UPS
EXPRESS
September
10,
2004
Mr.
James
I.
Palmer,
Jr.
Regional
Administrator
US
EPA,
Region
IV
Atlanta
Federal
Center
61
Forsyth
Street,
SW
Atlanta,
GA
30303
RE:
Tennessee's
response
to
EPA's
recommended
PM2.5
nonattainment
designations
Dear
Mr.
Palmer:

Tennessee
offers
the
following
comments
regarding
the
PM2.5
nonattainment
designations
recommended
by
the
Environmental
Protection
Agency
(
EPA)
as
outlined
in
EPA's
June
29,
2004
letter.

McMinn
and
Roane
Counties:

EPA
has
proposed
the
inclusion
of
McMinn
and
Roane
Counties
as
PM2.5
nonattainment
areas
primarily
because
of
a
large
source
in
each
county
despite
the
fact
that
these
two
counties
are
not
in
a
metropolitan
statistical
area
(
MSA).
Apparently,
the
sources
of
concern
are
Bowater
Newsprint
and
the
TVA
Kingston
Steam
Plant.
The
EPA
June
29,
2004
letter
declares
that
meteorology
or
geography/
topography
are
not
factors
in
the
EPA
rationale
for
including
the
counties.

Tennessee
avers
that
the
naming
of
these
rural
counties
as
nonattainment
based
upon
a
large
source
in
that
county
is
patently
unfair
to
the
citizens
of
that
county.
The
monitors
currently
measure
PM2.5
attainment,
so
it
has
to
be
an
argument
of
contribution.
Tennessee
agrees
that
in
general,
the
larger
sources
do
have
a
potential
to
be
contributors
to
the
formation
of
PM2.5,
but
there
has
been
no
plausible
demonstration
to
show
that
these
sources
actually
impact
either
the
Chattanooga
or
Knoxville
MSAs
where
air
monitoring
measures
PM2.5
nonattainment.

Therefore,
with
respect
to
McMinn
and
Roane
counties,
Tennessee
declares
the
following:
 
Neither
county
should
be
listed
as
significantly
contributing
to
the
nonattainment
of
another
county.
 
If
a
source(
s)
in
a
county
outside
of
an
MSA
is
to
be
listed
as
significantly
contributing
to
the
nonattainment
of
another
county,
it
should
be
listed
only
after
modeling
confirms
that.
 
Ultimately,
a
state
implementation
plan
to
ensure
that
all
of
Tennessee
will
attain
the
PM2.5
standard
will
be
required.
 
In
preparing
the
PM2.5
State
Implementation
Plan,
Tennessee
commits
to
model
the
two
sources
to
ascertain
their
impact
upon
the
Knoxville
and
Chattanooga
MSAs
and
to
the
extent
necessary,
require
sufficient
control
on
the
facilities
to
attain
the
standard.
 
EPA
extends
the
invitation
to
discuss
a
partial
county
designation
to
capture
these
sources
of
concern
as
long
as
the
ultimate
nonattainment
boundary
in
that
county
captures
the
source
and
is
contiguous
to
an
MSA
nonattainment
area.
Tennessee
rejects
this
offer,
as
it
has
no
scientific
or
technical
merit.
The
counties
measure
attainment,
so
it
is
not
an
argument
over
how
large
an
area
a
nonattaining
monitor
should
represent.
This
argument
concerns
contribution
from
point,
rather
than
area
sources.
If
a
boundary
is
to
be
drawn,
it
must
be
point
limited
without
a
peninsula
connecting
it
to
a
nonattaining
MSA.
 
Upon
designation
of
nonattainment,
existing
sources
are
expected
to
meet
a
RACT
level
of
control
for
the
pollutants
causing
nonattainment.
In
the
case
of
the
TVA
Kingston
Plant,
oxides
of
nitrogen
control
in
the
form
of
Low
NOx
burners
and
Selective
Catalytic
Reduction
units
is
underway.
Lower
sulfur
fuels
are
being
used
in
the
interim
and
ultimately
scrubbers
will
be
installed.
Details
of
the
control
efficiencies
and
timeline
for
implementation
are
enclosed
as
attachments
to
this
letter.
Since
the
facility
of
concern
will
have
controls
for
SOx
and
NOx
that
far
exceed
the
requirements
of
RACT,
it
seems
useless
to
name
a
county
or
a
well­
controlled
facility
as
being
nonattainment
contributing
without
a
specific
modeling
study
done
at
the
controlled
level
making
a
demonstration
of
attribution.
 
