STATE
OF
TENNESSEE
FOR
THE
CHATTANOOGA
EAC
Hamilton
County,
Meigs
County,
Marion
County
and
STATE
OF
GEORGIA
FOR
CHATTANOOGA
EAC
Catoosa
County
and
Walker
County
COMPLETENESS
CHECKLIST
FOR
EVALUATING
CONTROL
STRATEGIES
The
March
31,
2004
checklists
for
the
Chattanooga
and
Tennessee
EAC
area
is
supplemented
with
this
checklist
to
reflect
the
revisions
to
the
control
strategy
and
technical
demonstration
of
attainment.

1.
Does
the
control
strategy
describe
one
or
more
local
or
state
measures
that
are
specific,
quantified
and
permanent,
above
and
beyond
what
is
already
required?

Yes:
An
open
burning
ban
and
Stage
I
Vapor
Recovery
will
be
implemented
at
the
state
level
in
the
Chattanooga
(
GA)
area
in
Catoosa
and
Walker
counties.
Additionally,
Catoosa
and
Walker
counties
will
pursue
local
measures
such
as
truck
stop
electrification
projects,
school
bus
conversions
and
retrofits,
and
voluntary
smog
alert
programs.
In
Hamilton,
Meigs,
and
Marion
counties
and
ozone
season
open
burning
ban,
Stage
I
Vapor
Recovery,
anti­
idling
,
transit,
ozone
action
day
control
and
an
On­
Board
Diagnostics
vehicle
inspection
and
maintenance
program
for
Hamilton
County,
Tennessee
will
be
implemented.

2
through
6:
All
responses
for
checklist
items
2
through
6
are
still
current
as
presented
in
the
March
31,
2004
milestone
checklists
for
the
states
of
Georgia
and
Tennessee
for
the
Chattanooga
EAC
area.

COMPLETENESS
CHECKLIST
FOR
EVALUATING
TECHNICAL
ASSESSMENT
1.
Are
representative
episodes
modeled
that
were
reflective
of
a
typical
ozone
season
exceedance
that
meets
the
EPA
episode
selection
guidance
to
ensure
that
representative
meteorological
regimes
are
considered?

Yes:
Cartesian
Regression
Tree
(
CART)
analysis
used
to
identify
representative
regimes.
Three
regimes
were
identified
for
Chattanooga.
Two
exceedance
days
that
represent
two
of
the
three
key
exceedance
meteorological
regimes
for
Chattanooga,
with
a
range
of
8­
hour
ozone
exceedance
concentrations
from
98.1
to
105.5
were
modeled.
One
episode
was
modeled:
August
11­
20,
2000.
The
episode
is
representative
of
conditions
contributing
to
8­
hour
ozone
exceedances..

2.
Does
the
plan
include
MOBILE6
and
NONROAD
model
data
as
the
basis
for
the
emissions
inventory?
3.
Is
local
modeling
used
to
develop
the
attainment
control
strategy?

Yes:
The
8­
hour
ozone
attainment
demonstration
for
the
Chattanooga
EAC
was,
initially,
independently
developed
by
the
States
of
Georgia
and
Tennessee
using
different
modeling
systems
and
inputs
for
the
March
31,
2004
milestone
submittal.
Both
demonstrations
represent
reasonable
and
plausible
conditions.
The
Tennessee
modeling
in
the
March
31,
2004,
submittal
was
reviewed
as
the
primary
modeling
for
the
demonstration.
This
modeling
was
based
on
local
or
fine
grid
scale
(
i.
e.,
horizontal
grid
spacing
of
4
kilometers
(
km)).
The
Georgia
modeling
was
submitted
for
the
March
31,
2004
EAC
milestone
as
corroborative
or
supporting
data
for
the
Chattanooga
demonstration.
It
was
based
on
regional
modeling
using
a
horizontal
grid
scale
resolution
of
12
km.

The
revised
modeling
for
the
Chattanooga
EAC
area
submitted
in
June
2004
is
based
on
nested
grids
of
4/
12/
36
km
and
35
vertical
layers
were
used
in
the
MM5
meteorological
model.
Nested
grids
of
4/
12/
36
km
nested
grids
and
13
vertical
layers
were
used
in
the
CMAQ
air
quality
modeling.
The
local
assessment
for
the
Chattanooga
area
is
now
analyzed
within
a
4
km
grid.
The
revised
modeling
addresses
the
steps
that
should
be
developed
in
an
attainment
demonstration
and
adhere
to
draft
EPA
guidance.

4.
Does
the
plan
include
documentation
of
the
modeling
system
(
i.
e.,
meteorological,
emissions,
air
quality
models,
biogenic
processor)
used
in
the
local
demonstration?

