# TECHNICAL SUP PORT DOCUMENT

FOR

SO 2 

# DESIGNATION RECOMMENDATIONS
FOR ELECTRIC POWER FACILIT Y

AREAS :

Newton Power Station, Hennepin Power Station, Marion Power Station, Joppa Steam Coal Power Plant, and

Wood River Power Station



# AQPSTR 15

- 04

Illinois Environmental Protection Agency

Bureau of Air 1021 North Grand Avenue, East Springfield, Illinois 62794

- 9276

September 1 8 , 2015

### Table of Contents

List of Tables

................................ ................................ ................................ ................................ ..................... 1
List of Figures

................................ ................................ ................................ ................................ ................... 2
1.0 Introduction/Background

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

1.1 Consent Decree Designation Timeline

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

1.2 Federal Guidance

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

1.3 Illinois’ Five

- Factor Analyses and Designation Recommendations

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

2.0 Illinois SO 2 Monitoring Data Update

................................ ................................ ................................ ... 7
3.0 Illinois Modeling Analyses

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

3.1 Newton Power Station (Jasper County)

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

3.1.1 Study Area

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

3.1.2 Model Setup and Execution

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

3.1.2.1 Model Settings

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

3.1.2.2 Auer’s Analysis

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

3.1.2.3 Emissions

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

3.1.2.4 Me teorology

................................ ................................ ................................ ............................ 13

3.1.2.5 Receptor Network/Terrain

................................ ................................ ................................ ...... 15

3.1.2.6 Background SO 2
................................ ................................ ................................ ...................... 16

3.1.3 Summary of Results

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

3.1.4 Designation Recommendation

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

3.2 Hennepin Power Station (Putnam County)

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

3.2.1 Study Area

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

3.2.2 Model Setup and Execution

................................ ................................ ................................ ........ 20

3.2.2.1 Model Settings

................................ ................................ ................................ ........................ 20

3.2.2.2 Auer’s Analysis

................................ ................................ ................................ ....................... 20

3.2.2.3 Emissions

................................ ................................ ................................ ................................ 22

3.2.2.4 Meteorology

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

3.2.2.5 Receptor Network/Terrain

................................ ................................ ................................ ...... 25

3.2.2.6 Background SO 2
................................ ................................ ................................ ...................... 26

3.2.3 Summary of Results

................................ ................................ ................................ .................... 27

3.2.4 Designation Recommendation

................................ ................................ ................................ .... 28

3.3 Marion Power Station (Williamson County)

................................ ................................ ........................ 29

3.3.1 Study Area

................................ ................................ ................................ ................................ .. 293.3.2 Model Setup and Execution

................................ ................................ ................................ ........ 2 9

3.3.2.1 Model Settings

................................ ................................ ................................ ........................ 30

3.3.2.2 Auer’s Analysis

................................ ................................ ................................ ....................... 30

3.3.2.3 Emissions

................................ ................................ ................................ ................................ 31

3.3.2.4 Meteorology

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

3.3.2.5 Receptor Network/Terrain

................................ ................................ ................................ ...... 34

3.3.2.6 Background SO 2
................................ ................................ ................................ ...................... 35

3.3.3 Summary of Results

................................ ................................ ................................ .................... 36

3.3.3 Designation Recommendation

................................ ................................ ................................ .... 37

3.4 Joppa Steam Coal Power Plant (Massac County)

................................ ................................ ................ 38

3.4.1 Study Area

................................ ................................ ................................ ................................ .. 38

3.4.2 Model Setup and Execution

................................ ................................ ................................ ........ 39

3.4.2.1 Model Settings

................................ ................................ ................................ ........................ 39

3.4.2.2 Auer’s Analysis

................................ ................................ ................................ ....................... 39

3.4. 2.3 Emissions

................................ ................................ ................................ ................................ 41

3.4.2.4 Meteorology

................................ ................................ ................................ ............................ 42

3.4.2.5 Receptor Network/Terrain

................................ ................................ ................................ ...... 44

3.4.2.6 Background SO 2
................................ ................................ ................................ ...................... 45

3.4.3 Summary of Results

................................ ................................ ................................ .................... 46

3.4.4 Designation Recommendation

................................ ................................ ................................ .... 47

3.5 Wood River Power Station (Madison County)

................................ ................................ ..................... 48

3.5.1 Study Area

................................ ................................ ................................ ................................ .. 48

3.5.2 Model Setup and Execution

................................ ................................ ................................ ........ 49

3.5.2.1 Model Settings

................................ ................................ ................................ ........................ 49

3.5.2.2 Auer’s Analysis

................................ ................................ ................................ ....................... 49

3.5.2.3 Emissions

................................ ................................ ................................ ................................ 51

3.5.2.4 Meteorology

................................ ................................ ................................ ............................ 52

3.5.2.5 Receptor Network/Terrain

................................ ................................ ................................ ...... 54

3.5.2.6 Background SO 2
................................ ................................ ................................ ...................... 55

3.5.3 Summary of Results

................................ ................................ ................................ .................... 56

3.5.4 Designation Recommendation

................................ ................................ ................................ .... 57
4.0 Summary

................................ ................................ ................................ ................................ .................. 59

5.0 References

................................ ................................ ................................ ................................ ................. 606.0 Appendices

................................ ................................ ................................ ................................ ............... 61

Appendix A

................................ ................................ ................................ ................................ ..................... 61

Appendix B

................................ ................................ ................................ ................................ ..................... 71

Appendix C

................................ ................................ ................................ ................................ ..................... 771 List of Tables

Table 1 Illinois Consent Decree Facilities and Reported 2012 Emissions 3

Table 2 Illinois 2012

- 2014 1

- Hour SO 2 Design Values (ppb) 7

Table 3 Auer’s Analysis Land Use Percentages by Category

– Newton Study Area 12

Table 4 Modeled Facility Actual Emissions

– Newton Study Area 13

Table 5 Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentration

- Newton Study Area 17

Table 6 Auer’s Analysis Land Use Percentages by Category

– Hennepin Study Area 21

Table 7 Modeled Facility Actual Emissions

– Hennepin Study Area 2 2

Table 8 Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentration

- Hennepin Study Area 27

Table 9 Auer’s Analysis Land Use Percentages by Category

– Marion Study Area 3 1

Table 10 Modeled Facility Emissions

– Marion Study Area 3 2

Table 11 Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentration

- Marion Study Area 3 6

Table 12 Auer’s Analysis Land Use Percentages by Category

– Joppa Study Area 4 0

Table 13 Modeled Facility Actual Emissions

– Joppa Study Area 4 1

Table 14 Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentration

- Joppa Study Area 4 6

Table 15 Auer’s Anal ysis Land Use Percentages by Category

– Wood River Study Area 5 0

Table 16 Modeled Facility Actual Emissions

– Wood River Study Area 5 1

Table 17 Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentration

- Wood River Study Area

562 List of Figures

Figure 1 Illinois SO 2 Consent Decree Facilities 4
Figure 2 Illinois 1

- hour SO 2 Design Values 2012

- 2014 8
Figure 3 Newton Study Area (Jasper County) 9
Figure 4 Auer’s Analysis

- Newton Study Area 11
Figure 5 Evansville, I ndiana

, Cumulative Annual Wind Rose 2012

- 2014 14
Figure 6 Receptor Grid

- Newton Study Area 16
Figure 7 Maximum Predicted 99 th Pe r centile 1

- Hour SO 2 Concentrations

- Newton Study Area 18
Figure 8 Hennepin Study Area (Putnam County) 19
Figure 9 Auer’s Analysis

- Hennepin Study Area 21
Figure 10 Rockford, I llinois

, Cumula tive Annual Wind Rose 2012

- 2014 24
Figure 11 Receptor Grid

– Hennepin Study Area 26
Figure 12 Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentrations

- Hennepin Study Area

28
Figure 13 Marion Study Area ( Williamson County) 29
Figure 14 Auer’s Analysis

- Marion Study Area 3 0
Figure 15 Paducah, K entucky

, Cumula tive Annual Wind Rose 2012

- 2014 3 3
Figure 16 Re ceptor Grid

– Marion Study Area 3 5
Figure 17 Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentrations

- Marion Study Area

3 7
Figure 18 Joppa Study Area ( Massac County) 38
Figure 19 Auer’s Analysis

- Jopp a Study Area 4 0
Figure 2 0 Paducah, K entucky

, Cumula tive Annual Wind Rose 2012

- 2014 4 3
Figure 2 1 Receptor Grid

– Joppa Study Area 4 5
Figure 2 2 Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentrations

- Joppa Study Area

47
Figure 2 3 Wood River Study Area (Madison County) 48
Figure 2 4 Auer’s Analysis

– Wood River Study Area 5 0
Figure 2 5 St. Louis, M issouri

, Cumula tive Annual Wind Rose 2012

- 2014 5 3
Figure 2 6 Recept or Grid

– Wood River Study Area 5 5
Figure 2 7 Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentrations

- Wood River Study Area

57
Figure 28 Proposed Nonattainment Area Boundary for the Wood River Study Area 583



### 1.0 Introduction/Background

On March 2, 2015, the U.S. District Court for the Northern District of California issued a court order accepting a consent decree between the U.S. Environmental Protection Agency (U.S. EPA), Sierra Club, and Natural Resources Defense Council resolving liti gation concerning the deadline for U.S. EPA to complete area designations for the 2010 1

- hour SO 2 National Ambient Air Quality Standard (NAAQS). Per the court order, U.S. EPA will complete the area designations in three additional

rounds: the first round by July 2, 2016, the second round by December 31, 2017, and the final round by December 31, 2020. For each round, U.S. EPA will identify additional areas as either nonattainment, unclassifiable/attainment, or unclassifiable.

For the first round of designations, U.S. EPA will designate two groups of areas: 1) areas with newly

monitored violations of the 2010 SO 2 standard, and 2) areas that contain stationary sources that according to U.S. EPA’s Air Markets Database either emitted more than 16,000 to ns of SO 2 in 2012 or emitted more than 2,600 tons of SO 2 and had an emission rate of 0.45 pounds of SO 2 per million

BTU (lbs/mmBTU) or higher in 2012 and that had not been announced for retirement as of March 2,

2015. U.S. EPA identified five electric gen erating facilities in Illinois that meet the stationary source criteria
established in the court’s order. These five facilities are listed in Table 1 and their locations are shown in Figure 1. Thi s report provides Illinois’ area designation recommendatio ns for each of these five facilities, and the technical justification for those recommendations

.

Table 1 Illinois Consent Decree Facilit i es and Reported 2012 Emissions

State County Facility Name 2012 SO 2 Emissions (tons) 2012 SO 2

Emissions Rate (lbs/ mmBTU)
Illinois Jasper Newton Power Station 16,519 0.590

Illinois Putnam Hennepin Power Station 5,906 0.501

Illinois Williamson Marion Power Station 5,850 0.489

Illinois Massac Joppa Steam Coal Power Plant 16,991 0.475

Illinois Madison Wood River Power Station 6,756 0.4764 Figure 15

1.1 Consent Decree Designation Timeline

The court order stipulates a compressed timeline for states to submit updated recommendations to

U.S. EPA

, and for U.S. EPA to review this information and make final area designations. This

timeline is as follows:

 States submit updated recommendations based on 2012

- 2014 monitoring data and new actual

emissions

- based modeling to U.S. EPA by September 18, 20 15

.

 U.S. EPA notifies states of any intended modifications to their area designations (120

- day letters) no later than March 2 , 2016

.

 U.S. EPA publishes public notice of state recommendations and the U.S. EPA ’s intended

modifications and initiates a 30

- day public comment period on or about February 3, 2016

 The 30

- day public comment period ends on or about March 4, 2016

.

 States must respond to any modifications proposed by U.S. EPA on or about April 8, 2016

.

 U.S. EPA finalizes the first round of SO 2 area designations made under the court’s order, no later than July 2, 2016

.

1.2 Federal Guidance

The Illinois Environmental Protection Agency ( Illinois EPA ) relied on guidance provided in a

memorandum issue d March 20, 2015

, by Stephen D. Page, Director, Office of Air Quality Planning and Standards at U.S. EPA. This memorandum replaces the original designation guidance for the

2010 SO 2 NAAQS, which was issued on March 24, 2011. In this guidance, U.S. EPA recommend s that states analyze the following five factors when considering boundaries for the updated area designations: ambient air quality data or dispersion modeling, emissions and emissions

- related data, meteorology, geography/topography, and jurisdictional bound aries. Due to the localized nature of

SO 2 impacts, U.S. EPA considers county boundaries as the logical starting point, or presumptive boundary , for determining SO 2 nonattainment areas. However, U.S. EPA also provides states with the flexibility to desig nate nonattainment areas consisting of only a portion of a county when supported by an examination of the five factors and other information

. When defining partial county boundaries, states are advised to use well

- defined jurisdictional lines, such as geo political boundaries, immovable landmarks, and readily identifiable physical features.

U.S. EPA will designate areas as being nonattainment, attainment, or unclassifiable. Section 107(d)(1) of the Clean Air Act defines an area as nonattainment if it i s violating the 1

- hour SO 2 NAAQS or if emission sources located within the area contribute to a violation in a nearby area. For an area to be designated as attainment, it must meet the 1

- hour SO 2 NAAQS and not contribute to a violation in a nearby area. Lastly, areas can be designated as unclassifiable when U.S. EPA cannot determine based on available information whether an area is or is not meeting the 1

- hour SO 2 NAAQS or whether the area is contributing to a violation in a nearby area. The air quality data used6

to make these determinations can come from either air monitoring networks or air dispersion modeling.

Due to the short timeframe within which the first round of area designations under the court order must be completed, U.S. EPA anticipate d that air dispersion modeling would be the most reliable source of information for determining designation boundaries. However, U.S. EPA expect ed that

states would also review their latest available SO 2 monitoring data from 2012

- 2014. U.S. EPA intends to also consider any certified SO 2 monitoring that might be available for 2015 before the 120

- day letters are sent out.

1.3 Illinois’ Five

- F actor Analyses and Designation Recommendations

Per the guidance issued by U.S. EPA, this report contains Illinois’ updated 1

- hour SO 2 air quality data

for 2012

- 2014, along with air dispersion modeling analyses for the Newton Power Station, Hennepi n Power Station, Marion Power Station, Joppa Steam Coal Power Plant, and Wood River Power Station. The air dispersion modeling for each of these facilities was conducted in accordance with the guidance provided in the December 2013 Modeling Techni cal Assistance Document (TAD). In order to ensure that the air dispersion modeling conducted for area designations better simulates a monitoring approach, the Modeling TAD specifically recommends the following procedures:

 Use of actual emissions as a mode l input for assessing violations to provide results that reflect current actual air quality

.

