Granite City, Illinois Technical Support Document

---------------------------------------------------------------------------------------------------------------------

---------------------------------------------------------------------------------------------------------------------

Definition of important terms used in this document: 

1) Designated “unclassifiable” – an area where EPA could not determine if there was 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 2006-2008 and 2007-2009 and where additional 

monitoring data for 2010 could not result in a different designation. 

2) Designated “attainment” – an area which EPA has determined, based on the most 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 the 2008 lead NAAQS in a nearby area and that 

additional monitoring data from 2010 could not result 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 included in this document, has a violation of 

the 2008 lead NAAQS during the most recent 3 consecutive years of quality-assured, certified air 

quality data. 

4) Prior nonattainment area – an area that is currently designated as nonattainment 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 are necessary to produce a valid violating 

design value. 

7) 1978 lead NAAQS – 1.5 μg/m3

, National Ambient Air Quality Standard for lead promulgated 

in 1978. Based on Pb-TSP indicator and averaged over a calendar quarter. 

8) 2008 lead NAAQS – 0.15 μg/m3

, 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-based) standard from 1.5 micrograms per cubic 

meter (μg/m3) to 0.15 μg/m3 measured as total suspended 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, EPA 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 Illinois 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 Lead 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 for contributions to lead concentrations in 

the area. EPA has evaluated these counties based on 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 potentially 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 districts, reservations, etc.); and 

• Any other relevant information submitted to or collected by EPA (e.g., modeling where 

done appropriately). 
3

Figure 1: Granite City State Recommended Nonattainment Area 

(Office of Air Quality and Standards Planning - OAQPS) 

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 emissions are labeled; if the source emitted 0.1 – 0.5 

tons, only the symbol and emissions are labeled; and if the source emitted less than 0.05 tons, 

only the symbol is shown.1

 Emissions in Granite City and the surrounding areas will be 

discussed in the section addressing emissions in Madison County. The location of the detailed 

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

 

 

 

1Emissions greater than 0.05 tpy round up to 0.1 tpy, and they are marked with the symbol and the emissions value. 

* Sources that are not labeled emitted less 

than 0.05 tpy. 
Copyrighted page(s) have been removed from 

this document. 

Please contact the EPA Docket Center, Public 

Reading Room to view this document. 

Address: 

1301 Constitution Ave, NW 

Room 3334 

Washington, DC 20004 

Telephone: 

202-566-1744 

Fax: 

202-566- 9744 

Email: 

docket-customerservice@epa.gov
5

valid and less than or equal to 0.15 μg/m3. 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 valid 3-month site means (specifically for a 3-

year calendar period and the 2 previous months). For this purpose, a 

3-month site mean is valid if valid data were obtained for at least 75 percent of the scheduled 

monitoring days in the 3-month period. A lead design 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 monitor just 3 months and still produce a valid 

(violating) design value. 

The 2008 lead NAAQS design values for Madison County in Granite City and 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/m3) 

Lead Design 

Value, 

2007-2009 

(μg/m3) 

Madison, 

Illinois 

Yes Granite City 171190010 15th and 

Madison St. 

0.28 0.28 

Madison, 

Illinois 

No* Wood River 171193007 54 N. Walcott St. 0.04 0.04 

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 therefore not in the State recommended nonattainment area). 

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

Madison County shows a violation of the 2008 lead NAAQS. 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 sufficient 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 information. 

According to EPA’s monitor locator,2

 the monitor located at 15th and Madison St. (AQS ID 

171190010) has an objective of determining the highest concentration for lead. This monitor is 

in very close proximity to US Steel Granite City Works (US Steel). The location of this monitor 

will be discussed in the section addressing emissions 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 violating monitor are an important factor for 

determining whether a nearby area is contributing to a monitored violation. For this factor, EPA 

evaluated county level emission data for lead and population 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 national 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 information 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 considered 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 and sources emitting (or anticipate to 

contribute) 0.1 ton per year or greater of lead according 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 year 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 in the U.S. at which leaded aviation gasoline is 

consumed. To evaluate the potential impact of emissions at and near these facilities, EPA 

recommends that States use the draft 2008 NEI. These data are provided in Table 5, and contain 

the facilities emitting (or anticipate to contribute) 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 20th 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 Areas Lead Emissions for Stationary Sources 

* Total lead emissions for Madison County were calculated by adding the 2005 NEI data for facilities not using 

leaded aviation gas (stationary sources) to the 2008 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 Areas 2006-2008 

Lead Emissions for Stationary Sources (Illinois EPA) 

There are 2 facilities using leaded aviation gasoline in the Granite City area that have a 2008 

Draft NEI value of at, or greater, than 0.1 tpy. These 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 Areas Lead Emissions for Leaded Aviation Gas Facilities 
Copyrighted page(s) have been removed from 

this document. 

Please contact the EPA Docket Center, Public 

Reading Room to view this document. 

Address: 

1301 Constitution Ave, NW 

Room 3334 

Washington, DC 20004 

Telephone: 

202-566-1744 

Fax: 

202-566- 9744 

Email: 

docket-customerservice@epa.gov
10

(Winnebago County). Additionally, monitoring at Johnson 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 in the area being evaluated, as well as the 

population density for each county in that area. These data help assess the extent to which the 

concentration of human activities in the area and concentration of population-oriented 

commercial development may indicate emissions-based activity contributing to elevated ambient 

lead levels. This may include ambient lead contributions from activities that would disturb lead 

that has been deposited on the ground or on other surfaces. Re-entrainment of historically 

deposited lead is not reflected in the emissions inventory. 

