Technical Support Document

for

Recommended Nonattainment Boundaries in Illinois 

for the

Lead National Ambient Air Quality Standard

AQPSTR 09-12

October 15, 2009

Illinois Environmental Protection Agency

Division of Air Pollution Control

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276
2

Table of Contents

TABLES......................................................................................................................................... 3

FIGURES....................................................................................................................................... 4

INTRODUCTION......................................................................................................................... 5

FEDERAL GUIDANCE............................................................................................................... 6

MADISON COUNTY EIGHT FACTOR ANALYSIS.............................................................. 7

AIR QUALITY ............................................................................................................................... 7

EMISSIONS ................................................................................................................................... 9

POPULATION DENSITY AND URBANIZATION .............................................................................. 11

EXPECTED GROWTH RATES AND PATTERNS .............................................................................. 12

METEOROLOGY.......................................................................................................................... 14

GEOGRAPHY/TOPOGRAPHY ....................................................................................................... 15

LEVEL OF CONTROL OF EMISSION SOURCES .............................................................................. 16

RECOMMENDATIONS............................................................................................................ 17

MADISON COUNTY RECOMMENDATION ....................................................................... 18

Madison County (Partial County) ........................................................................................ 18

Remainder of Madison County ............................................................................................. 18

Remainder of Illinois............................................................................................................. 19

APPENDIX A.............................................................................................................................. 22
3

TABLES

Table 1 2006 – 2008 Lead Design Values in Illinois (ug/m3).................................... 8

Table 2 Stationary Lead Emission Sources in Madison County............................... 10

Table 3 Population and Population Density - 2008 Estimates by Municipality.............. 12

Table 4 EGAS Projected Emission Change (2008 to 2015) For Stationary Sources

 in Madison County ................................................................................................ 14

Table 5 Recommended Attainment/Nonattainment Designations in Illinois

 for the 2008 Revised Lead National Ambient Air Quality Standard................. 19

Table 6 Lead NAA Eight Factor Documentation................................................. 20
4

FIGURES

Figure 1 2006-2008 Lead Monitored Design Values ..................................... 23

Figure 2 Madison County Lead Emissons by Industry................................... 24

Figure 3 Location and Emissions of Stationary Sources in Madison County.......... 25

Figure 4 Proximity of Emission Sources to Nearby Monitor............................ 26

Figure 5 Location of NL Industries/Taracorp Superfund Site............................. 27

Figure 6 Madison County Population Density and Urbanization........................ 28

Figure 7 Madison County Total Population by Municipality............................ 29

Figure 8 Percent of Land Cover by Type in Madison County ........................... 30

Figure 9 Madison County Population Change ............................................. 31

Figure 10 Meteorology - St. Louis Wind Rose.............................................. 32

Figure 11 Madison County Elevation (Topography)....................................... 33

 

Figure 12 Proposed Lead Nonattainment Area, City of Granite City.................... 34
5

Introduction

On October 15, 2008, the U.S. Environmental Protection Agency (U.S. EPA) revised the lead

National Ambient Air Quality Standard (NAAQS) in response to numerous studies which link 

the health effects associated with lead exposure to adverse effects on IQ, learning and behavior 

in children. Studies show that these adverse health effects on the nervous system can persist into 

adulthood. The primary lead standard was strengthened from 1.5 ug/m3, set in 1978, to a level of

0.15 ug/m (73 FR66964; November 12, 2008). Like the 1978 standard, the revised 2008 

standard will be measured as the concentration of lead in Total Suspended Particulates (TSP).

As part of the revised lead NAAQS, U.S. EPA also modified how attainment is determined. U.S. 

EPA revised the averaging time to a “rolling 3-month average period with a maximum (not to be 

exceeded) form, evaluated over a three-year period” (73 FR66964; November 12, 2008). In 

addition, U.S. EPA strengthened the secondary lead standard to provide increased protection 

against adverse public welfare effects associated with impacts on organisms and ecosystems. 

