Granite City, Illinois Technical Support Document

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Definition of important terms used in this document :

1) Designated “unclassifiable” – an area where EPA could not determine if there w as a violation of the 2008 lead NAAQS or a contribution to a violation in a nearby area, because there was insufficient air quality data for both 2006-200 8 and 2007-2009 and where additional monitoring data for 2010 could not result in a diff erent designation.

2) Designated “attainment” – an area which EPA has determined, based on the m ost recent 3 years of certified air quality data from 2006-2008 or 2007-2009, has no violations of the 2008 lead NAAQS during 36 consecutive valid 3-month site means; and which EPA has further

determined does not contribute to a violation of th e 2008 lead NAAQS in a nearby area and that additional monitoring data from 2010 could not resu lt in a different designation.

3) Designated “nonattainment” area – an area which EPA has determined, based on a State recommendation and/or on the technical analysis inc luded in this document, has a violation of the 2008 lead NAAQS during the most recent 3 consec utive years of quality-assured, certified air quality data.

4) Prior nonattainment area – an area that is currently designated as nonattainme nt or maintenance for the 1978 lead NAAQS (including both current nonattainment areas and maintenance areas).

5 ) Recommended nonattainment area – an area a State or Tribe has recommended to EPA be designated as nonattainment.

6) Violating monitor – an ambient air monitor whose design value exceeds 0 .15 micrograms per cubic meter (μg/m3). As described in Appendix R of part 50, a violation can be based on either Pb-TSP or Pb-PM10 data and only 3 months of data a re necessary to produce a valid violating design value.

7) 1978 lead NAAQS – 1.5 μg/m 3 , National Ambient Air Quality Standard for lead pr omulgated in 1978. Based on Pb-TSP indicator and averaged ov er a calendar quarter.

8) 2008 lead NAAQS – 0.15 μg/m 3 , National Ambient Air Quality Standard for lead promulgated in 2008. Based on Pb-TSP indicator and a 3-month rolling average. Pb-PM10 data may be used in limited instances, including to show nonattainment.2 ILLINOIS Area Designations For the 2008 Lead National Ambient Air Quality Standards EPA has revised the level of the primary (health-ba sed) standard from 1.5 micrograms per cubic meter (μg/m3) to 0.15 μg/m3 measured as total suspe nded particles (TSP). EPA has revised the secondary (welfare-based) standard to be identical in all respects to the primary standard.

Pursuant to section 107(d) of the Clean Air Act, EP A must designate as “nonattainment” those areas that violate the NAAQS and those nearby areas that contribute to violations. The table below identifies the partial county in Il linois that EPA is designating as

“nonattainment” for the 2008 lead National Ambient Air Quality Standard (2008 lead NAAQS).

Area (listed alphabetically) Illinois Recommended Nonattainment County EPA’s Designated Nonattainment County Nonattainment

Area for 1978 Lead NAAQS Granite City Madison (partial) Madison (partial) NA

Table 1: Illinois Nonattainment Area for the 2008 L ead NAAQS

Technical Analysis for Granite City

Introduction

This technical analysis for Granite City identifies the partial county with a monitor that violates the 2008 lead NAAQS and evaluates nearby counties f or contributions to lead concentrations in

the area. EPA has evaluated these counties based o n the weight of evidence of the following factors recommended in previous EPA guidance:

• Air quality in potentially included versus excluded areas;

• Emissions and emissions-related data in areas poten tially included versus excluded from the nonattainment area, including population data, growth rates, patterns, and emissions controls;

• Meteorology (weather/transport patterns);

• Geography/topography (mountain ranges or other air basin boundaries);

• Jurisdictional boundaries (e.g., counties, air dist ricts, reservations, etc.); and

• Any other relevant information submitted to or coll ected by EPA (e.g., modeling where done appropriately).3 Figure 1: Granite City State Recommended Nonattainm ent Area (Office of Air Quality and Standards Planning - OAQ PS)

Figure 1 is a map of the area analyzed showing the locations and design values of air quality monitors in the area, and the counties surrounding any violating air quality monitors. Source data is also labeled in Figure 1 with the following guidelines: if the source emitted 0.5 or more tons, the symbol, name of the facility, and emissio ns are labeled; if the source emitted 0.1 – 0.5 tons, only the symbol and emissions are labeled; an d if the source emitted less than 0.05 tons, only the symbol is shown. 1 Emissions in Granite City and the surrounding are as will be discussed in the section addressing emissions in Ma dison County. The location of the detailed

area in relation to the remainder of the State is s hown in the bottom right corner of the figure.