 Use of three years of modeling results to calculate a simulated design value consistent with the approach used to calculate three

- year design values for air monito ring sites for comparison to the NAAQS

.

 Placement of receptors only in locations where a monitor could be located

.

 Use of actual stack heights rather than adjusting stack height values based on the Good Engineering Practice stack height policy when modeling actual emissions

.
The dispersion modeling simulations evaluated the emission impacts of each of the five power plants, together with the impacts of those nearby sources and background sources contributing to ambient

SO 2 levels in each modeling dom ain. The combined modeled impacts of these sources determined whether the NAAQS would be met. On this basis, a designation recommendation was developed for

each of the study areas , with the remaining four “ factors ” and facility

- specific information ultimat ely contributing to a final recommendation and boundary determination

.7



### 2.0 Illinois SO 2 

### Monitoring Data Update

Pursuant to the Consent Decree court order, U

. S

. EPA will first review the latest available air quality data to determine if any new areas of the country have monitored violations of the 2010 1

- hour SO 2 standard. Table 2 shows the most recent three consecutive years of quality assured air monitoring data in Illinois for 2012 through 2014, along with the resulting design values. The design valu e is

defined as the three

- year average of the annual 99th percentile daily maximum 1

- hour SO 2 concentrations collected at each monitor (which is generally the fourth highest daily maximum 1

- hour concentration, averaged over three consecutive years). Since Illinois EPA’s original SO 2 area designations were submitted to U

. S

. EPA in 2011, based on 20 08

- 2010 air quality data, there has

been a significant improvement in air quality statewide. At the end of 2010

, four monitors were violating the 2010 1

- hour SO 2 standard. By the end of 2014, there was only one monitor violating the

2010 1

- hour SO 2 stand ard. This last violating monitor is located in the Pekin SO 2 Nonattainment Area in Tazewell County (see Figure 2 ) and is currently being addressed through a rulemaking proposed by the Illinois EPA . Therefore, based on the latest available 2012

- 2014 air q uality data,

there are no new areas in the State of Illinois with monitored violations of the 2010 1

- hour SO 2 standard.

Table 2
Illinois 2012

- 2014 1

- Hour SO 2 Design Values (ppb)

AQS Code County Site Annual 99 th Percentiles Design
Value 2012 2013 2014
170191001 Champaign Bondville 14 14 15 14
170310076 Cook Chicago

- Com Ed 17 10 15 14
170311601 Cook Lemont 108 73 16 66
170314201 Cook Northbrook 17 10 12 13
170990007 La Salle Oglesby 6 9 10 8
171150013 Macon Decatur 38 33 38 36
171170002 Macoupin Nilwood 8 7 10 8
171191010 Madison South Roxana 17 23 18 19
171193007 Madison Wood River WTP 30 29 30 30
171430024 Peoria Peoria 44 32 38 38
171570001 Randolph Houston 24 11 12 16
171630010 St. Clair East St. Louis 24 19 25 23
171670006 Sangamon Springfield 15 12 21 16
171790004 Tazewell Pekin 245 195 190 210
171850001 Wabash Mount Carmel 89 55 53 668 Figure 29



### 3.0 Illinois Modeling Analyses

3.1 Newton Power Station (Jasper County )

The Newton area contain s a stationary source that satisfies both of the cond itions (only one or the other required to quali f y) of the March 2, 2015

, Cons ent Decree between U.S. EPA, Sierra Club,

and the NRDC. Newton Power Station emitted greater than 16,000 tons ( 16,519 ) tons per year of

SO 2 in 2012 and it also had an emissio n rate that exceed s 0.45 lb s /mm B tu (0.590) in 2012.

3.1.1 Study Area
The Newton Power Station (Illinois Power Generating Company)

, located in southeastern Illinois in the southwestern portion of Jasper County, is one of the five plants subject to the March 2015 SO 2 Consent Decree

. It is approximately seven miles southwest of the city of Newton in a rural area

bounded on the east and south by Newton Lake (see Figure 3 ). For the air quality impact analysis

, the determination of the extent of the study area (i.e.

, receptor grid) is based primarily on three key considerations. First, the location of the SO 2 emission source s/facilities considered for modeling ;

s econd, the extent of significant concentration gradien t s of nearby sources ; and third, sufficient
receptor coverage and density to adequately capture and resolve model predicted maximum SO 2 concentrations

.
Figure 3 Newton Study Area (Jasper County)10

3.1.2 Model Setup and Execution

Beginning in 2005, the American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) has been U.S. EPA’s preferred model for near

- field (out to 50 km) dispersion modeling applications in the United States. The AERMOD model itself is one part of a modeling system that includes companion pre

- processing programs that prepare other inputs into the

model. The model is capable of evaluating air quality impacts for averaging times that vary from 1

- hour to a year and from multiple emissions sources and types, while also incorporating the influences of complex terrain, varying land use, and meteorology . The model is designed to account for planetary boundary layer turbulence structure and to effectively handle scal ing concepts

. Plume

d ownwash induced by structures is also addressed in the model via the BPIP

- PRIME algorithm

.

3.1.2.1 Model Settings

For the Newton S tudy A rea, as with all of the study areas, the AERMOD dispersion model was run exclusively in the r egulatory default mode

. . The AERMOD modeling system includes the following programs, with the latest publicly available versions indicated in parentheses:

- AERMOD (15181)

- BPIP

- PRIME (04274)

- AERMET (15181), AERMINUTE (14337)

- AERMAP (11103)

- AERSURFACE (13016 )

This software is downloadable from U.S. EPA ’s Transfer Technology Network (TTN) website.

3.1.2.2 Auer’s Analysis

A n important first step in establishing the model settings for the Newton Study Area was determining if the sources within the study area are located within a rural or urban dispersion regime. Generally, urban areas cause higher rates of dispersion because of increased turbulence and buoyancy caused by higher sur face roughness (tall buildings) and enhanced thermal buoyancy from urban heat

island effects. U. S. EPA guidance allows the use of the Auer’s land use scheme within three

kilometers of a source to determine the predominant dispersion regime

. Essentially, if the percentage of land use types that are characteristic of an urban environment

, such as light to heavy industrial, compact residential

- single family or multi

- family etc., is equal to or greater than 50% of the area

with in the three

- kilometer radius c ircle, th e n the area should be classified (and modeled) as urban. If

o therwise, the model can be run in rural mode. Recent versions of AERMOD do allow some flexibility to mix and match sources as rural or urban instead of an either/or approach, as select11

subsets of sources can be flagged to be run with the AERMOD URBANOPT opt ion on , while leaving

other sources in Rural mode.

The three

- kilometer ring for the Newton Study Area is centered on the main stack at the Newton

Power Station. The data source for land cover is t he 2011 National Land Cover Database (NLCD)

, with a d ata cell size (raster) of 30 meter s by 30 meter s

. The results of the Auer’s analysis for the Newton Study Area are presented in F igure 4 and Table 3.

Figure 4 Auer’s Analysis

- Newton Study Area12 Table 3 Auer’s Analysis Land Use Percentages by Category

- Newton Study Area

The Auer’s analysis indicates the study area is approximately 98.2% rural and 1.8% urban; therefore the rural option appl ies to all emissions sources in the modeling domain.

3.1.2. 3 Emissions

U. S. EPA g uidance for developing designation recommendations based upon modeling specifies

the use of actual emissions (as opposed to allowable) as input to produce results that reflect the existing air quality in a study area. U.S. EPA recommends using the most recent three years of actual

emissions since they would best represent the emissions that would simulate the impacts of a three

year moni toring dataset for deter mining compliance with the NAAQS. In this application, actual

emissions were used from the years 2012

- 2014.

In using actual emissions, U. S. EPA suggest s that the best achievable characterization of the

three

- year hourly emissions profile be developed from continuous emissions monitoring system s (CEMS) data or from other me ans as described in the SO 2 NAAQS Designations Modeling TAD. If

CEMS data are not available, then detailed throughput, operating schedules, and exhaust information

is a next best option to create temporally varying emission profiles. AERMOD is equipped with two keyword functions

, HOUREMIS and EMISFACT

, which allow flexibility in terms of modeling

var i able emissions

, depending on the depth of data on

- hand

. The HOUREMIS function allows the incorporation of hourly varying emissions, stack exit temperature s, and stack exit velocitie s into a13

single model

- ready file. The keyword function EMISFACT can be used alone if there is insufficient information to determine hourly emissions , but enough information to approximate somewhat longer

timefram e characterizations. EMISFACT allows the model to multiply a constant emissions rate by

an emissio ns factor which can vary in a way that provide s for a reasonable profile of seasonal, daily, day of week

, and even hour of day characterization of emissions.

D etermin ing which source s to model in the Newton Study Area included compiling a list of SO 2 sources within a ten

- kilometer radius of the Newton Power Station from the Illinois EPA state wide inventory database , and also evaluating the potential for sources beyond 10 km to cause a significant concentration gradient within the Newton Study Are a. Th e Newton Power Station is the only SO 2

source with in the ten

- kilometer study area , and there are no sources beyond ten kilometers that

Illinois EPA considers to have the potential to cause significant gradient impacts within the study

area. Actual emissions for the year s 2012

- 2014 are pr ovided in Table 4.

Table 4 Modeled Facility Actual Emissions

- Newton Study Area

Company I.D. Facility Name SO 2 Emissions (tons per year)

2012 2013 2014
079808AAA Newton Power Station 16,533.83 16,144.5 16

, 372.76

Total Emissions All Facilities 16 , 533.83 16, 1 44.5 16 , 372.76

H ourly varying 2012

- 2014 CEMS data , coupled with hourly

- specific exit temperatures and exit velocities, were provided by Illinois Power Generating Company for use in the dispersion modeling.

See Appendix A for the full emissions inventory and stack parameters, including the substitution methods employed for addressing missing or erroneous data fields. For the Newton Study Area, the HOUREMIS factor was applied to the two point sources modeled

. The EMISFACT keyword was

not deemed necessary for representing this facility’s emissions

. The hourly emissions file is included

with this submittal and can be fo und on the DVD representing Appendix C.

3.1.2. 4 Meteorology

The SO 2 TAD recommends using the three most recent years of meteorology for modeling applicable to the SO 2 area designations process

. In this case, data for meteorological years 2012

- 2014 were available

. T his time period align s with the three years of hourly emissions data input into

the model. This temporal linking of e missions and meteorology in the model provide s the best approximation of the real

- world impacts which would occur during that time should a monitor have

been present.

The sel ection of a representative meteorological station for each of the study areas was based on proximity, similarity of terrain/surface roughness, and climatological consistency

. Central Illinois and

c entral Indiana share similar topography, climate, and land use

. For the Newton Study Area, National Climatic Data Center National Weather Service (NWS) surface meteorology from Evansville, Indiana14

( WBAN No. 93817, 123 km to the southeast)

, and coincident upper air observations from Lincoln,

I llinois ( WBAN No. 04833, 164 km to the northwest)

, w ere selected as best representative of meteorological conditions within the study area (EVV/ILX)

.

The three

- year surface wind rose for Evansville, Indiana

, is depicted in Figure 5. The frequency and magnitude of wind speed and direction are de fined in t erms of where the wind is blowing fr o m, parsed out in twelve 30

- degree wind sect ors . The predominant wind direction during the three

- year time period represe nted in the modeling is from the southwest, occurring approximately 11.3% of the

time . The highest percentage wind speed range, occurring 25.3% of the time, was in the 3.6

– 5.7 m/s

range

.
Figure 5

Evansville, I ndiana, Cumulative Annual Wind Rose

2012

- 201415

Meteorological data from the above surface and upper air stations w ere used in generating

AERMOD

- ready files with the AERMET processor, a part of the AERMOD software suite. The output meteorological data created by the AERMET processor is suitable for being applied with AERMOD input files for AERMOD modeling runs.

The metho dology and settings performed in the processing of the raw meteorological data into

AERMOD

- ready format followed the guidelines set forth in the draft guidance, Regional Meteorological Data Processing Protocol

, U.S. EPA Region 5 and States (February 1, 201 3). S urface

characteristics such as Albedo, Bowen Ratio, and Surface Roughness (Zo) were developed using AERSURFACE, an AERMET companion preprocessor

.

The s urface met eorological wind field data is input to AERMET from two separate sources. Hourly surfac e meteorological data records are read by AERMET and include all the necessary

elements for met eorological data processing. However

, w ind data taken at hourly intervals may not always portray wind conditions for the entire hour , which can be variable in nature compared to more

stable met eorological data categories not prone to wide ranging changes. Indeed, wind data that portrays calm conditions for the hour is not usable for modeling proposes and must be passed over by AERMOD when modeling is being perf ormed. In order to better represent actual wind conditions at

the met eorological tower, wind data of one minute duration was provided from the same instrument

tower, but in a different formatted file to be process ed by a separate preprocessor, AERMINUTE. This data is subsequently integrated into the AERMET processing to produce final hourly wind

records of AERMOD

- ready met eorological data that approach actual conditions and reduce the frequency of reported calm wind conditions

. This allows AERMOD to appl y more hours of meteorology to modeled inputs

, and therefore produce more concentration data output. As a guard against excessively high concentrations that could be produced in very light wind conditions, Illinois

EPA set a minim um threshold of 0.5 m/s i n processing met eorological data for use in AERMOD

. In setting this threshold, no wind speeds lower than this value would be used for determining concentrations. This threshold was specifically applied to the one minute wind data.

The AERMOD

- ready “ .sfc ” and “ .pfl ” meteorological data files are included in this submittal via

the DVD representing Appendix C.

3.1.2.5 Receptor Network/Terrain

The receptor grid for Newton was designed to be of sufficient density and size to capture all

relevant concentr ation gradients from modeled sources and to adequately resolve the maximum predicted SO 2 design value concentration. In the case of the Newton Study Area, the Newton Power
Station was the only source modeled. Thus, the receptor grid includes fine to coarse spacing in a Cartesian grid network extending outward in all directions from the facility fenceline . Receptor spacing was approximately:16

 50 meters along the fenceline

 100 meters from the fenceline out to 5.0 kilometers

 500 meters from 5.0 kilomet ers out to 8.0 kilometers

The Newton Study Area r eceptor grid is presented in Figure 6. A tota l of 12,165 receptors comprised the network , covering the southwest ern section of Jasper County and small portions of Effingham and Clay counties. The terrain i n the study area is best described as flat to gently rolling. To account for terrain changes, the AERMAP terrain program was used to specify terrain elevations and hill scale height for all the receptors. The source of the elevation data incorporated int o the model is from the USGS National Elevation Database (NED).