This standard is identical to the primary standard (0.15 ug/m3). In conjunction with 

strengthening the lead NAAQS, U.S. EPA is improving the existing lead monitoring network by 

requiring additional monitors (source oriented) to be placed in areas with sources that emit more 

than 1 ton per year (tpy) of lead and monitors (non-source oriented) in urban areas with 

populations greater than 500,000 people. In Illinois, these additional monitoring sites will be 

operational by January 1, 2010.

Section 107(d) of the Clean Air Act (CAA) governs the process for area designations. Following 

the promulgation of a new or revised air quality standard, the Clean Air Act (CAA) requires the 

Governor to recommend initial designations of the attainment status for all areas of the State. 

Areas can be classified as nonattainment (does not meet, or contributes to a nearby area that 

does not meet the NAAQS), attainment (meets the NAAQS), or unclassifiable (cannot be 

classified based on available data). Illinois is, therefore, required to provide recommendations 

for attainment/nonattainment area boundaries for the revised lead standard. The U.S. EPA will 

act on the State’s recommendations by either affirming and promulgating the recommended 

designation boundaries, or by promulgating new designations.
6

This report provides the basis for recommendations by the Illinois Environmental Protection 

Agency (IEPA) for attainment/nonattainment designation boundaries for all areas in the State of 

Illinois for the 2008 revised lead standard. Based on the most recent three years of ambient 

monitoring data (2006-2008), only one monitor in Illinois, located in Madison County, is 

currently violating the 2008 revised lead NAAQS. Based on an analysis of the factors contained 

in federal guidance, the IEPA is recommending that only a portion of Madison County, the City 

of Granite City, be designated as nonattainment for the 2008 revised lead standard. The IEPA 

considers the lead air quality problem to be due to local industrial emission sources. The

recommended boundaries reflect U.S. EPA guidance. The remaining areas of Illinois should be

classified as attainment for the lead standard.

Federal Guidance

IEPA relied on guidance identified in a memorandum issued by U.S. EPA on August 21, 2009 

which referenced pages in the preamble of the lead NAAQS final rule regarding subjects for 

developing this recommendation, and for establishing the geographic boundaries of 

nonattainment areas (NAA) for the 2008 revised lead standard. This memorandum is attached in 

Appendix A. In this guidance, U.S. EPA recommended that states designate areas with air 

quality data showing violations of the lead NAAQS, and nearby areas that cause or contribute to 

NAAQS violations, be designated nonattainment. Due to the non-pervasive nature of lead, U.S. 

EPA also recommends that the county perimeter associated with the violating monitor(s) serve as 

the starting point or “presumptive” boundary of the 2008 lead nonattainment area. Due to the 

fact that the 2008 revised primary and secondary lead NAAQS are identical, “U.S. EPA expects 

that each area will have the same designation and boundary for both standards”, (Appendix A). 

U.S. EPA provides states with the ability to depart from presumptive boundaries based on areaspecific analyses. States may request nonattainment area boundaries that are smaller than the 

existing violating county boundaries where counties, or portions of counties are rural and do not 

contribute to nonattainment based on an examination of eight factors. States may also request 

nonattainment area boundaries that are larger than the current county to include adjacent counties

when those counties contain emission sources, population, growth, and other factors that may 
7

contribute to the nonattainment problem. The monitor exceeding the 2008 lead standard in 

Illinois and the affected county are shown in Figure 1. Madison County is the only county in 

Illinois where a violation of the revised lead NAAQS is occurring, so Madison County is the 

only county represented as part of this analysis. The IEPA’s analysis of each of the eight factors 

for Madison County is provided in the following sections of this report. 

