I£PA ATIACHMENT NO._L 

ILliNOIS ENVIRONMENTAL PROTECTION AGENCY 

1021 North Grnnd Avenue East, P.O. Box 19276, Springfield, Illinois 62794-9276 • (217) 782-2829 

james R. Thompson Center, 100 West Randolph, Suite 11-300, Chicago, IL 60601 • (312) 814-6026 

217/785-4140 

217/782-9143 (IDD) 

June 2, 2011 

PAT QUINN, GOVERNOR 

Ms. Cheryl A. Newton, Director 

Office of the Air and Radiation Division 

U.S. Envirotunental Protection Agency, Region V (R18J) 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3507 

Dear· Ms. Newton: 

On behalf of Governor Quinn and pursuant to the U.S. Environmental Protection Agency's 

revision to the National Ambient Air Quality Standards (NAAQS) for S02 dated June 2, 2010, 

I am submitting our recommendations for attainment and nonattainrnent designations for the 

State of Illinois. Included with these recommendations is supporting documentation prepared by 

the illinois Environmental Protection Agency (Illinois EPA). The Illinois EPA is also providiog 

this documentation to your staff in electronic format to faCilitate your timely review. 

Specifically, the followiilg designations are recommended for illinois: 

Connty (Partial) 

Tazewell County: 

• Pekin and Cincinnati Townships 

• Remainder of Tazewell County 

La Salle County: 

• La Salle Township 

• Remainder of La Salle Countv 

Cook County: 

• Lemont Township 

• . Remainder of Cook County 

Will County: 

• Lockport and DuPage Townships 

• Remainder of Will County 

Madison Countv: 

• Chouteau and Wood River 

• Rymainder of Madison County 

All Other Counties 

Rod.ic:in::l• 43C!2 N. Main St., Rockford, IL 61103 • (815) 987-7760 

Bgin• 595 S.State, Elgin, ll &Ol23 • (847) 608-3131 

Bureau ofl.md- Peoria •7620 N. University St. Peoria, ll6l614 • (309) 693-5462 

Collinsville • ;:2009 Mall Street. Collinsville, Jl6223-4 • (618) 346-5120 

Desil!Diiffon Name of Area. 

Tazewell 

Nonattainment Colinty 

Unc;lassifiable 

La Salle 

Nonattainment County 

Unciassifiable 

Nonattainment Cook County 

Unclassifi.able 

Nonattainment Will County 

Unclassifiable 

Nonattainment Madison 

Unclassifiable 

Unc)assifiable illinois 

Des Pbines • 9511 W. Harrison St, Des Plaines, ll60016• {847) 294-4000 

Peoria• 5415 N. U.niversity SL. Peoria..ll61614 • (309) 693-5463 

Champaitn • 2125 5. First St... Champaign, It 61620• (217) 278--5800 

Marion• 2309 W. Main .St., Suite 116, Marion, ll62959 • {618)993·7200 

PrinLed on Rccyded P.o.prr 
We are recommending that portions of the following counties be designated as nonattainment for 

the 2010 primary 1-hour S02 NAAQS: Tazewell (Pekin and Cincinnati Townships), La Salle 

(La Salle Township), Cook (Lemont Township), Will (Lockport and DuPage Townships) and 

Madison (Chouteau and Wood River Townships). As violations of the revised S02 standard 

have been measured in these areas during 2008-2010, designating them as nonattainment is 

appropriate. We recommend that the remainder of Illinois be designated as unclassifiable. 

If there are any questions, please feel free to contact Rob Kaleel (217-524-4343), or myself. 

Sincerely, 

~of~. Laurel L. Kroack 

Chief, Bureau of Air 

· Attachment 
Technical Support Document: 

Recommended Attainment/Nonattainment Designations 

in Illinois for the 2010 Revised Primary 1-Hour S02 

National Ambient Air Quality Standard 

AQPSTR 11-02 

June 2, 2011 

Illinois Environmental Protection Agency 

Division of Air Pollution Control 

1021 North Grand Avenue East 

P.O. Box 19276 

Springfield, IL 62794-9276 

www .epa.sta te.il.us 
Table of Contents 

TABLES •••••••.•.....•....•.••••.••.....•...........•..•...........................••............................•••.•••••.•.................•.• 3 

FIGURES •••••.•..•••••••••••••••••............•.....•.••.........................••............................•••••••.•••................•.•.• 4 

INTRODUCTION ••••..••..••..............•...•..•...................................................•....•.•.•••••.................••..• 5 

FEDERAL GUIDANCE .•...........••••••••••••......................•••••.......••••••••.•......••.••••••••..•................•••..• 6 

FIVE FACTOR ANALYSIS ............................................................................................................................ 7 

1. AIR QUALITY DATA ................................................................................................................................. 7 

2. EMISSIONS-RELATED DATA. ................................................................................................................... 7 

3. METEOROLOGY ........................................................................................................................................ 7 

4. GEOGRAPHYffOPOGRAPHY .................................................................................................................... 7 

5. JURISDICTIONAL BOUNDARIES ............................................................................................................ 8 

ILLINOIS AIR QUALITY .••.•••••.•••••••...........•.....••.•••••.•..........•••••••.......•••••.••••••..........••.••••••••••... 8 

ILLINOIS 5 FACTOR ANALYSIS ..................•..........................................•..............•...•......... 11 

TAZEWELL COUNTY ................................................................................................................... 11 

LA SALLE COUNTY .. .. . . . . .. . . . . . . . . . . . . . . . .. . .. .. .. .. . . . . . . . . . . . . . . . . . . . .. .. .. . . . . . . . . . . . . .. .. . . . . . . . . . . . . . . . .. .. . . . . .. . . . . . . . . . . . . . . 1 7 

