### Illinois Unclassifiable Area Designations for the 2012 Primary Annual PM 2.5 

### National Ambient Air Quality Standards

Technical Support Document

1.0 Summary

**In accordance with section 107(d) of the Clean Air Act (CAA), the EPA must promulgate**  **designations for all areas of the country. In parti cular, the EPA must identify those areas that are**  **violating a National Ambient Air Quality Standard ( NAAQS) or contributing to a violation of the**  **NAAQS in a nearby area. The EPA identifies these ar eas as “nonattainment” areas. Additionally,**  **through the designation process, the EPA identifies areas that are meeting the NAAQS and those**  **areas without sufficient data for the Agency to mak e a determination. The EPA uses a**  **designation category of "unclassifiable/attainment" for areas where air quality monitoring data**  **indicate attainment of the NAAQS and for areas that do not have monitors but for which the**  **EPA has reason to believe are likely to be in attai nment and are not contributing to nearby**  **violations. The EPA reserves the category of "uncla ssifiable" for areas where the EPA cannot**  **determine based on available information whether th e area is meeting or not meeting the**  **NAAQS or where the EPA has not determined that the area contributes to a nearby violation.**  **The EPA must complete the initial area designation process within 2 years of promulgating a**  **new or revised NAAQS, or may do so within 3 years u nder certain circumstances.**  **1 This**  **Technical Support Document (TSD) describes the EPA’ s intent to designate certain areas in**  **Illinois as unclassifiable for the 2012 primary ann ual fine particle NAAQS (2012 annual PM**  **2.5 NAAQS).**  **2**

**Under section 107(d), states are required to submit area designation recommendations to the**  **EPA for the 2012 annual PM 2.5**  **NAAQS no later than 1 year following promulgation of the**  **NAAQS, or by December 13, 2013. On December 12, 201 3, Illinois recommended that specified**  **counties and portions of counties in the Illinois p ortions of the Chicago and St. Louis areas be**  **designated as nonattainment, and that the remaining counties and portions of counties in the state**  **be designated attainment/unclassifiable for the 201 2 annual PM**  **2.5 NAAQS, based on air quality**  **data from 2010 to 2012. Also on December 12, 2013, Indiana recommended that no counties**  **within the state be designated nonattainment, and I ndiana specifically recommended designating**  **Lake, Porter, and LaPorte Counties as attainment ba sed on monitoring data recorded within those** 

**1 Section 107(d) of the CAA requires the EPA to comp**  **lete the initial designation process within 2 years of**  **promulgation of a new or revised NAAQS, unless the Administrator has insufficient information to make**  **initial designation decisions in the 2-year time frame. In**  **such circumstances, the EPA may take up to 1 additi onal year to**  **make initial area designation decisions (i.e., no l ater than 3 years after promulgation of the standar**  **d).**

**2 On December 14, 2012, the EPA promulgated a revise**  **d primary annual PM 2.5**  **NAAQS (78 FR 3086, January 15, 2013). In that action, the EPA revised the primary**  **annual PM 2.5**  **standard, strengthening it from 15.0 micrograms pe r**  **cubic meter (μg/m 3**  **) to 12.0 μg/m 3** 

**. counties. On December 10, 2013, Missouri recommende**  **d that no portion of Missouri be**

**included in the St. Louis area and that all of the state be designated attainment/unclassifiable.** 

**However, a recent EPA-conducted technical systems a udit of the weighing of PM**  **2.5 samples in**  **Illinois revealed that the Cook County Department o f Environmental Control, which weighs all**  **of the filters in Illinois’ monitoring network, did not have appropriate equipment for determining**  **whether the laboratory conditions met the temperatu re and humidity criteria in 40 CFR 50**  **Appendix L for proper conditioning of filters, and the instantaneous temperature and humidity**  **information suggested that many of the weighings fa iled to meet these criteria.**  **3 As a result, the**  **EPA believes that no site in Illinois has sufficien t valid data to support a determination of either**  **nonattainment or attainment. Thus, the EPA cannot determine whether any area in Illinois is**  **meeting or not meeting the NAAQS. Furthermore, EPA cannot rely upon analyses the states**  **performed which partially rely upon this invalid mo nitoring data. Because the EPA cannot make**  **a final regulatory determination about whether a vi olation exists, in some cases the EPA is also**  **not able to determine whether counties nearby to th ose counties with incomplete monitoring data**  **contribute to a nearby violation. Consequently, the EPA intends to designate all of the affected**  **areas as “unclassifiable.”**

