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LOUISIANA Area Designations For the 2010 SO 2 Primary National Ambient Air Quality Standard Summary Pursuant to section 107(d) of the Clean Air Ac t (CAA), EPA must initia lly designate areas as either “nonattainment,” “attainment” or “uncla ssifiable” 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 NAAQ S or that contributes to poor ai r quality in a nearby area that does not meet the NAAQS. Table 1 below identifies the county (parish) in Louisiana that EPA is initially designating “nonattainment” based on monitored violations. The EPA is not yet prepared to designate ot her areas in Louisiana. Table 1. Nonattainment Area Designations for Louisiana

Area Louisiana’s Recommended Designation of Area/County (Parish) EPA’s Designation of Area/County (Parish)

St. Bernard Parish, LA 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 bill ion (ppb) which is met at an ambient air quality monitoring site when the 3-year average of the annual 99 th percentile of 1- hour daily maximum concentrations is less than or equal to 75 ppb, as determined in accordance with Appendix T of 40 CFR part 50. 40 CFR 50.17(a) -(b). The 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 el derly and those with asthma. These groups are particularly susceptible to the health eff ects associated with breathing SO 2 . The Agency is revoking the two prior primary standards of 140 ppb evaluated ove r 24-hours, and 30 ppb evaluated over an entire year because the standards will not add additi onal public health protection given a 1-hour standard at 75 ppb. Accordingly, EPA is not de signating areas in this process on the basis of either of these two prior pr imary standards. Similarly, the secondary standard for SO 2 has not been revised, so EPA is not designating areas in this process on the basis of the secondary standard.2 EPA’s SO 2 Designation Approach Section 107(d) of the CAA provides that not late r than 1 year after pr omulgation of a new or revised NAAQS, state Governors may submit their recommendations for designations and boundaries to EPA. For the 2010 SO 2 NAAQS, this deadline was in June 2011. Section 107(d) also requires EPA to provide a notification to stat es of no less than 120 days prior to promulgating an initial area designation that is a modification of a stat e’s recommendation. EPA has reviewed the state’s recommendations a nd has notified the State Commissioner through a letter signed by the Regional Administrator of any intended modifications. If a state or tribe did not submit designation recommendations, EPA is promulgating the designations that it deems appropriate. If a state or tr ibe disagreed with EPA’s inte nded area designations, it had an opportunity to demonstrate why any propos ed modification is inappropriate. Designations guidance was issued by EP A through a March 24, 2011, memorandum from Stephen D. Page, Director, U.S. EPA, Office of Air Quality Pl anning and Standards, to Air Division Directors, U.S. EPA Regions I-X. This memorandum identifies factors EPA has evaluated in determining boundaries for area s designated nonattainment. These 5 factors include : 1) air quality data; 2) emissions and emissions-related data (location of sources and potential contribu tion to ambient SO 2 concentrations); 3) meteorology (weather/transport patterns); 4) geography/topogra phy (mountain ranges or other ai r basin boundaries); and 5) jurisdictional boundaries (e.g., counties, air di stricts, pre-existing nonattainment areas, reservations , metropolitan planning organization), among any other information deemed to be relevant to establishing appropriate area designations and boundaries for the 1-hour SO 2 NAAQS. The March 24, 2011, designations guidance memo recommended that area boundaries be defaulted to the county boundary unless additiona l information justifies a larger or smaller boundary than that of the county. EPA believes it is appropriate to evalua te each potential area on a case-by-case basis, and to recognize that ar ea-specific analyses conducted by states, tribes and/or EPA may support a different boundary than that of a default county boundary.
In this TSD, EPA discusses its review and tec hnical analysis of the recommendations submitted by the State of Louisiana for designations of the 1-hour SO 2 standard and any modifications from these recommendations.

Definition of important term s 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 violatio n in a nearby area.

2 ) Recommended nonattainment area – an area that a state or tribe has recommended to EPA to be designated as nonattainment.3 3) Violating monitor – an ambient air monitor meeting a ll methods, quality assurance and citing criteria and requirements whose valid design va lue 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 annua l distribution of daily maximum1-hour average concentrations. 5) Design Value – a statistic that describes the air qual ity status of a given area relative to the level of the NAAQS.

