1Section
182(
b)(
3)
specifies
that
EPA
would
approve
any
request
from
a
State
to
reclassify
to
a
higher
classification.

1
Technical
Support
Document
for
Memphis
Ozone
Nonattainment
Area
September
2004
1.0
Summary.

The
States
of
Tennessee
and
Arkansas
presented
a
petition
to
EPA,
Regions
4
and
6,
requesting
downward
reclassification
of
the
Memphis
Ozone
Nonattainment
Area
(
MONA)
from
Moderate
to
Marginal
for
the
8­
hour
ozone
standard.
The
petition
was
presented
to
EPA
July
15,
2004.
The
petition
is
based
on
the
area's
Moderate
design
value
of
92
ppb
being
within
5%
of
the
maximum
Marginal
design
value
of
0.091
ppm
as
allowed
by
the
Clean
Air
Act.

2.0
Introduction.

This
section
describes
the
statutory
provisions
and
EPA
guidance
regarding
reclassification
of
ozone
nonattainment
areas.
Sections
181(
a)(
4)
and
182(
b)(
3)
of
the
Clean
Air
Act
provide
that
areas
may
be
reclassified
under
certain
circumstances.
This
technical
support
document
addresses
the
provisions
of
section
181(
a)(
4)
and
a
specific
request
for
reclassifications
received
by
the
State
of
Michigan.
The
EPA
has
not
received
any
requests
for
reclassification
under
section
182(
b)(
3)
for
the
8­
hour
ozone
standard.
1
Under
section
181(
a)(
4),
an
ozone
nonattainment
area
may
be
reclassified
"
if
an
area
classified
under
paragraph
(
1)
(
Table
1)
would
have
been
classified
in
another
category
if
the
design
value
in
the
area
were
5
percent
greater
or
5
percent
less
than
the
level
on
which
such
classification
was
based."
In
the
April
30,
2004
notice,
we
indicated
that
an
area
with
a
moderate
design
value
of
96
ppb
(
or
less)
would
be
eligible
to
request
a
bump
down
because
five
percent
less
than
96
ppb
is
91
ppb,
a
marginal
design
value.

The
EPA
previously
described
criteria
to
implement
the
section
181(
a)(
4)
provisions
in
a
final
rule
designating
and
classifying
areas
published
on
November
6,
1991
(
56
FR
56698).
As
stated
in
that
notice,
the
provisions
of
section
181(
a)(
4)
set
out
general
criteria
and
grant
the
Administrator
broad
discretion
in
making
or
determining
not
to
make,
a
reclassification.
As
part
of
the
1991
action,
EPA
developed
more
specific
criteria
to
evaluate
2
whether
it
is
appropriate
to
reclassify
a
particular
area.
The
EPA
also
described
these
criteria
in
the
April
30,
2004
final
rule.
The
general
and
specific
criteria
are
as
follows:

General:
The
EPA
may
consider
the
number
of
exceedances
of
the
national
primary
ambient
air
quality
standard
for
ozone
in
the
area,
the
level
of
pollution
transport
between
the
area
and
other
affected
areas,
including
both
intrastate
and
interstate
transport,
and
the
mix
of
sources
and
air
pollutants
in
the
area.

Request
by
State:
The
EPA
does
not
intend
to
exercise
its
authority
to
bump
down
areas
on
EPA's
own
initiative.
Rather,
EPA
intends
to
rely
on
the
State
to
submit
a
request
for
a
bump
down.
A
Tribe
may
also
submit
such
a
request
and,
in
the
case
of
a
multi­
state
nonattainment
area,
all
affected
States
must
submit
the
reclassification
request.

Discontinuity:
A
five
percent
reclassification
must
not
result
in
an
illogical
or
excessive
discontinuity
relative
to
surrounding
areas.
In
particular,
in
light
of
the
areawide
nature
of
ozone
formation,
a
reclassification
should
not
create
a
"
donut
hole"
where
an
area
of
one
classification
is
surrounded
by
areas
of
higher
classification.

