Appendix 

SO2 Nonattainment Boundary Five-Factor Analysis for Nassau County

Recommendation

The recommended area of nonattainment in the Fernandina Beach area of Nassau County is described 

by a circle of radius 2.4 kilometers, centered on the location of the violating monitor (AQS monitor ID 

0890005). The center of the recommended nonattainment area is located at UTM Easting 455530. 

meters, UTM Northing 3391737. meters, UTM zone 17, using the NAD83 datum.

The determination of this area was based on the five factors outlined in the EPA guidance 

memorandum, “Area Designations for the 2010 Revised Primary Sulfur Dioxide National Ambient Air 

Quality Standards (March 24, 2010),” and on air dispersion modeling completed following the general 

guidance in the same document. Analysis of the five factors to be considered and the modeling results

follow.

1. Air Quality Data

There are five SO2 monitors in the Nassau/Duval counties area. The monitor located in Fernandina 

Beach in Nassau County, Florida, is currently in violation of the new 1-hour SO2 standard. A violation 

occurs when the three-year average of the 99th percentile maximum daily 1-hour average concentration 

is greater than 75 ppb. All other monitors in the area are well below the standard. A summary of the 

monitoring data is below.

Site:B0890005 - FBHWWTP County:Nassau AQS Monitor ID:12-089-0005-42401-1

Year

Ranked 1-Hour Averages Ranked 3-Hour Averages Ranked 24-Hour Averages

Annual

Average

99th Percentile Values

Design

1 Value st 2nd 1st 2nd 1st 2nd Complete Days Valid

2008 146 (12/12) 100 (01/13) 83 (12/12:18) 79 (01/13:21) 30 (01/14) 28 (01/01) 3.3* 98* 98*

2009 145 (03/02) 121 (09/29) 52 (03/03:00) 49 (09/29:18) 22 (12/20) 21 (12/26) 2.2 73 73

2010 345 (01/12) 344 (02/13) 317 (02/13:18) 159 (02/16:03) 68 (02/13) 58 (02/16) 4.3 216 216 129†

Site:L0310032 - Kooker Park, Jacksonville County:Duval AQS Monitor ID:12-031-0032-42401-1

Year

Ranked 1-Hour Averages Ranked 3-Hour Averages Ranked 24-Hour Averages

Annual

Average

99th Percentile Values

Design

1 Value st 2nd 1st 2nd 1st 2nd Complete Days Valid

2008 32 (02/16) 21 (02/02) 16 (02/16:12) 10 (01/14:00) 4 (02/11) 4 (01/26) 1.4 17 17

2009 46 (02/06) 26 (05/13) 20 (05/13:15) 17 (02/06:09) 4 (02/06) 4 (05/13) 1.3 13 13

2010 24 (01/13) 23 (04/11) 13 (04/15:15) 11 (04/19:15) 5 (10/16) 5 (04/19) 1.4 16 16 15
Site:L0310080 - Minerva Street County:Duval AQS Monitor ID:12-031-0080-42401-1

Year

Ranked 1-Hour Averages Ranked 3-Hour Averages Ranked 24-Hour Averages

Annual

Average

99th Percentile Values

Design

1 Value st 2nd 1st 2nd 1st 2nd Complete Days Valid

2008 36 (01/28) 22 (11/01) 30 (01/28:09) 13 (11/01:12) 5 (01/26) 5 (01/28) 1.3 18 18

2009 25 (02/06) 18 (11/29) 11 (02/06:12) 10 (01/09:12) 4 (12/27) 3 (11/04) 1.2 15 15

2010 29 (01/13) 18 (02/24) 18 (01/13:09) 10 (02/24:09) 4 (01/07) 4 (01/13) 1.3 17 17 17

Site:L0310081 - Cedar Bay STP County:Duval AQS Monitor ID:12-031-0081-42401-1

Year

Ranked 1-Hour Averages Ranked 3-Hour Averages Ranked 24-Hour Averages

Annual

Average

99th Percentile Values

Design

1 Value st 2nd 1st 2nd 1st 2nd Complete Days Valid

2008 88 (06/07) 78 (06/06) 57 (06/06:12) 57 (06/07:15) 11 (06/06) 11 (06/07) 1.4 32 32

2009 36 (07/21) 26 (02/06) 22 (02/06:12) 18 (07/22:12) 6 (07/22) 4 (02/06) 1.2 24 24

2010 41 (05/06) 26 (09/25) 21 (05/05:12) 18 (05/06:15) 3 (05/20) 3 (05/05) 1.3 22 22 26

Site:L0310097 - Fort Caroline Road County:Duval AQS Monitor ID:12-031-0097-42401-1

