1 ----------------------------------------------------------------------------------------------------------------------------- - DRAFT Technical Support Document (TSD)

Tennessee Area Designations For the

2010 SO 2 Primary National Ambient Air Quality Standard

Summary

Pursuant to section 107(d) of the Clean Air Act (CAA), EPA must initially designate areas as either

“unclassifiable ,” “attainment ,” or “nonattainment” for the 2010 1

- hour sulfur dioxide (SO 2 ) primary national ambient air quality standard (NAAQS). The CAA defines a nonattainment area as one that does not meet the NAAQS or that contributes to poor air quality in a nearby area that does not meet the NAAQS. Table 1 be low identifies the counties or portions of counties (or areas of Indian Country ) in

Tennessee that EPA intends to designate “nonattainment” based on monitored violations

.

Table 1. Nonattainment Area Designations for Tennessee

Area Tennessee Recommended Designation of Areas/Counties EPA’s Intended Designation of

Areas/Counties

Sullivan County Area Sullivan County (partial) Nonattainment Nonattainment

Background

On June 2, 2010, EPA revised the primary SO 2 NAAQS (75 FR 35520, June 22, 2010) by establishing a

new 1

- hour standard at a level of 75 parts per billion (ppb) which is attained when the 3

- year average of

the 99 th percentile of the daily maximum 1

- hour average concentration at each monitor in an area does not exceed 75 ppb. EPA has determined that this is the level necessary to provide protection of public health with an adequate margin of safety, especially for children, the elderly and those with asthma. These groups are particularly susceptible t o the health effects associated with breathing SO 2 . The Agency is revoking the two prior primary standards of 140 ppb evaluated over 24

- hours, and 30 ppb evaluated over an entire year because the standards will not add additional public health protection given

a 1

- hour standard at 75 ppb. Accordingly, EPA is not designating areas in this process on the basis of either of these two prior primary standards. Similarly, the secondary standard for SO 2 has not been revised, so EPA is not designating areas in t his process on the basis of the secondary standard.

EPA’s SO 2 Designation Approach

Section 107(d) of the CAA requires that not later than 1 year after promulgation of a new or revised NAAQS, state Governors must submit their recommendations for designations and boundaries to EPA.

This deadline was in June 2011. Section 107(d) also requi res EPA to provide a notification to states of

no less than 120

- days prior to promulgating an initial area designation that is a modification of a state’s

recommendation. EPA has reviewed the State’s recommendations and has notified the Governor through a letter signed by the Regional Administrator of any intended modifications. While language in2 section 107 specifically addresses states, we intend to follow the same process for tribes, pursuant to section 301(d) of the CAA and Tribal Authority Rule (40 C FR Part 49). Therefore, we intend to designate areas of Indian C ountry, in consultation with the tribes, on the same schedule as state designations. If a State or Tribe did not submit designation recommendations, EPA will promulgate the designations that it deems appropriate. If a S tate or Tribe disagrees with EPA’s intended area designations, it has an opportunity to demonstrate why any proposed modification is inappropriate. Tennessee does not have any tribes affected by this intend designation.

Designations guidance was issued by EPA through a March 24, 2011, memorandum from Stephen D. Page, Director, U.S. EPA, Office of Air Quality Planning and Standards, to Air Division Directors, U.S. EPA Regions I

- X. This memorandum identifies factors EPA in tends to evaluate in determining boundaries for areas designated nonattainment. These 5 factors include: 1) Air quality data; 2)

Emissions and emissions

- related data (location of sources and potential contribution to ambient SO 2 concentrations); 3) Meteo rology (weather/transport patterns); 4) Geography/topography (mountain ranges or other air basin boundaries); and 5) Jurisdictional boundaries (e.g., counties, air districts, pre

existing nonattainment areas, reservations), among any other information deem ed relevant to establishing appropriate area designations and boundaries for the 1

- hour SO 2 NAAQS.

The March 24, 2011, memo recommended that area boundaries be defaulted to the county boundary unless additional information justifies a larger or smaller bo undary than that of the county. EPA believes it is appropriate to evaluate each potential area on a case

- by

- case basis, and to recognize that

area

- specific analyses conducted by states, tribes and/or EPA may support a different boundary than a

default cou nty boundary.

In this TSD, EPA discusses its review and technical analysis of the recommendations submitted by the states and/or tribes for designations of the 1

- hour SO 2 standard and any modifications from these

recommendations.

