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Tennessee 2010 Sulfur Dioxide 1-Hour Standard

Nonattainment Area Designations

Five-Factor Analysis
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Executive Summary

On June 22, 2010, the U.S. Environmental Protection Agency published the new primary sulfur dioxide

standard of 75 parts per billion (ppb). It was signed by Administrator Jackson on June 2, 2010. Pursuant 

to the Clean Air Act, the states have one year from issuance of the new standard to recommend areas of 

the state as nonattainment or attainment with the new standard. This technical summary document 

presents the State of Tennessee’s recommendations. As detailed in Table 1, the TAPCD recommends one 

county (Sullivan) be designated nonattainment and two counties (Bradley and McMinn) partially 

designated nonattainment with the new SO2 standard. Tennessee recommends that the remaining 92

counties and remaining portions of Bradley and McMinn counties each be designated as unclassifiable, as 

listed in Appendix 3. The unclassifiable designation is requested rather than attainment because of the 

lack of modeling data and will likely change as additional information becomes available. These 

recommendations are based on the five-factor analysis outlined in the EPA guidance dated March 24, 

2011. The TAPCD evaluated the counties shown below (Figure A) in each metropolitan statistical area 

(MSA) or micropolitan statistical area. The following is a summary of each MSA/MiSA in which at least 

one non-attaining monitor is located.

Figure A – Tennessee Proposed Designations
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Table 1 - Tennessee 1-Hour Sulfur Dioxide County Designations

(1) McMinn County is recommended to be partially designated nonattainment for that portion of the county contained in a circle

centered on Universal Transverse Mercator (UTM) coordinate 703.927 kilometers E, 3908.144 kilometers N, with a radius of 2.0 

kilometers. This area encompasses a pulp and paper mill that is the primary source of sulfur dioxide emissions in the two county 

area.

(2) Bradley County is a Micropolitan Statistical Area (MiSA). It is recommended to be partially designated nonattainment for that 

portion of the county contained in a circle centered on Universal Transverse Mercator (UTM) coordinate 703.927 kilometers E, 

3908.144 kilometers N, with a radius of 2.0 kilometers. This area encompasses a pulp and paper mill that is the primary source of 

sulfur dioxide emissions in the two county area.

(1) Kingsport-Bristol (TN)-Bristol (VA), MSA 

The TAPCD is recommending that one county in this Metropolitan Statistical Area be classified as 

nonattainment for the 2010 primary sulfur dioxide (SO2) standard. The single nonattainment county is 

Sullivan, and it was formerly classified as attainment. The air monitoring data in this county (Sullivan) 

showed a design value for 2008-2010 data that exceeded the new standard. The TAPCD recommends 

that Hawkins County be designated unclassifiable.

2010 Standard Recommendation

2009 MSA County Unclassifiable Nonattainment

Kingsport-BristolBristol TN-VA MSAHawkins Yes

Sullivan Yes

Athens MiSA McMinn(1) Partial

Cleveland MSA Bradley (2) Partial

Polk Yes
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Figure 1 – Sullivan County

COUNTY SUMMARY 

The following is a county summary of the factors that were considered in the inclusion/exclusion 

evaluation for the Kingsport-Bristol area. These factors include air quality data, emissions-related data, 

meteorology, geography/topography. and jurisdictional boundaries, as well as other available data. All 

factors in the applicable EPA guidance were considered. 

Sullivan County

• Recommendation: nonattainment

• Air Quality Data: There are two sulfur dioxide monitors in Sullivan County. One of these monitors 

did not have a complete data set for 2008-2010. The remaining sulfur dioxide monitor in Sullivan

County showed a design value for 2008-2010 data that is greater than the new standard of 75 ppb. 

• Emissions: 21,980.51 tons per year of SO2 emissions allowable from point sources, this includes 

facility and airport emissions. 38.98 tons per year of SO2 emissions from mobile sources, on-road and 

non-road. 4,139.19 tons per year of SO2 emissions from area sources.

• Meteorology: The winds are climatologically from the west, west-southwest, and southwest.

• Geography/topography: Most of the 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. This county is a rural area with urban centers. The topography of this region consists of 
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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.

• Jurisdictional boundaries: Entire county.

• Population: 154,552 people and 374.2 people per square mile.