The
"
urban
excess"
evaluations
conducted
by
EPA
and
proposed
as
a
method
for
"
L
factor"
ranking
of
the
counties
within
an
area
(
MSA),
according
to
their
relative
emissions
of
direct
and
indirect
PM2.5
related
air
contaminants,
also
provides
a
method
to
evaluate
potential
reductions
needed.
An
evaluation
of
the
urban
excess
data
for
Knoxville,
Tennessee
area
reveals
that
approximately
3
ug/
m3
total
urban
excess
is
present.
This
can
be
apportioned
based
on
the
emission
inventory.
The
approximate
amount
of
reduction
needed,
based
on
the
urban
excess
calculations
is
equal
to
about
2%
of
the
inventory.
This
is
the
projected
amount
needed
to
reduce
the
PM2.5
levels
below
the
15.0
ug/
m3
threshold
for
the
Knoxville
area.
When
the
entire
emission
reduction
amounts
are
actually
realized,
the
PM2.5
monitored
levels
could
be
reduced
to
approximately
14.0
ug/
m3
(
assuming
a
reduction
equal
to
the
total
urban
excess
amount).
 
The
existing
reductions
proposed
as
part
of
the
NOx
SIP
call
and
the
NOx
RACT
requirements
along
with
the
other
federal
program
reductions
planned
and
the
TVA
NOx
reductions
already
underway,
should
produce
reductions
that
will
achieve
these
goals.
 
It
is
unreasonable
to
include
the
Roane
and
McMinn
county
areas
that
are
monitoring
attainment
for
the
PM2.5
standard,
when
it
is
highly
likely
that
the
emission
reductions
described
above
will
alone
be
significant
enough
to
bring
the
Knoxville
area
into
attainment.
The
implementation
of
the
federal
programs
and
the
NOx
SIP/
RACT
requirements
will
also
bring
about
similar
reductions
for
the
sources
in
those
counties
as
well.
These
reductions
will
also
have
a
positive
impact
if
the
areas
are
considered
to
be
contributing
to
PM2.5
nonattainment
in
the
Knoxville
region.

Chattanooga
MSA:

Tennessee
does
not
object
to
the
naming
of
Hamilton
County,
as
it
is
consistent
with
our
most
recent
recommendation
and
the
fact
that
it
is
measuring
nonattainment
of
the
PM2.5
standard.
Tennessee
does
object
to
the
naming
of
Marion
County
as
there
are
essentially
no
point
source
emissions
and
most
of
the
county's
emission
inventory
is
mobile
source
emissions
from
through
commuters
(
heavy
duty
trucks)
along
Interstate
24.
Because
of
federal
preemptions
on
fuels
and
the
fact
that
these
trucks
are
not
stationed
in
Marion
County,
there
is
nothing
that
the
county
or
the
state
can
do
but
wait
on
the
federal
fuels
and
diesel
rules
to
take
effect.
It
makes
no
sense
to
place
a
county
in
economic
growth
jeopardy
by
declaring
them
to
be
nonattainment
contributing
when
the
facts
so
clearly
justify
otherwise.

There
have
been
numerous
meetings
since
June
with
local
city
&
county
representatives,
Metropolitan
Planning
Organizations,
Economic
and
Community
Development,
environmental
groups,
industry
and
the
public.
This
has
also
provided
an
opportunity
for
additional
discussions
regarding
the
potential
PM2.5
nonattainment
areas.
Control
measures
that
are
being
implemented
to
address
ozone
nonattainment
will
also
have
positive
impacts
in
mitigation
of
PM2.5
nonattainment.
Tennessee
is
also
planning
to
implement,
in
a
number
of
areas,
including
Knoxville
and
Chattanooga,
PM2.5
forecasting
or
Air
Quality
forecasts
(
in
areas
with
existing
Ozone
forecasting
programs).
The
opportunity
to
educate
the
public
and
encourage
business
participation
and
involvement
in
reducing
PM2.5
emissions
and
precursors
will
also
provide
a
positive
benefit
toward
achieving
and
maintaining
PM2.5
attainment.