Attainment:
Evidence
should
be
available
that
the
proposed
area
would
be
able
to
attain
by
the
earlier
date
specified
by
the
lower
classification
in
the
case
of
a
bump
down.

Emissions
reductions:
Evidence
should
be
available
that
the
area
would
be
very
likely
to
achieve
the
appropriate
total
percent
emission
reduction
necessary
in
order
to
attain
in
the
shorter
time
period
for
a
bump
down.

Trends:
Near­
and
long­
term
trends
in
emissions
and
air
quality
should
support
a
reclassification.
Historical
air
quality
data
should
indicate
substantial
air
quality
improvement
for
a
bump
down.
Growth
projections
and
emission
trends
should
support
a
bump
down.
In
addition,
we
will
consider
whether
vehicle
miles
traveled
and
other
indicators
of
emissions
are
increasing
at
higher
than
normal
rates.

Years
of
data:
For
the
8­
hour
ozone
standard,
the
2001­
2003
period
is
central
to
determining
classification.
Data
from
2004
may
be
used
to
corroborate
a
bump
down
request
but
should
not
be
the
sole
foundation
for
the
bump
down
request.
3
Limitations
on
Bump
Downs
An
area
may
only
be
reclassified
to
the
next
lower
classification.
An
area
cannot
present
data
from
other
years
as
justification
to
be
reclassified
to
an
even
lower
classification.
In
addition,
section
181(
a)(
4)
does
not
permit
moving
areas
from
subpart
2
into
subpart
1.

In
1991,
EPA
approved
reclassifications
when
the
area
met
the
first
requirement
(
a
request
by
the
State
to
EPA)
and
at
least
some
of
the
other
criteria
and
did
not
violate
any
of
the
criteria
(
emissions,
reductions,
trends,
etc.).
In
our
April
30,
2004
final
rule
on
designations
and
classifications,
we
stated
our
intention
to
use
this
method
and
these
criteria
once
again
to
evaluate
reclassification
requests
under
section
181(
a)(
4),
with
minor
changes
described
in
that
notice.
In
that
notice
we
also
described
how
we
applied
these
criteria
in
1991.
For
additional
information,
see
section
5,
"
Areas
requesting
a
5%
downshift
per
§
181(
a)(
4)
and
EPA's
response
to
those
requests,"
of
the
Technical
Support
Document,
October
1991,
for
the
1991
rule.
[
Docket
A­
90­
42A.]

EPA
is
not
basing
this
reclassification
determination
on
consideration
of
whether
the
nonattainment
area
being
reclassified
does
or
does
not
cause
any
pollution
transport.
The
EPA
is
presently
addressing
ozone
pollution
transport
issues
throughout
the
eastern
part
of
the
United
States
under
other
Clean
Air
Act
provisions.
Specifically,
EPA
has
proposed
a
determination
that
emissions
from
certain
states
contribute
significantly
to
downwind
nonattainment
for
ozone
under
CAA
section
110(
a)(
2)(
D)
through
the
Clean
Air
Interstate
Rule
(
CAIR).
The
CAIR
proposal,
published
in
a
Federal
Register
notice
dated
January
30,
2004,
would
require
upwind
States
to
eliminate
emissions
that
contribute
significantly
to
nonattainment
in
downwind
States.
69
Fed.
Reg.
454566.
The
EPA
previously
issued
the
NOx
SIP
call
(
63
FR
57356)
to
address
interstate
ozone
transport.
In
the
event
of
any
intrastate
transport
issue,
states
have
the
obligation
to
develop
attainment
SIPs
for
each
area
that
show
timely
attainment,
and
can
address
any
intrastate
transport
issues
in
that
context.