**After considering Illinois’, Indiana’s, Iowa’s and Missouri’s recommendations and based on the**  **EPA’s assessment of available information as descri bed in this TSD, EPA intends to designate**  **the areas identified in Table 1 as unclassifiable f or the 2012 annual PM**  **2.5 NAAQS at this time.**  **The CAA provides the EPA with discretion regarding whether and when to initiate a**  **redesignation process. The EPA may consider air qua lity data, planning and control**  **considerations, or any other air quality-related co nsiderations the Administrator deems**  **appropriate. As a result, the boundaries of any fut ure actions may not be those that EPA uses to**  **define the unclassifiable areas that EPA intends to promulgate now based on incomplete data.** 

Table 1. EPA’s Intended Unclassifiable Areas for th e 2012 annual PM 2.5 NAAQS

Area States’ Recommendations EPA’s Intended Unclassifiable Counties

**3 Memorandum dated August 14, 2014 from Liz Naess, G**  **roup Leader, Air Quality Analysis Group, US EPA Off ice**  **of Air Quality Planning and Standards, to EPA Docke t EPA-HQ-OAR-2012-0918,**  **Air Quality Designations for the 2012 PM**  **2.5 Standards, titled, “Data Quality Issues in Illinoi**  **s Affecting Air Quality Designations for the 2012 PM**  **2.5 National Ambient Air Quality Standard.”** **Chicago, IL-IN Illinois - Nonattainment for:**  **Cook County DuPage County**  **Kane County Lake County**  **McHenry County Will County**  **Grundy County (part) Kendall County (part)**  **Indiana: Attainment**  **Illinois: Cook County**  **DuPage County Kane County**  **Lake County McHenry County**  **Will County Grundy County (part)**  **Kendall County (part) Indiana:**  **Lake County Porter County** 

**St. Louis, IL-MO Illinois – Nonattainment for:**  **Madison County Monroe County**  **St. Clair County Randolph County (part)**  **Missouri: Unclassifiable/Attainment for all**  **counties Illinois:**  **Madison County Monroe County**  **St. Clair County Randolph County (part)**  **Missouri: St. Louis City**  **St. Louis County St. Charles County**  **Jefferson County Franklin County** 

**Davenport-Moline-Rock Island, IL-IA**  **Illinois – Unclassifiable/Attainment for:**  **Rock Island County Henry County**  **Mercer County Iowa –**  **Unclassifiable/Attainment for:**  **Scott County Illinois:**  **Rock Island County Henry County**  **Mercer County Iowa:**  **None - Scott County to be designated**  **Unclassifiable/attainment**

**Remainder of Illinois Unclassifiable/Attainment**  **Unclassifiable**

Chicago Area

**Chicago is the primary city of a three-state MSA th at includes fourteen counties: nine counties in**  **Illinois, four counties in Indiana, and one county in Wisconsin. The consolidated statistical area**  **(CSA) of which Chicago is the central city includes three additional MSAs (Kankakee, Michigan**  **City-LaPorte, and Ottawa-Peru) with an additional f ive counties. The urbanized portion of this**  **area includes substantial portions of the Chicago-N aperville-Elgin MSA, but the outer MSAs do**  **not contain significant urbanization as compared to the central Chicago area. The Chicago area**  **was designated nonattainment for the 1997 PM 2.5**  **NAAQS. Based on analysis of air quality, emissions, meteorological data, and other factors c**  **onsidering in determining those prior designations, EPA promulgated a Chicago, IL-IN nona**  **ttainment area that includes almost the entirety of the Chicago-Naperville-Arlington Height**  **s Metropolitan Division (Cook, Dupage, McHenry, and Will Counties along with portions for**  **Grundy and Kendall Counties) along with**

**selected counties from adjoining Metropolitan Divis ions of this MSA (Kane County from the**  **Elgin area, Lake and Porter Counties from the Gary, Indiana area, and Lake County, Illinois**  **from the Lake County-Kenosha County area). There ar e attaining monitors in Lake, Porter, and**  **LaPorte Counties in Indiana and in Kenosha County i n Wisconsin, as shown in Table 2. No data**  **for Illinois are shown in Table 2 because no site i n Illinois has sufficiently complete data for**  **computing a reliable design value.**

Table 2. Air Quality Data collected at Regulatory M onitors (all DV levels in μg/m 3 ) a