Madison County Eight Factor Analysis

U.S. EPA recommends that States and Tribes consider the following eight factors in assessing 

whether to depart from presumptive boundaries in the designated nonattainment area boundary:

1. Air Quality (in potentially included versus excluded areas)

2. Emissions (in areas potentially included versus excluded from NAA)

3. Population Density and Degree of Urbanization 

4. Expected Growth (extent, pattern and rate)

5. Meteorology 

6. Geography/Topography

7. Jurisdictional Boundaries

8. Level of Control of Emission Sources

Air Quality

U.S. EPA changed the calculation method for the averaging time to use a “rolling” three-month 

period with a maximum (not-to-be-exceeded) form, evaluated over a three-year period. This 

replaced the previous NAAQS interpretation which used a calendar quarter average not to be 

exceeded in a calendar year. A rolling three month average considers each of the 12 three-month 

periods associated with a given year, not just the four calendar quarters within that year.

Lead design values, calculated as a rolling 3-month average over a 3 year period (2006- 2008),

were derived from lead measurements collected from IEPA’s ambient air monitoring network. 

These values were collected for 13 monitors statewide and their design values are summarized in 

Table 1 and Figure 1. As shown in Table 1 and Figure 1, IEPA’s monitoring data indicates that 
8

between 2006 and 2008, violations of the lead standard have only occurred in Madison County, 

Illinois. Based on monitoring, the rest of Illinois currently meets the revised lead standard. 

There are two monitors within Madison County which measure lead. These monitors are located 

in Granite City and Wood River. Only one of these monitoring stations exceeds the NAAQS, 

however. The monitor located at 15th and Madison streets in Granite City exceeds the revised 

lead NAAQS. The monitor located in Wood River, in the northwestern portion of Madison 

County, is measuring well below the standard at 0.04 ug/m3. Lead air quality data collected in 

Madison County, therefore, indicates that it is appropriate to designate at least the southwest 

portion of Madison County as nonattainment areas for the revised lead standard. 

 

Table 1

2006-2008 

Lead Design Values in Illinois (ug/m3)

County Site Address

Maximum 3-Month

Rolling Averages Design 

Value 2006 2007 2008

Cook Alsip 4500 W. 123rd Street 0.01 0.02 0.02 0.02

Cook Chicago - Cermak 735 W. Harrison 0.06 0.04 0.05 0.06

Cook Chicago - Mayfair 4850 Wilson Avenue 0.03 0.02 0.02 0.03

Cook Chicago - Washington 3535 E. 114th Street 0.04 0.05 0.05 0.05

Cook Maywood 1500 Maybrook Drive 0.03 0.03 0.03 0.03

Cook Northbrook 750 Dundee Road 0.01 0.01 0.01 0.01

Cook Schiller Park 4743 N. Mannheim Road 0.01 0.02 0.01 0.02

Cook Summit 60th St. and 74th Ave. 0.02 0.02 0.02 0.02

Macoupin Nilwood Heaton and Dubois 0.01 0.01 0.01 0.01

Madison Granite City 15th and Madison 0.18 0.20 0.28 0.28

Madison Wood River 54 N. Walcott 0.02 0.03 0.04 0.04

Peoria Peoria 613 NE Jefferson 0.01 0.01 0.01 0.01

St. Clair East St. Louis 13th and Tudor 0.04 0.05 0.04 0.05

In conjunction with strengthening the lead NAAQS, the U.S. EPA requires states to expand the 

existing lead monitoring networks by requiring monitors to be placed in areas with large 

industrial sources (facilities) that emit lead and in urban areas with populations of more than 

500,000 people. The industrial-oriented monitors are to be in place by January 1, 2010 and are to 

be designed to measure the maximum concentration in areas near sources with lead emissions of 
9

one ton or more per year. The population-oriented monitors are to be in place by January 1, 2011 

and designed to gather information on the general population’s exposure to lead in air and ensure 

protection against sources of airborne dust containing lead. U.S. EPA recommends that

remaining portions of Illinois should be designated unclassifiable/attainment for the 2008 revised

lead standard, until the additional source-oriented monitors have been evaluated.