The
April
30,
2004
notice
invited
States
to
submit
the
reclassification
requests
within
30
days
of
the
effective
date
of
the
designations
and
classifications.
The
effective
date
was
June
15
which
means
that
reclassification
requests
were
to
be
submitted
by
July
15,
2004.
This
relatively
short
time
frame
is
necessary
because
section
181(
a)(
4)
only
authorizes
the
Administrator
to
make
such
reclassifications
within
90
days
after
4
the
initial
classification,
September
15,
2004.

3.0
Background.

The
MONA
was
designated
nonattainment
for
the
8­
hour
ozone
standard
on
April
15,
2004,
and
classified
"
Moderate"
based
on
a
design
value
of
92
ppb.

The
MONA
consists
of
Shelby
County,
Tennessee,
and
Crittenden
County,
Arkansas.
The
recently
revised
Memphis
Metropolitan
Stastical
Area
(
MSA),
which
has
a
population
of
just
over
1.2
million,
includes
Shelby,
Tipton,
and
Fayette
Counties,
Tennessee;
DeSoto,
Marshall,
Tate
and
Tunica
Counties,
Mississippi;
and
Crittenden
County,
Arkansas.
Crittenden
County,
which
lies
adjacent
to
the
Mississippi
River
and
just
west
of
Memphis,
Tennessee,
is
mostly
a
rural
county
with
small
communities
and
little
industry.
In
2001,
Crittenden
County
reported
a
population
of
just
over
51,000,
while
Shelby
County
(
which
includes
the
City
of
Memphis)
reported
a
population
of
896,000.
Fayette
County
had
a
population
of
31,000,
while
Tipton
County
had
a
population
of
53,000.
DeSoto
County,
Mississippi,
which
is
also
quite
rural
and
serves
as
a
bedroom
community
for
Memphis,
had
a
population
of
114,000.
Marshall,
Tate
and
Tunica
counties
in
Mississippi
were
added
to
the
MSA
as
a
result
of
the
findings
of
the
federal
Census
Bureau's
2000
Census.
In
2001,
their
populations
were
reported
as:
35,000,
25,000
and
9000,
respectively.
Interstate
40
runs
east­
west
through
Crittenden
County,
while
Interstate
55
runs
north
from
the
center
of
the
Crittenden
County
and
is
adjacent
to
the
City
of
Memphis.

Within
the
Memphis
MSA,
ground­
level
ozone
is
measured
at
the
Crittenden
County
monitor,
which
is
located
10
miles
northwest
of
downtown
Memphis
in
Marion,
Arkansas;
at
two
monitors
in
Shelby
County
(
Edmund
Orgill
Park
and
Frayser
Street);
and
at
one
monitor
located
in
the
central
part
of
DeSoto
County.
In
recent
years,
the
Marion
monitor
has
measured
some
of
the
highest
1­
and
8­
hour
average
ozone
concentrations
in
the
Memphis
MSA.
For
example,
the
8­
hour
design
values
for
2001,
2002,
and
2003
at
the
Marion
monitor
are
92,
94,
and
92
ppb,
respectively.
Design
values
for
the
Shelby
County
monitors
are:
93,
90,
and
89
ppb
at
the
Edmund
Orgill
Park
monitor,
and
93,
87,
and
84
ppb
at
the
Frayser
Street
monitor.
The
8­
hour
design
values
at
the
DeSoto
County
monitor
are
86,
86,
and
81
ppb.

4.0
Reclassification
Request
by
States.

The
State's
request
and
the
rationale
is
as
follows:
5
1.
Request
by
States:
The
States
of
Tennessee
and
Arkansas
present
this
petition.

2.
Discontinuity:
Multiple
screening
tests
demonstrate
that
no
discontinuity
exists
with
surrounding
areas.

3.
Attainment:
Local
modeling
and
a
meteorological
adjustment
methodology
was
used
in
the
discussion
for
attainment.

4.
Emissions
Reductions:
Emissions
reductions
that
were
included
in
the
local
modeling
and
additional
reductions
beyond
that
modeled
are
detailed
in
the
petition.