**County, State**  **Monitor**

**Site ID State Rec** 

**NA? 09-11** 

**DV 10-12** 

**DV 11-13** 

**DV** Lake, IN 18-089-0006 No 11.7 11.5 10.8 Lake, IN 18-089-0027 No 11.5 11.8 11.2 Lake, IN 18-089-0031 No 12.4 12.2 11.6 Lake, IN 18-089-2004 No 13.1 11.4 10.8 Lake, IN 18-089-2010 No 11.1 11 10.6 LaPorte, IN 18-091-0011 No 10.2 10.1 9.6 Porter, IN 18-127-0024 No 11.1 10.7 10.4 Kenosha, WI 55-059-0019 No 9.7 9.5 9.1

**a Where a county has more than one monitoring locatio**  **n, the county design value is indicated in red type**

**.**

**The TSD for the EPA’s designation of the Chicago ar ea for the 1997 standard provided an**  **extensive review of air quality data, emissions dat a, population, motor vehicle travel,**  **meteorology, and other related factors. While the I llinois air quality data are not sufficiently**  **complete to provide a reliable indication of the ma gnitude of concentrations, the available air**  **quality data suggest that the spatial distribution of exposure to PM**  **2.5 is similar to the distribution**  **EPA found in 2005, when it promulgated the Chicago 1997 PM**  **2.5 nonattainment area.**  **Furthermore, a review of the distribution of emissi ons, population, and vehicle travel also shows**  **a similar distribution of these parameters, in both cases showing the greatest quantity of**  **emissions, population, and vehicle travel in Cook C ounty but showing substantial quantities of**  **each of these parameters in the same list of surrou nding counties. This review therefore suggests**  **that if the Chicago area is violating the NAAQS, th e area that the EPA finds would likely be**  **contributing to that violation would likely be the same area as EPA found in 2005 to contribute**  **to violations of the 1997 PM 2.5**  **NAAQS.**
**Based on this analysis, the EPA intends to designat e a Chicago, IL-IN unclassifiable area that**  **includes the same area as was designated nonattainm ent for the 1997 PM**  **2.5 NAAQS. Thus, the**  **EPA intends to designate an unclassifiable area tha t includes Cook, Dupage, Kane, Lake,**  **McHenry, and Will Counties as well as Aux Sable and Goose Lake Townships in Gr**  **undy County and Oswego Township in Kendall County in Illinois**  **, and Lake and Porter Counties in Indiana. Other portions of Indiana are addressed in a TSD for the**  **Louisville area, and the EPA intends to designate the remainder of Indiana as unclassifiabl**  **e/attainment.**St. Louis Area

**St. Louis is the primary city of a two-state MSA th at includes the City of St. Louis and fifteen**  **counties: the City of St. Louis and seven counties in Missouri, and eight counties in Illinois. The**  **consolidated statistical area (CSA) of which St. Lo uis is the central city includes two additional**  **MSAs (Centralia, Illinois, and Farmington, Missouri ) with an additional two counties. The**  **urbanized portion of this area includes substantial portions of the St. Louis MSA, but the outer**  **MSAs do not contain significant urbanization relati ve as compared to the central St. Louis area.**  **The St. Louis area was designated nonattainment for the 1997 PM**  **2.5 NAAQS. Based on analysis**  **of air quality, emissions, meteorological data, and other factors considering in determining those**  **designations, EPA promulgated a St. Louis, IL-MO no nattainment area that included the urban**  **core of this area, including the City of St. Louis and four counties in Missouri and three counties**  **plus a portion of a fourth county in Illinois. The re are attaining monitors in Franklin, Jefferson,**  **St. Louis, and St. Charles Counties and St. Louis C ity, as shown in Table 3. No data for Illinois**  **are shown in Table 2 because no site in Illinois ha s sufficiently complete data for computing a**  **reliable design value.**

Table 3. Air Quality Data collected at Regulatory M onitors (all DV levels in μg/m 3 ) a

County, State Monitor

Site ID State Rec

NA? 09-11

DV 10-12

DV 11-13

DV **Franklin, MO N/A No No monitor Jefferson, MO 290990019**  **No 10.3 10.1**  **9.8 St. Louis, MO 291893001**  **No 10.9**  **10.9 St. Louis City, MO 295100085**  **No 12 11.7**  **11.1 St. Charles, MO**  **N/A No No monitor**

