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DRAFT Technical Support Document

ARIZONA Area Designations f or the

2010 Sulfur Dioxide (SO 2 ) Primary National Ambient Air Quality Standard

Summary

Pursuant to section 107(d) of the Clean Air Act (CAA), EPA must initially designate areas as either “unclassifiable”, “attainment”, or “nonattainment” for the 2010 1

- hour sulfur dioxide (SO 2 ) primary national ambient air quality standard (NAAQS). The CAA defines a nonattainment area as one that does not meet the NAAQS or that contributes to poor air quality in a nearby area that does not meet the NAAQS.

Table 1 below identifies the counties and portions of counties in Arizona that EPA intends to initially designate “ nonattainment ” based on monitored violations

.

Table 1 . Nonattainment Designation s for Arizona

Area (listed alphabetically) Arizona Recommendation of

Areas/Counties EPA’s Intended

Nonattainment

Areas/Counties Hayden Gila County (partial) Pinal County (partial) Nonattainment

Nonattainment Nonattainment

Nonattainment

Miami Gila County (partial) Nonattainment Nonattainment

Background

On June 2, 2010, EPA revised the primary SO 2 NAAQS (75 FR 35520, June 22, 2010) by establishing

a new 1

- hour standard at a level of 75 parts per billion (ppb)

, which is attained when the 3

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

- hour average concentration at each monitor in an area does not exceed 75 ppb. EPA has determined that this is the level necessary to provide protection of public health with an adequate margin of safety, especially for c hildren, the elderly

, and those with asthma. These groups are particularly susceptible to the health effe cts associated with breathing SO 2

. The Agency is revoking the two prior primary standards of 140 ppb evaluated over 24

- hours and 30 ppb evaluated ove r an entire year because the standards will not add additional public health protection given a 1

- hour standard at 75 ppb. Accordingly, EPA is not designating areas in this process on the basis of either of these two prior primary standards. Similarly, t he secondary standard for SO2 has not been revised, so EPA is not designating areas in this process on the basis of the secondary standard.2 EPA’s SO 2 Designation Approach

Section 107(d) of the CAA requires that not later than 1 year after promulgation of a new or revised NAAQS, state Governors must submit their recommendations for designations and boundaries to EPA. This deadline was June 3, 2011 . Section 107(d) also requires EPA to provide a notification to states of

no less than 120 day s prior to promulgating an initial area designation that is a modification of a state’s

recommendation. EPA has reviewed the State’s recommendations and has notified the Governor through a letter signed by the Regional Administrator of any intended modif ications. While language in section 107 specifically addresses states, we intend to follow the same process for tribes, pursuant to section 301(d) of the CAA and Tribal Authority Rule (40 CFR Part 49). Therefore, we intend to designate tribal areas, in c onsultation with the tribes, on the same schedule as state designations. If a

s tate or t ribe did not submit designation recommendations, EPA will promulgate the designations that it deems appropriate. If a s tate or t ribe disagrees with EPA’s intended are a designations, it has an opportunity to demonstrate why any proposed modification is inappropriate.

Designations guidance was issued by EPA through a March 24, 2011, memorandum from Stephen D. Page, Director, U.S. EPA, Office of Air Quality Planning and Standards, to Air Division Directors, U.S. EPA Regions I

- X. This memorandum identifies factors EPA intends to evaluate in determining boundaries for areas designated nonattainment. These 5 factors include: 1) Air quality data; 2)

Emissions and emission s

- related data (location of sources and potential contribution to ambient SO 2 concentrations); 3) Meteorology (weather/transport patterns); 4) Geography/topography (mountain ranges or other air basin boundaries); and 5) Jurisdictional boundaries (e.g., cou nties, air districts, pre

existing nonattainment areas, reservations, metropolitan planning organization), among any other information deemed relevant to establishing appropriate area designations and boundaries for the 1

- hour SO 2 NAAQS.

As defined at 18 U.S.C. 1151, “Indian country” refers to: “(a) all land within the limits of any Indian reservation under the jurisdiction of the United States Government, notwithstanding the issuance of any patent, and, including rights

- of

- way running through the reservat ion, (b) all dependent Indian communities within the borders of the United States whether within the original or subsequently acquired territory thereof, and whether within or without the limits of a state, and (c) all Indian allotments, the Indian titles to which have not been extinguished, including rights

- of

- way running through the same.” EPA recognizes the sovereignty of tribal governments, and has attempted to take the desires of the tribes into account in establishing appropriate unclassifiable and n onattainment area

boundaries , in accordance with EPA’s December, 2011 Policy for Establishing Separate Air Quality Designations for Areas of Indian Country 1

.

The March 24, 2011, memo recommended that area boundaries default to the county boundary unless

a dditional provided information justifies a larger or smaller boundary than the county. EPA believes it is appropriate to evaluate each potential area on a case

- by

- case basis, and to recognize that area

- specific analyses conducted by states, tribes and/or EPA may support a different boundary than a default county boundary.

1 http://www.epa.gov/ttn/caaa/t1/memoranda/20120117indiancountry.pdf3 In this TSD, EPA discusses its review and technical analysis of the nonattainment area recommendations submitted by the s tate of Arizona for designations of the 1

- hour SO 2 standard. Ba sed

on our review of information discussed below , EPA intends to agree with the state’s recommendation to designate portions of Gila County and Pinal County nonattainment

.4 Definition of important terms used in this document:

1) Designated nonattainment area

– an area which EPA has determined, based on a state recommendation and/or on the technical analysis included in this document, has violated the 2010 SO 2 NAAQS, based on the most recent three years of air quality monitoring da ta, or contributes to a violation in a nearby area.

2 ) Recommended nonattainment area

– an area a s tate or t ribe has recommended to EPA be designated as nonattainment.

3 ) Violating monitor

– an ambient air monitor meeting all methods, quality assurance and citing criteria and requirements whose valid design value exceeds 75 ppb, as described in Appendix T of 40 CFR part 50.

4 ) 2010 SO 2 NAAQS

- 75 ppb, national ambient air quality standard for SO 2 promulgated in 2010.

Based on the 3

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

- hour average concentrations

.

5 ) Design Value

– a statistic that describes the air quality status of a given area relative to the level of the NAAQS.5 Nonattainment Designations

Technical A nalysis for Hayden, Arizona

Introduction

Th is technical analysis for Hayden, Arizona identifies the partial county with a monitor that violate s the

2010 SO 2 NAAQS

, and evaluates nearby counties for contributions to SO 2 concentrations in the area.