State’s Recommendation Letter In May 2011, Secretary Peggy Hatc h, Secretary of the Louisiana Department of Environmental Quality (LDEQ), recommended that 20 parishes be designated as “unclassifiable” for the 2010 SO 2 NAAQS based on the absence of both monito red air quality data and of a modeling demonstration showing attainment of the standard. 1 Secretary Hatch also recommended that 42 parishes be designated as “attainment” for the 2010 SO 2 NAAQS. For 4 of these parishes, the attainment recommendation is based on monito red air quality data from regulatory and nonregulatory monitors with the absence of a mode ling demonstration showing attainment of the standard. For 38 parishes, the attain ment recommendation is based on 2009 SO 2 emissions from sources in the respective parish es. According to the 2009 Louisi ana emissions inventory, these 38 parishes each have total emissions less than 75 SO 2 tons per year (tpy). Secretary Hatch’s May 2011 letter also recommended that St. Bernar d Parish and West Baton Rouge Parish be designated as “nonattainment” for the 2010 SO 2 NAAQS based on monitored violations. Secretary Hatch’s May 2011 recommendations were based on 2008-2010 monitored air quality data. This is in accordance with the March 24, 2011, designations guidance memo from Stephen D. Page in which we stated our expectation th at states and tribes would review available SO 2 monitoring data from 2008-2010 in providing their recommendations to EPA. We also stated in the March 24, 2011, memo that we intended to consider 2011 SO 2 monitoring data in formulating any intended modifications to the st ates’ and tribes’ recommendations if such data were to become available prior to EPA issuing the 120 day letters. Sinc e 2011 data are currently available, in the analysis pr esented in this TSD, EPA is considering 2009-2011 monitored air quality data for all areas in Louisiana, with the exception of West Bat on Rouge Parish. Since 2012 data for the monitor in West Baton Rouge Pa rish was early certifie d by Louisiana, EPA is considering 2010-2012 monitored air quality data for this particular monitor. The 2010-2012 data for West Baton Rouge meets the 2010 SO 2 NAAQS. Consequently, this final initial designation doe s not address West Baton Rouge Parish, which will be further addressed in a subsequent round of designations.

1 May 26, 2011, letter from Peggy M. Hatch, Secretary, Louisiana Department of Environmental Quality, to Al Armendariz, Regional Administrator, EPA Region 6.4 Nonattainment Designations Technical Analysis for St. Bernard Parish

Introduction This technical analysis identifies St. Bernard Pa rish as having a monitor that violates the 2010 SO 2 NAAQS, and evaluates nearby pa rishes for contributions to SO 2 concentrations in the area. EPA has evaluated St. Bernard Parish and nearby parishes based on the weight of evidence of the factors recommended in the March 2 4, 2011, designations guidance memo. Figures 1 and 2 are maps of St. Bernard Paris h, showing the location a nd design values of air quality monitors in the area, the parishes surr ounding the violating air quality monitor, and the location of SO 2 point sources with 2008 emissions greater than 100 SO 2 tpy based on the 2008 National Emissions Inventory (NEI). As show n in the legend for Figure 1, the diamonds represent regulatory SO 2 monitors (red=violating, green=attaining) and the circles represent SO 2 emissions sources. In Figure 2, the stars represent regulatory SO 2 monitors (red=violating, blue=attaining); the green circles represent SO 2 emissions sources, with the size of the circle proportional to the source’s 2008 NEI SO 2 emissions (numbers shown are 2008 NEI SO 2 emissions in tpy). As shown in the figures, onl y one of the three regulatory monitors in St. Bernard Parish has a 2009-2011 design value above the 2010 1-hour SO 2 NAAQS. The violating monitor, shown as a red diamond in Figure 1 and a red star in Figure 2, is the Chalmette-Vista monitor (EPA Site ID 22- 087-0007), with a 2009-2011 de sign value of 287 ppb. The other two regulatory monitors in St. Bern ard Parish have design values under the 2010 1- hour SO 2 NAAQS. These monitors, shown as blue stars in Figure 2, are the Chalmette-High School monitor (EPA Site ID 22-087-0009) , with a 2009-2011 design value of 64 ppb (incomplete data), and the Meraux monitor (E PA Site ID 22-087-0004) , with a 2009-2011 design value of 26 ppb. Note that Figure 1 depicts onl y the Meraux monitor as having a design value under the standard (i.e., shown as a green diamond), as three full years of data are not available from the Chalmette-High School monitor.5 Figure 1. St. Bernard Parish 1-hr SO 2 NAAQS Nonattainment Area6 Figure 2. St. Bernard Parish 1-hr SO 2 NAAQS Nonattainment Area (close-up)