**a Where a county has more than one monitoring locatio**  **n, the county design value is indicated in red type**

**.**

**The TSD for EPA’s designation of the St. Louis area for the 1997 standard provided an extensive**  **review of air quality data, emissions data, populat ion, motor vehicle travel, meteorology, and**  **other related factors. While the Illinois air quali ty data are not sufficiently complete to provide a**  **reliable indication of the magnitude of concentrati ons at this time, the available air quality data**  **suggest that the spatial distribution of exposure t o PM**  **2.5 is similar to the distribution EPA found**  **in 2005, when it promulgated the St. Louis 1997 PM 2.5**  **nonattainment area. Furthermore, a review of the distribution of emissions, population**  **, and vehicle travel also shows a similar distribution of these parameters, with St. Louis Co**  **unty having approximately a fourth of the emissions of the various relevant pollutants and mo**  **re than a fourth of the area’s population and vehicle travel, and other surrounding counties in M**  **issouri and Illinois and the City of St. Louis also having significant nearby emissions, populatio**  **n and vehicle travel. This review therefore suggests that if the St. Louis area is violating th**  **e NAAQS, the area that EPA finds would likely be contributing to that violation would likely be t**  **he same area as EPA found in 2005 to**

**contribute to violations of the 1997 PM 2.5**  **NAAQS.**
**In conjunction with its recommendations, Missouri s ubmitted extensive documentation intended**  **to demonstrate that occasions when the Granite City monitor in Illinois exceeds the NAAQS, the**  **Missouri portion of the St. Louis area should not b e considered to contribute to those occurrences**  **of elevated concentrations. While this monitor has historically recorded the highest**  **concentrations in the area, Missouri’s analysis is tied to particular measurements at this monitor,**  **many of which the EPA has subsequently found to be unreliable. Therefore, this TSD does not**  **provide a detailed review of Missouri’s analysis. F urthermore, all data collected during the year**  **are important when determining contributions to an annual standard such as the 2012 annual**  **PM 2.5**  **NAAQS. Compliance with an annual NAAQS is dependen t upon monitor readings**  **throughout the year, including days with monitored ambient concentrations below the level of**  **the NAAQS. For the 2012 annual PM 2.5**  **NAAQS, the annual mean is calculated as the mean o f**  **quarterly means. A high quarter can heavily influen ce the mean for an entire year, which, in turn,**  **can contribute to an elevated 3-year design value. When 3 consecutive years of quality assured,**  **certified data are available for the St. Louis, IL- MO area intended PM**  **2.5 unclassifiable area,**  **Illinois, Missouri or the EPA may initiate the rede signation process. The CAA provides the EPA**  **with discretion regarding whether and when to initi ate a redesignation process. The EPA may**  **consider air quality data, planning and control con siderations, or any other air quality-related**  **considerations the Administrator deems appropriate. As a result of these potential future**  **analyses, the boundaries of any potential future no nattainment area may not the same as the**  **intended boundary for the St. Louis, MO-IL unclassi fiable area.** 
**Based on this analysis, we are preliminarily recomm ending designating a St. Louis, MO-IL**  **unclassifiable area that includes the same area as was designated nonattainment for the 1997**  **PM 2.5**  **NAAQS. Thus, the EPA intends to designate an uncla ssifiable area that includes St. Louis**  **City and Franklin, Jefferson, St. Charles, and St. Louis Counties in Missouri and Madison,**  **Monroe, and St. Clair Counties and Baldwin Township in Randolph County in Illinois. The EPA**  **intends to designate all other portions of Missouri as unclassifiable/attainment.** 

Davenport-Moline-Rock Island, IA-IL
**The Davenport- Moline-Rock Island, IA-IL MSA includes Rock Island,**  **Henry and Mercer Counties in Illinois and Scott County in Iowa. Both**  **Illinois and Iowa recommended the four counties within this area as unclassifiable/attainm**  **ent. The core of the urban area of Davenport, where the majority of the emissions and emissions a**  **ctivities are located, consists of Scott County, Iowa and Rock Island County, Illinois.** 

**As explained above, the EPA is designating all of I llinois unclassifiable at this time. However,**  **the EPA needs to evaluate whether the Iowa portion of the Davenport-Moline-Rock Island, IA**  **IL MSA could be contributing to any potential viola tions of the NAAQS in the Illinois portion of**  **this MSA. To do so, the EPA has considered informa tion relevant to the five factor analysis for**  **the Iowa portion of the MSA. Below is a brief discu ssion of the information pertaining to the five** **factors generally considered for a nonattainment ar ea, including air quality data, emissions data,** 

