Mr. Ron Curry 

Regional Administrator 

STATE OF ARKANSAS 

AsA HUTCHINSON 

GOVERNOR 

September 11, 2015 

U.S. -Environmental Protection Agency, Region VI 

1445 Ross Avenue, Suite 1200 

Dallas, Texas 75202-2733 

Re: Update to Sulfur Dioxide (S02) National Ambient Air Quality Standard (NAAQS) 

Area Attainment Designation Recommendation for Counties in the State of 

Arkansas. 

Dear Mr. Curry: 

Section 107( d)(l) of the Federal Clean Air Act requires state governors to 

recommend attainment status designations within one year of the promulgation of any 

new or revised NAAQS. On June 2, 2010, the federal Environmental Protection Agency 

(EPA) promulgated a new primary 1-hour NAAQS for S02 at 75 ppb for the 3-year 

average of the 99th percentiles of the maximum daily values per calendar year. The 

existing secondary standard of 0.5 ppm per 3-hour period remained unchanged. 

As per the State's letter dated March 22, 2011, all monitored counties in Arkansas 

are currently attaining the existing primary and secondary S02 standards. However, as 

part of the implementation of the new 1-hour NAAQS, EPA has begun requiring, in 

addition to monitoring data, the use of dispersion modeling for areas with facilities 

emitting large quantities of S02 as a means of determining compliance with the new 

standard. Currently, only two counties in Arkansas fall under this requirement: 

Independence and Jefferson. These counties are subject to this requirement because two 

facilities operated by Entergy Arkansas, Inc. have sulfur dioxide emissions that are 

greater than the level that the EPA determined would require review. 

Based on the analysis of modeling that was conducted by Environmental 

Resources Management (ERM) for Entergy Arkansas, Inc. and provided to the Arkansas 

Department of Environmental Quality for review, both Independence and Jefferson 

counties will comply with the standard. Copies of ERM's analysis reports, S02Air 

Dispersion Modeling Report for White Bluff Steam Electric Station and S02Air 

500 WOODLANE STREET • LITTLE ROCK, AR 72201 

TELEPHONE (501) 682-2345 

www.governor.arkansas.gov 
Dispersion Modeling Report for Independence Steam Electric Station, are enclosed for 

your review. 

Consistent with the previous recommendation, it is the State's recommendation 

that the two counties with existing monitor sites, Pulaski and Union should be 

designated "attainment". Based on the information contained in the enclosed reports, 

Independence and Jefferson counties should be designated "unclassifiable/attainment". 

All other counties in Arkansas should be designated "unclassifiable." 

The attached table lists all Arkansas counties and their recommended 

designations. For further information regarding these recommendations, please contact 

Stuart Spencer, Chief of the Air Division, Arkansas Department of Environmental 

Quality, by phone at 501-682-0750 or email at SPENCER@adeq.state.ar.us. 

attachment: Table of Arkansas County Designation Recommendations 

enclosures: 

S02 Air Dispersion Modeling Report for Independence Steam Electric Station 

S02 Air Dispersion Modeling Report for White Bluff Steam Electric Station 

500 WOODI.ANE STREET • LITTLE ROCK, AR 7220 I 

TELEPHONE (501 ) 682-2345 

www.governor.arkansas.gov 
Arkansas 1-Hour Sulfur Dioxide (S02) 

Designation Recon1mendations 

County Reco1nmended Designation 

Arkansas 

Ashley 

Baxter 

Benton 

Boone 

Bradlev 

Calhoun 

Carroll 

Chicot 

Clark 

Cl av 

Cleburne 

Cleveland 

Columbia 

Conway 

Craighead 

Crm.vford 

Crittenden 

Cross 

Dallas 

Desha 

Drew 

Faulkner 

Franklin 

Fulton 

Garland 

Grant 

Greene 

Hempstead 

Hot Spring 

Howard 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

500 Woom,/u"lE STREET • Lrn'LE ROCK, AR 7220 I 

TELEPHONE (501) 632-234-5 

www.govcr1101:arkansas.gov 
Arkansas 1-Hour Sulfur Dioxide (S02) 

Designation Recommendations (cont.) 

County Recommended Designation 

Independence 

Izard 

Jackson 

Jefferson 

Johnson 

Lafayette 

Lawrence 

Lee 

Lincoln 

Little River 

Logan 

Lonoke 

Madison 

Marion 

Miller 

Mississippi 

Monroe 

Montgomery 

Nevada 

Nevvton 

Ouachita 

Perry 

Phillips 

Pike 

Poinsett 

Polk 

Pope 

Prairie 

Pulaski 

Randolph 

St. Francis 

Saline 

Scott 

Searcy 

Unclassifiable/ Attainment 

Unclassifiable 

Unclassifiable 

Unclassifiable/ Attainment 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Attainment 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

500 WOODL.ANE STREET • LnTLE ROCK, AR 72201 

TELEPHONE (501) 682-23,15 

www.governor.arkansas.gov 
Arkansas 1-Hour Sulfur Dioxide (S02) 

Designation Recommendations (cont.) 

County Recommended Designation 

Sebastian 

Sevier 

Sharp 

Stone 

Union 

Van Buren 

Washington 

White 

Woodruff 

Yell 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Attainment 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

500 WoomANE STREET • LrrnE RocK, AR 72201 

TELEPHONE (50 I) 682-2345 

\vww.govcrno1:arkansas.gov