Figure 6 Receptor Grid

– Newton Study Area

3.1.2.6 Background SO 2

The r egional SO 2 sources not explicitly modeled in AERMO D were characterized as background

contributors to SO 2 in the study area and represented via background monitoring data. U.S. EPA recommends inclusion into the model data from the nearest representative background SO 2 monitor operated by federal, state, local, or tribal organizations. The Nilwood, I llinois, monitor was selected for the Newton study area. The Nilwood monitor is located approximately 142 kilometers northwest17

of the study area in rural Macoupin County. The monitor, operated and maintained by Illinois EPA

, has hourly SO 2 concentrations which ha ve been validated for the three years modeled in this analysis (2012

- 2014).

For this modeling application, Illinois EPA incorporated temporally

- varying background 1

- hour concentrations developed from the Nilwood, Illinois

, monitor. The values developed f or input into

AERMOD are based on the 99 th percentile monitored concentrations and vary by season and hour.

The seasons are characterized as : Winter (Dec

- Jan

- Feb), Spring (Mar

- Apr

- May), Summer (Jun

- Jul

Aug), and Fall (Sep

- Oct

- Nov). The second highest value for each hour of the day (24 values) by season was averaged for the years 2012

- 2014 to derive 96 distinct 1

- hour SO 2 background

concentration values , in total for the four seasons. The latest version of AERMOD allows inclusion

of these hour ly varying background values directly into the AERMOD runstream file via the SEASONHR keyword. For model results reported here, the maximum impacts include the contribution from background SO 2 in the modeled design value. A table of the background SO 2 ho urly varying values by season is provided in Appendix B

.

3.1. 3 Summary of Results

The AER M OD simulation for the Newt o n Study Area included two stacks, nine structures, one fenceline , and 12,165 receptors. The model simulated the years 2012

- 2014

, combining emissions, meteorology, terrain, and background SO 2 levels into the model to calculate a maximum 99 th
percentile 1

- hour SO 2 concentration for each receptor in the grid. The results presented in Table 5 report the magnitude and geographic location of the highest predicted concentration.

Table 5
Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentration

Newton Study Area

Averaging Period Data Period Receptor Location

(Meters) SO 2 Concentration ( μg/m 3 )
East North Modeled NAAQS
99 th Percentile 1

- Hour Average 2012

- 2014 390400 4314200 138. 8 9 196 .23 *

* Equivalent to the 75 ppb standard

The maximum predicted 99 th percentile 1

- hour average concentration within the modeling domain is
138. 8 9 μg/m3, or 53.0 ppb. The maximum occurred within the dense 100

- meter grid approximately

3.85 km northeast of the Newton Power station main stack. The c olored contour map of maxim um 99 th percentile concentrations presented in Figure 7 depicts the maximum predicted concentration for each receptor in the study area an d indicates the location of the overall predicted maximum.18 Figure 7
Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentrations

- Newton Study Area

3.1. 4 Designation Recommendation

Based on the modeling results, the extent of the study area, and consideration of other SO 2 sources in

the multi

- county area, Illinois EPA recommends that Jasper County be designated as attainment for

the 1

- hour SO 2 standard.19

3. 2 Hennepin Power Station (Putnam County )

The area near the city of Hennepin in Putnam County contain s a stationary source that satisfies one of the conditions (only one or the other required to qualify) of the March 2, 2015

, Consent

Decree between U. S. EPA, Sierra Club, and the NRDC. A source exists that emitted less than the 16,000 tons (5,906) tons per year of SO 2 in 2012

, but had an emission rate that exceeds 0.45

lb s /mm B tu (0.501) in 2012.

3. 2 .1 Study Area

The town of He n nepin, Illinois

, is located in north

- central Illinois in the northwestern portion of

Putnam County. The Hennepin Power Station ( Dynegy) is one of the five plants subject to the SO 2 Consent Decree

. As depicted in Figure 8, the plant operates approximately 5.6 kilometers north

northeast of the town of Hennepin in a rural area bounded on the north by the Illinois River . For the

air quality impact analysis, the determination of the size and extent of the study area (i.e.

, receptor grid) is based primarily on three key considerations : 1) the location of the SO 2 emission

sources/facilities to be included in the modeling; 2) the location and extent of significant concentration gradient s to be generated by SO 2 emission sources ; and, 3) sufficient receptor coverage and density to adequately capture and resolve model predicted maximum SO 2 concentrations within the study area.

Figure 8 Hennepin Study Area ( Putnam County)20

3. 2 .2 Model Setup and Execution

As described in Section 3.1.2, AERMOD was used for the designation recommendation modeling. AERMOD is the dispersion modeling component of a much broader modeling system that

includes multiple companion pre

- processing programs that prepare other inputs into the model (BPIP

PRIME, AERMET, AERMINUTE, AERMAP, and AERSURFACE)

.

3. 2 .2.1 Model Settings

The latest version of AERMOD (version 15181) was run in the standard r egulatory default

mode

.

3. 2 .2.2 Auer’s Analysis

The Auer’s discussion and analysis discussed in Section 3.1.1.1 was similarly applied to the Hennepin Study Area

. The Auer’s analysis is a methodology for determining if the sources within the study area are located w ithin a rural or urban dispersion regime.

The three

- kilometer ring appl ied in the Auer’s analysis for the Hennepin Study Area is centered

on the main stack at the Hennepin Power Station

. The data source for land cover was the 2011

National Land Cover Dat abase (NLCD), with a data cell size of 30 meter s by 30 meter s

. The results of the Auer’s analysis are presented in Figure 9 and Table 6

.21 Figure 9 Auer’s Analysis

– Hennepin Study Area

Table 6 Auer’s Analysis Land Use Percentages by Category

– Hennepin Study Area22

The Auer’s analysis indicates the study area is approximately 98. 1 % rural and 1. 9 % urban; therefore the rural option was applie d to all emissions sources in the modeling domain.

3. 2 .2.3 Emissions

U. S. EPA g uidance for the modeling of emissions for designation recommendations allows for use of actual emissions as input (as opposed to allowable) into the model to produce results that reflect the current existing air quality in a study area. U.S. EPA recommends using the most recent 3 years of actual emissions since they would best represent the emissions that would simulate the impacts of a 3

- year monitoring dataset for determining compliance with the NAAQS. In this application, actu al emissions were used from the most recent available years ( 2012

- 2014 )

.

The determination of sources to model in the Hennepin Study Area consisted of compiling a list from the state inventory database of SO 2 sources within a 10 km radius of the Hennepin Power Station, while also evaluating the potential for sources beyond 10 km to cause a significant concentration gradient within the area

. In the case of Hennepin

, four facilities were identified within

th is area with SO 2 emissions (refer to Figure 8) . T he four facilities were considered to have a potential impact in the near

- field where maximum concentrations are expected. There were no sources beyond 10 km that Illinois EPA considers to have the potential to cause significant gradient impacts within th e study area. The facili ties and their modeled actual SO 2 ton nages for 2012

- 2014 are presented in Table 7

.

Table 7

Modeled Facility Actual Emissions

- Hennepin Study Area

Company I.D. Facility Name SO 2 Emissions (tons per year)

2012 2013 2014
155010AAA Hennepin Power Station 5

, 911.25 4

, 274.35 3

, 965.36

155801AAC Washington Mills 890.20 929.43 1

, 035.01

155801AAJ Advanced Asphalt 13.63 13.62 5. 46

155010AAJ Marquis En ergy 8.56 9.30 4.05

Total Emissions All Facilities 68 23

. 64 52 26

. 70 50 09.88

Emissions profiles for the Hennepin invent ory were developed using a combination of the

AERMO D keywords HOUREMIS and EMISFACT. Illinois EPA used hourly varying 2012

- 2014

CEMS SO 2 emissions data provided by the Hennepin Power Station together with hourly

- specific exit
temperature s and exit velocit ies

. For Washington Mills, hourly varying emissions, temperature s , and

exit velocit ies w ere obtained for the largest emitting furnace stack (99.9% of the facility emission s )

. For the two smaller emitting units, Washington Mills provided operating information that allowed

Illinois EPA to construct an hourly varying emiss ions rate coupled with constant temperature and exit2 3

v elocit y values

. An hourly profile was developed for Advanced Asphalt’s sources based on company report ed seasonal throughput. A combination of seasonal emissions factors (EMISFACT) and an hourly emissions profile was used for Marquis E nergy sources

. Please reference Appendix A for the full emissions inventory and stack parameters, including the substitution methods employed for addressing missing or erroneous data fields. For the Hennepin Study Are a , a total of 12 point sources

were modeled. The HOUREMIS factor was applied to the seven point sources modeled and

EMISFACT to four sources

. O ne source was modeled with a conservative constant hourly emission

rate for the three

- year period

. The hourly emissions file is included in this submittal via the DVD representing Appendix C.

3. 2 .2.4 Meteorology

The SO 2 TAD recommends using the three most recent years of meteorology for use in the SO 2 Phase II Designation modeling. For the Hennepin Study Area, the National Climatic Data Center National Weather Service (NWS) surface meteorology from Rockford , I llinois (WBAN No. 9 4822

, 1 11 km to the north )

, and coincident upper air observations from Davenport, I owa (WBAN No.

94982 , 1 10 km to the northwest)

, w ere selected as best representative of meteorological conditions within the study area.

The three

- year surface wind rose for Rockford , I llinois

, is depicted in Figure 10 . The frequency and magnitude of wind speed and direction are de fined in terms of where the wind is blowing from, parsed out in twelve 30

- degree wind sectors. The predominant wind direction during the thre e

- year time period used i n the modeling is from the south, occurring approximately 1 2

. 8 % of the time. The highest percentage wind speed range, occurring 31.4 % of the time, was in the 3.6

– 5.7 m/s range.24 Figure 10
Rockford , I llinois , Cumulative Annual Wind Rose

2012

- 2014

Meteorological data from the above surface and upper air stations w ere used in generating

AERMOD

- ready files with the AERMET processor, a part of the AERMOD software suite. The output meteorological data created by the AERMET processor is suitable for being applied with AERMOD input files for AERMOD modeling runs. The methodology and settings performed in the processing of the raw meteorological data into AERMOD

- ready format followed the same procedure

as in the Newton Study Area. Please r efer to Section 3.1.2.4 for more details on the meteor o logical input procedure utilized. The Hennepin Study Area AERMOD

- ready “ .sfc ” and “ .pfl ” meteorological electronic files are included in this submittal via the DVD representing Appendix C.25

3. 2 .2.5 Receptor Network/Terrain

The receptor grid for Hennepin was designed to be of sufficient density and size to capture all relevant concentration gradients from modeled sources and to adequately resolve the maximum predicted SO 2 design value concentratio n. In the case of the Hennepin Study Area, three of the four facilities (Hennepin P ower Station /Washington Mills/Advance Asphalt) are located nearly adjacent to

one ano ther along the Illinois River. The fourth facility, Marquis Energy, is located roughly three

kilometers to the south

- southwest of the other facilities

. Th erefore

, to ensure adequate capture of predicted maximums the receptor grid ’s dense 100

- meter spacing was extended outward from each

fenceline to a distance of at least 3 kilometers from each facility. The study area r eceptor spacing was approximately:

 50 meters along the fenceline ( four facilities)

 10 0 meters from the fenceline out to a distance of approximately 4 .0 k ilometers

 500 meters from 4.0 kilometers out to a distance of approximately 8.0 k ilometers

 1,000 meter s from 8.0 kilometers out to a distance of approximately 11 k ilometers

The Henn epin Study Area r eceptor grid is presented in Figure 11 . The receptor network, consisting of 1 3,430 receptors, cover s the northern two

- thirds of Putnam County and the south east portion of Bureau County. The study area terrain is best characterized as flat to gently rolling. To account for terrain changes, the AERMAP terrain program was used to generate terrain elevations and hill height scales for all the receptors. The source of the elevation data incorporated into the model is from the USGS National Elevation Database (NED).26 Figure 11 Receptor Grid

– Hennepin Study Area

3. 2 .2.6 Background SO 2

The regional sources not explicitly modeled in AERMOD, but best characterized as background

contributors to SO 2 near or in the study area, are addressed via background monitoring data. U.S.

EPA recommends inclusion into the model data from the nearest representative background SO 2 monitor operated by state, local, or tribal organizations. The Oglesby , I llinois, monitor was selected

for the Hennepin study area. The Oglesby monitor is located ap proximately 23 km east of the study

area in western LaSalle C ounty in the town of Oglesby

. The monitor, operated and maintained by

Illinois EPA , has validated hourly SO 2 concentrations for the three years modeled in this analysis (2012

- 2014).

For this mo deling application, Illinois EPA employed temporally

- varying background 1

- hour concentrations developed from the Oglesby , Illinois

, monitor. The values developed for input into AERMOD for background SO 2 are based on the 99 th percentile monitored concentrations vary by

season and hour in the sa me method as described in the previously discussed study area . The seasons are characterized as: Winter (Dec

- Jan

- Feb), Spring (Mar

- Apr

- May), Summer (Jun

- Jul

- Aug), and Fall (Sep

- Oct

- Nov) . The second highest value for each hour of the day (24 values) by season was averaged for 2012

- 2014 to derive 96 distinct 1

- hour SO 2 concentrations background values total for27

the four seasons. For model results reported here, the maximum impacts includ e the contribution from background SO 2 into the modeled design value. A table of the background SO 2 seasonally and hourly varying values utilized in the Hennepin Study Area modeling is provided in Appendix B

.

3. 2 .3 Summary of Results

The AER M OD simulation for the Hennepin Study Area evaluated seven stacks, 9 0 structures, four

fenceline s , and 1 3

, 429 receptors. The model simulated the years 2012

- 2014, combining emissions, meteorology, terrain, and background SO 2 levels into the model to calculate a predicted maximum

99 th percentile 1

- hour SO 2 concentration for each receptor in the grid. The results presented in Table 8 report the magnitude and geographic location of the highest predicted concentration.

