumer solvent prod ucts. These reductions should be considered excess, since they were not quantified by ADEQ in the development of the Crittenden County maintenance plan.

Non-Road Source Reductions During 2000-2008, a number of federal measures a nd emissions standards were promulgated to address fuel usage and engine sp ecifications for a number of non-road categories. The Tier 1 and Tier 2 diesel engine sta ndards were phased in during this period. In 2004, EPA’s Clean Air Nonroad Diesel Rule specified limits on sulfur in diesel fuel used in marine vessel engines. This will primarily affect particulate matter (PM) emi ssions. In addition, EPA has also implemented a program that requires engine ma nufacturers to integrate engine and fuel controls to reduce NOx and PM emissions. These requirements came into effect in 2007 for various non-road engines used in construction and farming. These contro ls would affect NOx, VOC and CO emissions. A number of recent rules promulgated by EPA will also affect future emissions of smaller commercial marine vessel engines, gasoline boa t engines, personal wa tercraft, forklifts, generators, compressors, lawn and garden equipm ent, diesel locomotives, dirt bikes, and all-- 1 1

- terrain vehicles (ATV’s). As e quipment is replaced over time a nd these controls are fully phased in from 2009 through 2011, more em issions reductions are expected from these sources in the future.

Mobile Source Reductions The largest reductions in ozone precursor emi ssions in Crittenden County during this period were from the on-road mobile sector. This is primarily the result of engine improvements mandated by the Federal Motor Vehicle Contro l Program (FMVCP), which has stipulated extended warranties on emission control devices a nd improvements in fuel efficiency. Also, beginning in 2004, EPA’s Tier 2 motor vehicle emissions and fuel standards program was initiated and applied to passenger cars and light tr ucks. These measures also require a reduction of sulfur in gasoline which will result in mo re efficient and longer lasting onboard emission control systems. In addition, the replacement of older vehicles with newer, cleaner vehicles (fleet-turnover) was likely responsible for a good portion of the re alized reductions during this period. A newer on-road mobile fleet provides reductions in NOx, VOC and CO emissions. Also, EPA’s Heavy Duty Diesel Rule (also refe rred to as the “2007 Highway Rule”), which was originally promulgated in 2001 and was expected to take effect in 2006, would likely have resulted in some precursor emi ssions reductions from the high volum e of diesel trucks transiting the county through the I-40 and I-55 corridors.

Table 2. Crittenden County Emission Reductions Programs

Mobile Sources Basis

o Tier 2 Fuel and Vehicle Emission Standards 65 FR 6697

o Federal Motor Vehicle Control Program 40 CFR Part 86

o Heavy Duty Diesel Rule (2007 Highway Rule) 66 FR 5001, Amended 71 FR 51481 State and Local Measures

o Stage I Vapor Recovery 72 FR 18394

o Proform Company, LLC clos ure, air permit voided Voids permit - allowed 249.32 tpy of VOC

o CIBA Corporation reclassifi ed to minor source, MACT standard modifications Reduction of 1.6 tpy NOx, 448 tpy VOC Additional Voluntary Reductions

o Diesel Emissions Reduction Act – ADEQ received State Clean Diesel Grant in October 2008 Title VII(G) of Public Law 109-58

o Retrofit of city and coun ty (21 on-road, 12 non-road trucks w/diesel oxi dation catalyst – 2007 3.27 tpy reduction of hydrocarbons over life of vehicles

o Retrofit of 50 Marion and West Memphis School District buses w/diesel oxidation catalyst – 2006 59 tpy reduction of hydrocarbons over life of vehicles

o Retrofit of 12 City of West Memphis refuse trucks w/diesel oxidation catalyst – 2006 15 tpy reduction of hydrocarbons over life of vehicles

o 196 California Air Resources Board certified gas cans exchanged in Crittenden County, May-August 2008 1,136 lbs/yr estimated reduction of VOCs

o Truck stop electrification (equipped 65 parking spaces in EPA SmartWay funds- 1 2

- Crittenden County) – 2004 awarded to state

EPA Conclusion and Recommendation

I recommend approval of the State of Arkansas’ February 24, 2009 request to redesignate the Arkansas portion of the Memphis Tennessee-Arkansas 1997 8-hour ozone nona ttainment area to attainment for the 8-hour ozone National Ambient Air Quality Standard (NAAQS), as well as the accompanying State Implementation Plan (S IP) revision containing an 8-hour ozone maintenance plan for the Arkansas portion of th e bi-state Memphis TN-A R Area. EPA’s review of the submittal indicates that it is consistent with EPA’s guidance, a nd that the redesignation request and monitoring data demonstrate that the Crittenden County porti on of the Memphis TNAR area has attained, and will continue to maintain the 1997 8-hour ozone standard.- 1 3

- Guidance/Websites:

1. 40 CFR Part 51, Appendix V - Criteria for Determining the Completeness of Plan Submissions

2. "Procedures for Processing Requests to Rede signate Areas to Attainment," - Memorandum from John Calcagni, Director, Air Qualit y Management Division, September 4, 1992: http://www.epa.gov/ozonedesignations/1997standards/red esig/documents/Redesignation-Guidance-9-04-92.pdf

3. State Implementation Plans; "Ozone and Carbon Monoxide Design Value Calculations", Memorandum from Bill Laxton, June 18, 1990:

4. "Maintenance Plans for Redesignation of Ozone and Carbon Monoxide Nonattainment Areas," - Memorandum from G. T. Helms, Chief, Ozone/Carbon Monoxide Programs Branch, April 30, 1992: http://www.epa.gov/ozonedesignations/1997stand ards/redesig/documents/MainPlans_043092.pdf

5. "State Implementation Plan (SIP) Requirements for Areas Submitting Requests for Redesignation to Attainment of the Ozone and Carbon Monoxide (CO) National Ambient Air Quality Standards (NAAQS) On or After Nove mber 15, 1992," - Memorandum from Michael H. Shapiro, Acting Assistant Administrator for Air and Radiation, September 17, 1993: http://www.epa.gov/ozonedesignations/1997stand ards/redesig/documents/9-17-93Shapiro.pdf