USEPA,

Attachment

to

Exhibit

10,

Letter

to

Governor

Blagojevich

(August

18,

2008).

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

county

is

determined

to

be

contributing

to

the

violation

of

the

standard.

Where

EPA

intends

to

include

only

part

of

a

county

in

a

nonattainment

area,

we

have

indicated

the

boundaries

of

the

portion

of

the

county

that

will

be

included.

Following

this

table

is

a

discussion

of

each

area

and

the

basis

for

EPA's

intended

designations

and

then

a

description

of

the

data

EPA

examined.

EPA

intends

to

designate

as

attainment!

unclassifiable

all

other

Illinois

counties

or

parts

thereof

not

identified

in

the

table

below.

Area

Current

PM2.5

Illinois

Recommended

EPA'sIntended

Nonattainment

Area

Nonattainment

Counties

Nonattainment

Counties

Chicago-

Cook

Cook

Cook

Gary-

Du

Page

Du

Page

Du

Page

Kenosha,

Kane

Kane

Kane

IL-IN-WI

Lake

Lake

Lake

Mc

Henry

Mc

Henry

Mc

Henry

Will

Will

Will

Grundy:

Grundy:

Grundy:

Aux

Sable

Township

Aux

Sable

Township

Aux

Sable

Township

Goose

Lake

Twp.

Goose

Lake

Township

Goose

Lake

Township

Kendall:

Kendall:

Kendall:

Oswego

Townshio

Oswego

Townshio

Oswego

Townshio

Davenport-

None

None

Rock

Island

Rock

Island,

IA-IL

Paducah,

None

None

Massac

KY-IL

Saint

Louis,

Madison

Madison

Madison

MO-IL

Monroe

Monroe

Monroe

St

Clair

St

Clair

St

Clair

Randolph:

Randolph:

Randolph:

Baldwin

Townshio

Baldwin

Townshio*

Baldwin

Townshio

*

IllinOIS

recommended

a

slightly

smaller

partial

county

area,

excludmg

a

portIOn

of

BaldWin

Township

from

the

non

attainment

area.

EPA

intends

to

retain

the

entire

Baldwin

Township

in

the

non

attainment

area.

'EPA

designated

nonattainment

areas

for

the

1997

fine

particle

standards

in

2005.

In

2006,

the

24-hour

PM2.5

standard

was

revised

from

65

micrograms

per

cubic

meter

(average

of98'h

percentile

values

for

3

consecutive

years)

to

35

micrograms

per

cubic

meter;

the

level

of

the

annual

standard

for

PM2.5

remained

unchanged

at

15

micrograms

per

cubic

meter

(average

of

annual

averages

for

3

consecutive

years).

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

Pursuant

to

section

107(d)

of

the

Clean

Air

Act,

EPA

must

designate

as

nonattainment

thoseareas

that

violate

the

NAAQS

and

those

areas

that

contribute

to

violations.

The

technical

analysis

for

each

area

identifies

the

counties

with

monitors

that

violate

the

24-

hour

PM2.5

standard

and

evaluates

the

counties

that

potentially

contribute

to

fine

particle

concentrations

in

the

area.

EPA

has

evaluated

these

counties

based

on

the

weight

of

evidence

of

the

following

nine

factors

recommended

in

EPA

guidance

and

any

other

relevant

infonmation:

-

pollutant

emissions

-

air

quality

data

-

population

density

and

degree

of

urbanization

-

traffic

and

commuting

patterns

-

growth

-

meteorology

-

geography

and

topography

-

jurisdictional

boundaries

-

level

of

control

of

emissions

sources

Additional

background

information

on

each

of

the

nine

factors

can

also

be

found

in

the

background

section

below.

EPA

also

computed

a

Contributing

Emissions

Score

(CES)

for

each

county.

The

CES

is

a

metric

that

takes

into

consideration

emissions

data,

meteorological

data,

and

air

quality

monitoring

information

to

provide

a

relative

ranking

of

potential

impacts

of

counties

in

and

near

an

area

on

violating

monitors.