Table 8
Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentration

Hennepin Study Area

Averaging Period Data Period Receptor Location

(Meters) SO 2 Concentration ( μg/m3)
East North Modeled NAAQS
99 th Percentile 1

- Hour Average 2012

- 2014 3 11600 4570200 94.5 6 196 .23 *

* Equivalent to the 75 ppb standard

The maximum predicted 99 th percentile 1

- hour average concentration within the modeling domain is

94.5 6 μg/m 3 , or 36

. 1 ppb. The maximum occurred within the dense 100

- meter grid at a n elevated

location 7

. 2 km southeast of the Hennepin Power S tation. The highest predicted concentration in the

near

- field from the p ower plant was 89.59 μg/m 3 , located about two kilometers east

- southeast of the Hennepin Power Station and just east of the Advance d Asphalt facility

. T he colored contour map illustrated in Figure 12 provides a color

- coded maximum predicted concentration for each receptor in the study area and indicates the location of the predicted maximum.28 Figure 12
Maximum Predicted 99 th Percentile 1

- Hour SO 2 - Hennepin Study Area

3.2 .4 Designation Recommendation

Based on the Illinois EPA’s modeling results, the extent of the study area, and consideration of other

SO 2 sources in the multi

- county area, Illinois EPA recommends that Putnam and Bureau Count ies be designated as attainment for the 1

- hour SO 2 standard.29

3. 3 Marion Power Station ( Williamson County )

The area south of the city of Marion in Williamson County contains a stationary source that satisfies one of the conditions (only one or the other required to qualify) of the March 2, 2015

, Consent Decree between U.S. EPA , Sierra Club, and the NRDC. Th e Marion Power Station emit ted less than the 16,000 tons (5, 850 ) tons per year of SO 2 , but had an emission rate that exceeds 0.45

lb s /mm B tu (0. 489 ) in 2012.

3. 3 .1 Study Area

The town of Marion , Illinois

, is located in southern Illinois in the central portion of Williamson County. The Marion Power Station ( Southern Illinois Power Cooperative or SIPCO ) is one of the five plants subject to SO 2 Consent Decree. As depicted in Figure 13 , t he plant operates approximately 11

kilometers south

- southwest of town in a rural area bounded on the east side by the Lake of Egypt , and a golf course on the southeast

. T he determination of the size and extent o f the study area (i.e. receptor grid) was based on the same considerations assessed in the previous study areas

.

Figure 13 Marion Study Area ( Williamson County)

3.3.2 Model Setup and Execution

As described in Section 3.1.2, AERMOD was used for the designation recommendation modeling. AERMOD is the dispersion modeling component of a much broader modeling system that30

includes multiple companion pre

- processing programs that prepare other inputs in to the model (BPIP

PRIME, AERMET, AERMINUTE, AERMAP, and AERSURFACE).

3. 3 .2.1 Model Settings

The latest version of AERMOD (version 15181) was run in the standard regulatory default

mode.

3. 3 .2.2 Auer’s Analysis

The Auer’s discussion and analysis discussed in Section 3.1.1.1 was similarly applied to the

Marion Study Area. The Auer’s analysis is a methodology for determining if the sources within the study area are located within a rural or urban dispersion regime

.

The three

- kilometer ring appl ied in the Auer’s analysis for the Marion Study Area was centered

on the Marion Power Station. The data source for land cover was the 2011 National Land Cover Database (NLCD), with a data cell size of 30

- meter s by 30

- meter s

. The results of the Auer’s analysis are presented in Figure 14 and Table 9.

Figure 14 Auer’s Analysis

- Marion Study Area31 Table 9 Auer’s Analysis Land Use Percentages by Category

– Marion Study Area

The Auer’s analysis indicates the study area is approximately 98. 5 % rural and 1. 5 % urban; therefore the rural option applies to all emissions sources in the modeling domain.

3. 3 .2.3 Emissions

The determination of sources to model in the Marion Study Area consisted of compiling a list

from the state inventory database of SO 2 sources within a ten

- kilometer radius of the Marion Power Station, while also evaluating the potential for sources beyond ten kilometers to cause a significant concentration gradient within the area. In the case of Marion

, there w ere two facilities identified

within the ten

- kilometer area with SO 2 emissions. The Marion Power Station, located 11 kilometers

south

- southwest of the city of Marion, and the United States (U.S.) Penitentiary, located approximately six kilometers northwest of the power station. The two facilities were considered to have a potential impact in the near

- field where maximum concentrations are expected. There were no sources beyond ten kilometers that Illinois EPA considers to have the potential to caus e significant gradient impacts within the study area. The facility and their modeled tons per year 2012

- 2014 are presented in Table 10

.32 Table 10

Modeled Facility Emissions

– Marion Study Area

Company I.D. Facility Name SO 2 Emissions (tons per year)

2012 2013 2014
199856AAC Marion Power Station (SIPCO) 5512.11 5512.11 5512.11

155801AAC United States Penitentiary 0.18 0.18 0.18

Total Emissions All Facilities 5512.29 5512.29 5512.29

The four Marion Power Station stacks were modeled at max imum actuals expected from the

source . The other facility in the modeling, United States Penitentiary, had no detailed hourly throughput or operating schedule data available , thus the conservative worst

- case year emissions were applied to each year and spread uniformly thro u gh o ut every hour

. Please reference Appendix A for the full emissions inventory and stack parameters

. For the Marion Study Are a , a total of eight point

sources were modeled. The hourly emissions file is included in this submittal via the DV D representing Appendix C.

3. 3 .2.4 Meteorology

The SO 2 TAD recommends using the three most recent years of meteorology for use in the SO 2 Phase II Designation modeling.

The selection of a representative meteorological station for each of the study areas was based on proximity, similarity of terrain/surface roughness, and climatological consistency. For the Marion Study Area, National Climatic Data Center National Weather Service (NWS) surface meteorology

from Paducah

, Kentucky (WBAN No. 3816

, 64 km to the southeast )

, and coincident upper air

observations from Nashville

, T ennessee (WBAN No. 13897

, 260 km to the southeast )

, was selected as best representative of meteorological conditions within the study area ( PAH/NAS ).

The three

- year surface wind rose for Paducah

, Kentucky

, is depicted in Figure 1 5 . The frequency and magnitude of wind speed and direction are de fined in terms of where the wind is blowing from, parsed out in twelve 30

- degree wind sectors. The predominant wind direction during

the three

- year time period used in the modeling is from the south west , occurring approximately

1 1

. 4 % of the time. The highest percen tage wind speed range, occurring 32.9 % of the time, was in the

2

. 1

– 3

. 6 m/s range.33 Figure 1 5

Paducah , Kentucky, Cumulative Annual Wind Rose

2012

- 2014

Meteorological data from the above surface and upper air stations was used in generating

AERMOD

- ready files with the AERMET processor, a part of the AERMOD software suite. The output meteorological data created by the AERMET processor is considered suitable for being applied in AERMOD for regulatory modeling applications

. The methodology and settings performed in the processing of the raw meteorological data into AERMOD

- ready format followed the same procedure as in the Newton Study Area. Please refer to Section 3.1.2.4 for more details on the development pro cedure utilized for the meteorological input s

. The Marion Study Area AERMOD

34

ready “.sfc” and “.pfl” meteorological electronic files are included in this submittal via the DVD representing Appendix C.

3. 3 .2.5 Receptor Network/Terrain

The receptor gri d for Marion was designed to be of sufficient density and size to capture all relevant concentration gradients from modeled sources and to adequately resolve the maximum predicted SO 2 design value concentration. The terrain to the south of the Marion Power Station contains forested, complex terrain, thus the receptor grid was extended a sufficient distance to ensure the maximums were captured. T he receptor grid’s dense 100

- m eter spacing, using a Cartesian gridding method, was extended outward from each fenc eline to at least five kilometers distance from each facility (extent may vary slightly by direction) . The study area receptor spacing was approximately:

 50 meter s along the fenceline ( two facilities)

 100 meter s from the fenceline out to approximately 5 .0 kilometers

 500 meter s from 5.0 kilometers out to approximately 8.0 kilometers

 1,000 meter s from 8.0 kilometers out to approximately 1 0 kilometers

The Marion Study Area receptor grid is presented in Figure 1 6 . The receptor count totaled 25,118 receptors, covering central and south

- central Williamson County, the northe ast corner of Union County, and the northwest and north

- central part of Johnson County. The terrain in the study

area is best characterized as complex to gently rolling (south to n orth) . To account for terrain changes, the AERMAP terrain program was used to develop terrain and hill scale height for all the receptors. The source of the elevation data incorporated into the model is from the USGS National Elevation Database (NED).35 Figure 1 6 Receptor Grid

– Marion Study Area

3. 3 .2.6 Background SO 2

The regional sources not explicitly modeled in AERMOD, but best characterized as background

contributors to SO 2 near or in the study area, are addressed via background monitoring data. U.S.

EPA recommends inclusion into the model data from the nearest representative background SO 2 monitor operated by state, local, or tribal organizations. The Houston , I llinois, mo nitor was selected

for the Marion study area. The Houston monitor is located approximately 94 kilometers northwest of the study area in northern Randolph County in the small town of Houston

. The monitor, operated and maintained by Illinois EPA , has validated hourly SO 2 concentrations for the three years modeled in this analysis (2012

- 2014).

For this modeling application, Illinois EPA incorporated temporally

- varying background 1

- hour concentrations developed from the Houston , Illinois

, monitor. The values developed for input s are based on the 99 th percentile monitored concentrations and vary by hour and season in the sa me

manner as discussed previously for the other study area s

. M odel ed concentrations include the36

contribution of the background values

. A table of the background SO 2 seasonally and hourly varying

values utilized in the Marion Study Area modeling is provided in Appendix B.

3. 3 .3 Summary of Results

The AER M OD simulation for the Marion Study Area comprised eight stacks, 37 structures, two
fenceline s, and 25,118 receptors. The model simulated 2012

- 2014

, while taking into account maximum actual emissions expected from the source , combining such emissions, meteorology, terrain, and background SO 2 levels into the model to calc ulate a maximum 99 th percentile 1

- hour SO 2 concentration for each receptor in the grid. The results presented in Table 11 report the magnitude and geographic location of the highest predicted concentration.

Table 11
Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentration

Marion Study Area

Averaging Period Data Period Receptor Location

(Meters) SO 2 Concentration ( μg/m 3 )
East North Modeled NAAQS
99 th Percentile 1

- Hour Average 2012

- 2014 327 2 00 416 62 00 194.48 196 .3 2 *

* Equivalent to the 75 ppb standard

The maximum predicted 99 th percentile 1

- hour average concentration within the modeling domain is
194.48 μg/m 3 , or 74.3 ppb. The maximum occurred within the dense 100

- meter grid 1.2 km north

northwest of the Marion Power S tation. The c olor coded contour map in Figure 1 7 depict s maximum predicted concentration s for each receptor in the study area and indicate s the location of the predicted

maximum.37 Figure 1 7

Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentrations

- Marion Study Area

3.3 .3 Designation Recommendation

Based on the modeling results, the extent of the study area, and consideration of other SO 2 sources in

the multi

- county area, Illinois EPA recommends that Williamson County be designated attainment

for the 1

- hour SO 2 standard

.38



### 3.4 Joppa Steam Coal Power Plant (Massac County )

The area west of the town of Joppa in Massac County contains a stationary source that satisfies one of the conditions (only one or the other required to qualify) of the March 2, 2015

, Consent

Decree between U.S. EPA , Sierra Club, and the NRDC. The Joppa Power Station emitted greater
than the 16,000 tons ( 16,991 ) tons per year of SO 2 , and had an emission rate that exceeds 0.45

lb/mm B tu (0. 475 ) in 2012.

3.4.1 Study Area

The town of Jop pa , Illinois

, is located in southern Illinois in the west ern portion of Massac County. The Joppa Power Station is one of the five plants subject to the SO 2 Consent Decree. As depicted in Figure 18 , the plant is located approximately 1.0 kilometer west

- northwest of town in a

rural area bounded on the south by the Ohio River . The size and extent of the study area (i.e. receptor grid) was based on the same considerations described for previous study areas.

Figure 18 Joppa Study Area ( Mas sac County)39

3.4.2 Model Setup and Execution

As described in Section 3.1.2, AERMOD was used for the designation recommendation modeling. AERMOD is the dispersion modeling component of a much broader modeling system that includes multiple companion pre

- processing programs that prepare other inputs into the model (BPIP

PRIME, AERMET, AERMINUTE, AERMAP, and AERSURFACE).

3.4.2.1 Model Settings

The latest version of AERMOD (version 15181) was run in its standard regulatory default mode.

3.4.2.2 Auer’s Analysis

The Auer’s discussion and analysis discussed in Section 3.1.1.1 was similarly applied to the Joppa Study Area. The Auer’s analysis is a methodology for determining if the sources within the study area are located within a rural or urban dis persion regime.

The three

- kilometer ring applied in the Auer’s analysis for the Marion Study Area is centered on

the Marion Power Station. The data source for land cover was the 2011 National Land Cover Database (NLCD), with a data cell size of 30

- meters by 30

- meters. The results of the Auer’s analysis are presented in Figure 19 and Table 12.40 Figure 1 9 Auer’s Analysis

- Joppa Study Area

Table 12 Auer’s Analysis Land Use Percentages by Category

– Joppa Study Area41

The Auer’s analysis indicates the study area is approximately 9 6 % rural and 4 % urban; therefore the rural option applies to all emissions sources in the modeling domain.

3.4.2.3 Emissions

As discussed in previous sections, the most recent three years of actual emissions were used to best represent the emissions that would simulate the air quality for a three

- year monitoring dataset in determining compliance with the NAAQS. In this application, actual emissions were used from the most recently a vailable years ( 2012

- 2014 )

.

D etermin ing sources to model in the Joppa Study Area consisted of compiling a list from the state inventory database of SO 2 sources within a ten

- kilometer radius of the Joppa Power Station, while also evaluating the potential f or sources beyond ten kilometers to cause a significant concentration gradient within the area. In the case of the Joppa Study Area , there were six facilities

identified within the ten

- kilometer area with SO 2 emissions. The Joppa Power Station, Lafarge

Midwest Internat ional , Inc. Trunkline Gas Company, and Midwest Electric Power are all located

within a short distance from each other . The Honeywell International Inc. and the Tennessee Valley Authority (TVA) Shawnee Power Plant (Kentucky) are located appr oximately ten kilometers

southeast of th e other facilit ies. The se six facilities were considered to have a potential impact in the study area where maximum concentrations are expected. There were no sources beyond ten
kilometers that Illinois EPA consider s to have the potential to cause significant concentration gradient impacts within the study area. The facilit ies and associated annual actual emission tonnages ( 2012

- 2014 ) are listed in Table 1 3

.