Based on EPA's technical analysis described belo w, EPA is initially designating St. Bernard Parish as nonattainment for the 2010 SO 2 NAAQS, based upon currently available information. EPA is not yet prepared to designa te other areas of Louisiana. Ar eas and sources that we are not yet prepared to conclude are co ntributing to the monitored violat ion or other possible violations are not included in this initial nonattainment area , and will be addressed in a subsequent round of designations.7 Detailed Assessment Air Quality Data

This factor considers the SO 2 air quality monitoring data, in cluding the design values (in ppb) calculated for all air quality monitors in St . Bernard Parish, based on data for the 2009-2011 period. Secretary Hatch’s nonattainment recommendati on for St. Bernard Parish was based on 2008- 2010 data 2 from Federal Reference Method (FRM) or Federal Equivalent Method (FEM) monitors located in the state, in accordance with 40 CFR Part 53. As discussed elsewhere in this TSD, EPA is considering 2009-2011 air monitoring da ta for St. Bernard Pari sh in the technical analysis presented in this TSD. The 2009-2011 SO 2 NAAQS design values for the monitors in St. Bernard Parish are shown in Table 2. Table 2. Air Quality Data for Nonatta inment Designations in Louisiana

Parish State Recommended Nonattainment? Monitor Name* Monitor Air Quality System ID Monitor Location SO 2 Design Value, 2008-2010 (ppb) SO 2 Design Value, 2009-2011 (ppb)

St. Bernard Parish, LA Yes Meraux 22-087-0004 4101 Mistrot Drive 32 26

ChalmetteVista 22-087-0007 24 E. Chalmette

Circle 297 287

ChalmetteHigh School 22-087-0009 1100 E. Judge Perez Drive 60 64**

* The monitor in bold has the highest 2009-2011 design value in the parish. ** Design Value based on incomplete data.

St. Bernard Parish shows a violation of the 2010 SO 2 NAAQS. Therefore, some area in the parish and possibly additional areas in surrounding parishes must be designated nonattainment. The absence of a violating monitor alone is not a sufficient reason to eliminate nearby parishes as candidates for nonattainment status. Each area has been evaluated based on the weight of evidence of the five factors and other relevant information. As shown in Table 2, the Chalmette-Vista monitor (Air Quality System ID 22-087-0007) in St. Bernard Parish has a 2009-2011 design value of 287 ppb, which exceeds the NAAQS and is therefore violating the standard. The Chalmette -High School monitor (Air Quality System ID 22-087-0009) and the Meraux monitor (Air Qual ity System ID 22-087-0004), which are also located in St. Bernard Parish, have 2009-2011 de sign values of 64 ppb (incomplete data) and 26 ppb, respectively. The violating Chalmette-Vista monitor is approximately 5.1 km away from the Chalmette-High School monitor, and 2.2 km aw ay from the Meraux monitor. This suggests that the emissions source or sources causing or contributing to the recorded violation of the Chalmette-Vista monitor are in closer proximity to the Chalmette-Vista monitor than to the two

2 May 31, 2011, letter from Peggy M. Hatch, Secretary, Louisiana Department of Environmental Quality, to Al Armendariz, Regional Administrator, EPA Region 6.8 other monitors in St. Bernard Parish, and/or that the Chalmette-Vista monitor is located directly downwind from the emissions source(s) causing th e violation. There are no other regulatory SO 2 monitors within 100 km of the violating Ch almette-Vista monitor. The regulatory SO 2 monitor located nearest to the St. Bernard Parish mon itors is located in East Baton Rouge Parish (approximately 130 km away from the Chalmette -Vista monitor). Air quality data from a monitor located in a nearby parish could potentially be us ed to indicate whether sources in that parish are contributing to the monitored violation at the Chal mette-Vista monitor. In this case, however, regulatory SO 2 monitors in neighboring parishes ar e located too far away from the St. Bernard Parish violating monitor (Chalmette-Vista) for their design values to indicate whether or not emissions sources from these parishes may be contributing to the St. Bernard Parish violating monitor.

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 contribu ting to a monitored violation. In considering this factor, EPA evaluated count y level emission data for SO 2 and any growth in SO 2 emitting activities since the date repres ented by those emissions data.

Emissions EPA recognizes that there may be new informati on on any changes in emissions that may have occurred after 2008, and would consider more rece nt years if available. Louisiana did not provide updated emissions information, theref ore EPA relied on the 2008 NEI emissions data (NEI08V3) to identify sources that could pot entially be contributi ng to a violation.