Consistent with the November 12, 2008 monitoring revisions, IEPA and U.S. EPA reviewed the 

National Emissions Inventory and determined that six lead sources exceeded the one ton per year 

emissions criteria. IEPA proposes to conduct ambient lead monitoring at all of these facilities as 

required by the U.S. EPA rule. This will require new monitoring sites at five locations, and the

continuation of the existing site in Granite City. Additionally, source-oriented monitoring at

industrial locations in Mapleton and Chicago –Kramer have been proposed. The existing lead 

monitoring network contains numerous lead monitors in high density population areas within 

those urban areas that exceed 500,000 persons, so the IEPA has not proposed additional 

population-oriented monitors. 

Emissions

Lead is a metal found naturally in the environment as well as in manufactured products and can 

be emitted into the air in the form of particles small enough to stay suspended in the air, known 

as total suspended particulates. Lead emitted to the air can be inhaled directly or ingested after 

it settles onto surfaces or soil. U.S. EPA recommends that proposed nonattainment designations 

for the 2008 lead NAAQS reflect not only the areas of measured violations, but also the nearby 

areas that contribute to measured violations. The highest levels of lead in air are commonly

found near lead smelters. Additional sources include: iron and steel foundries, copper smelting, 

metal mining, industrial, commercial and utility boilers as well as leaded aviation gasoline

(AVGAS) in non-commercial small planes, waste incinerators, and cement and glass 

manufacturing. As shown in Figure 2, the majority of lead sources in Madison County are

stationary sources which use raw materials for metal production. IEPA estimated emissions 

data and Toxics Release Inventory (TRI) data for stationary lead sources show lead emissions 

during the 2006 – 2008 time period in Madison County, and are summarized by facility in Table 
10

2. According to this data, U.S Steel, Granite City Works is the largest source of lead in the 

Madison County. The U.S. Steel, Granite City Works facility located in this area exceeds the 1 

tpy threshold set for source-oriented monitoring. As seen in Figure 3, the highest emitting lead 

sources are located in the southwestern portion of Madison County within the limits of Granite 

City. Emission sources within Granite City make up approximately 70% of total emissions in 

the county. Other lead sources which are located in close proximity to the violating monitor are 

Mayco Industries LLC, American Colloid Company, Amsted Rail Company and Owens Corning 

Roofing & Asphalt, LLC (see Figure 4).

Table 2

Stationary Lead Emissions Sources in Madison County 

Name City

2006 

Estimated 

Emissions 

(tons/year)

2007 

Estimated 

Emissions 

(tons/year)

2008 Estimated 

Emissions 

(tons/year)

US Steel Granite City Works Granite City 0.92 1.33 1.54

Alton Steel Inc Alton 0.402 0.399 0.469

Olin Corp East Alton 0.18 0.18 0.1731

Amsted Rail Co Inc* Granite City 0.188 0.154 0.154

Dynegy Midwest Generation Inc East Alton 0.0119 0.0519 0.114

GBC Metals LLC DBA Olin Brass East Alton 0.00157 0.025

ConocoPhilipps Co Roxana 0.01 0.01 0.013

Mayco Industries LLC Granite City 0.006 0.01 0.000227

Richards Brick Co Edwardsville 0.000393 0.00026 0.00027

Christ Bros Products LLC South Roxana 0.000009 0.000019

Anderson Hospital Maryville 0.000009

Owens Corning Roofing

& Asphalt LLC Granite City 0.000007 0.000008 0.000009

Magnesium Elektron North America Madison 0.00004 0

Gateway Regional Medical Center Granite City 0 0

St Anthonys Hospital Alton 0 0 0

Conoco Phillips Hartford Lubricant Plant Hartford 0 0 0

St Clares Hospital Alton 0 0 0

Union Electric Co Venice 0 0 0

Alton Memorial Hospital Alton 0.000054 0

Kinder Morgan Transmix Co LLC Hartford 0 0

American Colloid Co* Granite City 0 0.125

Precoat Metals* Granite City 0 0 0.0125

Total 1.71835 2.13679 2.62613

*TRI Reported Values
11

According to U.S. EPA, “stationary sources are expected to be the primary contributor to 

violations of the NAAQS” (73 FR67033; November 12, 2008); however, fugitive dust emissions

from area sources containing deposited lead may also contribute to violations of the revised lead 