Table 1 3

Modeled Facility Actual Emissions

– Joppa Study Area

Company I.D. Facility Name SO 2 Emissions (tons per year)

2012 2013 2014
127855AAC Joppa PS (Electric Energy Inc.) 17,007.07 16,557.74 18,229.24

127855AAA Lafarge Midwest Inc

. 552.60 553.28 491.65

127899AAA M idwest Electric Power Inc. (MEPI) 5.68 0.00 0.00

127855AAB Trunkline Gas Company 0.866 0.866 0.866

127854AAD Honeywell International Inc. 162.51 58.73 143.15

2114500006 TVA

– Shawnee Power Plant 27

, 114.87 27

, 210.73 29

, 734.54

Total Emissions All Facilities 44,843.60 44,3 81

. 46 48,599.45

E missions profiles for the Joppa inventory were developed using the AERMOD keyword

HOUREMIS and from applying a direct worst

- case actual year for one of the facilities

. Illinois EPA used hourly varying 2012

- 2014 CEMS SO 2 emissions data provided by the Joppa Power Station for42

its boiler stacks , along with hourly

- specific exit temperature s and exit velocit ies

. For Lafarge, the emissions from the two cement kiln stacks constitute 99.9% of the facility emissions, therefore t hose

two source s were modeled with company provided hourly varying emissions, temperature, and exit velocity. MEPI provided hourly varying emiss io ns for their operating units/stacks for the three

- year period. Trunkline’s emissions were constructed from co ntained in the company’s A nnual Emiss ion s Repo r ts, incl uding yearly emissions data and seasona l thro ughput . Seasonal emis sion s were averaged

over the thre e years , multiplied by a scalar (via EMISFACT keyword in AERMOD), and then applied

to the three

- year m odeling period. Nearly all of Honeywell’s facility SO 2 emissions (99.9%) exhaust

from the waste incinerator unit. A three

- year hourly profile was constructed for the three years based on seasonal throughput. CEMS data obtained via U.S. EPA ’s CAMD database was used to construct hourly emissions rates for the TVA

- Shawnee Boiler Stacks. For all sources in the Joppa inventory that lacked CEMS data, Illinois EPA used a constant value for exit temperature and exit velocity for

each hour of the m odeled period. These constant values were obtained either from the Illinois EPA

database or from company

- provided emission report submittals. Please reference Appendix A for the full emissions inventory and stack parameters, including the substitution me thods employed for addressing missing or erroneous data fields for CEMS data . For the Joppa Study Are a , a total of 17 point source stacks were modeled. AERMOD’s HOUREMIS keyword was applied to 12 of the p oint

sources

. T he EMISFACT keyword was applied to the remaining five sources

. The hourly emissions

file is included in this submittal via the DVD representing Appendix C.

3.4.2.4 Meteorology

The SO 2 TAD recommends using the three most recent years of meteorology for use in SO 2 area designations modeling.

The selection of a representative meteorological station for each of the study areas was based on proximity, similarity of terrain/surface roughness, and climatological consistency. For the J oppa Study Area, the National Climatic Data Center National Weather Service (NWS) surface meteorology from Paducah, Kentucky (WBAN No. 3816, 18 km to the southeast)

, and coincident upper air observations from Nashville, Tennessee (WBAN No. 13897, 2 28 km to the southeast)

, were selected as best representative of meteorological conditions within the study area (PAH/NAS).

The three

- year surface wind rose for Paducah, Kentucky

, is depicted in Figure 20 . The frequency and magnitude of wind speed and direction are de fined in term s of where the wind is blowing from, parsed out in twelve 30

- degree wind sectors. The predominant wind direction during

the three

- year time period used for the modeling is from the southwest, occurring approximately 11.4% of the time. The highest percentag e wind speed range, occurring 32.9% of the time, was in the

2.1

– 3.6 m/s range.43 Figure 2 0

Paducah , K entucky, Cumulative Annual Wind Rose

2012

- 2014

Meteorological data from the above surface and upper air stations were used in generating

AERMOD

- ready files with the AERMET processor, a part of the AERMOD software suite. The output meteorological data created by the AERMET processor is considered suitable for use in

AERMOD in regulatory modeling applications

. The methodology and settings invoked in processing the raw meteorological data into AERMOD

- ready format followed the same procedure as in the Newton Study Area. Please refer to Section 3.1.2.4 for more details on the development procedure44

utilized for the meteorological inputs. The J oppa Study Area AERMOD

- ready “.sfc” and “.pfl” meteorological files are included in this submittal via the DVD representing Appendix C.

3.4.2.5 Receptor Network/Terrain

The receptor grid for the Joppa Study Area was design ed to be of sufficient density and size to capture all relevant concentration gradients from modeled sources and to adequately resolve the maximum predicted SO 2 design value concentration. The receptor grid’s dense 100

- m eter spacing was created in two distinct sections, one that surrounds the grouping of sources around the Joppa Power Station, and another that captures the impacts around the Honeywell/TVA plants. In general,

the fine 100

- meter Cartesian grid was extended outward from each fenceline to at least three kilometers distance from each facility (extent may vary slightly by direction). The entire study area receptor spacing was approximately:

 50 meter s spacing along the fenceline ( six facilities)

 10 0 meter s out to approximat ely 3 .0 kilometers

 500 meter s from 3.0 kilometers out to approximately 8.0 kilometers

 1,000 meter s from 8.0 kilometers out to approximately 1 2 k ilo m eters

The Joppa Study Area receptor grid is presented in Figure 21 . The receptor network contained 25, 649 receptors, covering northwestern Massac County in Illinois, the northeastern portion of Ballard County in Kentucky, and the northwestern portion of McCracken County in Kentucky. The terrain in the study area is best characterized as flat to gently rollin g and is bisected west

- to east through its central part by the Ohio River. To account for terrain changes, the AERMAP terrain program was used to generate elevations and hill height for all receptors. The source of the elevation

data is the USGS National Elevation Database (NED).45 Figure 2 1 Receptor Grid

– Joppa Study Area

3.4.2.6 Background SO 2

The regional sources not explicitly modeled in AERMOD, but best characterized as background

contributors to SO 2 near or in the study area, are addressed via background monitoring data. U.S.

EPA recommends inclusion in the model of data from the nearest representative background SO 2 monitor operated by state, local, or tribal organizations. The Paducah

, K entucky

, monitor was

selected for the Joppa study area. The Paducah monitor is located approximately 18 kilometers

southeast of the study area in north

- central McCracken County in the city of Paducah, Kentucky. The monitor, operated and maintained by the Kentucky Division of Air Quality ( KD A Q ) , has validated hourly SO 2 concentrations for the three years modeled in this analysis (2012

- 2014).

For this modeling application, Illinois EPA incorporated temporally

- varying background 1

- hour concentrations developed from the Paducah

, Kentucky

, monitor. The values developed for inputs into AERMOD for background are based on the 99 th percentile monitored concentrations that vary by46

season and hour in the same manner as in the previously discussed study areas. For modeled design value impacts for comparison to the standard reported here, the maximum impacts include the contribution of background. A table of the background SO 2 seaso nally and hourly varying values

utilized in the Joppa Study Area modeling is provided in Appendix B.

3.4.3 Summary of Results

The AER M OD simulation for the Joppa Study Area comprised 18 stacks, 127 structures, six

fenceline s, and 25, 649 receptors. The model simulated 2012

- 2014, combining emissions, meteorology, terrain, and background SO 2 levels into the model to calculate a maximum 99 th
percentile 1

- hour SO 2 concentration for each receptor in the grid. The results presented in Table 1 4 report the magn itude and geographic location of the highest predicted concentration.

Table 1 4
Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentration

Joppa Study Area

Averaging Period Data Period Receptor Location

(Meters) SO 2 Concentration ( μg/m 3 )
East North Modeled NAAQS
99 th Percentile 1

- Hour Average 2012

- 2014 332800 4121600 168. 29 196 .23*

* Equivalent to the 75 ppb standard

The maximum predicted 99 th percentile 1

- hour average concentration within the modeling domain is

168. 29 μg/m 3 , or 64.2 ppb. Th is maximum occurred within the dense 100

- meter grid approximately

2. 9 km northwest of the Joppa Power Station main stacks and 0.4 km northwest of the Lafarge

northern fenceline . The colored contour map of maximum 99 th percentile conce ntrations presented in Figure 22 depicts maximum predicted concentration for each receptor in the study area and indicates the location of the predicted maximum.47 Figure 2 2
Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentrations

– Joppa Study Area

3.4 .4 Designation Recommendation

Based on the modeling results, the extent of the study area, and consideration of other SO 2 sources in the study area, Illinois EPA recommends that Massac Count y be designated as attainment for the 1

- hour SO 2 standard.48

3.5 Wood River Power Station (Madison County )

Wood River in Madison County, I llinois, contains a stationary source that satisfies one of the conditions (only one or the other required to qualify) of the March 2, 2015

, Consent Decree between

U.S. EPA , Sierr a Club, and the NRDC. The Wood River Power Station emitted less than 16,000 tons ( 6,756 ) tons per year of SO 2 , but had an emission rate that exceeds 0.45 lb s /mmBtu (0. 476 ) in 2012.

3.5.1 Study Area

The city of Wood River is part of the St. Louis Metropolitan Statistical Area (MSA) and is

located northeast of the urban core east of the Mississippi River in Illinois

. The W ood River Power Station is one of the five plants subject to the SO 2 Consent Decree. As depicted in Figure 2 3 , the plant is loc ated along the Mississippi River in western Madison County in a community with residential, commercial, and industrial areas. T he size and extent of the study area (i.e.

, receptor grid)

were based on the same considerations described previously for other study areas.

Figure 2 3
Wood River Study Area ( Madison County)49

3. 5 .2 Model Setup and Execution

As described in Section 3.1.2, AERMOD was used for the designation recommendation modeling. AERMOD is the dispersion modeling component of a much broader modeling system that includes multiple companion pre

- processing programs that prepare other inputs into the model (BPIP

PRIME, AERMET, AERMINUTE, AERMAP, and AERSURFACE).

3. 5 .2.1 Model Settings

The latest version of AERMOD (version 15181) was run in the standard regulatory default

mode.

3. 5 .2.2 Auer’s Analysis

The Auer’s di scussion and analysis in Section 3.1.1.1 similarly appl y to the Wood River Study

Area. The Auer’s analysis is a methodology for determining if the sources within the study area are located within a rural or urban dispersion regime.

The three

- kilometer ring applied in the Auer’s analysis for the Wood River Study Area wa s centered on the Wood River Power Station. The data source for land cover was the 2011 National

Land Cover Dat abase (NLCD), with a raster data cell size of 30 meter s by 30 meter s

. The results of the Auer’s analysis are presented in Figure 2 4 and Table 1 5

. The Auer’s analysis indicates the study area is approximately 80.1% rural and 19.9% urban; therefore the rural option applies to all emissions sources in the modeling domain.50 Figure 2 4 Auer’s Analysis

– Wood River Study Area

Table 1 5 Auer’s Analysis Land Use Percentages by Category

– Wood River Study Area51

3. 5 .2.3 Emissions

T he most recent three years of act ual emissions were used to represent the emissions that would simulate the impacts of a three

- year monitoring dataset for determining compliance with the NAAQS. In this application, actual emissions were used from the 2012

- 2014.

Determining the sources to model in the Wood River Study Area consisted of compiling a list from the state inventory database of SO 2 sources within a 10 km radius of the Wood River Power Station, while also evaluating the potential for sources beyo nd 10 km to cause a significant concentration gradient within the area. In the case of the Wood River Study Area, there were five facilities (see Figure 2 3 ) identified and included in the modeling within the 10 km area with actual

SO 2 emissions greater tha n 0.5 tons per year in one of the three years evaluated . The y are the Wood

River Power Station, WRB Refining Inc. (formerly named ConocoPhillips), Alton Steel, Inc

. , Christ

Brothers Products LLC , and National Maintenance and Repair facilities

. The Ameren UE Sioux

Power Plant

, located just west of Portage D es Sioux, Missouri

, was also included in the modeling due to its tall stacks and high annual emissions. It is located approximately 18 kilometers west

- northwest

of the cen ter of the study a rea. There wer e seven addit io nal facilities examined in the Wood River Study A rea. All reported actual emissions of le ss than hal f a ton per year in any of the years 2012

- 2014, thus they are not explicitly modeled and their impacts are conside red to be represented by

e xisting background monitoring. In summary, six facilities were considered to have a potential significant impact gradient impact in the study area where maximum concentrations are expected.

Each facility and its modeled actual emissions for 2012

- 2014 are presented in Table 1 6

.