Table 3 shows total emissions of SO 2 according to the 2008 NEI (in tpy) in St. Bernard Parish and potentially contributing surrounding parishes , as well as emissions from sources emitting greater than 100 tpy of SO 2 in these parishes.

Table 3. 2008 NEI SO 2 Emissions (NEI08V3) in St. B ernard Parish and Surrounding Parishes

Parish Facility Located in State Recommended Nonattainment Area? Facility Name, Address, Coordinates, and EIS (or State

Facility ID) Facility Emissions (tpy) Approximate Facility Distance from

St. Bernard Parish Violating

Monitor (km) Total Parish SO 2 Emissions (tpy)

St. Bernard Parish, LA Yes Rain CII Carbon LLCChalmette Coke Plant

700 Coke Plant Rd. (29.9375, -89.97694)

EIS ID 5608111 4284 tpy 0.8 62679 Chalmette Refining

LLC- Chalmette Refinery 500 W St Bernard Hwy

(29.9379, -89.9699)

EIS ID 8020411 250 tpy 1.0

Murphy Oil USA Inc.- Meraux Refinery 2500 E St Bernard Hwy (29.93022, -89.94492)

EIS ID 7355411 753 tpy 3.4

St. Charles Parish, LA No Valero Refining Co. - New Orleans LLC- St. Charles Refinery

14902 River Rd

EIS ID 7449311 238 tpy 40.4

7824Rain CII Carbon LLCNorco Coke Plant 801 Prospect Ave (30.00194, -90.39694)

EIS ID 8020911 2350 tpy 41.0

Shell Chemical LPNorco Chemical PlantEast Site

15536 River Rd (30.00111, -90.40694)

EIS ID 8239511 1020 tpy 42.0

Motiva Enterprises LLC- Norco Refinery

15536 River Rd (29.99537, -90.41017)

EIS ID 8020811 769 tpy 42.2

Union Carbide Corp.- St. Charles Operations 355 Hwy 3142 Gate 28 (29.98229, -90.45562)

EIS ID 7202911 416 tpy 46.410 Entergy Louisiana LLC- Waterford 1&2

Generating Plant

17705 River Rd (29.9994, -90.4758)

EIS ID 5609311 1803 tpy 48.5

Orleans Parish, LA No N/A None > 100 tpy N/A 1900

Plaquemines Parish, LA No Chevron Oronite Co. LLC- Oak Point Plant 10285 Hwy 23 S (29.81028, -90.01139)

EIS ID 8018711 262 tpy 15.3

9316 Conoco Phillips Co.-

Alliance Refinery

15551 Hwy 23 (29.684887, -89.97613)

EIS ID 7203711 2785 tpy 29.0

Jefferson Parish, LA No Cornerstone Chemical Co.

10800 River Rd (29.95788, -90.26568)

EIS ID 7228511 863 tpy 27.9 3068

St. Tammany

Parish, LA No N/A None > 100 tpy N/A 154

See also Figures 1 and 2 above for facility location in re lation to air quality monitors. As shown in Figure 1, the emissions sources closest to th e violating monitor are located in St. Bernard Parish. This suggests that sour ces in St. Bernard Parish are causing or contributing to the monitored violation of the 2010 SO 2 NAAQS. Table 3 shows there are three sources within 30 km from the St. Bernard Parish violating monito r, located in neighboring parishes, and with 2008 NEI SO 2 emissions greater than 100 tpy (each ). One of these sources (863 SO 2 tpy, 2008 NEI) is in Jefferson Parish, and is located approximately 27.9 km from the St. Bernard violating monitor. The remaining two sources (262 SO 2 tpy and 2785 SO 2 tpy, 2008 NEI) are in Plaquemines Parish, and are located approximately 15.3 km a nd 29 km away from the St. Bernard violating monitor, respectively. However, these sources each have 2008 NEI SO 2 emissions that are lower than that of the largest point source in St. Bern ard Parish, and they are all located further away from the violating monitor than are St. Bernard Parish’s own sources. Based on this information, we are not yet prepared to conclude that the em issions from these sources in Jefferson Parish and Plaquemines Parish contribute to the monitored violation in St. Be rnard Parish. All the sources in St. Charles Parish are located at least 40 km fr om the St. Bernard Parish violating monitor, and each have SO 2 emissions that are lower than that of th e largest point source in St. Bernard Parish.11 Two other nearby parishes, Orleans and St. Tamm any Parishes, do not have any sources with emissions greater than 100 tpy. Based on this info rmation, we are not prepared to conclude that sources in St. Charles, Orleans, and St. Tammany Parishes contribute to the violating monitor’s design values. All of these sour ces and areas will be further a ddressed in a subsequent round of designations.