**meteorology, population, and jurisdictional boundar ies. [Additional analyses for the Davenport**  **Moline-Rock Island, IA-IL MSA are provided in EPA D ocket No. EPA-HQ-OAR-2012-0918,**  **Air Quality Designations for the 2012 PM 2.5**  **Standards. 4**  **]**
**For the first factor, the EPA considers air quality information for the area. The Iowa portion of**  **the Davenport area currently has four PM 2.5**  **monitors located in Scott County, Iowa. All four monitors have complete data showing attainment of t**  **he 2012 PM 2.5**  **NAAQs, with 2011-2013 design values ranging from 10.2 to 10.7 μg/m**  **3 . As noted above, the EPA does not have reliable**  **monitor data for the monitor located in Rock Island County, Illinois. The Rock Island County**  **monitor has historically measured annual values bel ow the Scott County, Iowa monitors, but**  **given the questions concerning the validity of the monitor data the EPA cannot place too much**  **reliance on this fact. Table 4 shows the 2013 desig n values for the four Iowa monitors located in**  **Scott County.**

Table 4. Air Quality Data collected at Regulatory Monitors in Davenport (all DV levels in μg/m 3 )

**State County Monitor ID State**  **Recommended Nonattainment?**  **PM 2.5**  **Annual**

**Design Value 2009-2011**  **PM 2.5**  **Annual**

**Design Value 2010-2012**  **PM 2.5**  **Annual**

**Design Value 2011-2013** 

Iowa Scott 191630015 No 11.4 11.0 10.2

Iowa Scott 191630018 No 11.5 11.2 10.4

Iowa Scott 191630020 No 11.3 10.7

Iowa Scott 191630019 No 10.6

**Historically, the Davenport area has not violated any annual PM**  **2.5 standards, and thus the EPA**  **has not previously established any nonattainment bo undary for this area. . In the absence of a**  **previously established nonattainment boundary, the EPA has considered relevant information to**  **assess the possibility of contribution to a potenti al violation of the NAAQS in the Illinois portion**  **of the MSA.**
**A review of population data shows an approximate eq ual split on each side of the respective state**  **lines, with 2010 Rock Island County population of 1 47,612 and 2010 Scott county population of**  **165,781. While Henry and Mercer have an additional population of 66,850 combined, the**  **population density in these counties is much less t han the two core counties of Rock Island and**  **Scott.**
**Looking at the emissions data in the Davenport area the EPA notes that there are several sizable**  **point sources in the area, including a power plant in Scott County (MidAmerican Energy**  **Riverside Station). Additional point sources of no te include Alcoa (located north and east of all**  **monitors in Scott County), as well as Lafarge North America (located in the Southwest portion** 

**4 Preliminary Technical Support Document, August 201**  **4, titled, Davenport-Moline-Rock Island, IL-IA Area Designation for the 2012 Primary Annual PM**  **2.5 National Ambient Air Quality Standard Technical Su**  **pport Document, prepared by the Region 7 US EPA.** **of Scott County), and the John Deere facility (loca ted in Rock Island County south of the** 

**MidAmerican Energy plant noted above.) Emissions f rom each of these stationary sources is**  **relatively low, with the highest being approximatel y 1,511 tons per year of NOx and 3,694 tons**  **per year of SO2 from the MidAmerican Energy Riversi de Station.** 

**Overall emissions are similar in the Iowa and Illin ois counties in the Davenport area with**  **population related and mobile source emissions in t he core areas at the same order of magnitude.**  **The aggregate emissions of direct PM 2.5**  **and precursor pollutants from the point sources mentioned above are slightly higher in Scott County**  **, but are generally from sources located in an area which would be less likely to impact the Rock**  **Island County portion of the Davenport area, based on the meteorological data.** 
**A review of the meteorological data for the Davenpo rt area indicates winds most frequently from**  **the south, east and west with a smaller northwest c omponent. Although the wind data suggests**  **that there could be contribution from sources in Sc ott County to potential violations of the**  **NAAQS in the Rock Island portion of the Davenport a rea, much of the emissions and emissions**  **activity in Scott County comes from sources located to the north and northeast of the monitor in**  **Rock Island and thus there is less likely to be con tribution from such sources.** 
**Based on this technical analysis, the EPA agrees wi th Iowa’s recommendation and we intend to**  **designate Scott County, Iowa as unclassifiable/atta inment with the remaining three counties in**  **Illinois (Rock Island, Henry and Mercer) designated as unclassifiable. The EPA intends to**  **designate all other counties in Iowa as unclassifia ble/attainment as recommended by Iowa.**