Summary: The TAPCD recommends that Sullivan County be designated as nonattainment for sulfur 

dioxide. The county contribution to the Kingsport-Bristol (TN)-Bristol (VA), TN-VA MSA remains to be 

determined for the entire MSA, which includes portions of Virginia. For the Tennessee portion of this

MSA, the county contribution for sulfur dioxide is 46.8%, of which the majority (39.3%) is from point

sources. About 72.8% of the population in the two county TN part of the MSA reside in Sullivan County. 

The population density is 374.2 per square mile. The county is a rural area with urban centers.

Hawkins County

• Recommendation: Unclassifiable

• Air Quality Data: There are no sulfur dioxide monitors in Hawkins County. 

• Emissions: 29,664.13 tons per year of SO2 emissions allowable from point sources, including facility 

and airport emissions. 11.48 tons per year of SO2 emissions from mobile sources, on-road and nonroad. 82.35 tons per year of SO2 emissions from area sources.

• Meteorology: The winds are climatologically from the west, west-southwest, and southwest.

• Geography/topography: The county is located in the Ridge and Valley Geographic Region, which 

covers 7,703 square miles and is situated between the Cumberland Plateau and Unaka Mountains. 

The topography of this region consists of long linear ridges with elevations of 1,100 to 1,500 feet, and 

parallel lowland valleys, where the elevations vary from 700 to 1,000 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.

• Jurisdictional boundaries: Entire county

• Population: 57,784 people and 118.7 people per square mile.

Summary: The TAPCD recommends that Hawkins County be designated as unclassifiable for sulfur 

dioxide. The county contribution to the Kingsport-Bristol (TN)-Bristol (VA), TN-VA MSA remains to be 

determined for the entire MSA, which includes portions of Virginia. For the Hawkins County TN part of 

this MSA, the county contribution for sulfur dioxide is 53.2%, of which the majority (99.7%) is from 

point sources. About 27.2% of the population in the two-county TN part of the MSA reside in Hawkins 

County. The population density is 118.7 per square mile. The county is almost entirely rural and agrarian.

(2) Cleveland TN MSA and Athens TN MiSA

Bradley County is included in the Cleveland, TN Metropolitan Statistical Area that includes Polk County,

and McMinn County is the only county in the Athens, TN Micropolitan Statistical Area. There is no sulfur 

dioxide monitor in Polk County. Tennessee recommends that Bradley and McMinn counties be designated 

partially nonattainment for the portions of the counties limited to a circle centered on Universal Transverse 
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Mercator (UTM) coordinate 703.927 kilometers E, 3908.144 kilometers N, with a radius of 2.0 kilometers, 

and that Polk County and the remainder of Bradley and McMinn counties be designated unclassifiable. This 

area encompasses a pulp and paper mill that is the primary source of sulfur dioxide emissions in the twocounty area. Note: Bowater is now AbitibiBowater.

Figure 2 – Bradley and McMinn Counties

COUNTY BY COUNTY SUMMARY 

The following is a county summary of the factors that were considered in the inclusion/exclusion 

evaluation for the Bradley, Polk, and McMinn Counties area. These factors include air quality data, 

emissions-related data, meteorology, geography/topography. and jurisdictional boundaries, as well as 

other available data. All factors in the applicable EPA guidance were considered. 

Bradley County

• Recommendation: partial nonattainment, remainder unclassifiable

• Air Quality Data: This county has one sulfur dioxide monitor. This monitor showed a design value 

for 2008-2010 data that is greater than the new standard of 75 ppb. 
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• Emissions: 489 tons per year of SO2 emissions from point sources, including facility and airport 

emissions. 26.962 tons per year of SO2 emissions from mobile sources, on-road and non-road. 

2,563.82 tons per year of SO2 emissions from area sources with the majority of the emissions coming 

from Source Classification Code 2102002000, Industrial - Bituminous/Subbituminous Coal.

• Meteorology: The winds are climatologically from the South, North, and Southwest.

• Geography/topography: The county is located in the Ridge and Valley Geographic Region, which 

covers 7,703 square miles and is situated between the Cumberland Plateau and Unaka Mountains. 

The topography of this region consists of long linear ridges with elevations of 1,100 to 1,500 feet, and 

parallel lowland valleys, where the elevations vary from 700 to 1,000 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.

• Jurisdictional boundaries: The portions of the county contained in a circle centered on Universal 

Transverse Mercator (UTM) coordinate 703.927 kilometers E, 3908.144 kilometers N, with a radius 

of 2.0 kilometers.

• 97,710 people and 297.0 people per square mile.