EPA has evaluated this county and nearby counties based on the weight

- of

- evidence of the factors in EPA’s Designation Guidance, issued on March 24, 2011

. 2

Figure 1 shows the areas in Arizona which EPA intends to designate nonattainment. Figure 2 is a m ap showing the locations of SO 2 monitors in Hayden, Arizona and surrounding counties. Violating monitors are shown with a red icon; monitors attaining the standard are shown with green icons.

D esign values for each monitor are listed in Figure 2 , and in Table 2 below

.

2 http://www.epa.gov/air/sulfurdioxide/guidance.html Figure 16 In May 2011, Governor Janice K. Brewer recommended that portions of Gila County and Pinal County be designated as “nonattainment” and the remaining counties and partial counties be designated

“unclassifiable” for the 2010 SO 2 NAAQS b ased on monitored air quality data from 2007

- 2009 ( l etter to EPA Region 9 Administrator Jared Blumenfeld from Governor Janice K. Brewer, May 25, 2011)

. Consistent with the existing Hayden nonattainment area and Miami maintenance area for the 1971 SO 2 NAAQS, the state recommended that t he same portions of Gila County and Pinal County (except those portions in Indian country) be designated as the Hayden and Miami nonattainment areas for the 2010

SO 2 NAAQS

. The state recommendation was based primarily on monitoring data and consideration of emissions data from the 2005 National Emissions Inventory (NEI).

Based on EPA's technical analysis described below, E PA intend s to concur with the state’s

recommendation to initially designate Gila County (partial) and Pinal County (partial) a s nonattainment

for the 2 010 SO 2 NAAQS as part of the Hayden nonattainment area. These counties are listed above in

Table 1

. Figure 27 Detailed Assessment

Air Q uality D ata

This factor considers the SO 2 air quality monitoring data, including the design values (in ppb) calculated for all air quality monitors in Gila County and Pinal County, in the intended Hayden

nonattainment area and in the surrounding area based on data for the 2009

- 2011 period.

The Governor’s recommendation was based on data from Federal Reference Method (FRM) or Federal Eq uivalent Method (FEM) monitors located in the st ate l etter to EPA Region 9 Administrator Jared

Blumenfeld from Governor Janice K. Brewer, May 25, 2011. 3

The 2011 SO 2 NAAQS design values for counties in the intended Hayden nonattainment area and surrounding area are shown in Table 2

. Design values are calculated using the 3

- year average of the

99 th percentile of 1

- hour daily maximum SO 2 concentrations , and compared to the NAAQS of 75 ppb

, according to requirements of 40 CFR 50.17.

Table 2 . Air Quality Data for Nonattainment Designations in Arizona

County State

Recommended

Nonattainment? Monito r Name Monitor Air Quality System ID Monitor Location SO 2 Design Value,

2009

- 2011 (ppb)

Gila,

Arizona Yes (partial) Miami Ridgeline 04

- 007

- 0009 4030 Linden Street 111

Hayden Old Jail 04

- 007

- 1001 Jail

- Canyon Dr, Hayden 259

Maricopa,

Arizona No Central Phoenix 04

- 013

- 3002 1645 E. Roosevelt St, Central

Phoenix 9

South Scottsdale 04

- 013

- 3003 2857 N. Miller Road, South

Scottsdale 8*

Durango Complex 04

- 013

- 9812 2702 AC Ester Brook Blvd 8**

JLG Supersite 04

- 013

- 9997 4530 N. 17th Ave 7*

Pima,

Arizona No 22nd and Craycroft 04

- 019

- 1011 1237 S. Beverly, Tucson 8*

Children’s Park

NCore 04

- 019

- 1028 400 W. River Road 4**

Monitors in Bold have the highest 2009

- 2011 design value in the respective county.

* Incomplete data, provided for informational purposes only, not relevant for comparison to the NAAQS. These stations stopped monitoring for comparison to the SO 2 NAAQS after December 2010. The South Scottsdale monitor was moved to the Durango Complex stat i on; JLG Supersite started monitoring for trace levels of SO 2 instead of for comparison to the NAAQS; 22 nd and Craycroft SO 2 monitoring was moved to the Children’s Park NCore station. **Incomplete data, provided for informational purposes only, not relevant for comparison to the NAAQS. These stations began monitoring for comparison to the SO 2 NAAQS in late 2010 or 2011.

3 Note: Monitors that are eligible for providing design value data generally include State and Local Air Monitoring Stations (SLAMS) that are sited in accordance with 40 CFR part 58, Appendix D ( Section 4

. 4 ) and operating with a FRM or FEM monitor that meets the requirements of 40 CFR part 58, Appendix A. All data from a special purpose monitor (SPM) using an FRM or FEM which has operated for more than 24 months are eligible for comparison to the NAAQS unl ess the monitoring agency demonstrates that the data came from a particular period during which the requirements of Appendix A (quality assurance requirements) or Appendix E (probe and monitoring path siting criteria) were not met.8 Gila County shows violations of the 2010 SO 2 NAAQS. No other SO 2 monitors in Arizona show

violations of the 2010 SO 2 NAAQS

. Therefore, some areas in Gila County and possibly additional areas in surrounding counties must be designated nonattainment. The absence of a violating monitor

alone is not a sufficient reason to eliminate nearby counties as candidates for nonattainment status.

Eac h area has been evaluated based on the weight

- of

- evidence of the five factors and other relevant

information.

Two SO 2 monitors are violating the standard in Arizona. Both violating monitors are located in Gila County. The Hayden Old Jail monitor (Air Quality System (AQS) ID 04

- 007

- 1001) is a source

oriented monitor located approximately 920 meters (0.57 miles) from the ASARCO, LLC

– Hayden smelter stack (see Figure 2). Nestled in the southern, V

- shaped tip of Gila County, the monitor is about

860 mete rs (0.54 miles) from the Pinal County border (see Figure 2 ). The Miami Ridgeline monitor (AQS ID 04

- 007

- 0009) is also a source

- oriented monitor, located approximately 1

, 390 meters (0.86 miles) from the Freeport

- McMoRan Miami Smelter

. The Freeport

- McMoRan Miami Smelter is roughly 45.5 kilometers (28 miles) northwest of the ASARCO, LLC

– Hayden smelter.