While

this

metric

provides

a

useful

synthesis

of

important

relevant

infonmation,

including

weighting

the

emissions

of

various

pollutants

according

to

estimates

of

the

relative

importance

of

each

pollutant,

the

CES

is

not

the

exclusive

variable

EPA

uses

to

consider

these

factors.

A

summary

of

the

CES

is

included

in

the

background

section,

and

a

more

detailed

descriptioncan

be

found

at

http://www.epa.gov/ttn/naaqslpm/pm252006techinfo.html#C.

Review

for

the

Illinois

Portion

of

the

Chicago-GaIT-Kenosha,

IL-IN-

WI

Metropolitan

Area

Discussion:

EPA

reviewed

relevant

information

for

the

ten

counties

(including

eight

counties

in

lIlinois)

partly

or

fully

within

the

area

designated

nonattainment

for

the

1997

standards

as

well

as

for

surrounding

counties.

There

are

violating

monitors

in

Cook

and

Will

Counties

and

in

Lake

County,

Indiana.

lIlinois

recommended

a

definition

of

the

2

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

EPA

also

examined

information

for

other

counties

within

and

adjacent

to

the

Combined

Statistical

Area

as

well

as

for

adjacent

counties.

The

bulk

of

emissions

and

population

are

captured

without

including

DeKalb,

Grundy,

Kankakee

and

Kendall

Counties,

since

these

counties

have

limited

emissions

and

population.

Nevertheless,

we

support

the

recommendation

by

the

Illinois

EPA

to

include

the

three

townships

in

Grundy

and

Kendall

counties

in

the

nonattainment

area

to

maintain

consistency

with

the

ozone

designations

and

the

prior

PM

25

designations

and

thereby

facilitate

planning,

as

well

as

to

include

slightly

more

emissions

in

the

planning

area.

Emissions

for

other

surrounding

counties

are

relatively

low,

and

no

other

factor

warranted

designating

these

other

counties

nonattainment.

Figure

1

is

a

map

of

the

counties

in

the

area

and

other

relevant

information

such

as

the

locations

and

design

values

of

air

quality

monitors,

the

metropolitan

area

boundary,

and

counties

reconnnended

as

nonattainment

by

the

States.

R¥!ne

sin

¥

Wmnebago

.

."

"".

e

L!,

Ii!l

~

La~/Ie

Illinois

Urit1stCXl

"'''

."

~

Iroq~S

•

Sin

reconvnendatXlo

for

nonatlilioolenl

-34

iii

Sla'.e

feconvnendation

for

partial

OOfIa:tainment

State

recorrvnendation

!of

a

differenl

metro

afea

Mon~or

\'ioIaliog

24-hc

PM2.5

NMOS

(preWnin.

2005-2007

design

vall.leS)

Mi.

Monitor

ana:ning

24.tlr

PM2.5

NMOS

(preIimin.

2005-2007

design

values)

Monitor

violating

24-h1

PM2.5

NMOS

(preli1lin.2005-2007

incomplete

design

values)

National

highways

~

2006

Combined

StaliStiCal

Area

~

PM25

Nonattainment

Alea

(1997

NMOS)

..

.L_

....

_

All

PM2.5

Nonaltainmenl

Areas

r.;

(1997

NMOS)

r+--t

Nonattainmenb'Mainteoanee

Area

~

fOf

8-hour

Ozone

I8J

EGU

....

ith

lotal

CAP

!ll'issions)

5.000

lortsIyear

In

2002

i&I

Othef

Point

Source

with

to:al

CAP

Ma'¥tall

emissions)

5.000

torIs/'fear

in

2002

-

Contribut;lgEmis~5coI'e(40~

Indiana

••.

Figure

1-

Note:

Map

produced

prior

to

Indiana's

nonattainment

recommendation

for

Lake

County,

Ind.

3

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

are

listed

in

descending

order

by

CES.

Table

I.

PM"

24-hour

Com

onent

EmISSions,

and

CESs.

County

State

CE5

PM2.5

PM

2S

PM

2

.