COOK AND WilL COUNTIES ....................................................................................................... 22 

MADISON COUNTY .................................................................................................................... 27 

RECOMMENDATIONS ..••.••.•••••••••••••.••...................••••••••.•......••••••••.......••.••••••••••••................•.• 33 

2 
TABLES 

Table 1 2008-2010 Illinois S02 Design Values (ppb) ................................................ 9 

Table 2 Peoria Area Air Quality Data for 2008-2010 (ppb) ....................................... 11 

Table 3 Tazewell and Peoria County Reported S02 Emissions for 2007-2009 ................ 12 

Table 4 La Salle County Air Quality Data for 2008-2010 (ppb) ........................................... 17 

Table 5 La Salle County Reported S02 Emissions for 2007-2009 ............................... 17 

Table 6 Cook and Will County Air Quality Data for 2008-2010 (ppb) ......................... 22 

Table 7 Cook and Will County Reported S02 Emissions for 2007-2009 ....................... 23 

Table 8 Metro-East Area Air Quality Data for 2008-2010 (ppb) ................................ 28 

Table 9 Madison County Reported S02 Emissions for 2007-2009 .............................. 28 

Table 10 Recommended Attainment/Nonattainment Designations in Illinois for the 2010 

Revised Primary 1-Hour S02 National Ambient Air Quality Standard ................. 3 5 

Table 11 S02 NAA Five Factor Documentation .................................................... 36 

3 
Figure 1 

Figure 2 

Figure 3 

Figure 4 

Figure 5 

Figure 6 

Figure 7 

Figure 8 

Figure 9 

Figure 10 

Figure ll 

Figure 12 

Figure l3 

Figure 14 

Figure 15 

Figure 16 

Figure 17 

Figure 18 

Figure 19 

Figure 20 

Figure 21 

Figure 22 

FIGURES 

lllinois 1-hour S02 Design Values 2008-2010 ...................................... 10 

Location of Major S02 Emission Sources in Tazewell and Peoria Counties ..... 12 

Greater Peoria Airport Climatological Wind Rose .................................. l3 

Pekin Pollution Rose ...................................................................... 14 

Aerial Photo of the Pekin Monitor and nearby Facilities ............................ 15 

Proposed S02 Nonattainment Area Boundary for Tazewell County .............. 16 

Location of Major S02 Emission Sources in La Salle County ..................... 18 

Greater Rockford Airport Climatological Wind Rose ............................... 19 

Oglesby Pollution Rose ................................................................. 20 

Aerial Photo of the Oglesby Monitor and nearby Facility .......................... 20 

Proposed S02 Nonattainment Area Boundary for La Salle County ............... 21 

Location of Major S02 Emission Sources in Cook and Will Counties..... . . . ..... 23 

Chicago-O'Hare Airport Climatological Wind Rose ................................ 24 

Lemont Pollution Rose .................................................................. 25 

Aerial Photo of the Lemont Monitor and nearby Facilities ........................... 26 

Proposed S02 Nonattainment Area Boundary for Cook and Will Counties ..... 27 

Location of Major S02 Emission Sources in Madison County ..................... 29 

St. Louis-Lambert Field Climatological Wind Rose ................................ 30 

South Roxana Poll uti on Rose ........................................................... 31 

Aerial Photo of the South Roxana Monitor and nearby Facility .................... 31 

Proposed S02 Nonattainment Area Boundary for Madison County .............. 32 

Proposed S02 Nonattinment Areas ..................................................... 34 

4 
Introduction 

On June 2, 2010, the U.S. Environmental Protection Agency (U.S. EPA) revised the primary 

Sulfur Dioxide (S02) National Ambient Air Quality Standard (NAAQS) in response to current 

scientific evidence which links short-term exposure to so2 with adverse health effects in 

humans. U.S. EPA health studies show that short-term exposure to S02, ranging from 5-

minutes to 24-hours, results in adverse respiratory effects and increased asthma symptoms, 

particularly in children, the elderly, and asthmatics. According to U.S EPA, there is currently 

little evidence suggesting a relationship between long-term exposure to S02 and health effects. 

As a result, U.S. EPA revoked both the previous 24-hour and annual primary S02 standards and 

established a new primary !-hour S02 standard at a level of 75 parts per billion (ppb) (75 FR 

35520; June 22, 2010). As part of the 2010 revised primary S02 NAAQS (further referenced as 

the revised S02 standar~), U.S. EPA also modified how attainment is determined. The revised 

S02 standard is attained when the three-year average of the annual 991

h percentile 1-hour daily 

maximum concentrations does not exceed 75 ppb (75 FR 35520; June 22, 2010). U.S. EPA will 

address the secondary S02 standard as part of a separate review. 

Section 1 07( d) of the Clean Air Act (CAA) governs the process for area designations, and directs 

states to submit their S02 designation recommendations to U.S. EPA by June 3, 2011. 