Definition of important terms used in this document:

1) 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 violated the 2010 SO 2 NAAQS, based on the most recent three years of air quality monitoring data, or contributes to a violation in a nearby area.

2 ) Recommended nonattainment area

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

3 ) Violatin g monitor

– an ambient air monitor meeting all methods, quality assurance and citing criteria and requirements whose valid design value exceeds 75 ppb, as described in Appendix T of 40 CFR part

50.

4 ) 2010 SO 2 NAAQS

- 75 ppb, national ambient air quality standard for SO 2 promulgated in 2010.

Based on the 3

- year average of the 99 th percentile of the annual distribution of daily maximum 1

- hour average concentrations

.3 5 ) Design Value

– a statistic that describes the air quality status of a given area relative to the level of the NAAQS.4 Nonattainment Designations

Technical A nalysis for Sullivan County

Introduction

This technical analysis for Sullivan County identifies the partial county with a monitor that violates the

2010 SO 2 NAAQS based on 2009

- 2011 data, and evaluates nearby counties for contributions to SO 2 concentrations in the area. EPA has evaluated this county and nearby counties based on the weigh t of evidence of the factors recommended in the March 24, 2011, issued EPA guidance.

Figure 1 is a map of the area analyzed showing the locations and design values of air quality monitors in

the A rea, and the counties surrounding any violating air qualit y monitors.

Figure 1 : Locations and Design Values of Monitors in the Sullivan County Area

In May 2011

, the Tennessee Department of Environment and Conservation’s Commissioner Robert J.

Martineau recommended that Sullivan County be designated as “nonattainment ” for the 2010 SO 2 NAAQS based on monitored air quality data from 2008

- 2010

. Tennessee updated the recommendations

with letters d a ted June 3, 2011, January 23, 2012, and January 28, 2013

. The State refined its 2011 SO 2 nonattainment area re commendations to define a portion of Sullivan County which consists of a 4.3

- kilometer radius circle centered on a point that encompasses the Eastman Chemical Company facility5 and the one vio lating monitor in the County. The State also included in this bo undary the other monitor in the County which has incomplete data

. This partial county boundary also encompasses two local SO 2 sources, AFG Indust ries and Domtar Paper Company. This circle is defined with a center point of approximately 36.522 degrees lat itude and

- 82.542 degrees longitude. A map of this recommendation is provided in Figure 2

.

Figure 2 : Tennessee Recommended Partial County Area

Based on EPA ’ s technical analysis described below, EPA is intending to designate a portion of Sullivan County in Tennessee as nonattainment for the 2010 SO 2 NAAQS as part of the Sullivan County nonattainment area, based upon currently available information. This county is listed above in Table 1

.

Detailed Assessment

Air Quality Data

This factor considers the SO 2 air quality monitoring data, including the design values (in ppb) calculated for all air quality monitors in Sullivan County in the Sullivan County Area and the surrounding area

based on data for the 2009

- 2011 period.6 TD EC Commissioner Robert J. Martineau’s recommend ation was based on data from the Federal Equivalent Method monitor located in the State (Tennessee Designation Recommendation Letter, June

3 , 2011), i n a ccordance with 40 CFR Part 53.

The 2011 SO 2 NAAQS design values for the cou nty in the Sullivan County area and surrounding area

are shown in Table 2

.

Table 2 . Air Quality Data for Nonattainment Designations in Sullivan County, Tennessee

County State

Recommended

Nonattainment? Monitor Name Monitor Air Quality System ID Monitor Location SO 2 Design Value,

2009

- 2011 (ppb)

Sullivan County,

TN Yes EASTMAN

ROSS N.

ROBINSON 47

- 163

- 0007 36.5348,

- 82.5171 196

Monitors in Bold have the highest 2009

- 2011 design value in the respective county.

Sullivan County shows a violation of the 2010 SO 2 NAAQS. T herefore, 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 co unties as candidates for inclusion in a nonattainment area. Each area has been evaluated based on the weight of evidence of the five

factors and other relevant information.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA evaluated county level emissions data for SO 2 and any growth in SO 2 emitting activities since the d ate represented by those emissions data.

Emissions

EPA recognize s that there might be no new information on any changes in emissions that may have

occurred after 2008, but would consider more recent years if available

. While Tennessee provided 2008

emi ssions data, the State did not provide updated emissions information since 2008 and t herefore

, EPA

relied on the 2008 National Emissions Inventory ( NEI ) emissions data ( NEI08V2 ).