Table 1 6

Modeled Facility Actual Emissions

– Wood River Study Area

Company I.D. Facility Name SO 2 Emissions (tons per year)

2012 2013 2014
119020AAE Wood River Power Station 6

, 719.49 7

, 662.27 7

, 034.66

119090AAA WRB Refining LLC 1,966.48 1,203.08 1,103.42

119010AAE Alton Steel, Inc

. 42.75 38.00 39.35

119097AAB Christ Brothers Products 7.20 7.20 7.20

1190801AAE National Maintenance and Repair 3.93 3.93 3.93

183

- 0001 Ameren Missouri Sioux Power Station 2

, 658.45 2

, 799.27 1

, 483.75

Total Emissions All Facilities 11,398.30 11 , 713.75 9 , 672.31

E missions profiles for the Wood River inventory were developed using AERMOD keyword

HOUREMIS , EMISFACT

, and

, in some instances when lacking sufficient info to construct hourly profiles, conservatively applying the worst

- case actual year to each of the three years

. Illinois EPA used hourly varying 2012

- 2014 CEMS SO 2 emissions data provided by the Wood River Power
Station for its boiler stacks in the dispersion modeling, including temporally varying exit temperature52

and exit velocity. For the Units 1

- 3 s tack, a conservative worst

- case emissions year was applied to all

three years. WRB Refi ning provided three years of hourly varying emiss i ons, temperature

, and exit velocity for their operating units/stacks for the modeling period. For Alton Steel, operating schedule and yearly em i ssion s provide d by the company for the Electric Arc Furnace ( EAF ) and Ladle

Metal lurgy Furnace ( LMF ) exhaust emissions allow ed Illinois EPA to constr u ct a three

- year emissions profile

. For the two other sources at the facility, a conservative worst

- case emissions year was applied to all three years. The worst

- case emissions year was applied for the entire simulation

for Chris t Bro ther s and National Maintena n ce and Repair. Hourly CEMS SO 2 emis sions data were

used for the Ameren Sioux Power Plant. In instances where s easonal throughput was available, emissions were allocated appropria tely via the EMISFACT keyword in AERMOD and applied to the

three

- year period. For sources lacking hourly varying temp erature or exit velocity, replacement

values were obtained either from the Illinois EPA database or from company

- provided emission
report s

. Please reference Appendix A for the full emissions inventory and stack parameters, including the s ubstitution methods implemented for addressing missing or erroneous data fields

within the CEMS data . For the Wood River Study Are a , a total of 82 point s ource stacks were modeled. AERMOD’s HOUREMIS keyword was applied to 75 of the p oint sources , while the remaining seven point sources received either worst

- case emissions uniformly applied for the entire simulation period , or utilized EMISFACT to make seas onal adjustments to em i ssions

. The electronic hourly emissions file is included in this submittal via the DVD located in Appendix C.

3. 5 .2.4 Meteorology

The SO 2 TAD recommends using the three most recent years of meteorology for use in the SO 2 Phase II Designation modeling.

The selection of a representative meteorological station for each of the study areas was based on proximity, similarity of terrain/surface roughness, and climatological consistency. For the Wood

River Study Area, the Natio nal Climatic Data Center National Weather Service (NWS) surface meteorology from St. Louis

, Missouri (WBAN No. 13994

, 27 km to the south west )

, and coincident upper air observations from Lincoln

, Illinois (WBAN No. 4833

, 158 km to the northeast )

, were selected as best representative of meteorological conditions within the study area ( STL / ILX ).

The three

- year surface wind rose for St. Louis, Missouri

, is depicted in Figure 2 5 . The frequency and magnitude of wind speed and direction are de fined in te rms of where the wind is blowing from, parsed out in twelve 30

- degree wind sectors. The most predominant wind direction during the three

year time period used in the modeling is from the southeast to southwest, occurring approximately

9.6 % of the time. The highest percentage wind speed range, occurring 3 3

. 8 % of the time, was in the

3

. 6

– 5

. 7 m/s range.53 Figure 2 5 St. Louis, Missouri , Cumulative Annual Wind Rose

2012

- 2014

Meteorological data from the above surface and upper air stations were used in generating

AERMOD

- ready files with the AERMET processor, a part of the AERMOD software suite. The output meteorological data created by the AERMET processor is considered suitable for being applied in AERMOD for regulatory modeling applications

. The methodology and settings performed54

in the processing of the raw meteorological data into AERMOD

- ready format followed the same procedure as in the Newton Study Area. Please refer to Section 3.1.2.4 for more details on the development procedure utilized for the meteorological inputs. The Wood River Study Area

AERMOD

- ready “.sfc” and “.pfl” meteorological e lectronic files are included in this submittal via DVD located in Appendix C.

3. 5 .2.5 Receptor Network/Terrain

The receptor grid for the Wood River Study Area was designed to be of sufficient density and size to capture all relevant concentration grad ients from modeled sources and to adequately resolve the maximum predicted SO 2 design value concentration. The receptor grid’s dense 100

- meter spacing was created in two distinct sections, one that surrounds the grouping of sources around the Wood

River Po wer Station, and another that captures the impacts around the WRB Refining facility . In general, the fine 100

- meter Cartesian grid was extended outward from each fenceline in the vicinity of the Power Station sources by a t least two kilometers distance fr om each facility (extent may vary slightly by direction) and by at least one kilometer from the smaller facilities south of WRB Refining

. The entire study area receptor spacing was approximately:

 50 meter s along the fenceline ( six facilities)

 100 meter s from the fenceline out to 1 .0 to 2. 0 k ilometers

 500 meter s from 1.0 to 2.0 kilometers out to 9 .0 k ilometers

The Wood River Study Area receptor grid is presented in Figure 2 6 . The receptor count totaled 11,746 receptors, covering extreme west

- central Madison County in Illinois, and eastern edges of St.

Louis and St. Charles Counties in Missouri . The terrain in the study area is best characterized as flat to gently rolling and is bisected northeast to southeast western extent by the Mississippi River. To account for terrain changes, the AERMAP terrain program was used to develop terrain and hill scale height for all the receptors. The source of the elevation data incorporated into the model is from the USGS National Elevation Database (NED).55 Figure 2 6 Receptor Grid

– Wood River Study Area

3. 5 .2.6 Background SO 2

The regional sources not explicitly modeled in AERMOD, but best characterized as background

contributors to SO 2 near or in the study area, are addressed via background monitoring data. U.S.

EPA recommends inclusion into the model data from the nearest representative background SO 2 monitor operated by state, local, or tribal organizations. The East St. Louis

, Illino is monitor was

selected for the Wood River S tudy area. The East St. Louis monitor is located approximately 28 kilometers south of the study area in northwestern St. Clair County and is ideally suited to characterize contributions from background sources in semi

- urbanized environment of the St. Louis

MSA area . The monitor, operated and maintained by Illinois EPA , has validated hourly SO 2 concentrations for the three years modeled in this analysis (2012

- 2014).

For this modeling application, Illinois EPA emp loyed temporally

- varying background 1

- hour concentrations developed from the East St. Louis

, Illinois

, monitor. The values developed for inputs56

into AERMOD for background are based on the 99 th percentile monitored concentrations vary by season and hour in the same manner as in the previously discussed study areas. For modeled design value impacts for comparison to the standard reported here, the maximum impacts include the

contribution of bac kground. A table of the background SO 2 seasonally and hourly varying values

utilized in the Wood River Study Area modeling is provided in Appendix B.

3. 5 .3 Summary of Results

The AER M OD simulation for the Wood River Study Area comprised 82 stacks, 527 structures, 10

fenceline s, and 11,746 receptors. The model simulated 2012

- 2014, combining emissions, meteorology, terrain, and background SO 2 levels into the model to calculate a maximum 99 th
percentile 1

- hour SO 2 concentration for each receptor in the g rid. The results presented in Table 14 report the magnitude and geographic location of the highest predicted concentration.

Table 1 7
Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentration

Wood River Study Area

Averaging Period Data Period Receptor Location

(Meters) SO 2 Concentration ( μg/m 3 )
East North Modeled NAAQS
99 th Percentile 1

- Hour Average 2012

- 2014 748051 4307978 456.50 196 .23*

* Equivalent to the 75 ppb standard

The maximum predicted 99 th percentile 1

- hour average concentration within the modeling domain is

460.50 μg/m 3 , or 174.2 ppb. The maximum occurred within the dense 100

- meter grid approximately

2. 5 kilometers northwest of the Wood River Power Station main stacks . The maximum occurred on

the north fenceline of Alton Steel, Inc. The colored contour map of maximum 99 th percentile concentrations presented in Figure 2 7 depicts maximum predicted concentration for each receptor in the study area and indicates the locat ion of the predicted maximum.57 Figure 2 7
Maximum Predicted 99 th Percentile 1

- Hour SO 2 Concentrations

- Wood River Study Area

3.5 .4 Designation Recommendation

The modeling results indicate there are 14 receptors along and near (with in 100 meters) of the north

fenceline of the Alton Steel facility predicted to exceed the 99 th percentile 1

- hour SO 2 standard.

C ulpability modeling analyses indicate that four SO 2 stacks at Alton Steel related to their LMF

process are causing these violati ons. These four stacks point down toward the ground at a 45 degree angle from the south side of the LMF baghouse structure and are heavily influenced by downwash

from the Ele ctric Furnace Shop building . Due to the “hotspot” nature of the modeled violations and their close proximity to the Alton Steel facility, Illinois EPA recommends that a portion of Madison County be designated as nonattainment for the 2010 1

- hour SO 2 NAAQS

– s pecifically, that portion of southern Alton Township that is east of the Corporal Belchik Memorial Expressway, south of East Broadway Street and Illinois Route 3, and north of Illinois Route 143 , as shown in Figure 28

.58

Per U.S. EPA’s guidance, this area contains both the violating receptors and the emission sources

causin g or contributing to nonattainment. Illinois EPA also recommends that all of Wood River Township and that portion of Chouteau Township north of the Cahokia Diversion Channel be designated as attainment . Lastly, the Illinois EPA recommends that the remain der of Madison County be designated as unclassifiable due to the presence of additional large SO 2 emitting facilities in other parts of the county that will likely need to be addressed later by the Illinois EPA in

accordance with the Data Requirements Rule (DRR).

Figure 28 Proposed Nonattainment Area Boundary for the Wood River Study Area59



### 4 .0 Summary

The Illinois EPA has conducted a five factor analysis that relies heavily upon the results of dispersion modeling to support recommendations for 1

- hour SO 2 NAAQS area designations under the March, 2015, consent decree between U

. S

. EPA, Sierra Club, and the Natural Resources Defense Council. That analysis specifically addressed five power plants in Illinois: Newton Power Station (Jasper County), Hennepin Power Station (Putnam County), Joppa Steam Coal Power Plant (Massac County), Ma rion Power Station (Williamson County) and Wood River Power Station (Madison County).

With the exception of Madison County, the Illinois EPA is recommending attainment for the presumptive area boundary (countywide) in which the power plant is located. In the case of the Hennepin Power Station, the Illinois EPA is also recommending attainment status for all of Bureau County, which is located across the Illinois River from the power plant. Modeled concentrations in Bureau County were well below the NAAQS, an d the aggregate contribution of all SO 2 - emitting sources in Bureau County is less than five tons per year (actual emissions, based upon Illinois EPA’s ICEMAN 2011 database).

Modeling conducted for the Wood River Power Station (Madison County) has yielded sub

- county area recommendations for attainment, nonattainment

, and unclassifiable. There is a small area in Alton Township (south of East Broadway and adjacent to the Alton Steel, Inc. facility) where modeled impacts exceed the NAAQS. This area is recomme nded for nonattainment ; however, the Agency fully expects that corrective measures will be taken that will enable a modeling demonstration of compliance with the NAAQS by January 15, 2016. Wood River Township contains the Wood River Power Station, and this area along with that portion of Chouteau Township north of the Cahokia Diversion Channel is recommended for attainment. All other portions of Madison County are recommended as unclassifiable.60



### 5 .0 References

Auer, Jr., A.H. (1978). Correlation of Land Use and Cover with Meteorological Anomalies . Journal of Applied Meteorology, 17(5) , 636

- 643.

U.S. EPA (December 2013). SO 2 NAAQS Designations Modeling Technical Assistance Document http://www3.epa.gov/airquality/sulfurdioxide/pdfs/SO2ModelingTAD.pdf

U.S. EPA (August 2015). AERMOD Implementation Guide http://www3.epa.gov/ttn/scram/7thconf/aermod/aermod_implmtn_guide_3August2015.pdf

U.S. EPA (November 2004). User’s Guide for the AERMOD Meteorological Preprocessor

U.S. EPA (March 2015). Updated Guidance for Area Designations for the 2010 Primary Sulfu r Dioxide National Ambient Air Quality Standard. From: Stephen D. Page T o : Regional Air Division Directors, Regions 1

– 10

.
U.S. EPA Region 5 and States ( August 2014). Regional Meteorological Data Processing Protocol

United States District Court for the N orthern District of California San Francisco Division (March 2, 2015). Final Court Order “Consent Decree” http://www3.epa.gov/airquality/sulfurdioxide /designations/pdfs/201503FinalCourtOrder.pdf

U.S. EPA (August 2015) Data Requirements Rule for the 2010 1

- Hour Sulfur Dioxide Primary National Ambient Air Quality Standard61



### 6 .0 Appendices



## Appendix A

Emission Inventories for the Study Area s62 

### Newton Study Area Emission Inventory

AERMOD Source

Description Receptor Location

(Meters) Stack

Height Temperature/Exit

Velocity Stack

Diameter Emissions

Profile

Source ID East North (m) (K/m/s) (m)

0003 Unit 1 Stack

(Newton PS) 389291.7 4310518.4 161.54 See Hourly File 5.49 A

0012 Unit 2 Stack

(Newton PS) 389333.4 4310458.9 161.54 See Hourly File 7.32 A

A: CEMS Data, hourly varying emissions, temperature, exit velocity

In hours with mass emissions, but no temperature/flow rates, the following constants were used (based on Annual Emission Report data/ Illinois EPA ICEMAN database):

0003 : Exit temperature = 325.93 deg. K, Exit velocity = 24.87 m/s

0012 : Exit temperature = 431.48 deg. K, Exit velocity = 23.08 m/s63 

### Hennepin Study Area Emission Inventory

AERMOD Source Description Receptor Location (Meters) Stack

Height Temperature/Exit

Velocity Stack

Diameter Emissions

Profile

Source ID East North (m) (K/m/s) (m) (g/s)

0001 Units #1 & 2

(Hennepin PS) 306166.52 4575006.81 84.43 See Hourly File 4.40 A

0001AA Drum Mix Asphalt

Plant (A dvanced Asphalt ) 307876.16 4574736.14 10.67 See Hourly File 1.37 B

0002AA Asphalt Tank

Heaters/Boilers (Advanced Asphalt) 307859.69 4574716.20 4.57 See Hourly File 1.13 B

0004HE RTO Stack

(Marquis Energy) 305795.48 4572111.48 39.62 See Hourly File 1.68 B

0010WM Silicone Carbide

Baghouse Furnace (Wash Mills) 307362.24 4574653.98 32.92 See Hourly File 2.44 C

0014WM Sulfurox Boiler Stack

(Wash Mills) 307450.02 4574642.25 5.18 See Hourly File 0.305 D

0018WM Product Dryer

Combustion (Wash Mills) 307305.83 4574293.85 8.23 See Hourly File 0.85 D

0001HE Boiler East Stack

(Marquis Energy) 305737.18 4572069.79 24.38 449.82/13.71 1.52 E

0016HE Boiler West Stack

(Marquis Energy) 305727.08 4572070.01 24.38 449.82/13.71 1.52 E

0011HE Loadout Flare

(Marquis Energy) 305698.09 4572090.90 9.14 668.71/20.53 0.43 E

0017HE Boiler No. 3 Stack

(Marquis Energy) 305729.23 4572094.94 24.38 470.37/19.14 1.52 E

0005 Heating Boiler Stack

(Hennepin PS) 306155.92 4574977.64 47.24 644.26/15.69 0.61 5.29E

- 04

A: CEMS Data, hourly varying emissions, temperature, exit velocity

B: Hourly Profile of Emissions based on seasonal operation/throughput from Annual Emissions Reports
C: Hourly emissions profile based on data provided by company

