## Technical Support Document

f or Recommended Nonattainment Boundaries in Illinois

f or t he

Lead National Ambient Air Quality Standard

AQPSTR 0 9

- 1 2

October 15

, 2009

Illinois Environmental Protection Agency

Division of Air Pollution Control

1021 North Grand Avenue East

P.O. Box 19276 Springfield, IL 62794

- 92762 

### Table of Contents

TABLES

................................ ................................ ................................ ................................ ......... 3

FIGURES

................................ ................................ ................................ ................................ ....... 4

INTRODUCTION

................................ ................................ ................................ ......................... 5

FEDERAL GUIDANCE

................................ ................................ ................................ ............... 6

MADISON COUNTY EIGHT FACTOR ANALYSIS

................................ .............................. 7

A IR Q UALITY

................................ ................................ ................................ ............................... 7

E MISSIONS

................................ ................................ ................................ ................................ ... 9

P OPULATION D ENSITY AND U RBANIZATION

................................ ................................ .............. 11

E XPECTED G ROWTH R ATES AND P ATTERNS

................................ ................................ .............. 12

M ETEOROLOGY

................................ ................................ ................................ .......................... 14

G EOGRAPHY /T OPOGRAPHY

................................ ................................ ................................ ....... 1 5

L EVEL OF C ONTROL OF E MISSION S OURCES

................................ ................................ .............. 16

RECOMMENDATIONS

................................ ................................ ................................ ............ 17

MADISON COUNTY RECOM MENDATION

................................ ................................ ....... 18

Madison County (Partial County)

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

................................ ................................ ............................. 18

Remainder o

f Illinois

................................ ................................ ................................ ............. 19

APPENDIX A

................................ ................................ ................................ .............................. 223 

### T ABLES

Table 1 2006

– 2008 Lead Design Values in Illinois (ug/m 3 )...............

......... ... ...... .. . 8

Table 2 Stationary Lead Emission Sourc es in Madison County...................

............ 10

Table 3 Population and Population Den sity

- 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

f or the 2008 Revised Lead National Amb ient Air Quality Standard

............ ... . . 19

Table 6 Lead NAA Eight Factor Documentation

.. ... ................................. ......... .. 204 

### F IGURES

Figure 1 2006

- 2008 Lead Monitored Design Values

.................................... . 23

F igure 2 Madison County Lead Emissons by Industry

................................. . . 24

Figure 3 Location and Emissions of Stationary Sources in Madiso n 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. Loui s Wind Rose

............................................. . 32

F igure 11 Madison County Elevation (Topography)

....................................... 33

Figure 12 Proposed Lead Nona ttainment Area, City of Granite City

.................. .. 345



### Introduction

On October 15

, 2008 , the U.S. Environmental Protection Agency (U.S. EPA) revised the l ead

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

the healt h effects associated with l ead ex posure 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 l ead standard was strengthened from 1.5 ug/m 3

, set in 197 8

, 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 Suspe nded 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, eva lua ted 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 identica l to the primary standard (0.15 ug/m 3 ). In conju n ction 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 source s that emit more

than 1 ton per year (tpy) of lead and monitors (non

- source oriented) in ur ban 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, req uired to provide recommendations

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

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

designation boundaries, or by promulgati ng 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 l ead standard

. Based on the most recent three years of ambient

monitoring data (200 6

- 200 8 ), 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

, th e IEPA is recommending that only a portion of Madison County , the C ity

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 pr eamble 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 l ead standard. This memorandum is attache d in

Appendix A. In this guidance, U.S. EPA recommend ed that s tates designate areas with air

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

NAAQS violations, be designated nonattainment. Due to the non

- pe rvasive nature of l ead , U.S.