Year

Ranked 1-Hour Averages Ranked 3-Hour Averages Ranked 24-Hour Averages

Annual

Average

99th Percentile Values

Design

1 Value st 2nd 1st 2nd 1st 2nd Complete Days Valid

2008 37 (01/28) 31 (01/04) 22 (11/11:15) 19 (01/28:09) 5 (01/04) 5 (01/21) 1.4 25 25

2009 21 (02/06) 17 (12/16) 11 (05/19:06) 10 (05/19:03) 5 (05/19) 4 (12/27) 1.2 13 13

2010 19 (01/13) 18 (09/03) 13 (12/03:21) 12 (01/13:09) 4 (12/04) 3 (12/03) 1.3 16 17 18

 *There was insufficient data to produce a valid average

 †Indicates the standard was exceeded

The violating monitor (L0890005) in Fernandina Beach is located less than 1 kilometer to the southeast 

of the Rayonier Performance Fibers plant, a major source of SO2. Rayonier is an acid sulfite based pulp 

mill using ammonia as a base chemical for the manufacture of dissolving pulps. All other SO2 monitors 

in the Northeast Florida area are in compliance with the ambient standard. 

2. Emissions-Related Data

The following map provides the location of large (100 TPY or greater) SO2 emitting sources in the 

Nassau/Duval Counties area in relation to the monitors. 
The emissions represented are actual values in 2009. The two facilities closest to the violating monitor 

are Rayonier (1 kilometer) and Rock Tenn (2.9 kilometers). The nearest other SO2 source is the JEA 

Northside/SJRPP power plant located 26.8 kilometers to the southwest. SO2 emissions from Rayonier 

in 2009 were 830 tpy, and emissions from Rock Tenn were 4,090 tpy. Rock Tenn, formerly Smurfit 

Stone, is a fully integrated Kraft linerboard mill that consists of major activities areas such

as: wood yard, pulp mill, recycle plant, chemical recovery, power house and paper mill..

Map ID Facility Name

2009 

SO2(tpy)

1 ANCHOR GLASS CONTAINER CORPORATION 196

2 RENESSENZ LLC 320

3 JEA NORTHSIDE/SJRPP 12,249

4 IFF CHEMICAL HOLDINGS, INC. 908

5 CEDAR BAY COGENERATION FACILITY 1,742

6 ROCK TENN 4,090

7 RAYONIER PERFORMANCE FIBERS LLC 830
3. Meteorology

A review of the monitoring data in relation to the wind direction at the time of maximum concentrations

revealed that all occurrences of SO2 above the level of the standard (75 ppb) were associated with winds 

coming from the Rayonier facility. The following aerial photo shows the direction of the Rayonier facility 

from the SO2 monitor. The distance from the facility of the monitor is 1 kilometer, with the direction of 

the entire facility ranging from 290o to 320o

. The following tables list all of the hours in which a 

concentration was greater than the ambient SO2 standard (75 ppb) along with its associated wind 

direction. The wind direction data come from the wind instrument located at the monitoring site. 

When the winds come from the direction of the nearby Rock Tenn pulp mill, the monitor typically 

registers single digit SO2 concentrations with highest value in the upper 30’s ppb. It is clear that the 

violation of the standard is due to the Rayonier facility. 
SO2 Concentration and Associated Wind Direction (2008)

(for hours greater than 75 ppb)

Date Time SO2 (ppb) WD

20080113 21:00 100 321

20080114 1:00 79 321

20080114 7:00 78 324

20080127 21:00 93 325

20080210 1:00 98 316

20080413 22:00 82 292

20080512 22:00 86 332

20081212 17:00 85 321

20081212 19:00 146 325

SO2 Concentration and Associated Wind Direction (2009)

(for hours greater than 75 ppb) 

Date Time SO2 (ppb) WD

20090302 4:00 145 325

20090303 0:00 77 347

20090929 20:00 121 297
SO2 Concentration and Associated Wind Direction (2010)

(for hours greater than 75 ppb) 

Date Time SO2(ppb) WD

20100106 20:00 106 291

20100106 23:00 76 301

20100109 23:00 253 287

20100110 0:00 134 323

20100110 20:00 105 330

20100111 0:00 79 334

20100111 5:00 152 315

20100111 6:00 80 297

20100111 7:00 216 284

20100111 8:00 105 316

20100112 17:00 143 295

20100112 18:00 345 295

20100112 19:00 121 322

20100127 2:00 81 325

20100203 4:00 76 321

20100213 18:00 289 294

20100213 19:00 320 290

20100213 20:00 344 288

20100214 1:00 102 314

20100214 3:00 145 276

20100214 9:00 86 289

20100215 23:00 93 297

20100216 0:00 176 294

20100216 3:00 201 291

20100216 4:00 190 294

20100216 5:00 88 300

20100216 6:00 121 295

20100216 7:00 135 295

20100216 22:00 124 293

20100217 3:00 132 301

20100314 0:00 186 321

20100315 1:00 84 296

20100315 23:00 80 294

20100316 1:00 81 289

20100316 4:00 78 330

20100318 7:00 85 330

20101007 5:00 111 323
4. Geography/Topography

There are no significant topographical features in the Fernandina Beach area. Elevation changes are 

minimal. The primary geographic feature is the intercoastal waterway, along which the Rayonier facility 

is located. 