Emissions Controls The emissions data used by EPA in this technica l analysis and provided in Table 3 represents emissions levels taking into accoun t any control strategies implem ented on stationary sources in St. Bernard and surrounding parish es up to and including 2008.

Meteorology (weather /transport patterns) Evidence of source-receptor relationships be tween specific emissions sources and high SO 2 values at violating monitors is another impor tant factor in determining the appropriate contributing areas and the appropr iate extent of the nonattainment area boundary. For this factor, EPA considered 30 years of National Weather Service data on average frequency of wind direction by season. The National Weather Service da ta for St. Bernard Parish is shown in Table 4. EPA also considered recent hourly meteorologi cal data to determine which wind vectors were associated with monitored 1-hour SO 2 NAAQS violations. The meteorological data used in this analysis were based on 2009-2011 data co-located with the St. Bernard Parish violating site. This data is presented in Ta ble 5. This meteorological da ta may provide evidence of the potential for SO 2 emissions sources located upwind of a violating monitor to contribute to ambient SO 2 levels at the violation location.

Table 4. National Weather Service 30-Year Average Frequency (%) of Wind Direction by Season for St. Bernard Parish Season 1 Wind Direction Winter Spring Summer Autumn

North-northeast 21.1 13.7 12.3 23.3

East-northeast 15.0 9.5 11.1 21.7

East-southeast 11.7 13.9 10.5 15.3

South-southeast 11.7 19.2 11.0 10.7

South-southwest 11.5 18.5 19.1 7.6

West-southwest 7.0 8.0 14.2 4.4

West-northwest 8.1 7.9 13.3 6.4

North-northwest 14.0 9.4 8.4 10.612 1 For purposes of this table, winter is de fined as the months of December, January, and February; spring is March, April, and May; summer is June, July, and August; and autumn is September, October, and November. The 30-year average frequency of wind direction data for St. Be rnard Parish shows that in general, the prevailing surface wi nds blow into St. Bernard Parish primarily from the northnortheast, east-northeast, south-southwest, south-southeast, and east-southeast. As shown in Table 5, monitored 1-hour SO 2 NAAQS exceedance events during 2009-2011 occurred throughout all seasons, but primarily took place in the spring and summer months in 2009 and 2010 and in the spring months in 2011. Table 4 s hows that in winter, th e wind has historically blown into St. Bernard Parish to a greater extent from the north-northeast (21.1% of time). In spring, the wind has historically bl own into St. Bernard Parish to a greater extent from the southsoutheast (19.2%) and south-sout hwest (18.5%). In summer, th e wind has historically blown into St. Bernard Parish to a gr eater extent from the south-sout hwest (19.1%). The data suggest that on months with the highest observed SO 2 levels in 2009-2011 (i.e., winter, spring, and summer), the prevailing surface winds were to a great er extent from directions that correspond to the location of sources in St. Bernard Parish (see Figures 1 and 2) and not to those of sources in surrounding parishes. As stated above, EPA also analyz ed wind direction as measured by the Chalmette-Vista monitor specifically during days with monitored 1-hr SO 2 NAAQS hourly exceedances (i.e., violation days) in 2009-2011 (see Table 5). Although so me violation days had multiple hourly SO 2 exceedances, only the maximum 1-hour SO 2 concentration and the corresponding wind direction during that hour are shown for each violation day.

Table 5. Wind Direction during 1-hour SO 2 NAAQS Exceedances at Chalmette-Vista Monitor in St. Bernard Pari sh- AQS Site ID 22-087-0007 2009 1-hour SO 2 NAAQS Hourly Exceedances

Date 1 Time 2 1-hr SO 2 Concentration (ppb) Wind Direction 3 (Compass °) Wind Direction 3 (Compass Point)