Following the promulgation of a new or revised air quality standard, the Clean Air Act (CAA) 

requires the Governor to recommend initial designations of the attainment status for all areas of 

the State. Areas can be classified as non attainment (does not meet, or contributes to a nearby 

area that does not meet the NAAQS), attainment (meets the NAAQS), or unclassijiable (cannot 

be classified based on available data). lllinois is, therefore, required to provide recommendations 

for attainment/nonattainment area boundaries for the 2010 revised primary so2 standard. The 

U.S. EPA will act on the State's recommendations by both affirming and promulgating the 

recommended designation boundaries, or by promulgating new designations. U.S. EPA stated in 

its preamble to the 2010 NAAQS, that in addition to air monitoring data, refined dispersion 

modeling information may be used as part of an analytical approach to designations. However, 

according to the U.S. EPA March 24, 2011 memorandum entitled, Area Designations for the 

5 
2010 Revised Primmy Sulfitr Dioxide National Ambient Air Quality Standards, the U.S EPA 

does not believe it would be "realistic or appropriate to expect states to complete modeling for all 

significant sources of S02 and assess the results in time for the June 2011 designation 

recommendations". States would instead present modeling to address additional violations in 

the course of developing State Implementation Plan (SIP) revisions under Section 11 O(a) of the 

Clean Air Act as a, "basis for re-designation of non attainment and unclassifiable areas to 

attainment" (75 FRat 35570). Illinois does not intend to submit dispersion modeling in support 

of designations at this time. Rather, IEPA will complete dispersion modeling in the course of 

developing SIP revisions. 

Federal Guidance 

The lllinois Environmental Protection Agency "(IEPA) relied on guidance identified in a 

memorandum issued by U.S. EPA on March 24, 2011 which referenced pages in the preamble of 

the lead NAAQS final rule regarding criteria for developing this recommendation and for 

establishing the geographic boundaries ofnonattainment areas (NAA) for the 2010 revised S02 

standard. In this guidance, U.S. EPA recommended that states designate areas with air quality 

data showing violations of the S02 NAAQS, and nearby areas that cause or contribute to 

NAAQS violations, be designated nonattainment. Due to the localized nature of S02 impacts, 

U.S. EPA also recommends that the "county line" associated with the violating monitor(s) serve 

as the starting point, or presumptive boundary, for new S02 nonattainment areas. U.S. EPA 

provides states with the ability to depart from county boundaries based on area-specific analyses. 

States may request nonattainment area boundaries that are smaller than the existing violating 

county boundaries where counties, or portions of counties, do not contribute to nonattainment 

based on an examination of five factors. States may also request nonattainment area boundaries 

that are larger than the current county to include adjacent counties when those counties contain 

emission sources and other factors that may contribute to the nonattainment problem. This 

report provides the basis for recommendations by the IEPA for attainment/nonattainment 

designation boundaries for all areas in the State of Illinois for the revised S02 standard. 

6 
Five Factor Analysis 

The U.S. EPA recommends that states consider the following five factors in assessing whether to 

depart from county boundaries as the designated nonattainment area boundary: 

1. Ail- Quality Data: an evaluation of the design value calculations for each monitor in the 

State. This calculation consists of the 3-year average of the annual 99th percentile daily 

maximum 1-hour S02 concentrations collected at each monitor. A detailed discussion of 

air quality in illinois is provided in the sections below. 

2. Emissions-Related Data: an evaluation of S02 emissions from sources located in and 

around the violating area which may potentially contribute to observed or modeled 

violations of the NAAQS. The emissions data used in this analysis are based on actual 

S02 emissions reported to the IEPA for 2007 through 2009. 

3. Meteorology: an evaluation of weather conditions, including wind speed and direction 

that affect the plume of sources contributing to ambient and monitored S02 

concentrations. Pollution roses are derived from IEPA sites in the proposed NAA areas, 

and all sites use either collocated wind measurements, or the nearest IEPA monitoring 

site with wind direction measurements, along with hourly S02 concentrations. The 

pollution roses show the frequency of wind directions at the monitor when !-hour 

concentrations of S02 that exceed the standard are occurring. Detailed meteorology used 

in !EPA's analysis is discussed in the following sections. 

4. Geog.-aphyffopography: Includes an evaluation of the physical features of the land that 

might have an effect on the airshed and, therefore, on the distribution of S02 at and near 

the monitors. Due to the fact that none of the recommended S02 nonattainment areas in 

Illinois have any geographical or topographical barriers that significantly limit air 

7 
pollution transport within the airsheds, the geography/topography factor did not play a 

significant role in detennining the nonattainment boundaries in Illinois. 

5. Jurisdictional Boundaries: Includes an analysis of areas that provide clearly defined 

legal boundaries including landmarks or geographic coordinates to carry out air quality 

planning and enforcement functions for the nonattainment area. The lllinois EPA is 

responsible for air quality regulatory programs for every county in the state. 

Jurisdictional boundaries considered in this analysis are consistent with recommended 

geographic boundaries, or "county line" definitions, outlined in U.S. EPA's guidance 

documentation. Sub-county boundaries in this study reflect 2009 Political Township 

boundaries provided by Property Tax Division of the Illinois Department of Revenue. 

Illinois Air Quality 

As recommended by U.S. EPA, the first step in identifying areas that are in violation of the 

revised S02 NAAQS is to evaluate the most recent three years of ambient air monitoring 

data. Table 1 shows the most recent three consecutive years of quality assured air monitoring 

data for 2008 through 2010, along with the resulting design values. The design value is 

defined as the 3-year average of the annual 99th percentile daily maximum 1-hour S02 

concentrations collected at each monitor (which is generally the fourth highest daily 

maximum 1-hour concentration, averaged over three consecutive years). The general trend in 

annual 1-hour 991

h percentile values statewide has been downward. Overall, 16 of the 19 

Illinois S02 monitoring sites had 991

h percentile values in 2010 that were lower than those 

same values in 2008. Despite the significant improvement in air quality statewide, four 

monitoring sites currently violate the revised S02 NAAQS. These four monitors are located 

in Tazewell, La Salle, Cook, and Madison counties (see Figure 1 ). The remaining fifteen 

monitoring sites are attaining the revised S02 NAAQS, most by a considerable margin. 