Six additional SO 2 monitors have been operated in recent years in Maricopa and Pima c ounties. These

monitors are not source

- oriented and are located in the urban cores of the Phoenix and Tucson metropolitan areas, which are over 50 miles away from the violating monitors located in Gila County (see Figure 2 , above). The low concentrations in these locations suggest that they are not impacted by the same sources that are impacting the violating monitors

.

Figure 39 Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is an importan t factor for determining whether a nearby area is contributing to a monitored violation. For th is factor, EPA evaluated county

- level emission data for SO 2 , as well as emissions from nearby point sources.

Emissions

For this analysis, EPA relied on information from the 2008 National Emissions Inventory (NEI)

emissions data base (NEI08V 2 ). Arizona did not provide updated emissions information . Should EPA become aware of new or updated emissions inventories, EPA will take the new information into

cons ideration for the final designations.

Table 3 shows total emissions of SO 2 in 2008 (given in tons) for all 15 counties in Arizona and single

s ources emitting greater than 10 0 ton s per year of SO 2 according to the 2008 NEI

. The counties that contain part of the intended Hayden nonattainment area for the 2010 SO 2 NAAQS are shown in bold

.10 Table 3 . SO 2 Emissions in 2008

County Facility

Located in

State

Recommended

Nonattainment

Area? Facility > 100 tons per year of SO 2 emissions Facility

Location SO 2 Air

Emissions (2008 NEIv 2 ) ( tons ) Total County

2008 SO 2 Emissions

(tons)

Gila Yes (Hayden) ASARCO, LLC

- H ayden S melter Hayden 21,742

28,940 Yes (Miami) Freeport

- McMoRan Miami Smelter Miami 7,091

- Other point, nonpoint, nonroad, onroad

- 107

Apache No Salt River Project (Coronado) St. Johns 15,900

22,57 4 No Tucson Electric Power Company Springerville 6,562

- Other point, nonpoint, nonroad, onroad

- 1 12

Navajo No Arizona Public Service (Cholla) Joseph City 16,421

19, 201 No Catalyst Paper (Snowflake) Inc. Snowflake 2,556

- Other point, nonpoint, nonroad, onroad

- 224

Pima No Tucson Electric Power (Irvington) Tucson 2,884

4, 78 1

- Other point, nonpoint, nonroad, onroad

- 1, 897

Maricopa No Phoenix Sky Harbor International Airport Phoenix 252

3,138

- Other point, nonpoint, nonroad, onroad

- 2,886

Cochise No AZ Electric Power (Apache) Cochise 1,903

3, 105 No Chemical Lime Company

- Douglas Douglas 1,013

- Other sources (nonpoint, nonroad, onroad)

- 1 89

Yavapai No Nelson Lime Plant Peach Springs 1,955

2, 323

- Other point, nonpoint, nonroad, onroad

- 3 68

Pinal

- Other point, nonpoint, nonroad, onroad

- 464 464

Mohave

- Other point, nonpoint, nonroad, onroad 408 408

Coconino

- Other point, nonpoint, nonroad, onroad

- 350 350

Yuma

- Other point, nonpoint, nonroad, onroad 248 248

La Paz

- Other point, nonpoint, nonroad, onroad 75 75

Santa

Cruz

- Other point, nonpoint, nonroad, onroad 7 1 7 1

Greenlee

- Other point, nonpoint, nonroad, onroad 54 54

Graham

- Other point, nonpoint, nonroad, onroad

- 38 38

Total emissions of SO 2 are highest from Gila County. In 2008, the ASARCO, LLC

– Hayden Smelter emitted over 20,000 tons of SO 2 , three times more than the second largest source ( Freeport

- McMoRan Miami Smelter) of SO 2 in Gila County. Both smelters in Gila County are primary copper smelters. Apache and Navajo c ounties also contain coal

- fired electric utility generating units that are large

sources of SO 2 : Coronado Generating Station (15,90 0 tons in 2008) and Springerville Generating Station ( 6,562 tons in 2008) in Apache County, and Cholla Power Plant (16,421 tons in 2008) in Navajo County. Total emissions of SO 2 from Pinal County are low ( 464 tons in 2008) compar ed to Gila, Apache, and Navajo c oun ties. Gila, Apache, and Navajo c ounties together comprise 8 2 % of total

SO 2 emissions from the state of Arizona. The se five largest stationary sources in th e three counties comprise d 79 % of total SO 2 emissions from Arizona in 2008

. See Figure 4 for the geographic distribution of these stationary sources.11 The state

- recommended Hayden nonattainment area for the 2010 SO 2 NAAQS includes the ASARCO,

LLC

– Hayden Smelter. As shown in Figure 4 and Table 3 , besides the two large st sources in Gila County, both of which EPA intends to include in nonattainment areas, there are no other facilities emitting greater than 100 tons per year of SO 2 in Gila, Pinal, or Graham County. The San Carlos tribal

lands to the east of the State’s rec ommended Hayden nonattainment area, also do not have any facilities emitting greater than 100 tons per year of SO 2 according to the 2008 NEIV2

.

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 3 represent emiss ions levels taking into account any control strategies implemente d on stationary sources in the Hayden,

Arizona intended nonattainment area up to and including 2008

. Since 2008, the ASARCO, LLC

– Hayden Smelter has completed two projects, one in 2010 inv olving addition of a revert screen, and one in 2012 involving additional ventilation and a baghouse to service three existing anode furnaces. Figure 412 Neither of these projects resulted in changes to permitted SO 2 emissions limits for the facility

. See the source’s Title V federal operating permit renewal and two ADEQ permit actions/revisions that occurred since 2008 (52397

- MPR and 54251

- MPR). 4

Pop ulation

Gila County’s population as of the 2010 census was 53,597. From 2000 to 2010 the county grew by 4.4% and had a population density of 11.3 persons per square mile. Pinal County’s population as of the 2010 census was 375,770. From 2000 to 2010 th e county grew by 109.1% and had a population density of 70.0 persons per square mile.

Meteorology (weather/transport patterns)

Evidence of source

- receptor relationships between specific emissions sources and high SO 2 values at violating monitors is another important factor in determining the appropriate contributing areas and the appropriate extent of the nonattainment area boundary. For this factor, EPA considered meteorological

data available for the area. Such dat a may provide evidence of the potential for SO 2 emissions sources located upwind of a violating monitor to contribute to ambient SO 2 levels at the violation location.