NAAQS. Illinois has one such source in close proximity to the violating monitor. The NL 

Industries/Taracorp Corporation Superfund site is located in Granite City just blocks from the 

monitor (see Figure 5). NL Industries and Taracorp operated a secondary lead smelter from the 

turn of the century until 1983. The site has a documented risk to public health from exposure to 

lead. Contamination from the site affected portions of Granite City, Madison and Venice. Lead 

contaminated soils and crushed battery case materials were deposited into a large slag pile

(Figure 5). The cleanup of this facility, under U.S. EPA’s Superfund Program, was initiated in 

1991 by the U.S. Army Corps of Engineers. The project consisted of the cleanup of residential 

properties as well as the consolidation and capping of a 250,000 ton slag pile within the main 

industrial site. The residential cleanup and capping of the Taracorp pile was completed in May

of 2000. Recent site visits indicate that the U.S. EPA remedy implemented at the site is

effective and may pose little impact on lead emissions. 

Population Density and Urbanization

The U.S. Census Bureau estimates that 268,078 people lived in Madison County in 2008. Table 

3 lists the population of Granite City and other cities within Madison County, as well as land 

areas, and population densities based on U.S. Census Bureau data. Figure 6 graphically depicts

population densities by census block groups within Madison County. According to the U.S. 

Census Bureau, Granite City is the largest populated city within Madison County, followed by 

Alton, Collinsville, Edwardsville and the village of Godfrey. Figure 7 compares the population 

of the largest municipalities in Madison County. 
12

Table 3

Population and Population Density

2008 Estimates by Municipality

(larger cities)

Source: U.S. Census Bureau estimate as of March 20, 2009, at http://factfinder.census.gov/

Source: U.S. Census Bureau’s State and County Quick Facts at 

http ://quickfacts.census.gov/qfd/states/17/1730926.html

Figure 8 depicts current land cover percentages within Madison County based on data compiled 

by the Illinois Department of Agriculture. According to the “Land Cover of Illinois 1999-2000

On-Line Statistical Summary”, Madison County has a high percentage of agricultural land 

(greater than 62%) indicating that Madison County is primarily rural in nature.

Expected Growth Rates and Patterns

The IEPA has evaluated both population and economic growth rates to identify expected trends 

of lead emissions in Madison County. Short term population growth can be an important 

indicator of potential emission increases in an area. Figure 9 shows change in population 

between 2000 and 2008 for Madison County. This data was provided by the U.S. Census Bureau 

and is based on estimates dated March 19, 2009. According to the data, Madison County has 

experienced an increase in population of 3.5%, although larger cities such as Granite City and 

Alton have both experienced an approximate 4% loss in total population. Municipalities located 

along and east of the bluff line and towards the rural/agricultural corridor in Madison County are 

experiencing growth due to urbanization. Collinsville and Edwardsville have experienced 

Municipality Population 2008

Land Area

(Square Miles)

Population Density 

(Persons per Sq. 

Mile)

Granite City 30,703 16.7 1,838.5

Alton 29,393 15.0 1,959.5

Collinsville 25,960 13.6 1,908.8

Edwardsville 24,557 14.1 1,741.6

Godfrey 17,524 36.2 484.1

Glen Carbon 12,607 7.5 1,680.9

Wood River 10,973 6.1 1,798.9
13

increases in population of 4 and 10 percent, respectively. This change indicates that population

in Madison County is moving from core industrial cities into bluff line areas beyond the 

American Bottoms floodplain communities and towards the City of Highland (East-West 

Gateway, 2004). 

Population and economic trends are developed for long range planning activities by both state 

and local governmental agencies. The East-West Gateway Council of Governments provides 

information for long range population and employment projections. According to a 2004 study, 

Madison County population is expected to increase by 7.6% in future years (2000 – 2015). 