D: Hourly emissions profile based on yearly/monthly operation and throughput, provided by company

E: Use EMISFACT, seasonal emissions averaged over 2012

- 2014, multiply by scalar per season

* In hours with mass emissions, but no temperature/flow rates, the following constants were used (based on Annual Emission Report data/ Illinois EPA ICEMAN database): 0001: Exit temperature = 325.93 deg. K, Exit velocity = 24.87 m/s

000 1 AA: Exit temperature = 427.64 deg. K, Exit velocity = 2 0

. 32 m/s

0002AA : Exit temperature = 455.97 deg. K, Exit velocity = 8

. 195 m/s

000 4HE : Exit temperature = 4 66.48 deg. K, Exit velocity = 18.60 m/s

00 10WM : Exit temperature = 754.32 deg. K, Exit velocity = 16.71 m/s

00 14WM : Exit temperature = 355.37 deg. K, Exit velocity = 40.45 m/s

00 18WM : Exit temperature = 355.37 deg. K, Exit velocity = 11.87 m/s64 

### Marion Study Area Emission Inventory

AERMOD Source Description Receptor Location (Meters) Stack

Height Temperature/Exit

Velocity Stack

Diameter Emissions

Profile

Source ID East North (m) (K/m/s) (m) (g/s)

0003 Unit No. 4

(Marion P S ) 327601.09 4165324.96 121.92 324.82/15.17 4.40 A 90.72

0011 Turbine No. 5

(Marion PS ) 326901.44 4165425.60 17.07 590.37/22.85 1.37 A 7.430976

0012 Turbine No. 6

(Marion P S ) 326839.03 4165425.94 17.07 590.37/22.85 1.13 A 7.430976

0013 CFB Boiler Unit

(Marion P S) 327700.40 4165369.62 59.13 392.04/12.22 1.68 A 52.983

00 08USP Boiler No. 1

(U.S. Penitentiary) 324736.94 4170242.33 14.33 460.93/6.83 2.44 B 0.00128

00 09USP Boiler No. 2

(U.S. Penitentiary) 324734.73 4170239.55 13.41 460.93/33.80 0.305 B 0.00128

00 10USP Boiler No. 3

(U.S. Penitentiary) 324733.35 4170242.39 14.33 460.93/6.83 0.85 B 0.00128

00 11USP Boiler No. 3

(U.S. Penitentiary) 324725.90 4170243.57 14.33 460.93/21.45 1.52 B 0.00128

A: Maximum actuals

B: Hourly emissions profile based on reported a ctuals per Annual Emissions Reports, modeling assumed 365

- 52

- 24

- 7 operation65 

### Joppa Study Area Emission Inventory

AERMOD Source

Description Receptor Location (Meters) Stack

Height Temperature/Exit

Velocity Stack

Diameter Emissions

Profile

Source ID East North (m) (K/m/s) (m) (g/s)

0001 Boiler Units No. 1

& 2 ( Joppa PS) 335066.99 4119612.77 152.4 See Hourly File 5.49 A

0001MP Turbine CT

- 01

( MEPI ) 334437.92 4120723.30 17.07 See Hourly File 4.51 B

0002 Boiler Units No. 3

& 4 (Joppa PS) 335109.60 4119719.05 152.4 See Hourly File 5.49 A

0002MP Turbine CT

- 02

( MEPI ) 334424.15 4120699.46 16.26 See Hourly File 4.51 B

0003 Boiler Units No. 3

& 4 (Joppa PS) 335153.93 4119837.40 152.40 See Hourly File 5.49 A

0004MP Turbine CT

- 04

( MEPI ) 334374.85 4120613.27 14.02 See Hourly File 3.35 B

0005MP Turbine CT

- 05

( MEPI ) 334401.35 4120598.14 14.02 See Hourly File 3.35 B

0052LF Kiln No. 2

( La f arge ) 332959.00 4120523.60 76.20 See Hourly File 2.59 B

0062HW Waste Gas

Incinerator ( Honeywell ) 344072.90 4115307.26 47.24 See Hourly File 2.13 C

0066LF Kiln No. 1

( Lafarge ) 332967.00 4120560.10 45.72 See Hourly File 3.66 B

TVA_EAST Boiler 1

- 5 Stack

( TVA

- Shawnee ) 342378.96 4113169.92 242.93 See Hourly File 8.50 D

TVA_WEST Boiler 6

- 50 Stack

( TVA

- Shawnee ) 342059.04 4113372.78 242.93 See Hourly File 8.50 D

0001TG Engine 5801

(Trunkline Gas) 334536.69 4121295.99 12.80 677.59/25.87 0.61 E

0002TG Engine 5802

(Trunkline Gas) 334545.24 4121295.73 12.80 677.59/25.87 0.61 E

0003TG Engine 5803

(Trunkline Gas) 334554.06 4121295.41 12.80 677.59/25.87 0.61 E

0005TG Engine 5805

(Trunkline Gas) 334571.88 4121294.89 13.41 660.93/19.60 0.76 E

0006TG Engine 5806

(Trunkline Gas) 334580.63 41211294.64 13.41 660.93/19.60 0.76 E

0007TG Engine 5807

(Trunkline Gas) 334560.99 4121462.88 14.94 677.59/13.98 1.98 E

A: CEMS Data, hourly varying emissions, temperature, exit velocity

B : Hourly varying emissions, temperature, exit velocity profile based on data provided by company
C : Hourly Profile of Emissions based on seasonal operation/throughput from Annual Emissions Reports (AER’s)

D: CEMS Data, hourly varying emissions obtained fro m U.S. EPA Air Market Program Data (CAMD)/SO 2 NAAQS Modeling Data made available from U. S. EPA specifically for modeling

E: Use EMISFACT, seasonal emissions averaged over 2012

- 2014, multiply by scalar per season

* In hours with mass emissions, but no temperature/flow rates, the following constants were used (based on Annual Emission Report data/I llinois EPA D atabase):66

0052LF and 0066LF: Exit temperature = 325.93 deg. K, Exit velocity = 24.87 m/s

- modulated hourly exit velocity for each year’s a verage around the constant based on flow rate changes per CAMD. TVA_WEST: Exit temperature = 422.09 deg. K, Exit velocity = 29.814 m/s (from KDAQ)

– modulated hourly exit velocity for each year’s average around the constant based on flow rate changes per CAMD. TVA_EAST: Exit temperature = 429.87 deg. K, Exit velocity = 29.639 m/s (from KDAQ)

– modulated hourly exit velocity for each year’s average around the constant based on flow rate changes per CAMD.67 

### Wood River Study Area Emission Inventory

AERMOD Source Description Receptor Location (Meters) Stack

Height Temperature/

Exit Velocity Stack

Diameter Emissions

Profile

Source ID East North (m) (K/m/s) (m) (g/s)

0001 Unit 5 Stack (WR

PS) 748683.76 4305506.89 106.68 See Hourly File 4.57 A

0001PS Boiler 1 Stack

(Ameren Sioux PS) 735067.23 4310829.84 151.33 See Hourly File * 7.19 B

0002PS Boiler 2 Stack

(Ameren Sioux PS) 735065.64 4310820.32 151.33 See Hourly File * 7.19 B

0003 Unit 4 Stack

(WR PS) 748666.89 4305531.27 76.20 See Hourly File 5.18 A

0004WRB CR

- 1 ULD HCU

STK12

- 4 (WRB) 754868.40 4302624.00 106.68 See Hourly File 4.57 C

0018WRB DU

- 1 Prim Htr South

STK5

- 2 (WRB) 454326.10 4303076.20 45.72 See Hourly File 2.59 C

0019WRB DU

- 1 Secondary Htr

STK5

- 1 (WRB) 754325.60 4303099.10 56.39 See Hourly File 2.44 C

0020WRB SMR Htr STK12

- 8

(WRB) 754872.30 4302749.40 60.96 See Hourly File 3.66 C

0024WRB RAU Debutanizer

Htr STK5

- 5 (WRB) 754469.50 4302942.70 22.86 See Hourly File 1.52 C

0027AS1 EAF Baghouse Vent

1 (Alton Steel) 747898.46 4307951.71 30.48 See Hourly File 7.38 D

0027AS2 EAF Baghouse Vent

2 (Alton Steel) 747956.48 4607951.71 30.48 See Hourly File 7.38 D

0027WRB CAU RO Still Heater

STK5

- 4 (WRB) 754467.40 4302962.50 25.91 See Hourly File 2.20 C

0043WRB Catalytic Cracking

Unit 2 (WRB) 454847.70 4302894.50 53.34 See Hourly File 3.35 C

0050WRB HCF Furnace

STK12

- 3 (WRB) 754723.80 4302515.50 54.56 See Hourly File 1.92 C

0052AS1 LMF Baghouse Vent

1 (Alton Steel) 747874.75 4307823.77 15.24 See Hourly File 1.06 D

0052AS2 LMF Baghouse Vent

2 (Alton Steel) 747878.53 4307823.77 15.24 See Hourly File 1.06 D

0052AS3 LMF Baghouse Vent

3 (Alton Steel) 747883.19 4307823.77 15.24 See Hourly File 1.06 D

0052AS4 LMF Baghouse Vent

4 (Alton Steel) 747886.84 4307823.77 15.24 See Hourly File 1.06 D

0056WRB HCNHT Furnace

STK12

- 1 (WRB) 754574.80 4302695.20 32.61 See Hourly File 1.22 C

0060WRB Alky HM

- 1 Heater

STK6

- 5 (WRB) 755121.20 4302814.40 28.96 See Hourly File 2.29 C

0061WRB Alky HM

- 2 Heater

STK6

- 6 (WRB) 754829.00 4303042.40 46.02 See Hourly File 1.75 C

0068WRB Boiler 15 STK12

- 15

(WRB) 754858.70 4302776.00 40.23 See Hourly File 2.13 C

0069WRB Blr16 STK12

- 16 754874.40 4302776.80 40.23 See Hourly File 2.13 C

0070WRB Boiler 17 STK12

- 17 754901.20 4302783.60 45.72 See Hourly File 3.05 C68 (WRB)

0071WRB Boiler 18 STK6

- 9

(WRB) 754919.20 4302807.80 30.48 See Hourly File 1.89 C

0073WRB HDU

- 1 Charge

Heater STK13

- 1 (WRB) 755216.70 4302586.90 45.72 See Hourly File 1.52 C

0076WRB HDU

- 2 Charge

Heater STK12

- 14 (WRB) 755021.10 4302529.40 45.72 See Hourly File 1.77 C

0077WRB CR

- 3 Stabilizer Re

-

boiler H

- 2 STK12

- 9 (WRB) 755013.20 4302579.70 45.72 See Hourly File 2.38 C

0078WRB CR

- 3 Regen Heater

H

- 3 STK12

- 10 (WRB) 755014.40 4302581.60 45.72 See Hourly File 2.38 C

0079WRB CR

- 3 Charge Heater

H

- 4 STK12

- 11 (WRB) 755018.30 4302570.40 45.72 See Hourly File 2.38 C

0080WRB CR

- 3 First

Interreactor Heater
H

- 5 STK12

- 13 (WRB) 755018.70 4302546.80 45.72 See Hourly File 2.38 C

0081WRB CR

- 3 Second

lnterreactor Heater
H

- 6 STK12

- 12 (WRB) 755018.60 4302558.00 45.72 See Hourly File 2.38 C

0083WRB DHT Charge Heater

STK12

- 5 (WRB) 755017.50 4302643.50 45.72 See Hourly File 1.62 C

0120WRB F

- 200 F

- 202 F

- 203 F

-

204 F

- 205 STK5

- 3 (WRB) 754414.80 4303015.80 95.10 See Hourly File 4.27 C

0124WRB VF

- 1 North/South

Heater STK6

- 1 (WRB) 754718.50 4303087.60 56.39 See Hourly File 2.07 C

0128WRB SRU North Oxidizer

STK3

- 1 (WRB) 752927.80 47303076.40 38.10 See Hourly File 2.20 C

0144WRB SRU South Oxidizer

STK3

- 2 (WRB) 752928.10 4303070.40 38.10 See Hourly File 2.20 C

0621WRB Distilling Flare

FLR1

- 1 (WRB) 754277.40 4303296.20 55.21 See Hourly File 0.65 C

0623WRB Arom North Flare

Aromatic FLR13

- 1 (WRB) 755265.80 4302634.50 61.93 See Hourly File 0.32 C

0624WRB Arom South Flare

FLR13

- 2 (WRB) 755267.00 4302549.20 63.63 See Hourly File 0.78 C

0625WRB North Property Flare

FLR1

- 2 (WRB) 754485.40 4303321.20 65.48 See Hourly File 1.64 C

0628WRB Boiler 4 STK9

- 1

(WRB) 752782.10 4302397.30 22.86 See Hourly File 1.22 C

0629WRB Boiler 5 STK9

- 3

(WRB) 752762.93 4302362.97 22.86 See Hourly File 2.13 C

0633WRB DCU Charge Heater

H

- 20 STK10

- 2 (WRB) 753183.30 4302406.70 54.86 See Hourly File 1.52 C69

AERMOD Source Description Receptor Location (Meters) Stack

Height Temperature/

Exit Velocity Stack

Diameter Emissions

Profile

Source ID East North (m) (K/m/s) (m) (g/s)