Yes:
Air
quality,
meteorological
and
emissions
models
used
are
CMAQ,
MM5
and
SMOKE
(
Mobile
6
and
NONROAD2002).
BEIS3
database
used
to
process
biogenic
emissions.
EGAS4.0
used
in
developing
future
emissions.

5.
Was
the
base
case
model
performance
evaluation
documented
and
acceptable
and
consistent
with
EPA
guidance?

Yes:
Model
performance
for
the
one
hour
ozone
concentrations
was
submitted
and
were
acceptable.
However,
more
work
to
improve
the
model
performance
is
indicated.
The
model
performance
for
the
8­
hr
statistics
are
needed
for
each
EAC
area.

6.
Was
a
modeling
protocol
submitted?

No.

7.
Does
the
modeling
demonstrate
that
all
ozone
design
values
are
less
than
85
ppb?

Yes.
In
the
March
31,
2004
milestone
submittal,
the
Tennessee
modeling
predicted
a
2007
future
design
value
of
85.6
parts
per
billion
(
ppb)
that
does
not
indicate
attainment
while
the
Georgia
modeling
did
predict
a
2007
future
design
value
less
than
85
ppb.
Attainment
is
indicated
when
the
future
design
value
is
less
than
85
ppb.
The
supporting
weight
of
evidence
analysis
(
overall
model
predicted
ozone
improvement,
meteorological
influences,
and
attainment
test
sensitivities)
that
accompanied
the
March
31,
2004
attainment
modeling
also
was
inconclusive
to
support
a
decision
that
Chattanooga
would
more
than
likely
attain
the
NAAQS
by
2007.
The
EPA
believed
additional
control
measures
would
be
needed.
Additional
details
on
the
March
31,
2004
submittal
and
EPA's
review
are
included
in
the
April
30,
2003
Federal
Register
(
69
FR
23858)
and
on
the
EAC
website
at:
http://
www.
epa.
gov/
ttn/
naaqs/
ozone/
eac/
index.
htm..
In
the
June
2004
revised
modeling
based
on
the
4
km
grid
developed
by
the
state
of
Georgia,
the
modeled
and
screening
test
indicates
attainment.
Future
design
values
are
indicated
in
the
following
table.

monitor
location
1999­
2001
ambient
design
values
2007
modeled
design
values
FDV
Sequoyah
93
81
Chattanooga
VAAP
92
81
Meigs
Co.
93
81
8.
If
the
modeling
does
not
demonstrate
that
all
design
values
are
less
than
85
ppb,
was
acceptable
weight
of
evidence
provided
and
consistent
with
EPA
guidance
that
shows
the
area
will
attain
the
8­
hour
ozone
standard
by
December
31,
2007?

Yes/
No
Comment
field:
A
weight
of
evidence
analysis
is
not
needed
if
the
modeled
and
screening
attainment
tests
are
passed.

CONCLUSION:
In
June
2004,
the
states
of
Georgia
and
Tennessee
collectively
submitted
revised
modeling
which
includes
additional
local
control
measures
to
support
the
first
deferral
of
the
effective
designation
date
for
the
Chattanooga
EAC.
area.
The
modeling
is
based
on
a
revision
to
the
March
31,
2004
Georgia
EAC
modeling
submitted
Chattanooga.
EPA
believes
the
technical
information
submitted
is
adequate
to
grant
a
deferral
of
the
effective
designation
data.
This
review
does
not
constitute
a
decision
of
approval
of
the
attainment
demonstration
which
will
be
submitted
in
December
2004.
EPA
will
perform
a
more
comprehensive
review
of
the
Georgia
and
Tennessee
technical
analyses
before
making
a
decision
on
the
attainment
demonstration.
Both
the
March
31,
2004
modeling
submitted
by
Tennessee
and
the
current
GA
modeling
address
the
steps
that
should
be
developed
in
an
attainment
demonstration
and
adhere
to
draft
EPA
guidance.
However,
the
conclusions
from
these
submittals
do
not
totally
agree.
The
TN
modeling
does
not
indicate
attainment
but
suggests
that
additional
controls
are
needed.
Additional
controls
have
been
identified
and
were
modeled
in
the
June
2004
state
of
GA
modeling.
Additional
information
in
needed
as
mentioned
above
to
complete
the
technical
demonstration.

*****************************************************************************

DOES
THE
EARLY
ACTION
COMPACT
PLAN
MEET
THE
MARCH
31,
2004
MILESTONE?
Yes
­
Hamilton
County
and
Meigs
County,
Tennessee,
and
Catoosa
County,
Georgia
have
met
the
March
31,
2004
milestone
to
qualify
for
a
deferral,
to
September
30,
2005,
of
the
effective
date
of
nonattainment
designation
for
the
8­
hour
ozone
standard.
Marion
County,
TN
and
Walker
County,
GA
are
designated
attainment,
effective
June
15,
2004.
******************************************************************************