Summary: The TAPCD recommends that Bradley County be designated as partially nonattainment for 

sulfur dioxide, with the remaining part of the county unclassifiable. For the Bradley County TN part of 

the Cleveland TN MSA, the county contribution for sulfur dioxide is 96.8%, of which the majority 

(80.6%) is from area sources. About 86.2% of the population in the Cleveland MSA reside in Bradley 

County. For the three-county area (Bradley, Polk, and McMinn), the county contribution for sulfur 

dioxide is 41.5%, of which the majority (34.5%) is from area sources. About 58.8% of the population in

the three-county area reside in Bradley County. The population density is 297.0 per square mile. The 

county is a mostly rural area.

Polk County

• Recommendation: unclassifiable

• Air Quality Data: This county does not have a sulfur dioxide monitor. 

• Emissions: 0.06 tons per year of SO2 emissions from point sources, this includes facility and airport 

emissions. 4.33 tons per year of SO2 emissions from mobile sources, on-road and non-road. 96.20 

tons per year of SO2 emissions from area sources.

• Meteorology: The winds are climatologically from the South, North, and Southwest.

• Geography/topography: Most of the county is located in the Unaka Mountains Region, which covers 

2523 square miles and is the eastern most physiographic province in Tennessee. The Unaka 

Mountains are known for having the highest and most rugged terrain in Tennessee. The highest point 

in both the region and Tennessee is Clingman’s Dome (6,643 feet) in Sevier County. In addition to 

Clingman’s Dome, there are 13 mountain peaks with elevations above 6,000 feet and 33 peaks with 

elevations above 5,000 feet. The topography includes lofty mountain ridges and peaks, narrow 

lowland valleys, and isolated coves, which are heavily forested and deeply carved by precipitous 

stream valleys. 

• Jurisdictional boundaries: Entire county

• Population: 15,648 people and 36.0 people per square mile.

Summary: The TAPCD recommends that Polk County be designated as unclassifiable for sulfur dioxide.

For the Polk County TN part of the Cleveland TN MSA, the county contribution for sulfur dioxide is 
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3.2%, of which the majority (3.0%) is from area sources. About 13.8% of the population in the Cleveland

MSA reside in Polk County. For the three-county area (Bradley, Polk, and McMinn), the county 

contribution for sulfur dioxide is 1.4%, of which the majority (1.3%) is from area sources. About 9.4% of 

the population in the three-county area reside in Polk County. The population density is 36.0 per square

mile. The county is a mostly rural area and mostly sparsely populated mountainous region.

McMinn County

• Recommendation: partial nonattainment with the remainder unclassifiable

• Air Quality Data: This county has one sulfur dioxide monitor. This monitor showed a design value 

for 2008-2010 data that is greater than the new standard of 75 ppb. 

• Emissions: 2519.47 tons per year of SO2 emissions from point sources, this includes facility and 

airport emissions. 21.89 tons per year of SO2 emissions from mobile sources, on-road and non-road. 

1706.16 tons per year of SO2 emissions from area sources.

• Meteorology: The winds are climatologically from the South, North, and Southwest.

• Geography/topography: Most of the county is located in the Ridge and Valley Geographic Region, 

which covers 7,703 square miles and is situated between the Cumberland Plateau and Unaka 

Mountains. The county is primarily rural. The topography of this region consists of long linear ridges 

with elevations of 1,100 to 1,500 feet, and parallel lowland valleys, where the elevations vary from 

700 to 1,000 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.

• Jurisdictional boundaries: The portions of the county contained in a circle centered on Universal 

Transverse Mercator (UTM) coordinate 703.927 kilometers E, 3908.144 kilometers N, with a radius 

of 2.0 kilometers.

• Population: 52,739 people and 122.6 people per square mile.

Summary: The TAPCD recommends that McMinn County be partially designated nonattainment for 

sulfur dioxide, with the remainder unclassifiable. For the McMinn County TN part of the affected threecounty area (Bradley, Polk, and McMinn), the county contribution for sulfur dioxide is 57.2%, of which 

the majority (33.9%) is from point sources. About 31.8% of the population in the three-county area reside 

in McMinn County. The population density is 122.6 people per square mile. The county is a mostly rural 

area.

