1 Draft Technical Support Document

WISCONSIN Area Designations f

or the

2010 SO 2 Primary National Ambient Air Quality Standard

Summary

Pursuant to section 107(d) of the Clean Air Act, EPA must initially designate areas as either “unclassifiable”, “attainment”, or “nonattainment” for the 2010 one

- hour sulfur dioxide (SO 2 ) primary national ambient air quality standard (NAAQS)

. The Clean Air Act defines a nonattainment area as one that does not meet the NAAQS or that contributes to a violation in a

n earby area

.

Wisconsin submitted recommendations on May 26, 2011 . Table 1 below lists Wisconsin’s recommendations and identifies the counties or portions of counties in Wisconsin that EPA intends to designate “nonattainment” based on monitored violations.

Table 1. Nonattainment Area Designation for Wisconsin

Area Wisconsin ’s Recommend ed Designation of

Areas/ Counties EPA’s Intended Designated

Nonattainment Areas/ Counties

Rhinelander , WI Oneida County (part ial ) City of Rhinelander and

the T owns of Crescent, Newbold, Pine Lake and

Pelican Nonattainment Nonattainment

Background

On June 3, 2010, EPA revised the primary SO 2 NAAQS (75 FR 35520, published on June 22, 2010). EPA revised the primary SO 2 standard by establishing a new one

- hour standard at a level

of 75 parts per billion (ppb) w hich is attained when the three

- year average of the 99 th percentile

of one

- hour daily maximum concentrations does not exceed 75 ppb. EPA has determined that this is the level necessary to provide protection of public health with an adeq uate margin of safety, especially for children, the elderly and those with asthma. These groups are particularly susceptible to the health effects associated with breathing SO 2

. EPA is revoking the two prior primary standar ds of 140 ppb evaluated over 24 hours, and 30 ppb evaluated over an entire year because they will not add additional public health protection given a one

- hour standard at 75 ppb. Accordingly, EPA is not designating areas in this process on the basis of either of these two primary stand ards. 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.2 EPA’s SO 2 Designation Approach

Section 107(d) of the Clean Air Act requires that not later t han one year after promulgation of a new or revised NAAQS, state Governors must submit their recommendations for designations and boundaries to EPA by June 2011. Section 107(d) also requires EPA to provide notification

to states no less than 120

- days prio r to promulgating an initial area designation that is a

modification of a state’s recommendation

. EPA was to promulgate initial area designations within two years of promulgation of the revised primary standard, although EPA has extended

this deadline for one additional year due to having insufficient information to promulgate the designations. If a state did not submit designation recommendations, EPA will promulgate the designations that it deems appropriate

. If a state or tribe disagrees with EPA’s in tended designations, they have an opportunity to demonstrate why any proposed modification is inappropriate.

Designations guidance was issued by EPA through a March 24, 2011, memorandum from Stephen D. Page, Director, U.S. EPA, Office of Air Quality Plann ing 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 five factors include: 1) air quality data; 2) emissions an d emissions

- related data (location of sources and potential contribution to ambient SO 2 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, pre

- existing nonattainment areas, reservations, metropolitan planning organization) , among any other criteria deemed to be relevant to establishing appropriate area designations and boundaries for the one

- hour SO2 NAAQS.

Th e March 24, 2011, memo recommended that area boundaries default to the county boundary unless

information provided by the state or tribe 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 differing boundary than a county boundary.

In this technical support document, EPA discusses its review and technical analysis of the recommendations regarding areas with monitored violations submitted by Wisconsin for designations

for the one

- 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 s tate
recommendation and/ or on the technical analysis included in this document, has violat ed the

2010 SO 2 NAAQS

, based on the most recent three years of air quality monitoring da ta , or contributes to a violation in a nearby area.

2 ) Recommended nonattainment area

– an area a s tate or t ribe has recommended that EPA designate as nonattainment.3

3 ) Violating monitor

– an ambient air monitor meeting all methods, quality assurance and siting criteria and requirements whose valid design value exceed s 75 ppb, as described in Appendix T of 40 CFR part 50.

4 ) 20 10 SO 2 NAAQS

– The NAAQS for SO 2 promulgated in 20 10

. This NAAQS is 75 ppb,

b ased on the three year average of the 99th percentile of the annual distribution of daily

maximum one

- hour average concentrations. See 40 CFR Part 50.17.

5) Design Value

- a statistic computed according to the data handling procedures of the NAAQS (in 40 CFR 50 Appendix T) that , by comparison to the level of the NAAQS , indicates whether the area is violating the NAAQS

.

Technical analysis for the Rhinelander , WI A rea

Introduction This technical analysis for the Rhinelander Area identifies Oneida County with a monitor that

violate s the 2010 SO 2 NAAQS

, and evaluates nearby counties for contributions to SO 2 concentrations in the area. EPA has evaluated this county and nearby counties based on the

evidence for the factors recommended in the March 24, 2011 EPA gu idance

.