5.
Trends:
Long
term
and
near
term
emission
and
air
quality
trends
support
reclassification.

6.
Years
of
Data:
2001
­
2003
air
quality
data
were
used
to
designate
the
area
to
nonattainment.

5.0
EPA
Review
of
the
Reclassification
Request.

5.1
Request
by
State.
The
States
of
Tennessee
and
Arkansas
submitted
the
petition
by
the
date
required.

5.2
Discontinuity
The
modeling
tests
documented
in
the
petition
demonstrate
that
no
discontinuity
exists
with
surrounding
areas.
Since
the
entire
MONA
is
included
in
the
request
and
the
MONA
is
surrounded
by
attainment
areas,
there
will
be
no
area
of
one
classification
(
MONA)
surrounded
by
an
area
of
a
higher
classification.

5.3
Attainment
The
modeling
submitted
showed
attainment
when
using
methodology
for
adjusting
meteorology.
The
appropriateness
of
this
method
is
under
review
by
EPA.
The
EPA's
evaluation
of
the
modeling
submitted
without
a
meteorology
adjustment
and
other
assumptions
shows
the
design
value
declining
to
88
ppb
by
2007,
which
makes
notable
progress
toward
attainment.
Also,
EPA's
Clean
Air
Interstate
Rule
(
CAIR)
modeling
shows
the
area
should
have
a
design
value
of
86
ppb
by
2010,
which
also
shows
notable
progress
towards
attainment.
In
addition,
the
CAIR
modeling
does
not
include
any
local
controls
expected
prior
to
2007.
Therefore,
local
controls
could
be
expected
to
further
lower
the
CAIR
2010
design
value.
Both
modeling
projects
indicate
more
reductions
are
needed
beyond
6
that
modeled
for
attainment
by
2007.
Additional
controls
beyond
that
modeled
have
been
identified
and
submitted
in
the
petition.
Local
modeling
to
assess
the
impact
of
the
additional
controls
and
to
identify
and
implement
more
controls
if
needed
will
be
performed
as
a
part
of
a
monitoring
study.

5.4
Emissions
Reductions
Attainment
is
expected
because
of
the
combination
of
measures
to
be
implemented
and
potential
measures
listed
in
the
petition
along
with
the
commitment
of
the
areas
to
implement
additional
measures
as
needed
to
achieve
attainment
As
strong
support
for
adequate
emission
reductions
being
implemented,
Arkansas
is
conducting
a
study
with
limited
additional
modeling
which
should
identify
the
sources
affecting
the
monitors
more
precisely.
EPA
is
providing
$
100,000
and
Arkansas
is
providing
$
50,000
for
this
study.
Arkansas,
Tennessee
and
the
Memphis­
Shelby
County
local
agency
are
committed
to
assess
the
results
of
the
study
and
implement
additional
controls
beyond
those
modeled
or
identified
in
the
reclassification
petition
by
2006,
if
required
by
the
study
results.
This
commitment
is
made
by
the
Governors,
State,
and
Local
officials
of
both
States
as
signatories
to
the
petition.
In
addition,
the
State
of
Tennessee
and
the
City
of
Memphis/
Shelby
County
have
submitted
letters
reinforcing
the
commitments
to
provide
additional
measures
as
the
modeling
and
study
results
might
identify.

The
petition
lists
19
emission
reduction
measures
for
potential
implementation
at
the
state
and
local
level.
Some
of
these
measures
are
quantifiable
and
enforceable
and
others
are
voluntary.
However,
these
measures,
when
combined
with
potential
Federal
measures
expected
during
the
period,
could
bring
the
area
into
attainment
by
2007.
Tennessee
is
considering
measures
such
as
NOx
Reasonably
Available
Control
Technology
rules
for
stationary
sources,
expanded
Stage
I
vapor
recovery,
emissions
inspections,
and
antitampering
measures.
Memphis­
Shelby
county
is
considering
measures
such
as
diesel
engine
idling
limits,
reduced
speed
limits,
controlled
burning
restrictions,
and
On
Board
Diagnostic
II
emission
testing.
Arkansas
is
considering
measures
such
as
Stage
I
vapor
recovery,
truck
stop
electrification,
and
replacement/
retrofit
construction
equipment
engines.