1/2/2009 06:00 109 191 South 1/3/2009 12:00 159 186 South 1/5/2009 18:00 200 188 South 1/6/2009 07:00 96 192 South-southwest 1/18/2009 02:00 87 194 South-southwest 1/21/2009 22:00 120 189 South 1/22/2009 19:00 95 175 South 1/23/2009 00:00 88 176 South 2/2/2009 07:00 120 238 West-southwest 2/10/2009 05:00 89 190 South 2/11/2009 05:00 316 177 South 2/13/2009 14:00 101 192 South-southwest 2/17/2009 23:00 81 185 South 2/20/2009 20:00 111 189 South 2/21/2009 20:00 126 185 South 2/27/2009 03:00 194 177 South13 3/8/2009 10:00 85 194 South-southwest 3/10/2009 14:00 108 181 South 3/11/2009 20:00 147 187 South 3/14/2009 07:00 206 179 South 3/25/2009 23:00 245 183 South 3/26/2009 00:00 285 182 South 3/27/2009 23:00 152 193 South-southwest 3/31/2009 09:00 83 195 South-southwest 4/5/2009 04:00 166 182 South 4/9/2009 06:00 311 181 South 4/10/2009 03:00 314 184 South 4/12/2009 21:00 279 181 South 4/19/2009 10:00 192 184 South 4/23/2009 12:00 148 185 South 4/24/2009 14:00 114 176 South 5/1/2009 19:00 249 185 South 5/2/2009 23:00 298 186 South 5/3/2009 21:00 239 182 South 5/4/2009 00:00 291 181 South 5/5/2009 23:00 104 184 South 5/6/2009 21:00 350 186 South 5/7/2009 15:00 83 198 South-southwest 5/8/2009 23:00 373 183 South 5/9/2009 20:00 281 184 South 5/10/2009 17:00 275 182 South 5/11/2009 18:00 88 178 South 5/12/2009 17:00 214 181 South 5/14/2009 10:00 83 171 South 5/24/2009 20:00 272 182 South 5/25/2009 00:00 147 203 South-southwest 5/26/2009 06:00 107 201 South-southwest 6/1/2009 20:00 232 194 South-southwest 6/7/2009 20:00 187 189 South 6/8/2009 02:00 99 190 South 6/9/2009 16:00 85 194 South-southwest 6/10/2009 16:00 225 179 South 6/19/2009 20:00 150 187 South 6/24/2009 16:00 86 319 Northwest 6/26/2009 18:00 188 189 South 6/27/2009 20:00 130 196 South-southwest 7/1/2009 21:00 79 191 South 7/3/2009 16:00 168 179 South 7/5/2009 16:00 115 195 South-southwest 7/6/2009 19:00 238 188 South 7/10/2009 17:00 123 185 South 7/16/2009 15:00 81 180 South 7/20/2009 18:00 78 184 South 7/21/2009 17:00 94 187 South 7/22/2009 02:00 110 187 South 7/25/2009 15:00 131 181 South 7/27/2009 10:00 95 184 South 7/28/2009 06:00 314 186 South14 7/30/2009 07:00 217 178 South 7/31/2009 17:00 86 194 South-southwest 8/1/2009 15:00 84 223 Southwest 8/6/2009 02:00 123 197 South-southwest 8/30/2009 18:00 187 190 South 9/14/2009 08:00 139 190 South 9/15/2009 02:00 124 184 South 9/16/2009 19:00 104 191 South 9/18/2009 12:00 97 189 South 9/20/2009 18:00 114 187 South 10/1/2009 08:00 177 191 South 10/4/2009 14:00 155 179 South 10/6/2009 07:00 178 185 South 10/13/2009 23:00 116 205 South-southwest 10/14/2009 05:00 83 198 South-southwest 10/22/2009 22:00 93 194 South-southwest 10/30/2009 16:00 161 187 South 11/14/2009 22:00 119 193 South-southwest 11/15/2009 22:00 90 189 South 11/16/2009 16:00 122 182 South 11/29/2009 11:00 118 177 South 11/30/2009 06:00 260 180 South 12/8/2009 14:00 238 178 South 12/14/2009 03:00 135 176 South 2010 1- hour SO 2 NAAQS Hourly Exceedances Date 1 Time 2 1-hr SO 2 Wind Direction 3 Wind Direction 3