The U.S. EPA developed a model referenced as the Economic Growth Analysis System or 

“EGAS”, to serve as a forecast tool for projecting emissions from industry sectors. EGAS 

determines growth factors for developing emission inventory projections based on economic 

activity datasets, both national and regional. Table 4 lists source related emissions in Madison 

County and their expected emission change from 2008 to 2015 in tons per year, based on EGAS 

output. This data shows a downward trend of -7.2% for most large metal manufacturing 

sources, while predicting an increase in smaller producers of lead. 
14

Table 4

EGAS Projected Emission Change (2008 to 2015)

For Stationary Sources in Madison County

Name City 2008 Estimated 

Emissions 

(tons/year)

Projected 2015 

Emissions 

(tons/year)

US Steel Granite City Works Granite City 1.54 1.429105

Alton Steel Inc Alton 0.469 0.435227

Olin Corp East Alton 0.1731 0.160635

Amsted Rail Co Inc* Granite City 0.154 0.142910

Dynegy Midwest Generation Inc East Alton 0.114 0.124835

GBC Metals LLC DBA Olin Brass East Alton 0.025 0.023200

ConocoPhilipps Co Roxana 0.013 0.014000

Mayco Industries LLC Granite City 0.000227 0.000211

Richards Brick Co Edwardsville 0.00027 0.000300

Christ Bros Products LLC South Roxana 0.000019 0.000020

Anderson Hospital Maryville 0.000009 0.000010

Owens Corning Roofing & Asphalt LLC Granite City 0.000009 0.000010

Magnesium Elektron North America Madison 0 0

Gateway Regional Medical Center Granite City 0 0

St Anthonys Hospital Alton 0 0

Conoco Phillips Hartford Lubricant Plant Hartford 0 0

St Clares Hospital Alton 0 0

Union Electric Co Venice 0 0

Alton Memorial Hospital Alton 0 0

Kinder Morgan Transmix Co LLC Hartford 0 0

American Colloid Co* Granite City 0.125 0.125

Precoat Metals* Granite City 0.0125 0

Total 2.62613 2.45546

 *TRI 2008 Emission base

Meteorology 

Illinois has a temperate climate, with cold winters and hot humid summers. The seasons are 

sharply differentiated between the northern and southern portions of the state, due to its 

elongated north-south orientation. Average winter temperatures are 22°F (–6°C) in the north and 

37°F (3°C) in the south. Average summer temperatures are 70°F (21°C) in the north and 77°F 

(25°C) in the south. Illinois averages 36 inches (91 cm) of precipitation a year. Annual snowfall 
15

of 37 inches (94 cm) is normal for northern Illinois, decreasing to 14 inches (36 cm) or less in the 

southern portions of the state. The predominant wind direction across the state is from the 

south/southwest, with an average wind speed of approximately 11 miles per hour.

For pollutant dispersion the most important meteorological parameters are wind speed and wind 

direction. Meteorology affecting Madison County is characterized in Figure 10. Wind rose 

information was provided by the Illinois State Climatologist Office, and incorporates long term 

wind statistics at Lambert International Airport showing wind directions for the averaging period 

of 1961 to 1990. Each vector on the wind rose represents the amount of time the wind blows 

from one of 16 compass sectors. The length of each vector represents the percentage of time that 

the wind is blowing from a particular direction. The various colors show the percentage of time 

that wind from a particular direction is in a particular range of wind speed (knots). According to 

this information, the predominant wind directions are south, south- southeast and westnorthwest, with the highest frequency of winds blowing from the south. No complex chemistry 

is needed to form lead or lead compounds in the ambient air, therefore, concentrations of lead are 

typically highest near lead sources. 