(3) Additional Monitoring Information

The following counties each have at least one sulfur dioxide monitor, and all monitors in these counties 

show attainment with the 1-hour sulfur dioxide standard:

1. Davidson (1 monitor)

2. Montgomery (2 monitors)

3. Sevier (1 monitor)

4. Shelby (1 monitor)
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Appendix 1: Additional Information for Sullivan County
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Tri-Cities 30-Year Wind Rose
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Appendix 2: Additional Information for Bradley and McMinn Counties
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2 Kilometer Radius Proposed Non-attainment Area
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Chattanooga 30-Year Wind Rose
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Appendix 3: Statewide County-by-County Designation Recommendations List
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County

2010 Standard 

Recommendation MSA/MiSA

Unclassifiable Nonattainment

ANDERSON Yes Knoxville MSA

BEDFORD Yes Shelbyville MiSA

BENTON Yes N/A

BLEDSOE Yes N/A

BLOUNT Yes Knoxville MSA

BRADLEY Partial Cleveland MSA

CAMPBELL Yes La Follette MiSA

CANNON Yes Nashville MSA

CARROLL Yes N/A

CARTER Yes Johnson City MSA

CHEATHAM Yes Nashville MSA

CHESTER Yes Jackson MSA

CLAIBORNE Yes N/A

CLAY Yes N/A

COCKE Yes Newport MiSA

COFFEE Yes Tullahoma MiSA

CROCKETT Yes N/A

CUMBERLAND Yes Crossville MiSA

DAVIDSON Yes Nashville MSA

DECATUR Yes N/A

DEKALB Yes N/A

DICKSON Yes Nashville MSA

DYER Yes Dyersburg MiSA

FAYETTE Yes Memphis TN-MS-AR MSA

FENTRESS Yes N/A

FRANKLIN Yes Tullahoma MiSA

GIBSON Yes Humboldt MiSA

GILES Yes N/A

GRAINGER Yes Morristown MSA

GREENE Yes Greeneville MiSA

GRUNDY Yes N/A

HAMBLEN Yes Morristown MSA

HAMILTON Yes Chattanooga TN-GA MSA

HANCOCK Yes N/A

HARDEMAN Yes N/A

HARDIN Yes N/A

HAWKINS Yes Kingsport-Bristol-Bristol TNVA MSA

HAYWOOD Yes Brownsville MiSA
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HENDERSON Yes N/A

HENRY Yes Paris MiSA

HICKMAN Yes Nashville MSA

HOUSTON Yes N/A

HUMPHREYS Yes N/A

JACKSON Yes Cookeville MSA

JEFFERSON Yes Morristown MSA

JOHNSON Yes N/A

KNOX Yes Knoxville MSA

LAKE Yes N/A

LAUDERDALE Yes N/A

LAWRENCE Yes Lawrenceburg MiSA

LEWIS Yes N/A

LINCOLN Yes N/A

LOUDON Yes Knoxville MSA

MCMINN Partial Athens MiSA

MCNAIRY Yes N/A

MACON Yes Nashville MSA

MADISON Yes Jackson MSA

MARION Yes Chattanooga TN-GA MSA

MARSHALL Yes Lewisburg MiSA

MAURY Yes Columbia MiSA

MEIGS Yes N/A

MONROE Yes N/A

MONTGOMERY Yes Clarksville TN-KY MSA

MOORE Yes Tullahoma MiSA

MORGAN Yes N/A

OBION Yes Union City MiSA

OVERTON Yes Cookeville MSA

PERRY Yes N/A

PICKETT Yes N/A

POLK Yes Cleveland MSA

PUTNAM Yes Cookeville MSA

RHEA Yes N/A

ROANE Yes Harriman MiSA

ROBERTSON Yes Nashville MSA

RUTHERFORD Yes Nashville MSA

SCOTT Yes N/A

SEQUATCHIE Yes Chattanooga TN-GA MSA

SEVIER Yes Sevierville MiSA

SHELBY Yes Memphis TN-MS-AR MSA

SMITH Yes Nashville MSA

STEWART Yes Clarksville TN-KY MSA
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SULLIVAN Yes Kingsport-Bristol-Bristol TNVA MSA

SUMNER Yes Nashville MSA

TIPTON Yes Memphis TN-MS-AR MSA

TROUSDALE Yes Nashville MSA

UNICOI Yes Johnson City MSA

UNION Yes Knoxville MSA

VAN BUREN Yes N/A

WARREN Yes McMinnville MiSA

WASHINGTON Yes Johnson City MSA

WAYNE Yes N/A

WEAKLEY Yes Martin MiSA

WHITE Yes N/A

WILLIAMSON Yes Nashville MSA

WILSON Yes Nashville MSA