Table 3 shows total emissions of SO 2 (given in tpy ) for violating and potentially contributing counties in

and around the Sullivan County Area , including sources emitting greater than 100 tons per year of SO 2 according to the 2008 NEI . The county that contain s all or part of the Sullivan County nonattainment

area for the 2 010 SO 2 NAAQS is shown in bold.7 Table 3 . Annual SO 2 Emissions ( NEI08V2 )

County Facility >100 tpy (EIS or State Facility ID) Facility Emissions (tpy) Total County SO 2 Emissions ( tpy ) Sullivan County, TN E astman Chemical Company 21,925

26,159 Domtar Paper Company 892

AFG Industries

– Blue Ridge Plant 49

Figure 3 : Map of Bradley and McMinn Counties SO 2 Nonattainment Area with Nearby SO 2 Monitors and SO 2 Emissions Sources

Emissions Controls

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 on stationary sources in the Sullivan8 County Area up to and including the year 2008. EPA ha s not received any additional information on emissions reductions resulting from federally enforceable controls put into place after 2008.

Meteorology (weather/transport patterns)

Evidence of source

- receptor relationships between specific emissions sources and high SO 2 values at violating monitors is another important factor in determining the appropriate contributing areas and the appropriate extent of the nonattainment area boundary. For this factor, EPA considered recent hourly

mete orological dat a from the NWS site neares t to the violating monitor to determine which wind vectors

were associated with 1

- hour SO 2 exceedances. For the Sullivan Area

, 2009

- 2011 meteorological data

was evaluated from two NWS sites in the area. The two sites are the Bri stol/Tri City Airport (ID #

723183

- 138 77 ) and the Virginia Highlands site (ID# 724058

- 53818 )

. Figure 3 shows a map of the SO 2 monitor location, meteorological data location s , and the major emissions sources in the area. The Bristol/Tri City Airport is ap proximately 12 km south east of the violating monitor and the Virginia Highl ands site is approximately 50 kilometers northeast of the violating monitor

. Data from the Virginia Highlands site was evaluated because data was not available after July 2010 from the Bristol/Tri City Airport site. The primary SO 2 emissions source nearby is the Eastman Chemical Company facility

, located approximately 2 .5 k ilometers southwest from the violating monitor.

Figure 4 shows a wind rose of the hours exceeding the 1

- hr SO 2 NAAQS (75 ppb) at the Sullivan County violating monitor. The wind rose was developed using wind data from the Bristol/Tri City Airport site.

Figure 4 . Wind Rose of 2009

- 2011 hours exceeding the 1

- hr

SO 2 NAAQS at the violating monitor with wind da ta from
the Bristol/Tri

- City Airport

.

WIND ROSE PLOT: Sullivan County, TN - Bristol/Tri City Airport 2009-2011 Exceedance Hours - Monitor AQS ID# 47-163-0007

COMMENTS: COMPANY NAME:

U.S. EPA Region 4

MODELER: Rick Gillam, APTMD/APB/AQMTS

DATE: PROJECT NO.: NORTH

SOUTH WEST EAST 5% 10% 15% 20% 25%

WIND SPEED (m/s)

>= 11.1

8.8 - 11.1

5.7 - 8.8

3.6 - 5.7

2.1 - 3.6

0.5 - 2.1

Calms: 0.00%

TOTAL COUNT:

41 hrs. CALM WINDS:

0.00% DATA PERIOD:

Start Date: 1/8/2009 - 06:00
End Date: 7/18/2010 - 17:00

AVG. WIND SPEED: DISPLAY: Wind Speed Direction (blowing from)9 Figure 5 shows a wind rose of the hours exceeding the 1

- hr SO 2 NAAQS (75 ppb) at the Sullivan County violating monitor. The wind rose was developed using wind data from the Virginia Highlands

site.

Figures 4 and 5 show that the majority of the exceeding hours have winds blowing from the southwest and west with generally moderate wind speeds. As can be seen in Figure 3 , the Eastman Chemical Company facility is located approximately 2.5 k ilometers southwest of the m onitor. No other major sources are located near the violating monitor in the southwest to west direction. Therefore, the

Eastman Chemical facility is likely the major contributor to the violations at the monitor. It should be

noted that since the Virgin ia Highlands site is located approximately 50 k ilometers from the A rea, the winds measured there are generally representative of the area, but may differ somewhat from the actual wind patterns near the violating monitor. Figure 5 . Wind Rose of 2009

- 2011 hours exceeding the 1

- hr
SO 2 NAAQS at the violating monitor with wind data from the Virginia Highlands site.