Figure 1 is a map of the area showing the locations and design values of air quality monitors in the area, and the counties surrounding any violating air quality monitors.4

Figure 1

. Map of sources and monitors in the Rhinelander , WI area and the intended

Rhinelander nonattainment area

For the Rhinelander , WI Area, Wisconsin recommended that part of Oneida County containing the City of Rhinelander and the Towns of Crescent, Newbold, Pine Lake, and Pelican be designated as nonattainment for the 2010 SO 2 NAAQS. Based on EPA's technical analysis described below, EPA agrees with the State’s recommendation and intends to designate this area

also listed in Table 1 as nonattainment for the 2010 SO 2 NAAQS

.

Detailed Assessment

A ir Quality Data

Wisconsin’s recommendation was based on data indicating nonattainment at an SO 2 monitor

located in Rhinelander, Oneida County. The SO 2 NAAQS design value representative of the

Rhinelander area is shown in Table 2

. The Oneida County monitor show s a violation of the 2010

SO 2 NAAQS for 2009

- 2011 . Therefore

, at least a portion of this county must be designated

nonattainment

.5

Table 2 . Air Quality Data for Nonattainment Designations in Wisconsin

County State

Recommended

Nonattainme nt? Monitor Air Quality

System ID Monitor Location SO 2 Design Value,

200 9

- 20 11 ( ppb )

Oneida Yes 55

- 085

- 0996 Rhinelander

Water Tower 1 51

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 emission data for SO 2

. Table 3 shows total emissi ons of SO 2 (given in tons per year) for violating and potentially contributing counties in and around the

Rhinelander area and sources emitting (or anticipated to contribute) greater than 100 ton s per year of SO 2

. The c ounty that contains the Rhinelander nonattainment area for the 2010 SO 2 NAAQS is shown in bold

. Wisconsin believes Wausau Paper Mills, LLC (Wausau Paper), is likely to be the primary cause of this NAAQS violation. This facility is less than one kilometer from the air quality monitor. Ther e are very few other SO 2 sources in Oneida County. The nearest source over 100 tons per year is located 33 kilometers from the Rhinelander air quality

monitor , in Lincoln County . It emits only slightly more SO 2 than Wausau Paper does, and its distance from the monitor indicates that it is unlikely to have a significant impact on the

monitored violation of the SO 2 NAAQS . Therefore, EPA finds that this source may be judged

not to contribute to the monitored viola tion.

Table 3 . SO 2 Emissions

County Facility Located in

State

Recommended

Nonattainment Area ? F acility Name

– Total SO 2 Air

Emissions [ NEI08V 2 ] (tons per year) Facility

Location /

Distance from

Monitor (km) Total County

SO 2 Emissions (tons per year)

Oneida County Yes Wausau Paper Mills, LLC

– 3071 Rhinelander/ 0.7 3128

Yes Red Arrow Foods

– 8 Rhinelander/ 4.5 Lincoln County No Packaging Corp. of America

– 46 4 1 Tomahawk / 33. 46 90

Emission Controls

The emissions data provided in Table 3 represent emiss ions levels taking into account any control strategies implemente d on stationary sources in the Rhinelander area up to and including

2008

. EPA does not have any additional information on actual emissions reductions resulting

from controls put into place after 2008. Wisconsin is currently working with Wausau Paper to

reduce its SO 2 emissions.

Geography/

T opography (mountain ranges or other air basin boundaries)

Oneida County does not have any geographical or topographical barr iers signifi cantly limiting

air pollution transport within its airshed. Therefore, this factor did not play a significant role in determining the nonattainment boundary.

Meteorology (weather/transport patterns)6

For this area, winds can be from any direction. There fore, sources in all directions can have some potential contribution. Given that the dominant SO 2 source is less than one kilometer from the air quality monitor, meteorology is not considered to be a significant factor in defining this

nonattainment area.

Tribal Recommendations

On May 10, 2011, the Forest County Potawatomi Community (FCPC) submitted its SO 2 designation recommendations to EPA. The FCPC has jurisdiction over parcels of land in several Wisconsin counties, including Oneida County. The Oneida County land parcel which belongs to the FCPC is located about 16 miles (26 kilometers ) east of Wausau P aper. The FCPC recommended that its Oneida County land parcel be designated “unclassifiable” for the 2010 SO 2 NAAQS, which is compatible with Wisconsin’s recommendation that that portion of the county be designated attainment. However, EPA at present is only designating the portion of Oneida County that is to be designated nonattainment and is not designating the portion of the county to which FCPC’s recommendations apply.

Conclusion

The air quality monitor in Oneida County shows a violation of the 20 1 0 SO 2 NAAQS, based on

200 9

- 201 1 air quality data. S ource proximity suggest s that Wausau Paper in Rhinelander,

Wisconsin is likely the dominant contribut or to SO 2 NAAQS violations at the Rhinelander SO 2 monitor . After considering the factors described abo ve, EPA intends to designate the portion of Oneida County containing the City of Rhinelander and the Towns of Crescent, Newbold, Pine Lake, and Pelican , as the Rhinelander , WI nonattainment area for the 20 10 SO 2 NAAQS , as recommended by Wisconsin.