In
addition,
EPA
has
provided
Arkansas
with
$
100,000
in
funds
to
implement
truck
stop
electrification
in
Crittenden
7
County.

5.5
Trends
The
area's
design
value
is
92
ppb,
one
ppb
above
the
Marginal
classification
design
value
based
on
2001
­
2003
data.
The
area
has
not
had
any
exceedences
at
the
Crittenden
County
monitor
in
2004
through
September
10.
The
4th
highest
monitor
value
is
78
ppb.
If
this
value
remains
the
4th
highest
for
2004,
the
design
value
will
decline
to
87,
well
within
the
Marginal
range
and
only
3
ppb
above
the
attainment
level.
With
the
monitor
values
already
established
for
2002
and
2003,
the
Crittenden
County
monitor
could
have
a
4th
high
value
as
high
as
91
ppb
for
2004
and
the
design
value
would
still
decline
from
92
to
91,
which
is
the
upper
limit
for
the
Marginal
classification.
Also,
with
the
monitor
values
already
established
for
2002
and
2003
for
the
Shelby
County
monitors,
the
2004
data,
to
date,
are
indicating
attainment.
The
design
value
trends
for
the
two
Shelby
County
monitors
have
declined
since
2000.
Air
quality
trends
data
from
1982
to
2003
for
the
Shelby
County
monitors
was
reviewed.
In
addition,
from
1998
to
present
the
number
of
8­
hr
ozone
exceedances
by
year
have
consistently
decreased
at
a
majority
of
the
monitors.
Therefore,
the
trends
in
design
value
and
exceedences
indicate
the
Marginal
classification
is
reasonable
at
this
time.
A
table
of
historical
design
values
is
in
Appendix
6.2.

The
emissions
from
ozone
precursors
VOC
and
NOX
from
stationary
sources
in
Shelby
County,
TN,
have
declined
significantly
since
1993.
Emissions
estimates
in
the
Memphis
MSA
(
excluding
Marshall,
Tate
and
Tunica),
from
the
Memphis
Early
Action
compact
March
31,
2004
submittal,
indicate
that
emissions
should
decrease
by
28%
for
NOX
and
19
%
for
VOCs
from
2001
to
2007.
The
air
quality
and
emissions
trends
support
reclassification.

Shelby
County
is
included
in
the
NOx
SIP
call
which
requires
reductions
of
57.5
tons
per
day
(
tpd)
of
NOx
emissions
from
the
Tennessee
Valley
Authority
(
TVA)
Allen
Power
Plant.
Selective
Catalytic
Reduction
Controls
are
on
all
emission
units
at
the
TVA
Allen
Plant.
These
and
other
NOx
SIP
call
controls
were
included
in
the
modeling
studies
and
should
further
reduce
the
possibility
of
regional
transport
affecting
the
MONA.
The
area
has
yet
to
fully
realize
the
air
quality
improvements
which
will
be
achieved
from
the
57.5
tpd
reduction.
We
anticipate
drops
in
the
number
of
8
exceedences
and
the
magnitude
of
the
4th
highest
monitor
observations
in
2004
which
would
begin
to
demonstrate
the
air
quality
improvement
achieved
in
response
to
the
measures.
Also,
it
is
anticipated
the
2004
and
2005
design
values
will
show
air
quality
improvements
from
these
measures.

Population
growth
projections
used
in
analysis
for
8­
hour
ozone
designations
show
virtually
no
growth
for
the
MONA
between
2000
and
2010.
Crittenden
County
is
projected
to
grow
0.2%
and
Shelby
County
5.2%
over
the
10
year
period.
This
low
level
of
growth
should
not
add
significant
emissions
to
the
MONA.