Temperature and precipitation data is available from the near by Winkelman 6 S station, p art of the National Weather Service Cooperative Observer Program. This station typically measure s only 14 inches of rain each year, with nearly half of that occurring during the summer months of July through September, coinciding with the Arizona “monsoon ” season. There is less than an inch of snow each year. Daily temperature highs range from 64 to 91 degrees Fahrenheit depending on season, and lows range from 31 to 69 degrees Fahrenheit

. See Figure 5 for the location of the Winkleman meteorological st ation.

The varied elevations in the area cause complex wind flow locally. Within and adjacent to the Gila River and San Pedro River valleys, drainage winds tend to dominate at night under stable conditions

. To the west of the smelter, drainage flows towa rd the west , while east of the smelter the drainage flows

to the south. Given the smelter's elevated location and plume buoyancy, some emissions would be expected to rise above these surface flows. However, on sunny days the heated ground warms the air

an d enhances vertical mixing

. U nder such convective conditions

, the plume could nevertheless be mixed down to the ground to varying degrees . This vertical mixing also causes the flow to be coupled with winds aloft, which generally flow toward the east.

Ove r the years, wind data has been collected at multiple locations in and around Hayden. Sites include the Hayden Maintenance Yard (“Hayden”), Hayden

- Winkelman High School (“Winkelman”), and Globe Highway (data prepared for “Draft Report, Remedial Investigat ion Report for the ASARCO,

LLC Hayden Plant Site, Hayden, Gila County, Arizona”, Prepared for U.S. Environmental Protection Agency Region IX, San Francisco, CA., CH2M Hill, August 2008). These stations are shown in Figure

5

. Wind roses from these station s are shown in Figure 6

. The Winkelman site is nearest the junction of the Gila and San Pedro River valleys, and the Globe Highway site is in the northeastern portion of the Gila River valley before it joins the San Pedro. All of the dominant wind direct ions are consistent with

4 Further information ab out Arizona federal Title V air permits can be found on EPA’s website at: http://www.epa.gov/region9/air/permit/title

- v

- permits.html13 the orientation of the valleys. However, when morning and evening wind frequencies are plotted separately, not all of the directions are consistent with slope flow, e.g.

, afternoon flow at Hayden is toward the east, but downslope flow in the Gila River valley would be toward the northwest. There is a

similar evening component toward the east at Winkelman on some days, but more of a downslope flow on other days. At Globe H ighway, flow directions are consistent with slope flows. The differences between sites located relatively close together show the complexity of the flow in the area. Transport of pollutants would be expected to occur mainly along the Gila

- San Pedro River valleys (northwest

southeast orientation), somewhat circumscribed by the orientations of the valleys and the surrounding

mountains.

Terrain Around Hayden, Arizona : with SO 2 monitor (red circle), cities (purple circle s & labels ), meteorological st ations (blue triangle s & labels )

.

Figure 514 Hayden a.m. and p.m. wind roses

Winkelman a.m. and p.m. wind roses

Figure 615 G eography/topography (mountain ranges or other air basin boundaries)

As shown in Figure 5 (above) and Figure 7 (below)

, Hayden and t he ASARCO , LLC

- Hayden smelter

are located in very complex terrain, with the Gila River making a winding semi

- circle around the east and south of the facility, and intersected by the San Pedro River valley from the south. The facilit y itself is elevated relative to the valleys; there is a 200

- foot hill just south of the facility. In all directions there is a mountain side. Hayden is at roughly 2

, 000 feet elevation; the Dripping Springs Mountains to

the north rise to 4

, 000 feet; the To rtilla Mountains on the northwest, west, and south rise 3

, 300 to 4

, 000 feet. Terrain rises more gently within the Gila

- San Pedro River valleys from the northwest toward the

southeast. The intended nonattainment area encompasses the Gila River valley from w here it narrows in the northwest corner of the area, to where it joins with the San Pedro River valley in roughly the center of the area, and to a bend in the San Pedro River in the southeast corner. The surrounding

mountains likely limit the extent of the area exceeding the SO 2 standard to a relatively small area around the smelter, the main source of SO 2 emissions. For the same reason, locations outside the particular valleys intersecting at Hayden are not expected to contribute to SO 2 NAAQS exceedances

there.

Figure 716 Jurisdictional boundaries

The Office of Management and Budget (OMB) defines metropolitan (metro) and micropolitan (micro)

statistical areas based on census information. A metro statistical area contains a core urban area of 50,000 or more in population, and a micro statistical area contains an urban core of at least 10,000 but less than 50,000 in population. A Core Based Statistical Area (CBSA) is a collective term for both

metro and micro a reas. OMB may further define a combined statistical area (CSA) as an aggregate of adjacent metro or micro statistical areas that are linked by commuting ties.

The state of Arizona is divided into 15 counties (listed in Table 3 ). Within the state, OMB has defined

11 CBSAs compris ing six metro statistical areas and five micro statistical areas. OMB has not aggregated any metro or micro statistical areas in Arizona into a CSA. Two counties in Arizona, Apache and La Paz, are not de fined by OMB as a metro or micro statistical area. The Payson Micropolitan Statistical Area comprise s Gila County, and the Phoenix

- Mesa

- Glen dale Metropolitan Statistical Area comprise s Maricopa and Pinal c ounties. The Payson metro area comprises the entir ety of Gila County, and is named for the most populated city of the county , Payson City

. Payson City is

outside the state’s recommended nonattainment area and there are no other large population centers in

the area , apart from the town of Hayden itself , w hich has several hundred residents

.