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

the starting point or “presum ptive” boundary of the 2008 l ead nonattainment area

. Due to the

fact that the 2008 revised primary an d secondary lead NAAQS a re identical, “U.S. EPA e xpects

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 area

specific a nalyses. States may request non attainment area boundaries that are smaller than the

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

contribute to non attainment based on an examination of eight factors. S tates may also request

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

when those counties contain emission sources, population, growth, and other factors that may7

contribute to the non attainment problem. The monitor exceeding the 2008 lead stand ard in

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

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

only c ounty represe nted 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 Tri bes consider the follow ing eight factors in asse ssing

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

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

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

3. Po pul ation Density and Degree of U rbanization

4. Expected Growth (extent, pattern and rate)

5. Meteorology

6. Geography/T opography

7. Jurisdictional Boundaries

8. Level of Control of Emission S ources

Air Quality

U

. S

. EPA changed the calculation method for the averagin g ti me 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 th ree month average considers each of the 12 three

- month

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

L ead 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 ind icate s tha t8

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

Illinois. Based on m onitoring, the rest of Illi nois currently meets the revised lead standard.

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

in Granite City and Wood River. O nly one of these mo nitoring station s exceeds the NAAQS,

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

lead NAAQS

. The monitor lo cated in Wood River, in the north western portion of Ma dison

County

, is measuring well below the standard at 0.04 ug/m 3

. Lead air qu ality data collected in

Madison County , therefore, indicate s that it is appropriate to de signate at least the southwest

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



### Table 1

2006

- 2008 Lead Design Values in Illinois (ug/m 3 

### )

County Site Address Maximum 3

- Month Rolling Averages Design

Value 2006 2007 2008

Cook Alsip 4500 W. 123 rd 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. 114 th 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 60 th St. and 74 th Ave. 0.02 0.02 0.02 0.02 Macoupin Nilwood Heaton and Dubois 0.01 0.01 0.01 0.01

Madison Granite Cit y 15 th 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 13 th 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 indus trial

- 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 of9

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 u nclassifia ble/attainment for the 2008 revised

lead standard

, until the additional source

- oriented monitors have been evaluated.

Consistent with the November 12, 2008 monitoring revisions, I EPA and U

. S

. EPA reviewed the

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

e missions 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

continuati on 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 ar eas within

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

population

- oriented monitors.

Emission s

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

be emitted into th e air in the form of particles small enough to stay suspended in the air, kn own

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 nonatt ainment designations

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

areas that contribute to measured violations

. T he highest levels of lead in air are commonly

found near lead smelters. A dditional sources include: iron and steel foundries, c o pper smelting,

m etal 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 source s which use raw materials for metal production

. IEPA estimated e missions

data and Toxics Release Inventory (TRI) d ata for stationary l ead sources show lead emissions

during the 2006

– 2008 time period in Madison County

, and are s ummarized by facility in Table10

2

. According to this data

, U.S Steel, Granite City Works is the largest source of lead in the

Madison C ounty. 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 sou rces which are located in close proximity to t he violating monitor are

Mayco Industries LLC, American Colloid Co mpany , Amsted Rail Co mpany 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

Con ocoPhilipps 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

Owen s 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 H artford 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

T otal 1.71835 2.13679 2.62613 *TRI Reported Values11

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 emission s

from area sources cont ain ing deposited lead may also contribut e to violations of the revised l ead

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

Industries/ Ta rac orp Corporat ion Superfund site is l ocated 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 fro m the site affected portions of Gr ani te City, Madison and Venice. Lead

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

(Figure 5) . T he cleanup of thi s 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 withi n 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 Madiso n Coun ty in 2008. Table

3 lists the pop ulati on of Granite City and other cities with in Madison County, as well as land

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

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 Coun ty

, followed by

Alton, Collinsville, Edwardsville and the village of Godfrey

. Figure 7 compares the population

of the larges t municipalities in Madison County.12 

### T able 3

Population and Population Density

2008 Estimates by Municipality (larger cities)

Source: U.S. Census Bu reau estimate as of March 20 , 2009 , at http://factfinder.census.gov/ Source: U.S. Census Bureau’s State and County Quick Facts at
h ttp :// quickfacts.census.gov/qfd/states/17/1730926.html

Figure 8 depict s current land cover percentages wit hin 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 per centage of agricultural land

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

Expected Growth Rates and Patterns

The IEPA has evaluated both p opulation and economic growth rates to i dentify expected trends