5. Jurisdictional Boundaries

The violating monitor is located in the northeastern part of Nassau County. The violating area 

associated with the primary source of SO2 at this monitor is well within the county boundary. The 

recommended nonattainment boundary encompasses this violating monitor as informed by air 

dispersion modeling.

Air Dispersion Modeling

The department used air dispersion modeling to help delineate the boundary of the recommended 

nonattainment area. In completing this modeling, the department generally followed the guidance 

provided in the March 24, 2011, EPA memorandum, “Area Designations for the 2010 Revised Primary 

Sulfur Dioxide National Ambient Air Quality Standards.” 

a) Model Selection – The department used the AERMOD modeling system.

a. AERMOD ver11103

b. AERMAP ver11103

c. AERMET ver11059

d. AERMINUTE ver11059

e. AERSURFACE ver08009

b) Modeling Domain – The focus of the nonattainment designation is on the monitor having the 

violation. As noted above, wind data at the monitoring site indicate that all of the high 

concentrations (greater than the standard of 75 ppb) occur within a small wind direction sector 

that implicates the nearby Rayonier facility. As a result, the modeling domain is centered on the 

Rayonier facility, which is located only 1 kilometer from the monitoring location, and the domain 

extends to a 10 by 10 kilometer area around this facility. 

c) Determining the Sources to Model – Because the Rayonier facility is the overwhelming source 

for the violation, this is the only source modeled for the purpose of determining the extent of 

the nonattainment area. The department recognizes that other SO2 sources in the area could 

interact with the Rayonier facility for certain wind directions. These sources will be evaluated 

individually and collectively through the maintenance SIP modeling that will be completed over

the next several years. In addition, the modeling demonstration associated with the 

nonattainment area corrective SIP will include all sources that significantly impact the area. 
d) Receptor Grid – The receptor grid used follows the guidance. A nested grid with 50 meter 

spacing within one kilometer of the source, 100 meter spacing from one to two kilometers, and 

250 meters from two to ten kilometers.

e) Source Inputs – Maximum allowable short-term limits on SO2 emissions or potential to emit 

levels were used for all sources. Stack and emission information were obtained from the 

department’s Air Resource Management System, Title V operating permit, and previous air 

construction permit applications. These data were reviewed by Rayonier to verify the correct 

geographic location of buildings and stacks. Where stack heights are less than GEP, building 

downwash effects are included. No stacks at this facility exceed GEP limits. The Rayonier facility 

is rural as determined through land-use data consistent with the guidance.

f) Meteorological Data – Five years (2006-2010) of meteorological data from the National Weather 

Service site at Jacksonville International Airport were used in this analysis. These data were 

processed through AERMET version 11059, using 1-minute data from the same site processed 

through AERMINUTE version 11059. The Jacksonville airport is located approximately 28.5

kilometers to the south of the violating monitor. 

g) Background concentration – The background concentration at the Fernandina Beach monitor 

was determined based on the 99th percentile maximum daily 1-hour value on hours that were 

not impacted by the Rayonier facility. A 90-degree sector of wind directions centered on the 

Rayonier facility was excluded from the calculation to avoid contribution from the Rayonier 

facility. The 99th percentile of the remaining concentrations associated with winds not from the 

direction of the Rayonier facility were calculated for each year and averaged. Based on this 

calculation, the background concentration is 26.0 ppb.

Modeling Results

The AERMOD model results were used to determine the areal extent to which this facility would be 

potentially violating the standard. The recommended nonattainment area is centered on the violating 

monitor and encompasses the area having a modeled violation of the ambient standard associated with 

the Rayonier facility. 

The maximum modeled design values associated with the Rayonier facility for 2006-2010 are as follows.

Year Date (MMDDHH) 4th High Concentration (ppb)*

2006 082909 230.7

2007 081709 267.0

2008 072214 274.7

2009 072812 276.6

2010 071812 284.5

5-Year Average 266.7

*includes background concentration of 26.0 ppb

It should be noted that the location of the design value concentration is on the Rayonier property.
The aerial photo below shows the bounds of the area having modeled concentrations greater than the 

ambient air quality standard. The red annotation circle outlines the area recommended for 

nonattainment classification, with the center being the location of the violating ambient monitor and 

the radius being 2.4 kilometers. Inside the shaded pink area outlines the modeled area greater than the 

ambient standard.