8 
Table 1 

2008-2010 Illinois S02 Design Values (ppb) 

AQS County Site Annual 991

" Percentiles Design 

Code 2008 2009 2010 Value 

170310050 Cook Chicago- SE Police 35 19 21 25 

170310063 Cook Chicago- CTA 26 21 14 20 

170310076 Cook Chicago- Com Ed 26 24 20 23 

170311601 Cook Lemont 97 114 90 100 

170314002 Cook Cicero 43 29 31 34 

170314201 Cook Northbrook 13 17 15 15 

170990007 La Salle Oglesby 326 8 14 116 

171150013 Macon Decatur 44 36 49 43 

171170002 Macoupin Nilwood 20 16 15 17 

171191010 Madison South Roxana 152 81 57 97 

171193007 Madison Wood River WTP 67 46 54 56 

171430024 Peoria Peoria 52 21 43 39 

171570001 Randolph Houston 35 26 31 31 

171630010 St. Clair East St. Louis 35 30 31 32 

171670006 Sangamon Springfield 131 24 31 62 

171790004 Tazewell Pekin 243 233 228 235 

171850001 Wabash Mount Carmel 90 69 66 75 

171851001 Wabash Rural Wabash Co. 57 53 59 56 

171970013 Will Joliet 56 32 24 37 

9 
Figure 1 

Illinois 1 -hour S 02 ~-'----]--'---c__!-l-,,--------J 

Design Values 

2008-2010 

Legend 

Monitors <= 75 ppb 

~ Monitors > 75 ppb 

Violating Counties 

10 
Illinois 5 Factor Analysis 

The U.S. EPA recommends that states consider the following five factors in assessing whether to 

depart from county boundaries as the designated nonattainment area boundary. As previously 

mentioned, illinois has four counties where monitored violations of the revised S02 NAAQS are 

occurring. The information in the following sections provides boundary recommendations based 

on the five factors outlined in U.S. EPA guidance within each violating county or adjacent 

county. 

Tazewell County 

Ail· Quality 

There are two S02 monitors in the Peoria area. The first monitor is located west of the illinois 

River in Peoria, while the second monitor is located east of the lllinois River in Pekin (see Figure 

2). Monitoring data for both sites is listed below in Table 2. The 2008-2010 design value for the 

Peoria monitor is below the revised 1-hour NAAQS, while the design value for the Pekin 

monitor is well above the revised 1-hour NAAQS. The 2008 through 2010 aunual 991

h 

percentiles show a small decrease at the Peoria site and consistently high values at the Pekin site. 

Table 2- Peoria A1·ea Air Quality Data for 2008-2010 (ppb) 

AQSCode County Site Annual 991

' Percentiles Design 

2008 2009 2010 Value 

171430024 Peoria Peoria 52 21 43 39 

171790004 Tazewell Pekin 243 233 228 2.35 

Emissions 

Table 3 lists the major S02 emission sources (reported S02 emissions over 100 tons per year for 

at least one of the years from 2007 through 2009) within both Tazewell and Peoria counties. The 

locations of these sources are shown in Figure 2. From Figure 2, there are two sources in the 

vicinity of the violating monitor in Pekin: Aventine Renewable Energy, and Midwest Generation 

- Powerton. Overall, there has been a small decrease in S02 emissions within the Peoria area 

11 
during the period, however Aventine and Midwest Generation-Powerton, have shown either 

steady or increasing emissions trends during this period. 

Table 3- Tazewell and Peoria County Reported SOz Emissions fot· 2007-2009 

Reported S02 Emissions 

County IDNumber Facility Name (Tons per Year) 

2007 2008 2009 

Tazewell 179060ACR Aventine Renewable Energy Inc 12239.93 11830.31 11819.57 

Tazewell 179801AAA Midwest Generation- Powerton 20543.67 22355.08 22125.00 

Peoria 143065AJE Archer Daniels Midland Co 3140.00 3049.00 2587.00 

Peoria 143805AAG Ameren- Edwards 14535.90 11224.10 117.34.40 

Peoria 143808AAA Keystone Steel & Wire Co 109.26 137.53 86.61 

Figure 2- Location of Majot· S02 Emission Sources in Tazewell and Peoria Counties 

Major 502 Emission Sources in 

Tazewell and Peoria Counties 

t""''"" FULTON 

MASON 

I '"<n i• '.?"-' 

/ t E < 

TAZEWELL 

cf 

"~' !>""' 

WOODFORD 

Legend 

Ill 100 TPY 802 Facilities 

l"::. 802 Monitors 

c::J County Boundaries 

: 

0 2.5 5 10 Miles 

12 
Meteo1·ology 

The closest National Weather Service (NWS) meteorological monitoring site to the Pekin area is 

located at the Greater Peoria Airport. The IEPA considers the meteorological characteristics of 

the airport site to generally be representative of the Tazewell County area, although it is possible 

that some local-scale differences may occur within the lllinois River valley, where Pekin is 

located. Figure 3 shows the climatological wind rose, or wind frequency distribution, for the 

Peoria Airport. The figure shows that southerly winds are most frequent in the Peoria area, with 

a secondary maximum from the northwest. 

Figure 3 - Greater Peol"ia Airport Climatological Wind Rose 

St;~tionl\'14842- PEORJA.It3REATER PEORIA ARPT, IL 

-- --~··;~,- --

' 

' -- t '. --- I ·-. 

: 

' - -:-----

' 

' 

' --- ~----

13 

<S'> 
Figure 4 shows the pollution rose for the Pekin monitor, which depicts the wind directions 

associated with measured S02 concentrations exceeding 75 ppb at this location. Comparing the 

pollution rose in Figure 4 to Figure 5, which shows the locations of major S02 emission sources 

with respect to the Pekin monitor, it is apparent that the wind direction during exceedance hours 

is either from the west or west-southwest, which aligns the nearby Aventine facility, and, to a 

lesser extent, Midwest Generation- Powerton with the monitor location. 