1 Emissions greater than 0.05 tpy round up to 0.1 tpy , and they are marked with the symbol and the emiss ions value. * Sources that are not labeled emitted less than 0.05 tpy.

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valid and less than or equal to 0.15 μg/m 3 . A design value is only valid if minimum data completeness criteria are met. A lead design value that meets the NAAQS is generally considered valid if it encompasses 36 consecutive v alid 3-month site means (specifically for a 3- year calendar period and the 2 previous months). F or this purpose, a

3-month site mean is valid if valid data were obtai ned for at least 75 percent of the scheduled monitoring days in the 3-month period. A lead desi gn value that does not meet the NAAQS is

considered valid if at least one 3-month mean that meets the same 75 percent requirement is above the NAAQS. That is, a site does not have to monitor for 3 full calendar years in order to have a valid violating design value; a site could m onitor just 3 months and still produce a valid (violating) design value.

The 2008 lead NAAQS design values for Madison County in Granite City an d the surrounding

area are shown in Table 2.

County State

Recommended

Nonattainment? Monitor Name Monitor Air Quality System ID Monitor Location Lead Design Value,

2006-2008 (μg/m 3 ) Lead Design

Value,

2007-2009 (μg/m 3 )
Madison,

Illinois Yes Granite City 171190010 15 th and

Madison St. 0.28 0.28

Madison,

Illinois No* Wood River 171193007 54 N. Walcott St. 0.04 0.0 4

Monitor in bold has the highest 2006-2008 and 2007- 2009 design value in the respective county. * This monitor is in Madison County, but is in the city of Wood River (and there fore not in the State recommended nonattainment are a).

Table 2: Granite City, Illinois and Surrounding Are as Air Quality Data

Madison County shows a violation of the 2008 lead N AAQS. Therefore some area in this county and possibly additional areas in surrounding counties must be designated nonattainment. The absence of a violating monitor alone is not a s ufficient reason to eliminate nearby counties

as candidates for nonattainment status. Each area has been evaluated based on the weight of

evidence of these factors and other relevant inform ation.

According to EPA’s monitor locator, 2 the monitor located at 15 th and Madison St. (AQS ID 171190010) has an objective of determining the high est concentration for lead. This monitor is in very close proximity to US Steel Granite City Wo rks (US Steel). The location of this monitor will be discussed in the section addressing emissio ns for Madison County.

2 http://www.epa.gov/air/data/geosel.html.6

Emissions and Emissions-Related Data

Evidence of lead emissions sources surrounding a vi olating monitor are an important factor for determining whether a nearby area is contributing t o a monitored violation. For this factor, EPA evaluated county level emission data for lead and p opulation data.

Emissions

Emissions data were derived from the 2005 National Emissions Inventory (NEI), version 2, which is the most up-to-date version of the nationa l inventory available when these data were compiled for the designations process in 2009. See http://www.epa.gov/ttnchie1/net/2005inventory.html. EPA recognizes that for certain counties, emissions may have changed since 2005. For example , certain large sources of emissions in or near this area may have installed emission controls or otherwise significantly reduced emissions since 2005. Some States provided updated informati on on emissions and emission controls in their comments to EPA. Illinois provided estimated emissions inventory data for Madison County in their submittal, which will also be consi dered in this analysis. Emissions data are provided in Table 3 and Table 4 below.

Table 3 shows total emissions of lead given in tons per year (tpy) for violating and potentially contributing counties in and around Granite City an d sources emitting (or anticipate to contribute) 0.1 ton per year or greater of lead acc ording to the 2005 NEI. The county that is part of the Granite City nonattainment area for the 2008 lead NAAQS is shown in boldface . Table 4 shows total emissions of lead given in tons per yea r for violating and potentially contributing counties in and around Granite City for all sources . This table is based on 2006-2008 estimated emissions, and was provided by Illinois EPA in its October 2009 submittal.

There are approximately 20,000 airport facilities i n the U.S. at which leaded aviation gasoline is consumed. To evaluate the potential impact of emis sions at and near these facilities, EPA

recommends that States use the draft 2008 NEI. The se data are provided in Table 5, and contain the facilities emitting (or anticipate to contribut e) 0.1 ton per year or greater of lead according to

the draft 2008 NEI.7

County Facility in State

Recommended

Nonattainment Area? Facility Name 2005 NEI (tpy) Location City

Madison County Yes US Steel Corporation – Granite City 0.9 1520 20 th St. Granite City

Madison County Yes ASF-Keystone, Inc 0.2 1700 Walnut St. Granite City

Madison County No Chemetco Inc 0.2 3754 Chemetco

Ln. Hartford

Madison County No Stein Steel Mill

Services Inc 0.2 5 Cut St. Alton

Madison County No Olin Corp 0.1 427 N Shamrock

St. East

Alton

Madison County No BP Products North America, Inc: Wood

River Terminal 0.1 335 S Old St.

