UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REG I ON 4



### The Honorable Governor Bill Haslam Governor of Tennessee Tennessee State Capitol Nashville , Tennessee 37243-0001 Dear Governor Has l am : ATLANTA FEDERAL CE N TER 61 FORSYTH STREET ATLA N TA, GEORG I A 30303 - 8960 

# FE B 1 6 2016

Thank you for your updated recommendations , submitted on behalf of you by Robert J
. Martineau , Commissioner of the Tennessee Department of Environment and Conservation (TDEC) , dated September 16 , 2015 , on a ir quality designat ions for the State ofTennessee for the 2010 revision to the primary National Ambient Air Quality Standard (NAAQS) for sulfur diox i de (S0 2 )
. Reducing levels of S02 pollution is an important part of the U.S. Environmental Protection Agency ' s commitment to a clean , healthy environment. Exposure to S02 can cause a range of adverse health effects, including narrowing of the a irways which can caus e difficulty breathing and increased asthma symptoms. This letter is to notify you of the EPA's prelim inary intentions regarding your recommended designations. On June 3 , 2010 , the EPA strengthened the health

- based or "primary " standard for S02 by establishing a standard for 1

-hour average S02 concentrations at a leve l of 75 parts per billion. Within 1 year after a new or r ev ised standard is established , the C lean Air Act require s the Gov e rnor of each state to submit to the EPA a list of all areas in the state , with recommendations for whether each area mee ts the standard. Through an interactive process , the EPA considers the recommendations and then promulgates designations for all areas across the country. On July 25,2013, the EPA designated 29 areas in 16 states as nonattainment, but did not at that time designate other areas. Pursuant to a March 2, 2015 , courtordered schedule , 1 

### the EPA must complete the remaining S0 2 designations by three specific deadlines: July 2 , 2 0 1 6 , December 31, 2017, and December 3 1 , 2020. Th is current round of designations , to be completed by Ju ly 2 , 2016, addresses two groups of areas: (1) area s that have new ly monitored vi olations of the 2010 S0 2NAAQS based on the most recent three calendar years of certified mon itored ambient air quality data, and (2) areas that contain an y stationary source that had not been announced as ofMarch 2, 2015 , for retirement and that according to the EPA ' s Air Markets Database emitted in 2012 either: ( i ) more than 16 , 000 tons of S02 or ( ii) more than 2 , 600 tons of S0 2 with an annual average emission rate of at least 0.45 pounds of S0 2/ nunBTU.

1 

### Sie rra Club v. McCarthy, No. 3

- 13-cv-3953 (SI) (N
. D. Cal. Mar. 2, 2015)
.
Internet Addres s ( URL ) • http://www .epa.gov Recyled/Recyc l able • Prin ted wi th Vegetab l e O il Based I nks o n Recycled Paper (M in imum 30% Postcon sume r )Because the EPA has insufficient infonnation to determine w heth e r the fo llo wi ng areas are meeting or not meeting the S0 2 NAA Q S , the E P A intends to d esig n ate the se areas as unclassifiable: Inte nd e d Unclassifiable Area Sumne r County , TN* Inte nd e d Unclassifiable Co unties S umn er County , TN The asteri sk(*) indicates the des ig nation and bou ndary fo r this intended unclassifiable area represents a modifi cat ion to the designati o n and bound ary that you have recommended. We understand that the State is working with the affected source to put in place federa ll y -enf orce able emissions limit s that might be creditable towa rd s an unclassifiable / atta inment designation, assuming that no outstand in g technical modeling iss ues remain, and all oth er conditions in the imp acte d areas as identified in the e nclo se d teclmi cal s upport document are reso l ved. 

### It will be nec essa ry for these federa ll y - enforceab le e mi ssions limits to be in place early e nou g h to be cons id ered fo r the EPA's final designation which is court
- o rde red to happen no later th an July 2 , 20 16. The e nclos e d Technical Support Docume nt provides a d e tailed analy s is that supports our inte nded designation deci s ions, and considers inform ation that Te nn ess ee provided as of October 30, 20 1 5
. As late as January 2016 , the E P A has received additional information from Tennessee in support of the State · s bound ary and designation recommendation. We will consider this infonn ation prior to co mpl eti ng final designations. I f your State has additional informati o n that the EPA s hould cons ider prior to finali z in g these desi g nations , pl ease s ubmit it to u s by April 19 , 2016. W e also will be publishing a notice in the 

### Federal Register announci n g a 30 -day period for the public to provide input on the EPA ' s intended designation decisions. We w ill promulgate the desig nation for this area by July 2 , 2016. We wi ll designate all other previously undesignated areas in th e State on a sc hedule consistent with th e prescribed timing of the court order , i.e. , by D ecember 31 , 20 17 , or D ecember 31, 2020
. We look forward to a co ntinu ed dialogue with you and your staff as we wo rk together to complete the area designations and implement the 20 I 0 primary S02 standard. For add iti onal information regarding designations und er the S02 standar d , pl ease v isit our website at 

### www.epa. gov /

so2des i gnations. Sho uld yo u have any questions, ple ase do not hesi ta te to call me , or have your staff contact Beverly 

### H. Banister, Director , A ir , Pesticides and Toxics Management Division at (404 ) 562

- 9070 or banister. beverlv {a).epa . !!OV
.



# ~ H

eat her McTeer



# Tone **~** R eg ional Administrator
Enclosure

cc: Robett J. Martineau , Jr. Comm i ss ioner , TDECM ichelle Walker Owenby Director , TD E C, Division of Air Pollution Control Janet G. McCabe , Acting Assistant Administrator for Air and Radiation Stephen D. Page , Director , Office of Air Quali ty Planning and Standards