1/20/2010 17:00 158 178 South 1/24/2010 04:00 181 178 South 2/14/2010 18:00 217 181 South 2/25/2010 20:00 125 192 South-southwest 2/28/2010 23:00 112 191 South-southwest 3/10/2010 15:00 147 178 South 3/23/2010 21:00 107 181 South 3/31/2010 22:00 117 186 South 4/1/2010 18:00 90 181 South 4/3/2010 06:00 103 185 South 4/6/2010 16:00 119 180 South 4/7/2010 19:00 246 186 South 4/8/2010 12:00 80 184 South 5/20/2010 16:00 151 185 South 5/21/2010 19:00 137 191 South 5/22/2010 20:00 160 186 South 5/23/2010 00:00 100 194 South-southwest 5/29/2010 16:00 131 195 South-southwest 5/30/2010 17:00 135 184 South 5/31/2010 14:00 213 175 South 6/1/2010 16:00 98 197 South-southwest 6/2/2010 15:00 143 185 South 6/3/2010 15:00 105 203 South-southwest 6/4/2010 18:00 230 189 South 6/5/2010 18:00 254 193 South-southwest15 6/6/2010 15:00 112 190 South 6/10/2010 18:00 111 194 South-southwest 6/11/2010 08:00 110 182 South 6/12/2010 20:00 135 190 South 6/26/2010 00:00 115 195 South-southwest 7/5/2010 08:00 153 191 South 7/9/2010 14:00 83 198 South-southwest 7/17/2010 18:00 77 191 South-southwest 7/25/2010 20:00 230 181 South 7/26/2010 18:00 127 183 South 7/27/2010 15:00 143 197 South-southwest 8/2/2010 19:00 106 184 South 8/17/2010 23:00 230 182 South 8/18/2010 00:00 176 188 South 8/19/2010 10:00 83 176 South 10/24/2010 19:00 153 175 South 10/25/2010 21:00 244 180 South 10/26/2010 20:00 242 180 South 10/27/2010 13:00 163 177 South 10/31/2010 22:00 125 183 South 11/1/2010 01:00 83 185 South 11/8/2010 21:00 95 198 South-southwest 11/22/2010 13:00 106 171 South 11/23/2010 07:00 242 182 South 11/24/2010 12:00 136 180 South 11/25/2010 15:00 208 180 South 11/29/2010 23:00 378 180 South 11/30/2010 03:00 149 185 South 12/11/2010 12:00 248 181 South 12/15/2010 23:00 266 181 South 12/16/2010 01:00 243 177 South 12/21/2010 09:00 235 192 South-southwest 12/30/2010 14:00 247 178 South 2011 1- hour SO 2 NAAQS Hourly Exceedances

Date 1 Time 2 1-hr SO 2 Concentration (ppb) Wind Direction 3 (Compass °) Wind Direction 3 (Compass Point)