Geography/Topography

Illinois is typified by flat to gently rolling terrain, with the exception of the Driftless Area in the 

northwest corner of the state and the Ozark Plateau in southern portion of the state. Illinois

occupies a land mass of approximately 55,584 square miles. The average elevation of the state is 

approximately 600 feet (183 m) above sea level. Charles Mound, located in Jo Davies County, is 

the highest point in the state with an elevation of 1,235 feet (376 m) above sea level. The lowest 

point in the state is 279 feet (85 m) above sea level along the Mississippi River in Alexander

County. Total topographic relief across the state is less than 1000 feet, demonstrating the 

general flatness of the terrain. According to U.S. Department of Agriculture, Soil Survey Data, 

Madison County is characterized by topographic features ranging from upland till plains and 

bluffs, to the alluvial Mississippi River Valley, known as the “American Bottoms”. The 

American Bottoms makes up approximately 15 percent of the county. Elevation in the county
16

ranges from 650 feet above sea level on the bluffs, to approximately 450 feet in the southeast 

corner of the county, and drops as low as 400 feet in some areas (swales). Madison County does 

not have significant topographic features which affect lead pollution transport (see Figure 11)

and therefore, topography is not considered a significant factor in defining the boundaries of the 

lead nonattainment areas.

Jurisdictional Boundaries

The Illinois EPA is responsible for air quality regulatory programs for every county in the state. 

Madison County is also located within the East-West Gateway Council of Governments study 

area. Jurisdictional boundaries considered in this analysis are consistent with recommended 

geographic boundaries, or “presumptive boundary” definitions, outlined in the lead rule and 

guidance documentation. Boundaries in this study reflect May 2009 municipal boundaries (see 

Figure 12) provided by the Madison County, Chief County Assessment Office, Maps and Plats 

Division. Based on the geographic location of Granite City and individual sources, it is expected 

that the coordination of planning activities required to address nonattainment designations, can 

be carried out in a cohesive manner.

Level of Control of Emission Sources

Emission control measures which have been promulgated at the federal and state level have 

impacted emission levels from a wide spectrum of emission sectors in the Metro-East/St. Louis 

area (of which Madison County is a part). These have led to significant air quality 

improvements. Further emission reductions through State Implementation Plan approved 

regulations regarding particulate emissions from stationary sources and are expected to enhance 

these air quality gains. Principal among existing emission reduction measures include the 

following:
17

Stationary Point Sources

MACT Standard for integrated Iron and Steel Manufacturing

MACT Standard for Iron and Steel Foundries

PM NAA

o Areas historically in NAA subject to PM emission limits developed to address 

standards 

NESHAPS

o Mass Emission Rate Limits on PM

o Opacity limits for capture systems and control devices

NSPS

o Mass Emission Rate Limits on PM for new sources

Mobile Sources

U.S EPA removal of leaded gasoline 

o began in the early 1970s, with significant reductions in 1985 and 1986,

o complete elimination of lead in motor vehicle fuel gasoline at the end of 1996.

Locomotive Engine Standards

New emission sources are required to obtain construction permits from the IEPA. Typically, 

state-of-the-art emission controls are required on new emission sources before they can operate.

Recommendations

IEPA’s recommendations for attainment/nonattainment designations in Illinois for the revised 

lead national ambient air quality standards are contained in Table 5. Current air quality data 

collected by the IEPA indicate that the only area in Illinois where the revised lead standard is not 

being met is in Granite City, Illinois. Nonattainment designations for this area are, therefore, 

warranted. 

The CAA does not specify the geographic boundaries, size, or the extent to which source 

contributions would require that an area be designated as nonattainment for the 2008 revised lead 

standard, nor has U.S. EPA promulgated rules prescribing such. IEPA’s recommendations are 
18

consistent with the guidance memorandum provided by U.S. EPA (Appendix A), and are based 

on an evaluation of present air quality, the distribution of emissions, and other factors. The 

IEPA recognizes that each of the factors considered in this evaluation are not necessarily 

conclusive when evaluated individually. Rather, IEPA’s recommendations are based on 

consideration of all of the data and projections taken together. Documentation of data sources 

utilized in this analysis is summarized in Table 6. The IEPA’s recommendation for inclusion of 

the City of Granite City to represent the boundaries of the nonattainment areas are discussed in 

the following section and geographically depicted in Figure 12.