WNW I. 

Figm·e 4 - Pekin Pollution Rose 

NW 

sw··. 

Wind Rose 

Pekin Hours> 75 ppb 

2008-2010 

N 

NNW NNE 

s 

14 

NE 

ENE 

' ' ESE 

Wind data from Peoria, !L 

Average wind direction = 247 degrees 
Since the Pekin monitor is at a slightly higher elevation than the two facilities to the westsouthwest, IEPA believes that the high concentrations that are occurring at this monitor are 

primarily due to emissions from these local sources. 

Jurisdictional Boundaries 

The Illinois EPA is responsible for air quality regulatory programs for every county in the state. 

Jurisdictional boundaries considered in this analysis are consistent with recommended geographic 

boundaries, or "presumptive boundary" definitions, outlined in U.S. EPA's guidance documentation. 

Boundaries in this study reflect the 2009 political township boundaries provided by tl1e Property Tax 

Division of the Illinois Department of Revenue. Based on tl1e geographic location of Pekin and the 

individual sources, it is expected that the coordination of planning activities reqnired to address the 

nonattainment designation can be carried out in a cohesive manner. 

15 
Recommendation 

Based on the factors discussed above, illinois recommends that Pekin and Cincinnati Townships 

in Tazewell County be designated as nonattainment for the 2010 1-hour S02 NAAQS (see Figure 

6). These two townships contain both the violating monitor and the two most culpable emission 

sources. 

Figm·e 6- Proposed S02 Nonattainment Area Boundary for Tazewell County 

Proposed 502 Nonattainment 

Area in Tazewell County 

"''"'"'0 g 

= ''"="'"" t 

l 

l 

' 

16 

" £ 

l 

B 

P''~"'"" (¢_..,.,""""'"" 

TAZEWELL 

COUNTY s,.,.Rq,.,.~- ~ 

,; 

i 

Legend 

CJ Proposed NM 

/::. S02 Monitors 

IIi S02 FaC1!it1aS 

o L,,.,,,,--,2:-:.,~--.,,r's Miles 

.J '"' 
La Salle County 

Air Quality 

There is one S02 monitor in La Salle County located in Oglesby. Monitoring data for this site is 

listed below in Table 4. The 2008-2010 design value for the Oglesby monitor currently exceeds 

the revised !-hour NAAQS. However, the 2008 through 2010 annual 99th percentiles show a 

large decline in S02 values measured at the Oglesby site related to the suspension of operations 

at the Lone Star Industries cement plant in 2008. The 99th percentiles for both 2009 and 2010 

were the lowest values in the state and the Oglesby monitor is expected to attain the revised !-

hour NAAQS by the end of2011. 

Table 4- La Salle County Air Quality Data fot· 2008-2010 (ppb) 

AQSCode County Site Annual 99th Percentiles Design 

2008 I 2009 I 2010 Value 

170990007 La Salle Oglesby 326 I 8 I 14 116 

Emissions 

Table 5 lists the major S02 emission sources (reported S02 emissions over I 00 tons per year for 

at least one of the years from 2007 through 2009) in La Salle County. The locations of these 

sources are shown in Figure 7. From Figure 7, there is only one source in the vicinity of the 

violating monitor in Oglesby: Lone Star Industries. This facility has been closed since 2008, 

which is reflected in the large decrease in S02 emissions shown in Table 5. There has also been 

a significant reduction in S02 emissions at the illinois Cement Company plant in La Salle, 

although this facility remains operational. 

Table 5- La Salle County Reported S02 Emissions fot· 2007-2009 

Reported S02 Emissions 

County IDNumber Facility Name (Tons per Year) 

2007 2008 2009 

La Salle 099030AAZ Illinois Cement Co 167.8 160.34 90.17 

La Salle 099490AAD Owens-Brockway Glass Container Inc 228.24 221.72 208.69 

La Salle 099816AAF Lone Star Industries Inc 2937.16 2241.18 0.00 

La Salle 099825AAG Pilkington North America Inc 293.66 255.1 308.22 

17 
Figure 7- Location of Major S02 Emission Sources in La Salle County 

Major S02 Emission Sources 

in La Salle County 

" 

\i;v;;"',_ C·it /"" 

MARSHALL 

Meteot·ology 

fl:ttid:t-:J& 

_:'\W;LMt 

LIVINGSTON L\. S02 Monitors 

:r, (:_J'!Y;V-_; ·::' 

1!1 100 TPY S02 Facilities 

C=:J County Boundaries 

3.5 7 14 M11es 

The Oglesby monitor is in north-centrallllinois, roughly the same distance from NWS stations at 

the Rockford Airport and at the Peoria Airport. Figure 8 shows the climatological wind rose for 

the Rockford airport. The Rockford wind rose looks very similar to the Peoria wind rose, 

presented previously in Figure 3. There is a pronounced maximum frequency of southerly winds 

at Rockford, as at Peoria, with a secondary maximum from the northwest. The IEPA considers 

these NWS stations to generally be representative of conditions occurring in La Salle County, 

although it is recognized that the Vermillion River valley, where the Lone Star facility is located, 

may cause localized meteorological influences. 

18 
Figm·e 8- G•·eate•· Rockf01·d Airport Climatological Wind Rose 

Station #94S22- ROCKFORD.'GREATER ROCKFORD ARP, ll 

__ .---- :;,;,;;~---­

' ' ' ' --- -~- ---

' ' : 

' ' --- -:- ---

Figure 9 shows the pollution rose for the Oglesby monitor, while Figure I 0 is an aerial photo that 

shows the relationship of the one large source to the monitor. The pollution rose shows that the 

wind direction during exceedance hours is primarily from the southwest, which corresponds well 

with the location of Lone Star Industries, which is located to the south and southwest of the 

monitor. Based on this analysis, the IEPA concludes that exceedances of the revised !-hour S02 

NAAQS at Oglesby are due primarily to emissions from the Lone Star facility. 