WRPLOT View - Lakes Environmental Software WIND ROSE PLOT: Sullivan County, TN - Virginia Highlands 2009-2011 Exceedance Hours - Monitor AQS ID# 47-163-0007

COMMENTS: COMPANY NAME:

U.S. EPA Region 4

MODELER: Rick Gillam, APTMD/APB/AQMTS

DATE:

8/3/2012 PROJECT NO.: NORTH

SOUTH WEST EAST 4% 8% 12% 16% 20%

WIND SPEED (m/s)

>= 11.1

8.8 - 11.1

5.7 - 8.8

3.6 - 5.7

2.1 - 3.6

0.5 - 2.1

Calms: 0.00%

TOTAL COUNT:

132 hrs. CALM WINDS:

0.00% DATA PERIOD:

Start Date: 1/8/2009 - 06:00
End Date: 12/15/2011 - 11:00

AVG. WIND SPEED:

3.99 m/s DISPLAY: Wind Speed Direction (blowing from)10 Two additional points should be no ted. First, t he State submittal indicates that for Sullivan County the winds are climatologically from the west, west

- southwest, and southwest. Second, Eastman Chemical Company is undertaking a study to collect representative, site

- specific meteorology d ata around the facility for use in future modeling of the facility’s emissions. Additionally, the Eastman Chemical Company is planning to expand its SO 2 monitoring network in conjunction with a project to install and
operate a new on

- site meteorological monitoring station that will operate for a minimum of one year. This data will be useful for future analyses of SO 2 air quality in the A rea.

Geography/T opography (mountain ranges or other air basin boundaries)

M ost of Sullivan County is located in the Ridge and Valley Geographic Region, which covers 7,703 square miles and is situated between the Cumberland Plateau and the Unaka Mountains. Sullivan

C ount y is a rural area with urban centers. The topography of this region consists of long linear ridges with elevations of 1100 to 1500 feet, and parallel lowland valleys, where the elevations vary from 700 to

1000 feet. The ridges and valleys are typically o riented from northeast to southwest. Generally, the ridges and valleys have a higher elevation in the northern part of the region and slightly less elevated in

the south.

The violating SO 2 monitor and the major SO 2 emissions source (Eastman Chemical Co mpany) in the Sullivan County area are both located in a broad valley at an elevation of approximately 1

, 200 f ee t. There are ridges up to approximately 2

, 100 f eet within 5 kilometers from the Eastman Chemical Company, and the violating monitor. These rid ges potentially affect the wind directions and pollutant transport. However, t he Eastman Ross N. Robinson monitor is located in relatively flat terrain about 2.5 kilometers to the east northeast of the Eastman facility

. Therefore, this factor did not pla y a significant role in determining the nonattainment boundary.

Jurisdictional Boundaries

Once EPA identified the general areas that the Agency anticipated would be included in the nonattainment area, EPA then consider ed existing jurisdictional boundaries for the purposes of providing a clearly defined legal boundary and to help identify the areas appropriate for carrying out the air quality planning and enforcement functions for nonattainment areas.

No area in Sulliva n County has been or is currently designated nonattainment for a SO 2 NAAQS, so

EPA had no boundary related to previous nonattainment designations to consider for this area. Therefore, this factor did not play a significant role in determining the nonatt ainment boundary.

Modeling Analysis for Nonattainment Area Boundaries

The State did not supply air quality dispersion modeling for the Sullivan County A rea.

Other Relevant Information

There is no other relevant informatio n that EPA considered for this A rea.11 Conclusion

After considering the factors described above, EPA intends to find that it is appropriate to agree with the State of Tennessee’s recommendation to designate nonattainment the portion of Sullivan County

contained in a 4.3

- kilometer ra dius circle centered on a point that encompasses the Eastman Chemical Company facility and the one violating monitor in the County

. EPA’s conclusion is premised on the fact

that the air quality m onitor in Sullivan County shows a violation of the 2010 SO 2 NAAQS, based on

2009

- 2011 air quality data. T wo additional sources are captured within the boundary. Based on the consideration of all the relevant and available information, as described above, EPA believes that the boundary described herein encompass es the entire area that does not meet the 2010 SO 2 NAAQS.