To manage air quality, the state of Arizona has one state agency

, the Arizona Department of Environmental Quality (ADEQ), and three local agencies : Maricopa County Air Quality Department, Pima County Department of Envir onmental Quality, and Pinal County Air Pollution/Quality Control

District. Air quality planning for the existing Hayden nonattainment area under the 1971 SO 2 NAAQS, composed of the same portions of Gila and Pinal counties as the state’s recommended nonatta inment area for the 2010 SO2 NAAQS, is under the jurisdiction of ADEQ. Originally

, for the 1971 NAAQS

, the Hayden area was split between two county

- wide SO 2 nonattainment areas for Gila and Pinal

c ounties (see 43 FR 8968, March 3, 1978). At the request of the state of Arizona, the boundar y for the Hayden area w as reduced to nine townships in and around the town of Hayden (44 FR 21261, April 10, 1979). See also, 40 CFR Section 81.303. In addition, six adjacent townships were designated as

‘‘cannot be cl assified

. ’’ Section 107(d)(1)(C) of the 1990 Clean Air Act Amendments (CAAA) brought forward, by operation of law, the nonattainment designations for areas, such as the Hayden SO 2 area, that continued to be designated as nonattainment at the time of enactm ent of the CAAA, i.e., areas that had not been redesignated to ‘‘attainment’’ prior to the CAAA’s November 15, 1990 enactment date

. The then

- existing nonattainment area for Hayden under the 1971 SO 2 NAAQS included a portion of Indian country along the eas tern boundary. T he intended Hayden nonattainment area for the 2010 SO 2 NAAQS is the same area as the existing 1971 SO 2 NAAQS brought forward by operation of law following the 1990 CAAA , without the portion of Indian country

. The existing Hayden nonattainment

area attained the 1971 SO 2 NAAQS such that ADEQ submitted a maintenance plan to EPA in 2002. EPA has not acted on the redesignation request and maintenance plan.

As defined at 18 U.S .C. 1151 , “Indian country” refers to: “(a) all land within the limits of any Indian reservation under the jurisdiction of the United States Government, notwithstanding the issuance of any patent, and, including rights

- of

- way running through the reservation, (b) all dependent Indian

communities wit hin the borders of the United States whether within the original or subsequently acquired territory thereof, and whether within or without the limits of a state, and (c) all Indian allotments, the Indian titles to which have not been extinguished, includin g rights

- of

- way running17 through the same.” EPA recognizes the sovereignty of tribal governments, and has attempted to take the desires of the tribes into account in establishing appropriate unclassifiable and nonattainment area

boundaries. No areas of In dian country ar e included in the intended Hayden , Arizona nonattainment

area.

Other Relevant Information

In its May 25, 2011 letter, ADEQ provided additional information to support its assertion th at presumptive use of full county boundaries as the nonattainment area boundary is inappropriate for geographically large counties

. The state argued that the use of full county boundaries as the presumptive nonattainment area boundary for a violating monito r results in disparities in the size of nonattainment areas. For example, the state compared the area of Gila County (4,796 square miles) with the area of the entire state of Connecticut (4,845 square miles). A violating monitor in Middlesex County, Connec ticut, would result in a presumptive nonattainment area boundary encompassing 369 square miles. Applying this presumption in Arizona would result in a nonattainment area (Gila County) that is 13 times larger than a full Middlesex County nonattainment area in Connecticut. The state further highlighted that the violating monitor in the ir recommended Hayden nonattainment area is

less than 0.5 miles from the southwest border of Gila and Pinal c ounties, and more than 100 miles from

the northern border of Gila and Coconino c ounties. Therefore, the state concluded that its consideration of partial counties for the Hayden and Miami nonattainment areas was appropriate.

Conclusion

After considering the factors described above, EPA intends to concur with the state’ s recommendation

to initially include Pinal County (partial) and Gila County (partial) as the Hayden, Arizona

nonattainment area for the 2010 SO 2 NAAQS , based on the violating monitor

.

The air quality monitor in Hayden, Arizona shows a violation of th e 20 10 SO 2 NAAQS based on 2009

- 2011 air quality data. EPA preliminarily concludes that the state’s recommended boundary contains the area violating the standard as well as areas causing or contributing to the violation. The monitor is

source

- oriented, and is located in the southernmost tip of Gila County

. D ue to constraints imposed by the complex terrain in the Hayden area (see Geography/Topography discussion above), it is expected that the extent of the area exceeding the SO 2 standard is confined to a relatively small area around the

main source of SO 2 emis sions, the ASARCO, LLC

- Hayden smelter. For the same reason, locations outside the particular valleys intersecting at Hayden are not expected to contribute to NAAQS exceedances at the Hayden monitor. The meteorology factor is not significant in determin ing a boundary for the nonattainment area, but available data confirms the importance of the topography in limiting the intended nonattainment area to the nearby river valleys and their surroundings. The state’s recommended boundary for the intended Hayde n nonattainment area is also consistent with the existing Hayden nonattainment boundary for the 1971 SO 2 NAAQS , without areas of Indian country

. The existing (for the 1971 SO 2 NAAQS) Hayden SO 2 nonattainment area attained the standard prior to 2002, at whi ch time ADEQ submitted a maintenance plan and request for EPA to redesignate the area

to attainment for the 1971 NAAQS. A ll non

- Indian country lands are under the jurisdiction of ADEQ

.18 Based on the consideration of all the relevant and available information, as described above, EPA ’s preliminary conclusion is that the boundaries described herein encompass a n area that does not meet (or that contributes to ambient air quality in a nearby area that does not meet) the 2010 SO 2 NAAQS , based

on the violating monitor information

.19 Technical A nalysis for Miami , Arizona

Introduction

This technical analysis for Miami , Arizona identifies the partial county with a monitor that violates the

2010 SO 2 NAAQS and evaluates nearby counties for contribution s to SO 2 concentrations in the area. EPA has evaluated this county and nearby counties based on the weight

- of

- evidence of the factors in EPA’s Designation Guidance, issued on March 24, 2011

. 5

Figure 8 shows the areas in Arizona which EPA intends to designate nonattainment. Figure 9 is a map

of SO 2 monitors in the area and the surrounding counties

. Violating monitors are shown with a red icon; monitors attaining the standard are shown with green icons. D esign values for each monitor are listed in Fi gure 9 and in Table 4 , below

.

5 http://www.epa.gov/air/sulfurdioxide/guidance.html Figure 820 In May 2011, Governor Janice K. Brewer recommended that portions of Gila County and Pinal County be designated as “nonattainment”, and the remaining counties and partial counties be designated

“unclassifiable” for the 2010 SO 2 NAAQS based on monitored air quality data from 2007

- 2009 ( l etter to EPA Region 9 Administrator Jared Blumenfeld from Governor Janice K. Brewer, May 25, 2011). Consistent with the existing Hayden nonattainment area and Mia mi maintenance area for the 1971 SO 2 NAAQS, the state recommended that the same portions of Gila County and Pinal County be designated as the Hayden and Miami nonattainment areas for the 2010 SO 2 NAAQS. The state recommendation was based primarily on monit oring data and consideration of emissions data from the 2005 National Emissions Inventory (NEI).