Louis Rd. Wood

River

Total Lead Emissions for Madison County 2.0* Table 3: Granite City, Illinois and Surrounding Are as Lead Emissions for Stationary Sources * Total lead emissions for Madison County were calcul ated by adding the 2005 NEI data for facilities not using leaded aviation gas (stationary sources) to the 200 8 Draft NEI data for facilities using aviation gas. Sources with emissions below 0.1 tpy were included in this final calculation.8 Table 4: Granite City, Illinois and Surrounding Are as 2006-2008 Lead Emissions for Stationary Sources (Illinois EPA )

There are 2 facilities using leaded aviation gasoli ne in the Granite City area that have a 2008 Draft NEI value of at, or greater, than 0.1 tpy. T hese facilities are located below in Table 5.

City Facility Name Type 2008 Draft NEI (tpy)
Alton/St. Louis St. Louis Regional Airport 0.2

St. Jacob St. Louis Metro-East/Shafer

Field Airport 0.1 Table 5: Granite City, Illinois and Surrounding Are as Lead Emissions for Leaded Aviation Gas Facilitie s

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(Winnebago County). Additionally, monitoring at Jo hnson Controls Battery Group (Kane County) will be necessary if a permit is issued to expand operations beyond 1.0 ton per year.

Population Data, Growth Rates, and Patterns

Table 6 shows the 2008 population for each county i n the area being evaluated, as well as the population density for each county in that area. T hese data help assess the extent to which the

concentration of human activities in the area and c oncentration of population-oriented commercial development may indicate emissions-based activity contributing to elevated ambient lead levels. This may include ambient lead contrib utions from activities that would disturb lead that has been deposited on the ground or on other s urfaces. Re-entrainment of historically deposited lead is not reflected in the emissions in ventory.

County State

Recommended

Nonattainment? 2008

Population 2008

Population Density (pop/sq mi) Population

Change

2000-2008 Population %

Change

2000-2008

Madison Yes 268,078 362 8,961 3

Table 6: Population Data for Madison County, Illino is

[Source of data: U.S. Census Bureau estimates for 2 008 (http://www.census.gov/popest/datasets.html) and es timation of the area of U.S. counties]

EPA has considered the population growth rate for t his area and does not believe that it affects the boundary recommendation.

Emissions Controls

Under this factor, the existing level of control of emission sources is taken into consideration. The emissions data used by EPA in this technical an alysis and provided in Table 3 represent emissions levels taking into account any control st rategies implemented in Granite City before 2005 on stationary sources. EPA has not received d etailed information on emissions reductions resulting from controls put into place at US Steel Corporation since 2005, but Illinois included

emissions reductions measures that have assisted in impacted emissions levels from a wide spectrum of sectors in the Metro-East/St. Louis are a. These measures include: MACT for Iron and Steel Manufacturing and Foundries; promulgation of the St. Louis nonattainment area for

PM 2.5 , NESHAPS limits; and NSPS limits. Additionally, I llinois EPA has cited new locomotive engine standards that have assisted with emissions reductions.

Meteorology (weather/transport patterns)

For this factor, EPA considered data from National Weather Service instruments and other meteorological monitoring sites in the area. Histo rical wind direction frequencies collected between 1960 and 1992 are included in Figure 4 and Table 7. These data may provide evidence of the potential for lead emissions sources located upwind of a violating monitor to contribute to

ambient lead levels at the violation location. Ill inois EPA provided a wind rose for Madison11

County based on data collected between 1961 and 199 0 at St. Louis/Lambert International Airport. The graphical representation is shown in Figure 5.