19 
Figure 9- Oglesby Pollution Rose 

IIW 

WtiW. 

sw 

Wind Rose 

Oglesby Hours> 75 ppb 

2008 

NNW_ 

ssw 

\iO,O-.;--·- --

?0.0% 

-.;o,ro>-----

.>o,o%-- -· < _ 

'" 

ENE 

Wlnd data trorn Ogie5by 

SE Averuge wi"d d'rection ~ 227 <kuree~ 

Figure 10 -Aerial photo of the Oglesby Monitor and nearby Facility 

20 
Judsdictional Boundaries 

TI1e Illinois EPA is responsible for air quality regulatory programs for every county in the state. 

Jurisdictional boundaries considered in this analysis are consistent with recommended geographic 

boundaries, or "presumptive boundary" definitions, outlined in U.S. EPA's guidance documentation. 

Boundaries in this study reflect the 2009 political township boundaries provided by the Property Tax 

Division of the Illinois Department of Revenue. Based on the geographic location of Oglesby and 

the individual sources, it is expected that the coordination of planning activities required to address 

the nonattainment designation can be carried out in a cohesive mam1er. 

Recommendation 

Based on the factors discussed above, illinois recommends that La Salle Township in La Salle 

County be designated as nonattainment for the 20 I 0 1-hour S02 NAAQS (see Figure 11 ). This 

township contains both the violating monitor and the most culpable source of S02 emissions. 

Figure 11- Proposed S02 Nonattainment Area Boundary f01· La Salle County 

Proposed 502 Nonattainment 

Area for La Salle County 

"""'"" -~ ,,, .. ,.,, 

.,J 

21 

Legend 

CJ Pro::>O>ed NAA 

/:::. S02Monl!ots 

lliil S02 ~l!l::ili~.as 

2~ti!<S:o 

-•'" 
Cook and Will Counties 

Ail· Quality 

There are seven S02 monitors located in Cook and Will Counties. Monitoring data for these 

sites are listed below in Table 6. The 2008-2010 design values for all of the sites are well below 

the revised 1-hour NAAQS, except for the monitor at Lemont. As can been in Figure 12, the 

distribution of design values across northeastern illinois indicates that the Lemont monitor 

represents a "hot spot" due to impacts from local emission sources. 

Table 6- Cook and Will County Ail· Quality Data for 2008-2010 (ppb) 

AQSCode County Site Annual 991

" Percentiles Design 

2008 2009 2010 Value 

170310050 Cook Chicago- SE Police 35 19 21 25 

170310063 Cook Chicago- CTA 26 21 14 20 

170310076 Cook Chicago- Com Ed 26 24 20 23 

170311601 Cook Lemont 97 114 90 100 

170314002 Cook Cicero 43 29 31 34 

170314201 Cook Northbrook 13 17 15 15 

171970013 Will Joliet 56 32 24 37 

Emissions 

Table 7lists the major S02 emission sources (reported S02 emissions over 100 tons per year for 

at least one of the years from 2007 through 2009) within Cook and Will counties. The locations 

of these sources are shown in Figure 12. From Figure 12, there are three sources in the vicinity 

of the violating monitor in Lemont: Oxbow Midwest Calcining, CIT GO Petroleum, and Midwest 

Generation- Will County. It should be noted that all three nearby sources are located in Will 

County, although the Lemont monitor is located in Cook County. Overall, S02 emissions in 

Cook and Will counties have dropped by almost 50% since 2007, with the most significant 

reductions occurring at the two oil refineries (CITGO and Exxon Mobil). 

22 
Table 7- Cook and Will County Reported S02 Emissions for 2007-2009 

Repot1ed S02 Emissions 

County IDNumber Facility Name (Tons per Year) 

2007 2008 2009 

Cook 031012ABI Corn Products International Inc 1942.00 2203.00 991.00 

Cook 031069AAI Saint-Gobain Containers Inc 354.05 344.84 300.30 

Cook 031123ABP Congress Development Co 57.43 81.33 204.00 

Cook 031300AAJ Koppers Inc 846.80 823.17 705.38 

Cook 031600ADY Carmeuse Lime Inc 359.57 321.46 0.00 

Cook 031600AIN Midwest Generation -Crawford 8881.90 6626.90 7107.50 

Cook 031600AMI Midwest Generation- Fisk 4954.51 4485.561 4217.56 

Cook 031600CTF Saints Mary and Elizabeth Med. Center 0.07 0.10 125.01 

Will 197090AAI CITGO Petroleum Corp 14170.75 6135.86 336.62 

Will 197800AAA Exxon Mobil Oil Corp 22095.05 16404.03 1914.79 

Will 197803AAK Oxbow Midwest Calcining LLC 7153.21 6204.85 4990.62 

Will 197809AAO Midwest Generation- Joliet 20265.72 18281.72 17996.87 

Will 197810AAK Midwest Generation- Will County 17310.81 16496.78 12602.53 

Figure 12- Location of Major S02 Emission Sources in Cook and Will Counties 

23 
Meteo.-ology 

The Lemont monitor is located in Cook County, so the nearest NWS site is at Chicago's O'Hare 

Airport. Since the Lemont site is a similar distance from Lake Michigan as O'Hare airport, the 

effect of Lake Michigan on local wind directions should be comparable. Figure 13 shows the 

climatological wind rose for O'Hare Airport. Unlike the Peoria and Rockford wind roses shown 

previously, a higher frequency of wind directions occur at 0 'Hare from southerly through 

westerly, with a secondary maximum from the northeast. 