5.6
Years
of
data
The
period
used
for
classification
is
2001
­
2003.

5.7
Additional
Information
The
petitioners
have
emphasized
that
the
States
of
Tennessee
and
Arkansas,
along
with
the
local
governments
of
Shelby
and
Crittenden
Counties,
have
produced
a
plan
of
action
which
will
result
in
real
ozone
reductions
and
attainment
by
2007
through
an
exhaustive
collaborative
effort.

EPA
Regions
4
and
6
received
letters
from
City,
State
and
Congressional
Representatives,
supporting
approval
of
the
petition.
In
addition,
the
Tennessee
Chapter
of
the
Sierra
Club
sent
a
letter
to
the
Memphis
and
Shelby
County
Health
Department
and
copied
EPA
Region
4
requesting
that
EPA
require
public
participation
in
the
petition
process
for
reclassification
and
that
the
area
retain
the
moderate
designation
until
five
years
of
data
are
collected
to
justify
a
downward
reclassification
of
the
area.

EPA
Regions
4
and
6
also
received
additional
letters
from
the
State
of
Tennessee
and
the
City
of
Memphis/
Shelby
County
on
September
9,
2004,
further
strengthening
the
commitment
to
implement
additional
measures
shown
necessary
to
attain
the
8­
hour
ozone
standard
by
the
beginning
of
the
2006
ozone
season
(
Appendix
6.1).

5.8
Conclusions
The
Request
by
States
criteria
is
satisfied
since
the
petition
was
submitted
by
the
governors
of
Tennessee
and
Arkansas.
The
Discontinuity
criteria
is
satisfied
since
the
9
modeling
tests
submitted
showed
there
would
be
no
area
surrounded
by
one
or
more
areas
of
higher
classification.
The
Attainment
criteria
is
not
failed
since
the
modeling
shows
notable
progress
toward
attainment.
The
Emissions
Reductions
criteria
is
satisfied
because
of
the
emission
reductions
available
and
the
commitment
by
the
state
and
local
agencies
to
add
any
controls
necessary
to
attain
the
8­
hour
standard
based
on
a
comprehensive
study
of
sources
contributing
to
nonattainment.
The
Trends
criteria
is
satisfied
since
the
downward
trends
in
air
quality
monitor
and
emissions
data
and
the
lack
of
growth
over
the
time
period
to
attainment
are
strong
indicators
of
progress
towards
attainment.
The
Years
of
Data
criteria
is
satisfied
since
the
years
chosen
(
2001
­
2003)
are
consistent
with
the
time
period
used
for
the
designations
for
the
8­
hour
ozone
standard.
In
addition,
the
air
quality
monitor
data
through
September
10,
2004,
indicates
that
the
area's
design
value
is
likely
to
be
in
the
Marginal
range
by
the
end
of
the
2004
ozone
season.

In
summary,
the
data,
analysis,
and
commitments
presented
in
the
petition
support
the
likelihood
of
attainment
of
the
8­
hour
NAAQS
by
2007
and
support
the
request
for
downward
revision
to
the
8­
hour
ozone
classification
for
the
MONA.
The
EPA
will
be
working
with
the
States
and
the
MONA
to
assist
in
the
development
of
measures
through
use
of
the
field
study
results
and
updated
modeling.

5.9
EPA
action
The
request
meets
certain
criteria
EPA
established
(
request,
discontinuity,
emission
reductions,
trends,
and
data)
and
does
not
violate
any
of
the
criteria
(
attainment).
Therefore,
EPA
is
approving
the
reclassification
request
for
Memphis.

6.0
Additional
Information
Additional
information
regarding
the
bump
down
request
for
this
area
is
contained
in
the
docket
for
this
action.
This
information
includes
the
State
request,
supporting
documents,
and
other
necessary
material.