Knoxville
MSA:

Tennessee
does
not
object
to
the
naming
of
Knox
County,
as
it
is
consistent
with
our
most
recent
recommendation
and
the
fact
that
it
is
measuring
nonattainment
of
the
PM2.5
standard.
The
additional
consideration
of
the
"
L"
factor
analysis
proposed
by
EPA
as
a
method
to
rank
the
emission
component
of
the
9
factors
to
be
considered
in
including
or
excluding
counties
in
a
given
area
as
contributing
to
nonattainment,
identifies
several
counties
other
than
Knox
as
significantly
contributing
to
nonattainment
in
the
Knox
County
area.
Tennessee
agrees
that
Anderson
and
Loudon
counties
have
a
significant
"
L
factor"
score.
However,
the
"
urban
excess"
contributions
should
be
further
discussed.
Blount
County
has
an
attaining
PM2.5
monitor
and
relatively
lower
emissions
than
either
Knox,
Anderson
or
Loudon
counties.
In
fact
the
reported
NOx
emissions
are
the
lowest
in
the
MSA
except
for
Sevier
County.
Carbon
and
nitrates
are
identified
as
significant
in
the
EPA
calculated
"
urban
excess"
for
the
Knoxville
region.
The
fact
that
nitrates
are
a
significant
component
of
the
"
urban
excess"
with
Blount
County
demonstrating
monitored
attainment
for
PM2.5
does
not
support
naming
Blount
county
nonattainment.
Tennessee
agrees
that
there
are
other
components
of
the
"
9"
factors
that
are
identified
as
significant
for
Blount
County
in
the
EPA
analysis.
However,
attainment
of
the
standard
is
the
true
test
for
significant
contribution.
Again,
Blount
County
has
measured
attainment
with
the
PM
2.5
standard
and
should
be
given
due
credit
for
this.

The
following
control
measures
are
being
considered:
more
stringent
controls
for
open
burning,
a
NOx
RACT
rule
for
portions
of
West
Tennessee
and
for
the
Tennessee
Valley
connecting
Chattanooga
and
Knoxville.
Statewide
anti­
tampering
rules
for
vehicles
have
been
adopted
by
the
State
Air
Pollution
Control
Board
in
addition
to
a
vehicle
emission
testing
program
in
Hamilton
County.

Tennessee
recommends
that
Marion,
Anderson,
Blount,
Loudon,
McMinn,
Roane
and
Sevier
be
classified
attainment
and
if
that
is
not
possible,
they
should
be
designated
as
unclassifiable.

Tennessee
commits
to
examine
its
counties
in
accordance
with
PM2.5
SIP
requirements
and
further
commits
to
prepare
a
SIP
for
the
attainment
of
the
Federal
PM2.5
standards
in
accordance
with
Federal
guidance
and
regulations.
Sources
will
be
analyzed
and
if
additional
controls
are
needed,
they
will
be
imposed
in
order
to
achieve
the
PM2.5
standards
within
the
Federally
established
compliance
deadlines.

I
urge
you
to
take
our
comments
into
consideration
when
making
the
final
designations
for
PM2.5
nonattainment.
If
you
have
any
questions
please
feel
free
to
contact
me
at
615
532­
0554.

Sincerely,

Barry
R
Stephens,
P.
E.
Director
Division
of
Air
Pollution
Control
Attachments
cc:
EPA,
Region
IV
­
Kay
T.
Prince,
Anne
Marie
Hoffman
&
Dick
Schutt,
Tennessee
Air
Pollution
Control
Board
Members
Tennessee
Local
Air
Pollution
Control
Program
Directors