0643WRB Catalytic Cracking

Unit No. 1 STK6

- 2B (WRB) 754863.70 4302894.50 53.34 See Hourly File 3.35 C

0685WRB Alky Flare FLR6

- 1

(WRB) 755034.60 4303080.00 66.77 See Hourly File 1.62 C

0702WRB VF

- 4 Charge Heater

H

- 28 STK9

- 6 (WRB) 753053.00 4302387.20 54.86 See Hourly File 1.37 C

0703WRB DCU Preheater H

- 36

STK10

- 3 (WRB) 753193.20 4302396.10 54.86 See Hourly File 1.83 C

0704WRB DU

- 4 Charge Heater

H

- 24 STK9

- 5 (WRB) 753050.90 4302412.20 54.86 See Hourly File 2.59 C

0705WRB Heat Medium Furnace

H

- 35 STK9

- 4 (WRB) 752802.50 4302398.30 45.72 See Hourly File 1.83 C

0706WRB HP

- 1 Flare FLR12

- 2

(WRB) 755193.80 4302792.10 43.09 See Hourly File 0.94 C

0709WRB HP

- 1 Heater STK12

- 6

(WRB) 755193.00 4302792.10 38.71 See Hourly File 2.29 C

0711WRB ULD H

- 4 Re

- boiler

STK12

- 2 (WRB) 755038.00 4302710.50 39.78 See Hourly File 1.80 C

0712WRB SZorb Heater STK13

-

3 (WRB) 755218.20 4302666.40 45.72 See Hourly File 2.90 C

0715WRB Distilling West Flare

FLR10

- 1 (WRB) 753646.00 4302545.40 61.55 See Hourly File 0.38 C

0716WRB SZU Stack (0716)

(WRB) 755240.90 4302682.20 13.49 See Hourly File 0.61 C

0717WRB Benzene Extraction

Unit Heater H

- 3
STK6

- 4 (WRB) 754922.50 4302928.90 56.39 See Hourly File 2.96 C

0718WRB Lubes Flare FLR12

- 1

(WRB) 754609.60 4302495.50 48.79 See Hourly File 0.40 C

0724WRB VOC Flare (West)

FLR4

- 1 (WRB) 753427.00 4303072.60 10.82 See Hourly File 0.43 C

0725WRB VOC Flare (East)

FLR4

- 2 (WRB) 753440.50 4303073.00 10.82 See Hourly File 0.43 C

0726WRB Coker North Flare

FLR1

- 3 (WRB) 754946.10 4303683.30 60.96 See Hourly File 0.39 C

0727WRB VF

- 5 Heater/H350H4

STK1

- 1 (WRB Refining) 754936.80 4303458.30 60.96 See Hourly File 3.05 C

0728WRB Coker North

Heater/H351H2
STK1

- 2 (WRB) 754952.70 4303304.10 64.01 See Hourly File 3.05 C

0729WRB Coker North

Heater/H351H1
STK1

- 3 (WRB) 754985.20 4303304.90 64.01 See Hourly File 3.05 C

0730WRB DCNH

Heater/H353H3
STK1

- 4 (WRB) 754903.70 4303543.30 24.38 See Hourly File 0.64 C

0731WRB SRUF Oxd i zr STK3

- 3 752913.10 4303020.00 60.66 See Hourly File 1.22 C70

0732WRB SRU

- E Oxidizer

STK3

- 4 (WRB) 753001.50 4303022.90 60.66 See Hourly File 1.22 C

0735WRB HP

- 2 Flare FLR7

- 1

(WRB) 755262.00 4302919.70 43.09 See Hourly File 0.94 C

0736WRB HP

- 2 Heater STK7

- 1

(WRB) 755262.90 4302919.70 39.62 See Hourly File 3.84 C

0739WRB NHT Charge Heater

H

- 21 STK10

- 1 (WRB) 753160.30 4302411.90 30.48 See Hourly File 1.37 C

0900WRB CR

- 1 Regen Vent

STK12

- 18 (WRB) 754883.68 4302607.56 17.68 See Hourly File 0.15 C

0901WRB CR

- 3 Regen Vent

STK 12

- 19 (WRB) 755029.45 4302593.48 9.14 See Hourly File 0.09 C

0902WRB Misc Unit (WRB) 754669.60 4303047.00 19.81 See Hourly File 1.22 C

0903WRB STK6_2 754647.80 4303005.50 19.81 See Hourly File 1.13 C

FLR_MVC Barge Loading Flare

(WRB Refining) 751375.17 4302867.10 12.19 See Hourly File 1.22 C

0031AS 14 inch rolling mill

reheat furnace (Alton Steel) 747645.22 4307691.38 32.31 366.48/0.73 4.88 E 0.0076

0099AS Caster (Alton Steel) 747849.10 4307673.65 19.81 294.26/0.001 9.00 E 8.0E

- 04

0001CB Drum Mix Asphalt

Stack ( CBP ) 755684.51 4299821.86 9.75 394.82/16.34 1.25 F

0003CB Asphalt Tank Heaters

and Boilers (CBP) 755700.20 4299839.80 9.45 486.48/11.05 1.04 F

0002NM Cleaver Brooks boiler

Stack 1 of 2 (NM) 750915.14 4300903.33 10.36 505.37/7.12 0.61 F

0004NM Cleaver Brooks boiler

Stack 2 of 2 (NM) 750918.74 4300902.96 10.36 505.37/7.12 0.61 F

A: CEMS Data, hourly varying emissions, temperature, exit velocity provided by company.

B: CEMS Data for emissions, constant temperature, varying exit velocity based on Emissions modeling Clearinghouse

State

- Level Hourly Sulfur Dioxide Data

- flow modulation around a constant

. http://ww w.epa.gov/ttn/chief/emch/index.html
C : Hourly varying emissions, temperature, exit velocity based on data provided by company

D : Uniformly distributed h ourly emissions based on company provided daily operating schedule per year, used constant

for temperatu re / exit velocity profile based on I llinois EPA Database/AER data provided by company

E : Distribute worst

- case actual Annual Emissions year, to all 3years, applied uniformly for each hour

F : Use worst

- case Annual Emissions year 2012

- 2014 for all 3 years, a pply EMISFACT seasonally , and multiply by scalar

per season

.

* In hours with mass emissions, but no temperature/flow rates, the following constants were used (based on Annual Emission Report data/I llinois EPA ICEMAN database): 0001: Exit temperature = 416.48 deg. K, Exit velocity = 19.798 m/s 0003: Exit temperature = 394.26 deg. K, Exit velocity = 8.511 m/s 0001PS: Exit temperature = 330.37 deg. K, Exit velocity = 16.62 m/s

– modulated hourly exit velocity for each year’s average around the cons tant based on flow rate changes per U.S EPA SO 2 NAAQS CAMD derived inventory. 0003PS: Exit temperature = 330.37 deg. K, Exit velocity = 16.62 m/s

– modulated hourly exit velocity for each year’s average around the constant based on flow rate changes per U.S EPA SO 2 NAAQS CAMD derived inventory.71 

## Appendix B Background SO 2 

## Data for Modeling72 

### N ilwood * , Illinois Monitor
Season * and Hourly Varying Background SO 2



### Newton Study Area

Hour of Day SO 2 Concentration (μg/m3)

Winter Spring Summer Fall
1 7.77 4.01 3.84 4.62

2 7.50 4.19 5.32 4.80

3 8.55 4.25 3.93 5.67

4 7.68 5.06 5.58 4.80

5 7.59 4.10 4.80 5.67

6 7.50 4.45 6.02 5.50

7 7.24 4.89 7.33 5.58

8 7.15 8.11 8.64 5.76

9 8.81 10.91 10.03 8.73

10 12.13 11.60 12.04 9.51

11 15.36 13.44 11.43 13.79

12 13.00 12.30 10.91 15.53

13 13.96 10.47 8.29 15.01

14 13.61 8.73 8.64 12.56

15 11.95 7.59 8.38 10.38

16 11.60 9.07 6.19 9.95

17 11.52 7.42 7.68 9.07

18 10.30 6.46 6.72 8.38

19 7.50 6.46 4.89 6.63

20 9.86 3.84 4.89 5.41

21 9.07 4.62 5.06 5.50

22 6.63 4.10 4.01 5.76

23 7.24 3.58 3.32 5.41

24 7.59 3.66 4.97 5.15

* Monitor Latitude/Longitude Coordinates: (+ 39.396075

– 89.80974 )

* * Seasons defined as: Winter ( Dec, Jan, Feb ), Spring (Mar, Apr, May), Summer (Jun, Jul, Aug), Fall (Sep, Oct, Nov)73 

### Oglesby * 

### , Illinois Monitor
Season ** 

### and Hourly Varying Background SO 2



### Hennepin Study Area

Hour of Day SO 2 Concentration (μg/m3)

Winter Spring Summer Fall
1 5.85 7.07 4.54 4.62

2 6.11 7.33 5.06 4.62

3 4.45 6.02 3.49 3.66

4 5.15 6.19 2.70 4.36

5 6.19 4.97 2.09 6.46

6 6.28 6.89 2.44 6.89

7 5.58 6.54 4.80 5.06

8 6.63 9.42 7.59 4.36

9 8.55 11.17 9.34 5.58

10 10.64 11.60 9.16 6.98

11 10.47 12.39 10.64 10.56

12 12.83 12.30 8.20 9.25

13 14.31 9.16 7.59 9.16

14 14.92 9.51 6.72 9.42

15 11.52 8.90 7.33 7.85

16 10.38 6.54 6.72 8.03

17 11.08 7.15 7.68 7.94

18 8.81 7.24 6.89 7.07

19 8.64 8.64 7.15 5.67

20 6.98 8.20 4.80 7.33

21 7.94 9.16 4.80 5.50

22 6.37 9.34 5.67 5.58

23 6.02 7.94 4.71 4.54

24 5.76 6.72 4.62 4.80

* Monitor Latitude/Longitude Coordinates: (+41.29301

- 89.04942)

* * Seasons defined as: Winter ( Dec, Jan, Feb ), Spring (Mar, Apr, May), Summer (Jun, Jul, Aug), Fall (Sep, Oct, Nov)74 

### Houston *



### , Illinois Monitor
Season ** 

### and Hourly Varying Background SO 2



### Marion Study Area

Hour of Day SO 2 Concentration (μg/m3)

Winter Spring Summer Fall
1 5.76 6.46 4.71 5.41

2 6.46 7.42 5.76 6.37

3 7.50 7.38 4.71 6.63

4 10.12 7.33 4.45 5.93

5 9.86 6.98 4.62 6.81

6 12.65 8.03 4.80 7.77

7 10.73 8.73 7.24 7.68

8 13.00 11.26 9.51 10 .82

9 13.96 14.13 17.01 10.03

10 14.48 19.81 20.94 19.54

11 19.28 18.41 27.05 17.28

12 19.37 22.51 32.81 21.03

13 18.58 15.44 26.87 19.72

14 24.61 13.61 16.49 20.94

15 26.87 11.43 17.01 13.18

16 18.06 15.79 16.23 16.23

17 16.14 15.36 14.83 12.91

18 15.09 12.83 8.99 10.30

19 12.48 8.46 8.38 9.34

20 10.38 9.07 5.41 8.81

21 7.68 6.63 3.75 9.07

22 9.69 6.19 5.32 8.38

23 11.17 7.24 3.58 5.06

24 7.50 7.24 3.93 4.89

* Monitor Latitude/Longitude Coordinates: ( +38.1762 8

- 89.7884 6 )

* * Seasons defined as: Winter ( Dec, Jan, Feb ), Spring (Mar, Apr, May), Summer (Jun, Jul, Aug), Fall (Sep, Oct, Nov)75 

### Paducah *



### , Kentucky Monitor
Season ** 

### and Hourly Varying Background SO 2



### Joppa Study Area

Hour of Day SO 2 Concentration (μg/m3)

Winter Spring Summer Fall
1 11.34 7.85 6.11 5.24

2 13.09 10.47 3.49 4.36

3 12.22 5.24 3.49 6.11

4 15.71 7.85 2.62 4.36

5 13.08 7.85 3.49 5.24

6 10.47 5.24 5.24 5.24

7 8.73 5.24 6.98 6.98

8 10.47 9.60 10.47 11.34

9 11.34 10.47 17.45 12.22

10 17.45 13.09 16.58 17.45

11 18.32 31.41 14.83 25.30

12 19.20 24.43 28.79 21.81

13 27.05 27.92 29.67 28.79

14 32.28 17.45 21.81 24.43

15 20.94 13.09 24.43 34.03

16 21.81 16.58 20.94 27.92

17 25.30 17.45 23.56 20.94

18 27.92 12.22 19.20 16.58

19 13.96 9.60 18.32 8.73

20 13.96 5.24 13.09 6.11

21 9.60 2.62 6.98 6.11

22 10.47 3.49 5.24 6.98

23 10.47 5.24 4.36 6.11

24 9.60 6.11 5.24 5.24

* Monitor Latitude/Longitude Coordinates : (+3 7

. 05822

- 8 8.57251 )

* * Seasons defined as: Winter ( Dec, Jan, Feb ), Spring (Mar, Apr, May), Summer (Jun, Jul, Aug), Fall (Sep, Oct, Nov)76 

### East St. Louis *



### , Illinois Monitor
Season ** 

### and Hourly Varying Background SO 2



### Wood River Study Area

Hour of Day SO 2 Concentration (μg/m3)

Winter Spring Summer Fall
1 22.60 16.14 13.70 10.73

2 19.11 13.00 14.48 10.12

3 12.39 14.83 13.61 14.57

4 13.44 17.54 19.28 10.38

5 10.56 24.17 18.41 11.69

6 16.05 15.88 13.79 9.51

7 18.15 19.81 15.27 10.91

8 26.26 18.24 27.48 24.34

9 18.41 23.03 34.81 22.69

10 23.91 18.50 31.50 39.09

11 29.67 27.48 26.61 28.27

12 23.65 19.63 19.37 23.47

13 31.76 16.40 26.26 18.85

14 25.74 17.10 19.89 23.38

15 21.20 15.18 12.65 18.35

16 21.55 12.39 13.370 15.71

17 18.50 18.50 11.60 19.20

18 20.77 15.53 12.74 24.87

19 14.83 13.26 10.30 15.09

20 10.12 13.61 9.07 9.60

21 8.90 11.95 12.39 6.81

22 11.69 9.86 10.12 10.03

23 13.70 10.30 11.26 9.07

24 28.36 13.79 9.51 10.82

* Monitor Latitude/Longitude Coordinates : (+3 8.61203

- 90.16048 )

* * Seasons defined as: Winter ( Dec, Jan, Feb ), Spring (Mar, Apr, May), Summer (Jun, Jul, Aug), Fall (Sep, Oct, Nov)77 

## Appendix C Model Input/Output Files for the Study Areas

DVD Media