# Appendix

SO 2 

### 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 4555 3 0.

meters, UTM Northing 3391737. meters, UTM zone 17, using t he 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 dispe rsion 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 SO 2 

### monitors in the Nassau/Duval counties area. The monitor loca ted in Fernandina

Beach in Nassau County , Florida

, is currently in violation of the new 1

- hour SO

2 

### standard. A violation

occurs when the three

- year average of the 99 th 

### percentile maximum daily 1

- hour average concentration

is greater than 75 ppb. All othe r 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

Value 1 st 2 nd 1 st 2 nd 1 st 2 nd 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

Value 1 st 2 nd 1 st 2 nd 1 st 2 nd 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 15Site: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

Value 1 st 2 nd 1 st 2 nd 1 st 2 nd 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

Value 1 st 2 nd 1 st 2 nd 1 st 2 nd 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

Value 1 st 2 nd 1 st 2 nd 1 st 2 nd 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 (L0 89 0 005 ) in Fernandina Beach is located less than 1 kilometer to the southeast

of the Rayonier Performance Fibers plant , a major source of SO

2



### . Rayonier is an acid sulfite based pulp

mill using ammonia as a base chemical for the manufacture of dissolving pulps. All other SO 2 

### 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) SO

2 

### emitting sources in the

Nassau/Duval Counties area in relation to the monitors.

### The emissions represented are actual values in 2009. The two facilit ies closest to the violating monitor

are Rayonier (1 kilometer ) and Rock Tenn (2.9 kilometers ) . The nearest other SO

2 

### source is the JEA

Northside/SJRPP power plant located 26.8 kilometers to the south west. SO 2 

### 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 liner board 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

SO 2 

### (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 concentration s

revealed that all occurrences of SO

2 

### 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 SO

2 

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

the entire facility ranging from 29 0 o 

### to 3 2 0 o



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

concentration was greater than the ambient SO 2 

### 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 SO

2 

### co ncentrations with highest value in the upper 30’s ppb. It is clear that the

violation of the standard is due to the Rayonier facility.

### S O 2 

### Concentration and Associated Wind Direction (2008)

(for hours greater than 75 ppb)

Date T ime SO 2 (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



### SO 2 

### Concentration and Associated Wind Direction (2009)

(for hours greater than 75 ppb)

Date Time SO 2 (ppb) WD

20090302 4:00 145 325

20090303 0:00 77 347

20090929 20:00 121 297

### SO 2 

### Concentration and Associated Wind Direction (2010)

(for hours greater than 75 ppb)

Date Time SO 2 (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. G eography/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 SO

2 

### 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 Designation s for the 2010 Revised Primary

Sulfur Dioxide Nationa l Ambient Air Quality Standards.”

a) Model Selection

– The department used the AERMOD modeling system.

a. AERMOD ver11 103

b. AERMAP ver 11103

c. AERMET ver 11059

d. AERMINUTE ver11059

e. AERSURFACE ver 08009

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 s ector

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 1 0 by 1 0 kilometer area around this faci lity.

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 othe r SO 2 

### 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 add ition, 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 SO

2 

### emissions or potential to emit

levels were used for all sources. Stack and em ission 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 Dat a

– Five years (200 6

- 20 10 ) 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 proce ssed

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

kilometers to the s outh of the violating monitor

. g) Background concentration

– The background concentration at the Fernandina Beach monitor

was determined based o n the 99 th 

### 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

fa cility . The 99 th 

### percentile of the remaining concentrations associated with winds not from the

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

calculation, the background concentration is 26

. 0 ppb.

Modeling R esults

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

potentially violating the standard. The recommend ed nonattainment area is centered on the violating

monitor and encompasses th e 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 200 6

- 20 10 are as follows.

Year Date (MMDDHH) 4 th 

### High Concentration (ppb) *

200 6 08 2909 230.7

200 7 0 81709 267.0

200 8 0 72214 274.7

200 9 0 72812 276.6

20 10 0 71812 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 viol ating ambient monitor and

the radius being 2.4 kilometers

. Inside t he shaded pink area outlines the modeled area greater than the

ambient standard.