Based on EPA's technical analysis described below, EPA intends to concur with the state’s

recommendation and initially designate Gila County (partial) as no nattainment for the 2010 SO 2 NAAQS as the Miami nonattainment area. The county is listed above in Table 1. Figure 921 Detailed Assessment

Air Quality Data

This factor considers the SO 2 air quality monitoring data, including the design values (in ppb) calculated for all air quality monitors in Gila County, in the intended Miami nonattainment area and the surrounding area based on data for the 2009

- 2011 period.

The Governor’s recommendat ion was based on da ta from Federal Reference Method (FRM) or Federal Eq uivalent Method (FEM) monitors located in the st ate (l etter to EPA Region 9 Administrator Jared

Blumenfeld from Governor Janice K. Brewer, May 25, 2011). 6

The 2010 SO 2 NAAQS design val ues for counties in the intended Miami nonattainment area and

surro unding area are shown in Table 4

. Design values are calculated using the 3

- year average of the

99 th percentile of 1

- hour daily maximum SO 2 concentrations , and compared to the NAAQS of 75 ppb

, according to requirements of 40 CFR 50.17

.

Table 4 . Air Quality Data for Nonattainment Designations in Arizona

County State

Recommended

Nonattainment? Monitor Name Monitor Air Quality System ID Monitor Location SO2 Design Value,

2009

- 2011 (ppb)

Gila,

Arizona Yes (partial) Miami Ridgeline 04

- 007

- 0009 4030 Linden Street 111

Hayden Old Jail 04

- 007

- 1001 Jail

- Canyon Dr, Hayden 259

Maricopa,

Arizona No Central Phoenix 04

- 013

- 3002 1645 E. Roosevelt St,

Central Phoenix 9

South Scottsdale 04

- 013

- 3003 2857 N. Miller Road, South

Scottsdale 8* Durango Complex 04

- 013

- 9812 2702 AC Ester Brook Blvd 8**

JLG Supersite 04

- 013

- 9997 4530 N. 17th Ave 7*

Pima,

Arizona No 22nd and Craycroft 04

- 019

- 1011 1237 S. Beverly, Tucson 8*

Children’s Park

NCore 04

- 019

- 1028 400 W. River Road 4**

Monitors in Bold have the highest 2009

- 2011 design value in the respective county. *Incomplete data, provided for informational purposes only, not relevant for comparison to the NAAQS. These stations stopped monitoring for comparison to the SO 2 NAAQS after December 2010. The South Scottsdale monitor was moved to the Durango Complex station ; JLG Supersite started monitoring for trace levels of SO 2 instead of for comparison to the NAAQS; 22 nd a nd Craycroft SO 2 monitoring was moved to the Children’s Park NCore station. **Incomplete data, provided for informational purposes only, not relevant for comparison to the NAAQS. These stations began monitoring for comparison to the SO 2 NAAQS in late 2010 or 2011.

6 Note: Monitors that are eligible for providing design value data generally include State and Local Air Monitoring Stations (SLAMS) that are sited in accordance with 40 CFR Part 58, App endix D (Section 4.4) and operating with a FRM or FEM monitor that meets the requirements of 40 CFR Part 58, Appendix A. All data from a special purpose monitor (SPM) using an FRM or FEM which has operated for more than 24 months are eligible for compariso n to the NAAQS unless the monitoring agency demonstrates that the data came from a particular period during which the requirements of Appendix A (quality assurance requirements) or Appendix E (probe and monitoring path siting criteria) were not met.22 Gila County shows violations of the 2010 SO 2 NAAQS. No other SO 2 monitors in Arizona show

violations of the 2010 SO 2 NAAQS

. Therefore, some areas in Gila County and possibly additional areas in surrounding counties must be designated nonattainment. The absence of a violating monitor

alone is not a sufficient reason to eliminate nearby counties as candidates for nonattainment status. Each area has been evaluated based on the weight

- of

- evidence of the five factors and other relevant

in formation.

Two SO 2 monitors are violating the standard in Arizona. Both violating monitors are located in Gila County (see Figure 9 ). The Miami Ridgeline monitor (AQS ID 04

- 007

- 0009) is a source

- oriented monitor, located approximately 1

, 390 meters (0. 86 miles) from the Freeport

- McMoRan Miami Inc. (FMMI) copper smelter (see Figure 10 ). The FMMI smelter is roughly 45.5 kilometers (28 miles) northwest of the other violating monitor, Hayden Old Jail, a source

- oriented monitor located near the ASARCO, LLC

– Hayden smelter.

Figure 1023 Six additional SO 2 monitors have been operated in Maricopa and Pima c ounties in recent years . These

monitors are not source

- oriented and are located in the urban cores of the Phoenix and Tucson metropolitan areas, which are over 50 miles away from the violating monitors located in Gila County (see Figure 9 , above). The low concentrations in these locations suggest that they are not impacted by the same sources that are impacting the violating monitors

.

Emissions and Emissions

- Related Data

Evidence of SO 2 emissions sources in the vicinity of a violating monitor is an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA evaluated county level emission data for SO 2 , as well as emissions from n earby point sources.

Emissions

For this analysis, EPA relied on information from the 2008 National Emissions Inventory (NEI)

emissions data base ( NEI08V 2 ). Arizona did not provide updated emissions information . Should EPA become aware of new or updated emissions inventories, EPA will take the new information into consideration for the final designations.

