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DRAFT Technical Support Document (TSD)

Tennessee

Area Designations For the 

2010 SO2 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 (SO2) 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 below 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 SO2 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 99th 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 to the health effects associated with breathing SO2. 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 SO2 has not been 

revised, so EPA is not designating areas in this process on the basis of the secondary standard.

EPA’s SO2 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 requires 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 in 
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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 CFR Part 49). Therefore, we intend to 

designate areas of Indian Country, 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 State 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 intends 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 SO2

concentrations); 3) Meteorology (weather/transport patterns); 4) Geography/topography (mountain 

ranges or other air basin boundaries); and 5) Jurisdictional boundaries (e.g., counties, air districts, preexisting nonattainment areas, reservations), among any other information deemed relevant to 

establishing appropriate area designations and boundaries for the 1-hour SO2 NAAQS.

The March 24, 2011, memo recommended that area boundaries be defaulted to the county boundary 

unless additional information justifies a larger or smaller boundary 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 county 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 SO2 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 SO2

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) Violating 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 SO2 NAAQS - 75 ppb, national ambient air quality standard for SO2 promulgated in 2010. 

Based on the 3-year average of the 99th percentile of the annual distribution of daily maximum 1-hour 

average concentrations.
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5) Design Value – a statistic that describes the air quality status of a given area relative to the level of 

the NAAQS.
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Nonattainment Designations

Technical Analysis for Sullivan County

Introduction 

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

2010 SO2 NAAQS based on 2009-2011 data, and evaluates nearby counties for contributions to SO2

concentrations in the area. EPA has evaluated this county and nearby counties based on the weight 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 Area, and the counties surrounding any violating air quality 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 SO2

NAAQS based on monitored air quality data from 2008-2010. Tennessee updated the recommendations 

with letters dated June 3, 2011, January 23, 2012, and January 28, 2013. The State refined its 2011 SO2

nonattainment area recommendations 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 facility 
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and the one violating monitor in the County. The State also included in this boundary the other monitor 

in the County which has incomplete data. This partial county boundary also encompasses two local SO2

sources, AFG Industries and Domtar Paper Company. This circle is defined with a center point of 

approximately 36.522 degrees latitude 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 SO2 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 SO2 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. 
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TDEC Commissioner Robert J. Martineau’s recommendation was based on data from the Federal 

Equivalent Method monitor located in the State (Tennessee Designation Recommendation Letter, June

3, 2011), in accordance with 40 CFR Part 53.

The 2011 SO2 NAAQS design values for the county 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

SO2 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 SO2 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 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 SO2 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 SO2 and any growth in SO2 emitting activities since the date 

represented by those emissions data.

Emissions 

EPA recognizes 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 

emissions data, the State did not provide updated emissions information since 2008 and therefore, EPA 

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

Table 3 shows total emissions of SO2 (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 SO2

according to the 2008 NEI. The county that contains all or part of the Sullivan County nonattainment 

area for the 2010 SO2 NAAQS is shown in bold. 
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Table 3. Annual SO2 Emissions (NEI08V2)

County Facility >100 tpy 

(EIS or State Facility ID) Facility Emissions (tpy)

Total County SO2

Emissions

(tpy)

Sullivan County, TN Eastman Chemical 

Company 21,925

Domtar Paper Company 892 26,159

AFG Industries – Blue 

Ridge Plant 49

Figure 3: Map of Bradley and McMinn Counties SO2 Nonattainment Area with Nearby SO2

Monitors and SO2 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 Sullivan 
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County Area up to and including the year 2008. EPA has 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 SO2 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 

meteorological data from the NWS site nearest to the violating monitor to determine which wind vectors 

were associated with 1-hour SO2 exceedances. For the Sullivan Area, 2009-2011 meteorological data 

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

723183-13877) and the Virginia Highlands site (ID# 724058-53818). Figure 3 shows a map of the SO2

monitor location, meteorological data locations, and the major emissions sources in the area. The

Bristol/Tri City Airport is approximately 12 km southeast of the violating monitor and the Virginia 

Highlands 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 SO2 emissions source nearby is the Eastman Chemical Company facility, 

located approximately 2.5 kilometers southwest from the violating monitor.

Figure 4 shows a wind rose of the hours exceeding the 1-hr SO2 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 

SO2 NAAQS at the violating monitor with wind data 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)
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Figure 5 shows a wind rose of the hours exceeding the 1-hr SO2 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 kilometers southwest of the monitor. 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 Virginia Highlands site is located approximately 50 kilometers from the Area, 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 

SO2 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)
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Two additional points should be noted. First, the 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 data around the 

facility for use in future modeling of the facility’s emissions. Additionally, the Eastman Chemical 

Company is planning to expand its SO2 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 SO2 air quality in the Area.

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

Most 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 

County 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 oriented 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 SO2 monitor and the major SO2 emissions source (Eastman Chemical Company) in the 

Sullivan County area are both located in a broad valley at an elevation of approximately 1,200 feet. 

There are ridges up to approximately 2,100 feet within 5 kilometers from the Eastman Chemical 

Company, and the violating monitor. These ridges potentially affect the wind directions and pollutant 

transport. However, the 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 play 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 considered 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 Sullivan County has been or is currently designated nonattainment for a SO2 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 nonattainment boundary.

Modeling Analysis for Nonattainment Area Boundaries

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

Other Relevant Information

There is no other relevant information that EPA considered for this Area. 
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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 radius 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 monitor in Sullivan County shows a violation of the 2010 SO2 NAAQS, based on 

2009-2011 air quality data. Two 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 encompasses the entire area that does not meet the 2010 SO2 NAAQS.