Figure 4: Historical Wind Direction Frequencies for Madison County, Illinois

Figure 4 is a 3-dimensional bar chart that shows th e wind frequencies in 8 directions for the 4

seasons. These data are taken from 1960-1992 Solar and Meteorological Surface Observation Network information issued jointly by the U.S. Depa rtment of Commerce: National Climatic Data Center and the U.S. Department of Energy: Nati onal Renewable Energy Laboratory. The chart frequencies reflect the directions from which the winds come.12 Madison County Wind Frequencies

**Frequency as a % Seasonal Wind** 

**Directions**

**7.90 WINWINDFNNE** 

**5.21 WINWINDFENE** 

**11.62 WINWINDFESE** 

**13.87 WINWINDFSSE** 

**12.75 WINWINDFSSW** 

**11.34 WINWINDFWSW** 

**25.62 WINWINDFWNW** 

**11.69 WINWINDFNNW** 

**8.62 SPRWINDFNNE** 

**7.28 SPRWINDFENE** 

**15.73 SPRWINDFESE** 

**15.74 SPRWINDFSSE** 

**14.52 SPRWINDFSSW** 

**10.35 SPRWINDFWSW** 

**18.26 SPRWINDFWNW** 

**9.50 SPRWINDFNNW** 

**10.08 SUMWINDFNNE** 

**7.59 SUMWINDFENE** 

**13.27 SUMWINDFESE** 

**13.95 SUMWINDFSSE** 

**20.88 SUMWINDFSSW** 

**14.40 SUMWINDFWSW** 

**12.34 SUMWINDFWNW** 

**7.48 SUMWINDFNNW** 

**8.45 AUTWINDFNNE** 

**5.27 AUTWINDFENE** 

**12.99 AUTWINDFESE** 

**18.51 AUTWINDFSSE** 

**17.36 AUTWINDFSSW** 

**10.63 AUTWINDFWSW** 

**17.08 AUTWINDFWNW** 

**9.70 AUTWINDFNNW**  Table 7: Historical Wind Frequency Data as Percents for Madison County, Illinois

As shown in Figure 4 and Table 7, the period with t he highest wind frequency occurs in the winter months, with winds blowing from the west nor thwest. There is also a strong representation of winds from any variation of the s outh.13 Figure 5: Wind Rose for Madison County (Illinois EP A)

The wind rose for Madison County based on data coll ected between 1961 and 1990 at St. Louis/Lambert International Airport provided by Ill inois EPA corroborates the bar graph representation provided in Figure 4. The wind rose shows the winds blowing from the west northwest, as well as the strong consistent represe ntation of winds from the south and southeast.

Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the phy sical features of the land that might have an effect on the air shed and, therefore, on the distr ibution of lead over Granite City and the surrounding area.14

The Granite City area does not have any geographica l or topographical barriers significantly limiting air pollution transport within its air she d. Therefore, this factor did not play a significa nt role in determining the nonattainment boundary.

Jurisdictional boundaries

Existing jurisdictional boundaries may be helpful i n articulating a boundary for purposes of nonattainment designations, and for purposes of car rying out the governmental responsibilities of planning for attainment of the lead NAAQS and imple menting control measures. These existing boundaries may include an existing nonattainment or maintenance area boundary, a county or township boundary, a metropolitan area boundary, an air management district, or an urban planning boundary established for coordinating busi ness development or transportation activities.

In EPA’s August 21, 2009 guidance memorandum, “Area Designations for the 2008 revised Lead National Ambient Air Quality Standard,” EPA re iterated that the presumptive boundary for each nonattainment area should be the county contai ning the violating monitor. This concept was first introduced in the guidance for the 1978 l ead NAAQS designations, and is described in the 1992 General Preamble (57 FR 13549). This same presumptive boundary guidance was addressed most recently in the final rulemaking for the 2008 lead NAAQS (73 FR 66964). EPA observed, however, that States have the flexibility in their recommendations to deviate from the presumptive county boundary to portions of the coun ty containing the violating monitor, stating that any “nonattainment area boundaries that deviat e from presumptive county boundaries should be supported by an assessment of several factors... ,” all of which have been discussed already in this document, except for jurisdictional boundaries

.

For the Granite City nonattainment area, there are several jurisdictional boundaries that can be considered, as discussed further below. Madison Co unty is located within the East-West Gateway Council of Governments study area, and Illi nois EPA is responsible for all air quality regulatory programs in every county in the State. As a result, air quality planning efforts to address the impending lead nonattainment area in Gr anite City should not be problematic; it should be noted that the final rulemaking for the 2 008 lead NAAQS (73 FR 66964) specifically addressed transportation conformity by stating, “In light of the elimination of lead additives from gasoline, transportation conformity does not apply to the Lead NAAQS.”

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Although not included with the October 2009 submitt al, Illinois EPA performed modeling analysis for US Steel as part of the agency’s “Illi nois Ambient Air Lead Monitoring Plan.” The supporting documents for the monitoring plan were s ubmitted to EPA in a letter dated July 30, 2009 from Robert Kaleel, Manager of the Air Quality Planning Section, Bureau of Air. The receptor grid that Illinois EPA to construct the mo deling and the results from this modeling analysis are shown below in Figure 7 and Figure 8 b elow.