Table 5 shows total emissions of SO 2 (given in tons per year) for all 15 counties in Arizona and sources emitting greater than 100 tons per year of SO 2 according to the 2008 NEI. The county that contain s all

of the Miami nonattainment area for the 2010 SO 2 NAAQS is shown in bold

.24 Table 5 . SO 2 Emissions in 2008

County Facility

Located in

State

Recommended

Nonattainment

Area? Facility > 100 tons per year of SO 2 emissions Facility

Location SO 2 Air

Emissions (2008 NEI v2 ) (tons) Total County

2008 SO 2 Emissions

(tons)

Gila Yes (Hayden) ASARCO, LLC

- Hayden Smelter Hayden 21,742

28,940 Yes (Miami) Freeport

- McMoRan Miami Smelter Miami 7,091

- Other point, nonpoint, nonroad, onroad

- 107

Apache No Salt River Project (Coronado) St. Johns 15,900

22,57 4 No Tucson Electric Power Company Springerville 6,562

- Other point, nonpoint, nonroad, onroad

- 1 12

Navajo No Arizona Public Service ( Cholla) Joseph City 16,421

19, 201 No Catalyst Paper (Snowflake) Inc. Snowflake 2,556

- Other point, nonpoint, nonroad, onroad

- 224

Pima No Tucson Electric Power (Irvington) Tucson 2,884

4, 78 1

- Other point, nonpoint, nonroad, onroad

- 1, 897

Maricopa No Phoenix Sky Harbor International Airport Phoenix 252

3,138

- Other point, nonpoint, nonroad, onroad

- 2,886

Cochise No AZ Electric Power (Apache) Cochise 1,903

3, 105 No Chemical Lime Company

- Douglas Douglas 1,013

- Other sources (nonpoint, nonroad, onroad)

- 1 89

Yavapai No Nelson Lime Plant Peach Springs 1,955

2, 323

- Other point, nonpoint, nonroad, onroad

- 3 68

Pinal

- Other point, nonpoint, nonroad, onroad

- 464 464

Mohave

- Other point, nonpoint, nonroad, onroad 408 408

Coconino

- Other point, nonpoint, nonroad, onroad

- 350 350

Yuma

- Other point, nonpoint, nonroad, onroad 248 248

La Paz

- Other point, nonpoint, nonroad, onroad 75 75

Santa

Cruz

- Other point, nonpoint, nonroad, onroad 7 1 7 1

Greenlee

- Other point, nonpoint, nonroad, onroad 54 54

Graham

- Other point, nonpoint, nonroad, onroad

- 38 38

Total emissions of SO 2 are highest from Gila County. In 2008, the FMMI copper smelter was the second largest source of SO 2 in Gila County, and the fourth largest source in Arizona. Both smelters (FMMI and ASARCO, LLC) in Gila County are primary copper smelters. Apache and Navajo c ounties

also contain coal

- fired electric utility generating units that are large sources of SO 2 : Coronado Generating Station (15,900 tons in 2008) and Springerville Generating Station (6,562 tons in 2008) in Apache County, and Cholla Power Plant (16,421 tons in 2008) in Navajo County. Total emissions of

SO 2 from Pinal County are low ( 464 tons in 20 08) compar ed to Gila, Apache, and Navajo c oun ties. Gila, Apache, and Navajo c ounties together comprise 8 3 % of total SO 2 emissions from the state of

Arizona. The five largest stationary sources in those three counties comprise d 79 % of total SO 2 emissions f rom Arizona in 2008

. The existing Miami maintenance area for the 1971 SO 2 NAAQS is25 identical to the state’s recommended Miami nonattainment area for the 2010 SO2 NAAQS and includes

the FMMI smelter

. See Figure 11

.

Emissions Controls

The emissions data used by EPA in this technical analysis and provided in Table 5 represent emissions levels taking into account any control strategies implemented on stationary sources in the Miami

, Arizona intended nonattainment area up to and including 2008. Since 2008, FMMI has had several permit revisions, including: installation of a coal injection system with a dust collector system, clarification and/or correction to existing permit conditions, revision to allow additional use of an existing screen ing machine, update of the sulfur balance methodology to include a gravimetric method, and addition of small internal combustion engines. None of the permit revisions resulted in changes to permitted SO 2 emission limits. See seven ADEQ permit actions/rev isions from 2008 to the present:

43398

- SPR, 45593

- MPR, 48448

- MPR, 49986

- MPR, 54218

- MPR, 55226

- MPR, and 55691

- MPR. These seven permit actions/revisions were included in the Title V Renewal Operating Permit 53592 issued November 26, 2012. 7

7 Furt her information about Arizona federal Title V air permits can be found on EPA’s website at: Figure 1126 Population

Gila County’s population as of the 2010 census was 53,597. From 2000 to 2010 the county grew by 4.4% and had a population density of 11.3 persons per square mile.

Meteorology (weather/transport patterns)

Evidence of source

- receptor relationships betwe en specific emissions sources and high SO 2 values at violating monitors is another important factor in determining the appropriate contributing areas and the appropriate extent of the nonattainment area boundary. For this factor, EPA considered meteorolog ical

data available for the area. The data may provide evidence of the potential for SO 2 emissions sources located upwind of a violating monitor to contribute to ambient SO 2 levels at the violation location.

Temperature and precipitation data are available from the Miami station, part of the National Weather Service Cooperative Observer Program. Around 20 inches of rain fall each year at the Miami station

, roughly evenly distributed between the months, except in April, May, and June, when less th an a half

inch of rain falls per month . Normal daily temperature highs range from 96 degrees Fahrenheit (°F) in summer to 62 °F in winter, while normal lows are 65 °F in summer to 34 °F in winter.

The closest meteorological station to the violating Miami monitor is Globe station CW1546, part of the National Weather Service Cooperative Observer Program. T he city of Globe is about five miles from

Miami , roughly to the east . Globe is in the Pinal Cre e k Valley, oriented at right angles to the valley

where Miami is located , with a more west

- east orientation. The 2010 wind data shows flows consistent with the valley orientation (see Figure 1 2 ) . Flow toward the west is the most frequent, but flow toward

the east

- southeast also occurs

. Some, but not all of t he flows are consistent with diurnal slope flows; the complexity of the surrounding terrain means there are multiple influences controlling the flow. Because of the complex terrain, and the spatial separation from Miami, this data is of limited usefulness for drawing conclusions about the Miami nonattainment area boundary, except to illustrate that flows largely conform to valley orientation, with slope flow being an important phenomenon.

http://www.epa.gov/region9/air/permit/title

- v

- permits.html27 Globe CW1546 Wind Rose, 2010; A.M. hours

Globe CW1546 Wind Rose, 2010; P .M. hours G lobe a.m. and p.m wind r oses

Figure 1228 Geography/topography (mountain ranges or other air basin boundaries)

As shown in Figures 1 3 and 1 4

, Miami and the FMMI smelter are located in complex terrain. Miami is at roughly 3

, 500 feet elevation, located in the southwest

- northeast tending river valley of the Bloody Tanks Wash. To the northeast, this valley joins the Pinal Wash at a right angle; the Wash then tends northwest and merges with the Pinal Cre e k Valley. Northeast be yond this j uncture , the Apache Peaks

rise to 4

, 300 feet, and to 6

, 200 feet a bit outside of the intended nonattainment area. To the northwest,

Webster Mountain rises to 5

, 000 feet; the Pinal and other mountain ranges to the south and southwest

rise to 6

, 5 00 feet; there are various other ridges to the southeast. Thus, Miami is essentially surrounded by mountains in all directions; its immediate valley makes a right

- angle turn into the Pinal Cre e k

V alley, which is all within the intended nonattainment area except for a short narrow portion in the

north. The existing nonattainment boundaries contain all the areas topographically connected with

Miami.