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

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

between 2000 and 200 8 for Madison County . This data was provided by the U.S. Census Bureau

and is b ased on estimates dated March 19 , 2009

. According t o the data, Madison County has

experien ced an increase in population of 3. 5% , although l arger cities such as Granite City and

Alton have both experienced a n 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 exper ienced Municipality Population 2008 Land Area (Square Mile s ) 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 1,798.913

increase s in population of 4 and 10 percent

, respectively

. This change indicates tha t population

in Madison County is moving from core industrial cities in to 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 ran ge plannin g activities by both s tate

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 i s expected to increas e 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 developin g 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 p er year
, based on EGAS

output

. Thi s data shows a downward trend of

- 7.2% for most large metal manufacturing

sources
, while predicting an increase in smaller producers of lead

.14 

### Ta ble 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
Dyne gy 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

Chr ist 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 C ity 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 differentiat ed 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 7 7°F

(25°C) in the south. Illinois averages 36 inches (91 cm) of precipitation a year. Annual snowfall15

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 wi nd 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 Madis on 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 informa tion

, the predominant wind direction s are south, south

- southeast and west

n orthwest

, with the highest frequency of winds bl owing from the south

. No complex chemistry

is needed to form lead or lead co mpo unds in the ambient air

, therefore , concentrations of lead are

typically highest near lead sources.

Geography/ Topography

Illinois is typified by f

lat to gently rolling terr ain

, with the exception of the Driftless A rea 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

approxima tely 600 f

ee t (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 Missi ssippi 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 D ata,

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

bluffs

, to the alluvial Mississippi River Valley

, know n as the “ American Bottoms ”

. The

Am erican Bottoms makes up approximately 15 percent of the county. E levation in the county16

rang e s from 650 feet abo ve 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 Fig ure 1 1 )

and therefore, topography is no t considered a significant factor in defining the boundaries of the

lead nonattainment areas.

Jurisdictional Boundaries

The Illinois EPA is responsible for air quality regulatory pr ograms for every county in the s ta te.

Madison County is also located with in the East

- West Gateway Council of Governments study

area

. Jurisdictional boundaries considered in this analysis are consistent with recommended

geographic boundaries

, or “presumptive boundary” de finitions

, outline d in the lead rule and

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

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

Division

. Based on the geographic location of Gra nite 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 h ave been promulgated at the federal and s tate 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. Furth er emission reductions through State Implementation Plan approved

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

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

fol lowing:17

Stationary Point Sources

MACT Standard for integrated Iron and Steel Manufacturing

MACT Stand ard 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 r emoval of leaded gasoline

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

o comple te 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 emissio n controls are required on new emissio n sources before they can operate.



### R ecommendations

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 t he 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 desi gnated as nonattainment for the 2008 revised lead

standard

, nor has U.S. EPA promulgated rules prescribing such. IEPA’s recommendations are18

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

on an eval uation of present air qualit y, 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 t his analysis is summarized in Table 6

. The IEPA’s recommen dation for inclusion of

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

the following section and geographically depicted in Fi gure 12

.



### Madison County Rec om m endation

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 C ounty , located in the C ity of Wood River

,

indicates that northern portions of the C ounty currentl y meet the revised lead NAAQS

, while the

one monitor in Granite City lo cated 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 origi nate 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 Gran ite 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 reason s , the boundaries of the C ity of Granite City should be

conside red nonattainment for the 2008 revised lead NAAQS

.

Remainder of Madison County

Areas of th e 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 Il linois

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 S tandard

County Designation Name of

Area

Madison : G ranite 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 At tainment Illinois20

Factor Data Analysis Data Source Date of Study

1. Air Quality Lead 200 6

- 200 8 Design Values

at individual monitors (statewide) IEPA BOA Database, Air Monitoring

Section 200 6

- 200 8

2. Emissions Emission inve ntory 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

Marc h 20, 2009

2 00 7

4. Expected Growth (Extent

Rates and Patterns ) Total population change based on short and long

- term population projection s

U.S. EPA EGAS Emission Projections (2008 to 2015) Table 2: Cumulative

Estimates of the

Resident P opulation 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 Documentation21

* http://www.census.gov 5. Geo graphy/ 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

informatio n; 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 200922 

### APPENDIX A