Madison County Recommendation

Madison County (Partial County)

Madison County is the only county where current air quality data (2006-2008) does not meet the 

revised lead standard. A monitor in Madison County, located in the City of Wood River,

indicates that northern portions of the County currently meet the revised lead NAAQS, while the

one monitor in Granite City located to the southwest portion of the county is not attaining the 

lead standard. Granite City has the highest level of lead emissions in Madison County. As 

discussed previously, approximately 70% of total county emissions originate from sources within 

the City of Granite City. As indicated previously, the City of Granite City has the highest 

population of all the municipalities in Madison County. In addition, a monitor located in St. 

Clair County directly to the south of Granite City is currently meeting the revised lead NAAQS, 

further indicating that the violation is associated with local activities in close proximity to the 

Granite City Monitor. For these reasons, the boundaries of the City of Granite City should be 

considered nonattainment for the 2008 revised lead NAAQS.

Remainder of Madison County

Areas of the Madison County, outside of the city of Granite City, are in attainment with the 2008 

revised lead NAAQS and should be designated as attainment. 
19

Remainder of Illinois

The remainder of Illinois is attaining the revised lead standard and should, therefore, be 

designated as attainment. 

Table 5

Recommended Attainment/Nonattainment Designations in Illinois

For the 2008 Revised Lead National Ambient Air Quality Standard

County Designation Name of 

Area

Madison: Granite City (City)

Limits

 Aux Sable Township

 Goose Lake Township

 All Other Townships

Nonattainment Metro-East

Remainder of Madison County Attainment Metro-East

All Other Counties Attainment Illinois
20

Factor Data Analysis Data Source Date of Study

1. Air Quality Lead 2006-2008 Design Values 

at individual monitors 

(statewide)

IEPA BOA Database, 

Air Monitoring 

Section

2006-2008

2. Emissions Emission inventory information 

for Lead: 

IEPA 2008 Estimated 

Emissions, TRI data, 

RAPIDS

2008; 2002

3. Population Density and 

Degree of Urbanization

Annual Estimates of the 

Population in Illinois. Total 

population and population 

density estimates*

Population Division, 

U.S. Census Bureau;

Resident Population 

for Incorporated 

Places in Illinois, 

April1, 2000 – July 1, 

2008 (SUB-EST2008-

04-17)

Annual Estimates of 

Population for 

Counties in Illinois

(CO-EST2008-01-17)

ESRI Maps and Data

Release Date: 

July 1, 2009

March 20, 2009

2007

4. Expected Growth (Extent 

Rates and Patterns)

Total population change based 

on short and long-term 

population projections

U.S. EPA EGAS Emission 

Projections

(2008 to 2015)

Table 2: Cumulative 

Estimates of the 

Resident Population 

Change for Counties 

of Illinois: April 1, 

2000 to July, 2008 

(CO-EST2008-02-17);

East-West Gateway

Council of 

Governments

Long-Range 

Population and 

Employment 

Projections

Release Date: 

March 19, 2009

June 2004

EGAS Version 

5.0

Table 6

Lead NAA Eight Factor Documentation
21

*http://www.census.gov

5. Geography/Topography Madison County Elevation Google Maps Data 

U.S.D.A. Soil Survey 

of Madison County 

East-West Gateway 

Elevation Map

2008

1999

April 2005

6. Jurisdictional Boundaries Madison County Boundary and 

municipal boundary 

information; 

Madison County, 

Chief County 

Assessment Office, 

Maps and Plats GIS 

Division 

May 2009

Annexed areas

7. Meteorology Weather patterns – Wind Rose 

1961 -1990 

National Weather 

Service, Illinois State 

Climatologist Office

October 7, 2004

8. Level of Control of Emission 

Sources

Existing and expected controls IEPA – BOA 

Programs

2009
22

APPENDIX A