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, Illinois 

[Source of data: U.S. Census Bureau estimates for 2008 

(http://www.census.gov/popest/datasets.html) and estimation of the area of U.S. counties] 

EPA has considered the population growth rate for this 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 analysis and provided in Table 3 represent 

emissions levels taking into account any control strategies implemented in Granite City before 

2005 on stationary sources. EPA has not received detailed 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 area. These measures include: MACT for Iron 

and Steel Manufacturing and Foundries; promulgation of the St. Louis nonattainment area for 

PM2.5, NESHAPS limits; and NSPS limits. Additionally, Illinois 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. Historical 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. Illinois EPA provided a wind rose for Madison 
11

County based on data collected between 1961 and 1990 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 the 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. Department of Commerce: National Climatic 

Data Center and the U.S. Department of Energy: National 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 the highest wind frequency occurs in the 

winter months, with winds blowing from the west northwest. There is also a strong 

representation of winds from any variation of the south. 
13

Figure 5: Wind Rose for Madison County (Illinois EPA) 

The wind rose for Madison County based on data collected between 1961 and 1990 at St. 

Louis/Lambert International Airport provided by Illinois 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 representation of winds from the south and southeast. 

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

The geography/topography analysis evaluates the physical features of the land that might have an 

effect on the air shed and, therefore, on the distribution of lead over Granite City and the 

surrounding area. 
14

The Granite City area does not have any geographical or topographical barriers significantly 

limiting air pollution transport within its air shed. Therefore, this factor did not play a significant 

role in determining the nonattainment boundary. 

Jurisdictional boundaries 

Existing jurisdictional boundaries may be helpful in articulating a boundary for purposes of 

nonattainment designations, and for purposes of carrying out the governmental responsibilities of 

planning for attainment of the lead NAAQS and implementing 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 business 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 reiterated that the presumptive boundary for 

each nonattainment area should be the county containing the violating monitor. This concept 

was first introduced in the guidance for the 1978 lead 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 county containing the violating monitor, stating 

that any “nonattainment area boundaries that deviate 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 County is located within the East-West 

Gateway Council of Governments study area, and Illinois 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 Granite City should not be problematic; it 

should be noted that the final rulemaking for the 2008 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.” 
Copyrighted page(s) have been removed from 

this document. 

Please contact the EPA Docket Center, Public 

Reading Room to view this document. 

Address: 

1301 Constitution Ave, NW 

Room 3334 

Washington, DC 20004 

Telephone: 

202-566-1744 

Fax: 

202-566- 9744 

Email: 

docket-customerservice@epa.gov
16

Although not included with the October 2009 submittal, Illinois EPA performed modeling 

analysis for US Steel as part of the agency’s “Illinois Ambient Air Lead Monitoring Plan.” The 

supporting documents for the monitoring plan were submitted 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 modeling and the results from this modeling 

analysis are shown below in Figure 7 and Figure 8 below. 

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

Although the receptor grid was included in this image provided by Illinois EPA, no additional 

information about the receptor resolution was provided. 
17

Figure 8: Modeling Analysis Results for Granite City (Illinois EPA) 

The modeling performed for US Steel was performed for 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 detailed aerial photography information for 

buildings. Modeled fugitive lead emission sources included uncaptured basic oxygen furnace 

roof monitor emissions and coke battery door emissions. 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 thus not modeled. The point of maximum impact 

was modeled to be 0.04 μg/m3

 along the northeast fenceline. 
Copyrighted page(s) have been removed from 

this document. 

Please contact the EPA Docket Center, Public 

Reading Room to view this document. 

Address: 

1301 Constitution Ave, NW 

Room 3334 

Washington, DC 20004 

Telephone: 

202-566-1744 

Fax: 

202-566- 9744 

Email: 

docket-customerservice@epa.gov
20

 

 

In an August 16, 2010 letter, Douglas P. Scott, Director of Illinois EPA stated, on behalf of the 

Governor of Illinois that IEPA did not agree with EPA’s proposed expansion of the boundaries 

because “no additional lead emission sources are in the added area and that including this area 

establishes a relatively esoteric boundary.” 

Illinois also included in the August 16, 2010 letter an “alternate recommendation,” to revise the 

boundaries to include Granite City Township4 and Venice Township. In support of this 

recommendation, Illinois stated “[c]oincident jurisdictional boundaries, such as Townships, will 

help articulate the boundary of the nonattainment area while still encompassing the contributing 

emissions sources and the area that U.S. EPA proposes 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 City Township. 
21

Figure 11 illustrates Illinois EPA’s recommendations. 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 recommendation, is to include both Granite City 

Township (represented by the darker yellow) and Venice 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 recommendation as a revision to the State’s original 

October 5, 2009, recommendation and is accepting the alternate recommendation as the 

nonattainment boundary for the Granite City area. 

EPA has concluded that including in the nonattainment area some area to the south of the US 

Steel facility, and outside the boundaries of the city 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 belief that U.S. Steel’s facility extends beyond 

the city limits. However, EPA believes that extending 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 tendencies of the modeling provided in 

conjunction with meteorological data. 

Having determined that the boundary needs to be extended 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 encompasses the entire area of nonattainment. 

Additionally, Illinois EPA’s recommendation consists of well-delineated jurisdictional 

boundaries, which facilitates air quality planning for the area. Likewise, the revised 

recommendation clarifies and simplifies the boundaries of the final nonattainment area for 

interested parties. For these reasons, EPA is adopting Illinois’ alternative recommendation as the 

basis for the nonattainment boundaries for this area, as seen below in Figure 12. (Source data is 

also labeled in Figure 12 with the following guidelines: 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 the source emitted less than 0.05 tons, only the 

symbol is shown.)5

 

5Emissions greater than 0.05 tpy round up to 0.1 tpy, and they are marked with the symbol and the emissions value. 
22

Figure 12: Granite City, Illinois Final Nonattainment Area