Terrain Around Miami , Arizona SO 2 Intended Nonattainment Area : with SO 2 monitor (red circle), cities (pur ple circle s & labels ), meteorological stations (blue triangle s & labels )

.

Figure 1329 Jurisdictional boundaries

The Office of Management and Budget (OMB) defines metropolitan (metro) and micropolitan (micro)

statistical areas based on census information. A metro statistical area contains a core urban area of 50,000 or more in population, and a micro statistical area contains an urban core of at least 10,000 but less than 50,000 in population. A Core B ased Statistical Area (CBSA) is a collective term for both metro and micro areas. OMB may further define a combined statistical area (CSA) as an aggregate of adjacent metro or micro statistical areas that are linked by commuting ties.

The state of Arizona is divided into 15 counties (listed in Table 5 ). Within the stat e, OMB has defined

11 CBSAs: six metro statistical areas and five micro statistical areas. OMB has not aggregated any

metro or micro statistical areas in Arizona into a CS A. Two counties in Arizona, Apache and La Paz, are not defined by OMB as a metro or micro statistical area.

The intended Miami nonattainment area represents a portion of Gila County, located close to the borders of Maricopa and Pinal c ounties. Gila Count y comprises the entirety of the Payson Micropolitan Figure 1430 Statistical Area. Although Gila County is adjacent to the Phoenix

- Mesa

- Glen dale Metropolitan

Statistical Area (comp o s ed of Maricopa and Pinal c ounties) , the degree of socio

- economic integration

between th e Payson and the Phoenix

- Mesa

- Scottsdale CBSAs is not sufficient to meet the OMB

definition of a CSA.

As discussed in the technical analysis for the intended Hayden nonattainment area, for air quality

management purposes , Gila County falls under the juri sdiction of ADEQ. Originally, the currently

intended Miami SO 2 nonattainment area was not separately defined but rather was included in a

county

- wide SO 2 nonattainment area (see 43 FR 8968, March 3, 1978). At the request of the state of Arizona, the bound aries were reduced to nine townships in and around the city of Miami (44 FR 21261, April 10, 1979). See also, 40 CFR s ection 81.303. In addition, six adjacent townships were designated

as ‘‘cannot be classified

. ’’ Section 107(d)(1)(C) of the 1990 Clean Air Act Amendments (CAAA) brought forward, by operation of law, the nonattainment designations for areas, such as the Miami SO 2 area, that continued to be designated as nonattainment at the time of enactment of the CAAA, i.e., areas

that had not been redes ignated to ‘‘attainment’’ prior to the CAAAs’ November 15, 1990 enactment
date

. The area achieved attainment with the 1971 SO 2 NAAQS in 1984, and ADEQ submitted a maintenance plan to EPA in 2002. I n January 2007, EPA redesignated the Miami nonattainment a rea to attainment (72 FR 3061 , January 24, 2007 ). In this redesignation and maintenance plan approval, EPA also corrected the boundary of the Miami SO 2 nonattainment area to exclude a noncontiguous township that was erroneously included in the description of the area and to fix a transcription error in the listing of one of the other townships (see 72 FR 3061 , January 24, 2007 and 40 CFR s ection 81.303). The

intended Miami nonattainment area for the 2010 SO 2 NAAQS is the same area as the 1971 SO 2 NAAQS ma intenance area.

Other Relevant Information

In its May 25, 2011 letter, ADEQ provided additional information to support its assertion th at presumptive use of full county boundaries as the nonattainment area boundary is inappropriate for geographically large counties. The state argued that the use of full county boundaries as the presumptive nonattainment area boundary for a violating monito r results in regional disparities in the size of nonattainment areas. For example, the state compared the area of Gila County (4,796 square miles) with the area of the entire state of Connecticut (4,845 square miles). A violating monitor in

Middlesex Count y, Connecticut, would result in a presumptive nonattainment area boundary encompassing 369 square miles. Applying this presumption in Arizona would result in a nonattainment area (Gila County) that is 13 times larger than a full

- county nonattainment area in Connecticut. Therefore, the state concluded that its consideration of partial counties for the Hayden and Miami nonattainment areas was appropriate.

Conclusion

After considering the factors described above, EPA intends to concur with the state’s reco mmendation

to initially include the portion of Gila County listed in Table 1 as the Miami nonattainment area for the

2010 SO 2 NAAQS , based on the violating monitor

.

The air quality monitor in Gila County shows a violation of the 2010 SO 2 NAAQS, based on 2009

- 2011 air quality data. The Freeport

- McMoRan Miami Inc. (FMMI) copper smelter located less than31 1

, 400 meters (less than 0.86 mile) away from the violating monitor is expected to be the source of the emissions causing the violation. Miami is essential ly surrounded by mountains in all directions. Due to the constraints imposed by the complex terrain in the Miami area (see Geography/Topography discussion above), the extent of the area exceeding the SO 2 standard is expected to be confined to a relatively small area around the main source of SO 2 emissions, the FMMI copper smelter. For the same reason, locations outside the particular valley containing Miami are not expected to contribute to Miami monitor’s exceedances. The meteorology factor did not play a significant role in determining a boundary for the nonattainment area, but available data confirms the relevance of the topography in limiting the intended nonattainment area to the nearby river valleys and their surroundings. The

nonattainment boundari es recommended by the state are therefore expected to contain all the areas topographically connected with Miami and causing or contributing to the violation.

Based on the consideration of all the relevant and available information, as described above, EPA’s preliminary conclusion is that the boundaries described herein for the intended Miami, Arizona

nonattainment area encompass a n area that does not meet (or t hat contributes to ambient air quality in a nearby area that does not meet) the 2010 SO 2 NAAQS , based on the violating monitor information

. No areas of Indian country are included in the intended Miami, Arizona nonattainment area.