1/1/2011 04:00 180 176 South 1/5/2011 04:00 245 176 South 1/15/2011 21:00 186 195 South-southwest 1/16/2011 00:00 78 202 South-southwest 1/29/2011 23:00 127 178 South 1/30/2011 03:00 89 173 South 2/1/2011 12:00 214 179 South 2/15/2011 18:00 135 181 South 2/20/2011 03:00 230 174 South 2/21/2011 01:00 96 178 South 2/24/2011 18:00 238 178 South 2/27/2011 09:00 145 177 South 3/12/2011 18:00 213 175 South16 3/14/2011 13:00 162 180 South 3/16/2011 23:00 92 186 South 3/17/2011 00:00 83 189 South 3/18/2011 07:00 143 176 South 3/19/2011 19:00 117 192 South-southwest 4/2/2011 21:00 185 184 South 4/3/2011 16:00 178 187 South 4/4/2011 01:00 243 178 South 4/7/2011 15:00 153 188 South 4/8/2011 18:00 180 179 South 4/9/2011 02:00 127 176 South 4/10/2011 02:00 168 188 South 4/11/2011 03:00 190 179 South 4/15/2011 07:00 237 184 South 4/18/2011 17:00 300 182 South 4/19/2011 05:00 159 177 South 4/20/2011 02:00 128 178 South 4/23/2011 12:00 121 188 South 4/25/2011 23;00 204 180 South 4/26/2011 00:00 202 178 South 4/27/2011 07:00 255 186 South 5/6/2011 19:00 170 188 South 5/9/2011 18:00 218 178 South 5/10/2011 16:00 137 179 South 5/11/2011 17:00 133 179 South 5/13/2011 04:00 126 171 South 5/21/2011 17:00 149 180 South 5/22/2011 17:00 224 178 South 5/23/2011 12:00 153 181 South 5/24/2011 16:00 198 179 South 5/25/2011 15:00 173 184 South 5/26/2011 02:00 129 199 South-southwest 5/28/2011 01:00 76 192 South-southwest 6/14/2011 17:00 85 137 Southeast 6/19/2011 20:00 111 144 Southeast 6/20/2011 16:00 86 170 South 6/21/2011 03:00 131 190 South 6/22/2011 16:00 198 182 South 6/24/2011 16:00 165 168 South-southeast 6/26/2011 20:00 228 142 Southeast 6/27/2011 19:00 165 135 Southeast 7/3/2011 17:00 91 359 North 8/6/2011 19:00 358 186 South 8/20/2011 11:00 90 191 South 8/23/2011 16:00 86 215 Southwest 9/4/2011 09:00 223 171 South 9/5/2011 02:00 296 169 South 9/13/2011 17:00 196 202 South-southwest 9/19/2011 11:00 115 357 North 9/25/2011 23:00 177 183 South 9/26/2011 02:00 226 189 South17 10/23/2011 21:00 189 197 South-southwest 10/27/2011 23:00 82 188 South 11/9/2011 08:00 139 187 South 11/11/2011 20:00 80 186 South 11/13/2011 13:00 127 180 South 11/14/2011 15:00 218 181 South 11/15/2011 23:00 350 182 South 11/16/2011 04:00 375 184 South 11/26/2011 23:00 299 189 South 12/5/2011 11:00 256 180 South 12/16/2011 04;00 122 193 South-southwest 12/20/2011 12:00 159 194 South-southwest 1 In some cases, there was more than one hourly exceedan ce on a given day. However, only the maximum 1-hour SO 2 concentration and corresponding wind direction during that hour are shown for each violation day. 2 Based on Local Standard Time. 3 Wind Direction corresponds to the specific time interval during which the 1-hour SO 2 NAAQS hourly exceedance took place. As shown in Table 5, there were a total of 92 violation days in 2009, 58 violation days in 2010, and 76 violation days in 2011 at the Chalmette-Vista monitor in St. Bernard Parish. The data shows that from 2009-2011, the prevailing surfa ce winds were predominantly from the south during 1-hour SO 2 NAAQS hourly exceedances. The data shows that prevailing surface winds were also often from the s outh-southwest during 1-hour SO 2 NAAQS hourly exceedances (although to a much lesser extent than from the s outh). The direction from which wind blew into St. Bernard Parish during 1-hour SO 2 NAAQS hourly exceedances co rresponds to the location of the Rain CII Carbon coke plant (depicted in Figur es 1 and 2 as a green circle labeled “4284”) and the ExxonMobil Refinery Complex (depicted in Figur es 1 and 2 as a green circle labeled “250”), both located in St. Bernard Parish. Taken together , the wind data in Tables 4 and 5 suggest that the Chalmette-Vista monitor in St. Bernard Pa rish is located downwind from the Rain CII Carbon coke plant and the ExxonMobil Refinery in St. Bernard Parish, and that these sources are causing the violation of the 1-hour SO 2 NAAQS at the Chalmette-Vista monitor.

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

St. Bernard Parish 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 for St. Bernard Parish.

Jurisdictional boundaries
As discussed above, our evaluation of the factors indicate that St . Bernard Parish’s own sources are causing the violation of th e Chalmette-Vista monitor. The State recommended St. Bernard Parish to be the area designated nonattainment. Si nce there are no other data available to support a nonattainment boundary smaller than the St. Be rnard Parish boundary, th e only jurisdictional boundary we considered in our eval uation is the parish boundary.18 Other Relevant Information

EPA did not receive additional information from the state relevant to establishing the initial nonattainment area boundary for St. Bernard Parish.

EPA’s Area Designations Conclusion for Louisiana After considering the factors described above and consideri ng and responding to comments submitted by the state and the public (see our Response to Comments Document), EPA is initially designating St. Bernard Pari sh as nonattainment (see Table 1). An air quality monitor in St. Bernard Parish shows a violation of the 2010 SO 2 NAAQS based on 2009-2011 air quality data. The nonattainment area boundary that EPA describes above is based on the following five factors: air qualit y data, emissions-related data, meteorology, geography/topography, and jurisdictional boundaries. Based on the consideration of all the relevant and available information, as de scribed above, EPA believes that the boundary described herein encompasses the appropriate ini tial area that does not meet the 2010 SO 2 NAAQS, based on monitoring, and the sources that contribute to the monitored violation.

Based on the consideration of all the relevant and available informati on, as described above, EPA is initially designating St. Bernard Parish as nonattainment for the 2010 SO 2 NAAQS. EPA is not yet prepared to conclude that the emissions from sources located outside the initial nonattainment boundary contribute to the monitored vi olation or to other po ssible violations. In a subsequent round of designations, we will further address these ar eas and sources and make final initial designation decisions for areas in Loui siana not included in the nonattainment area designation addressed in this TSD.