Figure 7: Air Dispersion Modeling Receptor Grid for Granite City, Illinois (Illinois EPA)

Although the receptor grid was included in this ima ge provided by Illinois EPA, no additional information about the receptor resolution was provi ded.17 Figure 8: Modeling Analysis Results for Granite Cit y (Illinois EPA)

The modeling performed for US Steel was performed f or a 5 year period between 2003 and 2007

based on actual emissions. Illinois EPA determined that the St. Louis surface meteorological data and Lincoln upper air meteorological data were representative of the Granite City area. Downwash parameters were developed based on detaile d aerial photography information for buildings. Modeled fugitive lead emission sources included uncaptured basic oxygen furnace roof monitor emissions and coke battery door emissi ons. They were treated as 17 discrete volume sources. In addition, 5 point sources were included in the modeling, though emission estimates from re-entrainment of dust from roadways , stockpiles, or other traditional fugitive sources were not available for this facility, and t hus not modeled. The point of maximum impact was modeled to be 0.04 μg/m 3 along the northeast fenceline.

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In an August 16, 2010 letter, Douglas P. Scott, Dir ector of Illinois EPA stated, on behalf of the Governor of Illinois that IEPA did not agree with E PA’s proposed expansion of the boundaries

because “ no additional lead emission sources are in the adde d area and that including this area establishes a relatively esoteric boundary. ”

Illinois also included in the August 16, 2010 lette r an “ alternate recommendation, ” to revise the boundaries to include Granite City Township 4 and Venice Township. In support of this recommendation, Illinois stated “ [c]oincident jurisdictional boundaries, such as Tow nships, will help articulate the boundary of the nonattainment a rea while still encompassing the contributing emissions sources and the area that U.S. EPA propos es to be added to our initial

recommendation. ”

Figure 11: Alternate Recommendation for the Granite City Nonattainment Area (Illinois EPA)

4 There is a small difference between the boundaries of the city of Granite City and those of Granite C ity Township.21

Figure 11 illustrates Illinois EPA’s recommendation s. Illinois’ preferred recommendation is the borders of the City of Granite City, (shown in the black outline, “IEPA Original Proposed Boundary”). Illinois EPA’s alternative recommendat ion, is to include both Granite City Township (represented by the darker yellow) and Ven ice Township (represented in green) as the final nonattainment area for the 2008 lead NAAQS.

Granite City, Illinois Final Nonattainment Area

EPA is treating the proposed alternate recommendati on as a revision to the State’s original October 5, 2009, recommendation and is accepting th e alternate recommendation as the nonattainment boundary for the Granite City area.

EPA has concluded that including in the nonattainme nt area some area to the south of the US Steel facility, and outside the boundaries of the c ity of Granite City, is necessary in order to encompass the entire area of nonattainment. EPA’s decision that the nonattainment area extends beyond the city of Granite City is not based on a b elief that U.S. Steel’s facility extends beyond the city limits. However, EPA believes that extend ing the boundary beyond the city of Granite City is appropriate in order to capture all likely impacts from the emissions at the facility on the surrounding area, based on the under predicting ten dencies of the modeling provided in conjunction with meteorological data.

Having determined that the boundary needs to be ext ended beyond the city limits of Granite City

in order to include all areas that do not meet the 2008 lead NAAQS, EPA agrees that Illinois’ alternative recommendation appropriately encompasse s the entire area of nonattainment. Additionally, Illinois EPA’s recommendation consist s of well-delineated jurisdictional boundaries, which facilitates air quality planning for the area. Likewise, the revised recommendation clarifies and simplifies the boundar ies of the final nonattainment area for interested parties. For these reasons, EPA is adop ting Illinois’ alternative recommendation as the

basis for the nonattainment boundaries for this are a, as seen below in Figure 12. (Source data is also labeled in Figure 12 with the following guidel ines: if the source emitted 0.5 or more tons, the symbol, name of the facility, and emissions are labeled; if the source emitted 0.1 – 0.5 tons, only the symbol and emissions are labeled; and if t he source emitted less than 0.05 tons, only the symbol is shown.) 5

5 Emissions greater than 0.05 tpy round up to 0.1 tpy , and they are marked with the symbol and the emiss ions value.22 Figure 12: Granite City, Illinois Final Nonattainm ent Area