Figure 13- Chicago-O'Hare Airport Climatological Wind Rose 

Smtion#ft.ffi.W • CHICAG0'0'HARE INT'L ARPT, ll 

---- T'·¢,;.;.-

: 

L-----

~ w"'~~ 

' ,' 

: 

. 

. . 

24 
Figure 14 shows the pollution rose for the Lemont monitor, while Figure 15 is an aerial photo 

that shows the spatial relationship of major emission sources to the monitor. The pollution rose 

shows that the wind direction during exceedance hours is mostly from the west, which indicates 

likely contributions from Oxbow Midwest Calcining, and, to a lesser extent, CITGO Petroleum. 

With the close proximity of major sources upwind from the monitor on high concentration days, 

IEPA believes that nonattainment at the Lemont monitor is primarily due to these local sources. 

Figure 14 - Lemont Pollution Rose 

NW 

WNW. 

wsw>' 

sw' 

Wind Rose 

lemont Hours > 75 ppb 

2008-2010 

N 

NNW 0.0%~---.. , "'-.,NNE 

),i.O!O%· ~- ~--- _ 

\ 1.0.6%---.... _· _____ -

39,0%- , ___ 7'--

zp._q% 

s 

25 

NE 

ENE 

Wind data from lisle, IL 

SE Average wind direction = 268 degrees 
Figure 15 - Aeiial photo ofthe Lemont monitor and nearby Facilities 

Jurisdictional Boundaries 

TI1e Illinois EPA is responsible for air quality regulatory programs for every county in the state. 

Jurisdictional boundaries considered in this analysis are consistent with recommended geographic 

boundaries, or "presumptive boundary" definitions, outlined in U.S. EPA's guidance documentation. 

Boundaries in this study reflect the 2009 political township boundaries provided by the Property Tax 

Division of the Illinois Department of Revenue. Based on the geographic location of Lemont and the 

individual sources, it is expected that the coordination ofplam1ing activities required to address the 

nonattaiim1ent designation can be carried out in a cohesive manner. 

Recommendation 

Based on the factors discussed above, TI!inois recommends that Lemont Township in Cook 

County and DuPage and Lockport Townships in Will County be designated as nonattainment for 

the 2010 !-hour S02 NAAQS (see Figure 16). These three townships contain both the violating 

26 
monitor and the most culpable sources of S02 emissions impacting the Lemont monitor. 

Figure 16- Proposed S02 Nonattainment Area Boundary for Cook and Will Counties 

Madison County 

Ail· Quality 

There are three SOz monitors in the Metro-East area. Two of the monitors are located in western 

Madison County, while the third monitor is located in East St. Louis in St. Clair County. 

Monitoring data for all three sites is listed in Table 8. The 2008-2010 design values for the 

Wood River and East St. Louis monitors are well below the revised 1-hour NAAQS, while the 

design value for the South Roxana monitor exceeds the revised 1-hour NAAQS. The 2008 

through 2010 annual 991

h percentiles decreased at all three sites, with the most significant 

improvement occurring at the South Roxana monitor. 

27 
Table 8- Mett·o-East Area Air Quality Data fot· 2008-2010 (ppb) 

AQS Code Coul!tY Site Annual99'" Percentiles Design 

2008 2009 2010 Value 

171191010 Madison South Roxana 152 81 57 97 

171193007 Madison Wood River WTP 67 46 54 56 

171630010 St. Clair East St. Louis 35 30 31 32 

Emissions 

Table 9lists the major S02 emission sources (reported S02 emissions over 100 tons per year for 

at least one of the years from 2007 through 2009) in Madison County. The locations of these 

sources are shown in Figure 17. From Figure 17, there is only one source in proximity to the 

violating monitor in South Roxana: ConocoPhillips. S02 emissions in Madison County have 

decreased significantly during the 2007-2009 period. The largest reductions occurred at the 

ConocoPhillips oil refinery, which is located near the South Roxana monitor, and US Steel's 

Granite City Works. 

Table 9- Madison County Reported 802 Emissions for 2007-2009 

Reported S02 Emissions 

County IDNumber Facility Name (Tons per Year) 

2007 2008 2009 

Madison 119010AAE Alton Steel Inc 121.43 142.88 63.25 

Madison 119020AAE Dynegy Midwest Gen.- Wood River 6462.30 6873.20 9089.10 

Madison 119040ATN Gateway Energy & Coke Co LLC 0.00 0.00 580.34 

Madison 119090AAA ConocoPhillips Co 13629.96 12273.72 5761.00 

Madison 119813AAI US Steel- Granite City 6187.15 5612.67 1428.31 

28 
Figure 17- Location of Major S02 Emission Sources in Madison County 

Major S02 Emission Sources MACOUPIN MONTGOMERY 

in Madison County f----------"'.;_''=-,v-~,+--.,.,...,-L--..,--,JI 

ST. CLAIR 0 2 

Meteorology 

4 

BOND 

SMiles . 

The nearest NWS site to Madison County is Lambert Field in St. Louis. Figure 18 shows the 

climatological wind rose for Lambert Field. Unlike the wind roses previously shown, the most 

frequent wind directions are from the south through southeast, with a strong secondary maximum 

from the northwest. The IEPA considers the meteorological conditions at Lambert Field to 

generally be representative of conditions occurring in Madison County, although it is recognized 

that the South Roxana monitor is located on the flood plain of the Mississippi River and may 

experience some localized differences. 

