UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 4 

The Honorable Governor Bill Haslam 

Governor of Tennessee 

Tennessee State Capitol 

Nashville, Tennessee 37243-0001 

Dear Governor Haslam: 

ATLANTA FEDERAL CENTER 

61 FORSYTH STREET 

ATLANTA, GEORGIA 30303-8960 

FEB 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 air quality designations for the State ofTennessee for the 2010 revision to the 

primary National Ambient Air Quality Standard (NAAQS) for sulfur dioxide (S02). 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 airways which can cause difficulty breathing and increased asthma symptoms. This 

letter is to notify you of the EPA's preliminary 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 level of 75 parts per billion. Within 1 year after a 

new or revised standard is established, the Clean Air Act requires the Governor of each state to submit 

to the EPA a list of all areas in the state, with recommendations for whether each area meets 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 S02 designations by three specific deadlines: 

July 2, 2016, December 31, 2017, and December 31, 2020. 

This current round of designations, to be completed by July 2, 2016, addresses two groups of areas: (1) 

areas that have newly monitored violations of the 2010 S02 NAAQS based on the most recent three 

calendar years of certified monitored ambient air quality data, and (2) areas that contain any 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 S02 with an annual average emission rate of at least 0.45 pounds of S02/nunBTU. 

1 Sierra Club v. McCarthy, No. 3-13-cv-3953 (SI) (N.D. Cal. Mar. 2, 2015). 

Internet Address (URL) • http://www.epa.gov 

Recyled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) 
Because the EPA has insufficient infonnation to determine whether the following areas are meeting or 

not meeting the S02 NAAQS, the EPA intends to designate these areas as unclassifiable: 

Intended Unclassifiable Area 

Sumner County, TN* 

Intended Unclassifiable Counties 

Sumner County, TN 

The asterisk(*) indicates the designation and boundary for this intended unclassifiable area represents a 

modification to the designation and boundary that you have recommended. 

We understand that the State is working with the affected source to put in place federally-enforceable 

emissions limits that might be creditable towards an unclassifiable/attainment designation, assuming that 

no outstanding technical modeling issues remain, and all other conditions in the impacted areas as 

identified in the enclosed teclmical support document are resolved. It will be necessary for these 

federally-enforceable emissions limits to be in place early enough to be considered for the EPA's final 

designation which is court-ordered to happen no later than July 2, 20 16. 

The enclosed Technical Support Document provides a detailed analysis that supports our intended 

designation decisions, and considers information that Tennessee provided as of October 30, 20 15. As 

late as January 2016, the EPA has received additional information from Tennessee in support of the 

State·s boundary and designation recommendation. We will consider this infonnation prior to 

compl eting final designations. If your State has additional information that the EPA should consider 

prior to finalizing these designations, please submit it to us by April 19, 2016. We also will be 

publishing a notice in the Federal Register announcing a 30-day period for the public to provide input 

on the EPA's intended designation decisions. We will promulgate the designation for this area by July 2, 

2016. We will designate all other previously undesignated areas in the State on a schedule consistent 

with the prescribed timing of the court order, i.e., by December 31 , 20 17, or December 31, 2020. 

We look forward to a continued dialogue with you and your staff as we work together to complete the 

area designations and implement the 20 I 0 primary S02 standard. For additional information regarding 

designations under the S02 standard, please visit our website at www.epa.gov/so2designations. Should 

you have any questions, please do not hesitate to call me, or have your staff contact Beverly H. Banister, 

Director, Air, Pesticides and Toxics Management Division at (404) 562-9070 or 

banister. beverlv{a).epa. !!OV. 

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Administrator 

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Enclosure 

cc: Robett J. Martineau, Jr. 

Commissioner, TDEC 
Michelle Walker Owenby 

Director, TDEC, Division of Air Pollution Control 

Janet G. McCabe, Acting Assistant Administrator for Air and Radiation 

Stephen D. Page, Director, Office of Air Quality Planning and Standards