### Attachment A

Table 1: 2010

- 2012 Annual PM 2.5 Design Values

Monitoring Location Monitor ID Annual PM 2.5 Design Value (μg/m 3 ) Muscatine HS E Campus (Garfield) 191390015 12.2 Muscatine, Franklin School 191390018 11.8 Keokuk, Fire Station 191110008 11.4 Davenport, Hayes School 191630020 11.3 Davenport, Adams Sch. 191630018 11.2 Muscatine, Greenwood Cemetery 191390016 11.1 Council Bluffs, Franklin Sch. 191550009 11.1 Davenport, 10th and Vine 191630015 11 .0 Clinton, Rainbow Park 190450021 10.7 Iowa City, Hoover Sch. 191032001 10.5 Waterloo, Water Tower 190130009 10.4 Cedar Rapids, Public Health 191130040 10.3 Sioux City, Bryant School 191930019 9.9 Des Moines, Public Health 191530030 9.7 Clive, Indian Hills School 191532510 9.6 Lake Sugema 191770006 9.6 Viking Lake State Park 191370002 9.2 Emmetsburg, College 191471002 8.8

0.0 3.0 6.0 9.0 12.0 15.0 18.0Fine Particulate (PM2.5) Design Value(micrograms per cubic meter) Figure 1: Monitored Fine Particulate in Ambient Air in Muscatine Compared to the Annual Standard

Muscatine HS E Campus

Greenwood Cemetery

Franklin School

Musser Park Not a Design Value (*2011-2012 Avg) 1997 Standard (15ug/m3)

2012 Standard (12ug/m3)

A

- 1

### Attachment B

Annual PM 2.5 

### Nonattainment Boundary Recommendation for Muscatine , Iowa

Summary On December 14 , 201 2 , the U.S. Environmental Protection Agency (EPA) revised the primary annual National Ambient Air Quality Standard (NAAQS) for fine particulate matter (PM 2.5 ) from 15.0 μg/m 3 to 12.0 μg/m 3 , based on the latest public health studies. Under the provisions of section 107(d)(1)(A) of the Clean Air Act, within one year after EPA promulgates a new NAAQS, s tate s must recommend area designations to EPA. States review the most recent monitoring data to develop their recommendations on whether the monitoring data shows each county or portion thereof in attainment, nonattainment, or unclassifiable with the NAAQ S.

All areas of the state, except one, show attainment with the NAAQS, or are unclassifiable. T he PM 2.5 monitor located at Muscatine High School East Campus has a 2010

- 2012 annual design value that exceeds 12.0 μg/m 3 , indicating that the area should be recommended for a designation of “nonattainment” with the annual PM 2.5 NAAQS. A modeling analysis was conducted by the Iowa Department of Natural R esources (DNR) regarding possible limitations of the extent of the area of nonattainment in Muscatine with t he annual PM 2.5 NAAQS.

As summarized herein, the recommended boundaries with in the City of Muscatine characterize the area where violations of the annual PM 2.5 NAAQS extend, and include sources that are significant contributors to those violations . This d ocument provides technical support for this recommendation

. Dispersion modeling is appropriate because the boundary recommendation in Muscatine County is not influenced by secondary formation of PM 2.5 beyond the inclusion of a representative background co ncentration. This dispersion modeling analysis combines emissions data and federally enforceable emissions limits, meteorological conditions, terrain information, and background concentrations in a peer

- reviewed regulatory approach to produce air quality data immediately relevant to a boundary recommendation.

Dispersion Modeling Inputs The modeling analysis was conducted using the most recent version of EPA’s regulatory dispersion model, AERMOD (version 12345), National Elevation Dataset (NED) terrain elev ations, and building downwash parameters for all point sources. As previously approved by EPA in the modeling protocol for the SIP call modeling demonstration, meteorological data from the Davenport ASOS site for the period 2008

- 2012 were used. The follo wing major sources of PM 2.5 were included in the analysis:

• Grain Processing Corporation (GPC)

• Muscatine Power & Water (MPW)

• Union Tank Car (UTLX)

These sources were chosen because they were included in the 24

- hour PM 2 .5 State Implementation Plan deficiency modeling demonstration for Muscatine, and as part of that analysis were determined to be important contributors to PM 2.5 concentrations in the area. Hourly PM 2 .5 emission rates used in the SIP call modeling for these three facilities were used in this analysis. The emissions inventories for MPW and UTLX utilized in the modeling were based on the post

- control PM 2 .5 emissions levels used in modeling for the 24

- hour PM 2 .5 SIP call analysis because those emission levels h ave been permitted and are federally enforceable. For

B

- 1GPC, the pre

- control PM 2 .5 emissions levels from the SIP call were used because the control strategy for GPC is still in the final stages of being permitted and made federally enforceable

. Dispersion M odeling Results Two modeling analyses were conducted: a culpability test of the impact of each facility at the East Campus monitor location, and a full grid analysis to determine the extent of the predicted exceedances.

East Campus Monitor Exceedance Culpability The results of the culpabil ity analysis indicated that neither MPW nor UTLX PM 2.5 emissions are predicted to have a significant contribution at the East Campus monitor location. The res ults also indicate that GPC emissions have a significant PM 2 .5 contribution. The maximum contributions from these facilities at the monitor location are summarized in Table 1.

Table 1. Maximum Contribution to Predicted Annual PM 2 .5 Concentration s at East Campus.

Facility Maximum Contribution (μg/m 3 ) Significant Impact Level (μg/m 3 )
GPC 2.81
0.3 MPW 0.27
UTLX 0.07

Full Grid Analysis To evaluate the special extent of the area being impacted by PM 2.5 emissions, the dispersion modeling receptor grid was centered on the East Campus monitor location and extended out to ten kilometers . Receptors that fell on the property of any of the three facilities were omitted from the analysis. Receptor spacing varied as follows:

• 0

- 0.5 km: 50

- meters

• 0.5

- 1.5 km: 100

- meters

• 1.5

- 3 km: 250

- meters

• 3

- 5 km: 500

- meters

• 5

- 10 km: 1,000

- meters

A default ba ckground concentration of 10.5 μg/m 3 was added to the results of the analysis. This background value is the annual PM 2 .5 20 10

- 201 2 design concentration for the Iowa City monitor

. The use of this monitor to represent PM 2 .5 background values in Muscatine w as previously approved by EPA in the modeling protocol used to address recent exceedances of the 24

- hour PM 2.5 standard in the Muscatine area.

The modeling analysis results indicate that the combined emissions from the modeled sources will result in predic ted exceedances of the annual PM 2 .5 NAAQS in the vicinity of the Muscatine industrial area adjacent to the Mississippi River

. Proposed Nonattainment Boundary Based on the ambient air quality monitoring and the dispersion modeling analysis results

, Iowa recommend s that a small area of Muscatine County be classified as nonattainment for the annual PM 2 .5 NAAQS

.

B

- 2Figure 1 identifies the recommended nonattainment boundary (green) and section lines (light blue). Major roads and highways are labeled for ease o f identification. The suggested nonattainment boundary is contained within the Fruitland Township of Muscatine County and uses jurisdictional boundaries clearly defined by section numbers (Table 2)

. Figure 1

. Recommended Nonattainment Boundary.

Table 2. Legal Description of Recommended Nonattainment Area.

Township Sections T76N R2W* (Fruitland township) Southern half of 2 and 3 Entirety of 10 and 11 Northern half of 14 and 15 *T = Township and R = Range.

B

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