29 
Figm·e 18 - St. Louis-Lambert Field Climatological Wind Rose 

Station #13994. ST LOU!S'LAMBERT !tiTl ARPT, MO 

', 

. . 1,l0i-rk~ .* 

' ' : 

' --- -~-----

: 

: 

' ' ----:-----

' ' ' 

Figure 19 shows the pollution rose for the South Roxana monitor, while Figure 20 is an aerial 

photo that shows the relationship of the one large source to the monitor. The pollution rose 

shows that the wind direction during exceedance hours is primarily from the northwest which 

aligns the nearby ConocoPhiliips refinery with the monitor location. With the proximity of this 

major nearby source to the monitor, IEPA concludes that emissions from this facility are 

primarily responsible for exceedances of the revised 1-hour S02 NAAQS at South Roxana. 

30 
Figm·e 19 - South Roxana Pollution Rose 

!;','.< 

w:;w 

w 

'NSW 

•w 

Wind Rose 

South Roxana Hours> 75 ppb 

ZOOS-2010 

,, !,\w M!.(n.- ~ .... \!};:,;;,-

ssw S>t 

M 

fM 

-

' 

DO 

'h6j !IH~l<~m E. St l()u'l ,, !\WMi!.~•·,id ~:r~:o;~~ • })l dtJ>f'<!r• 

Figm·e 20 -Aerial photo of the South Roxana Monitor and nearby Facility 

31 
Jurisdictional Boundaries 

l11e Illinois EPA is responsible for air quality regulatory programs for every county in the state. 

Jurisdictional boundaries considered in this analysis are consistent with recommended geographic 

boundaries, or "presumptive boundary" definitions, outlined in U.S. EPA's guidance documentation. 

Boundaries in this study reflect the 2009 political township boundaries provided by the Property Tax 

Division of the Illinois Department of Revenue. Based on the geographic location of Roxana and the 

individual sources, it is expected that the coordination of planning activities required to address the 

nonattaimnent designation can be carried out in a cohesive manner. 

Recommendation 

Based on the factors discussed above, lllinois recommends that Chouteau and Wood River 

Townships in Madison County be designated as nonattainment for the 201 0 !-hour S02 NAAQS 

(see Figure 21). These two townships contain both the violating monitor and the most culpable 

source of S02 emissions impacting the South Roxana monitor. 

Figure 21- Proposed S02 Nonattainment At·ea Boundary for Madison County 

i Proposed 502 Nonattainment 

· Area for Madison County 

32 

t"""' 

!!'=" 

' 51t<lci> 
Recommendations 

IEPA's recommendations for attainment/nonattainment boundary designations in lllinois for the 

20 I 0 revised !-hour S02 national ambient air quality standard are contained in Table I 0. 

Current air quality data collected by the IEPA indicates that the 20 I 0 revised primary S02 

NAAQS is not being met in the areas listed in Table I 0, and that they should be designated as 

nonattainment areas. The locations ofiEPA's recommended S02 nonattainment areas for the 

State of lllinois are shown in Figure 22. 

The Clean Air Act does not specify the geographic boundaries, size, or the extent to which 

source contributions would require that an area be designated as nonattainment for the 2010 

revised primary S02 standard, nor has U.S. EPA promulgated rules prescribing such. IEPA's 

recommendations are consistent with the guidance memorandum provided by U.S. EPA and are 

based on an evaluation of current air quality, the location and magnitude of S02 emission 

sources, and other factors. The IEPA recognizes that each of the factors considered in this 

evaluation, when evaluated individually, are not necessarily conclusive. Rather, IEPA's 

recommendations are based on consideration of all of the factors taken together. It is expected 

that the coordination of planning activities required to address the non attainment designations 

can be carried out in a cohesive manner. The data sources utilized in the preparation of this 

report are summarized in Table II. 

33 
Figure 22 

Proposed 502 

Nonattainment Areas r-----'-r----~,-j 

Legend 

Nonattainment Areas 

D Unclassifiable Areas 

34 
Table 10 

Recommended Attainment/Nonattainment Designations in Illinoisfor the 2010 

Revised Primary 1-hour S02 National Ambient Air Quality Standard 

County (Partial) Desij!;nation Name of Area 

Tazewell County: 

• Pekin and Cincinnati Townships Nonattainment Tazewell County 

• Remainder of Tazewell County Unclassifiable 

La Salle County: 

• La Salle Township Nonattainment La Salle County 

• Remainder of La Salle County Unclassifiable 

Cook County: 

• Lemont Township Nonattainment Cook County 

• Remainder of Cook County Unclassifiable 

Will County: 

• Lockport and DuPage Townships Non attainment Will County 

• Remainder of Will County Unclassifiable 

Madison County: 

• Chouteau and Wood River Townships Nonattainment Madison County 

• Remainder of Madison County Unclassifiable 

All Other Counties Unclassifiable Illinois 

35 
Table 11 

802 NAA Five Factor Documentation 

1.•·· '> .. . Factor. • ·.· ... · 1 >·... •>·.·· Data Analysis .. ,· ·.· I Data Sout"Ce .. ·•.·. ·. ··nateofStu~ 

1. Air Quality S02 2008-2010 Design Values !EPA BOA Database, 

at individual monitors Air Monitoring 2008-2010 

(statewide) Section 

2. Emissions Emission inventory information !EPA 2007-2009 

for so2 Reported Emissions, 2009 

3. Geography/Topography Statewide elevations Google Maps Data 2008 

illinois Department of 

4. Jurisdictional Boundaries illinois Department of Revenue, Property 

Revenue, Political Townships Tax Division, 2009 

Springfield, illinois 

5. Meteorology Weather patterns- Wind Roses National Weather 

and Pollution Roses. Service, Illinois State October 7, 2004 

1961- 1990 Climatologist Office 

36