S

SO,

NOx

VOCs

NH,

Recommended

emissions

emissions

emissions

(tpy)

(tpy)

(tpy)

(tpy)

Nonauainment?

total

carbon

other

(tDY)

(tDY)

(tDY)

Cook,IL

Ves

100

10081

5,407

4,674

35,354

175.267

152.288

4,550

Lake

IN

No

100

7079

1.219

5,861

39,500

54,203

24679

3,784

Will

IL

Ves

95

5432

1236

4195

78792

46028

19886

1407

Porter

IN

No

41

3901

719

3183

24,458

29930

9,795

909

DuPaee,IL

Ves

16

2075

1259

816

2,013

36880

29541

1.385

JaSDer

IN

ND

14

2,641

280

2,360

40,723

20,104

3,367

2929

Kankakee

IL

No

9

1,660

419

1242

366

7,351

6830

1,699

Kane,IL

Ves

4

1997

733

1263

1,037

16528

15,578

1,293

Grundy.IL

Partial

3

1

lOS

248

857

362

4057

4223

1

027

Lake

IL

Ves

3

2657

1070

1

587

14,719

29478

32778

747

Kendall

1L

Partial

2

811

230

581

351

3697

3693

753

McHenrY.IL

Ves

1

2102

634

1468

592

9493

10596

1,224

Kenosha,

WI

No

I

I

489

460

1030

33,988

15,967

7,857

647

Within

lIIinois,

emissions

are

highest

in

Cook,

Will,

DuPage,

Lake,

Kane,

and

McHenry

Counties.

Emissions

are

moderate

in

Kankakee,

Grundy,

and

Kendall

Counties.

Factor

2:

Air

quality

data

The

24-hour

PM

2

.

5

design

values

for

counties

in

the

Chicago

area

are

shown

in

Table

2.

Table

2.

Air

Q

ualily

Data

County

State

Design

Values

Design

Values

Recommended

2004-06

(~g/m)

2005-07

(~g/m)

Nonattainment?

Cook,IL

Yes

42

40

Lake

IN

No

38

37

Will,IL

Yes

36

37

Porter,

IN

No

31

32

DuPage,IL

Yes

33

35

Kane,IL

Yes

32

35

GrundY,IL

Partial

Lake,IL

Yes

33

35

Kendall,IL

Partial

McHenry,IL

Yes

31

31

For

purposes

of

its

review,

EPA

used

data

available

from

the

Chemical

Speciation

Network

and

the

Interagency

Monitoring

of

Protected

Visual

Environments

(IMPROVE)

4

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

llg/m

3

of

sulfate,

3.1

Ilg/m3

of

organic

particles,

and

OJ

Ilg/m3

of

miscellaneous

inorganic

particulate.

These

estimates

were

used

for

weighting

of

the

emissions

of

different

pollutants

in

calculating

the

contributing

emissions

scores.

Factor

3:

Population

density

and

degree

of

urbanization

(includingcommercial

development)

Table

3

shows

the

2005

population

for

each

county

in

the

area

being

evaluated,

as

well

as

the

population

density

for

each

county

in

that

area.

Population

data

give

an

indication

of

whether

it

is

likely

that

population-based

emissions

might

contribute

to

violations

of

the

24-hour

PM

25

standards.

T

hi

3

PI'

ae.

cou

atlOo

County

State

2005

2005

Population

Recommended

Population

Density

(pop/sq

Nonattainment?

mj)

Cook

IL

Yes

5303943

5545

Lake

IN

No

491,706

980

Will

IL

Yes

642,625

758

Porter

IN

No

157,408

375

DuPa.e,IL

Yes

931,219

2769

Kane,IL

Yes

483,208

923

Grundy,IL

Partial

43,736

102

Lake,

IL

Yes

704,086

1504

Kendall

IL

Partial

79,597

247

McHenry,IL

Yes

304,701

499

Kankakee

No

107,824

158

Within

Illinois,

the

counties

with

the

greatest

population

are

Cook,

DuPage,

Lake,

Will,

Kane,

and

McHenry

Counties.

The

populations

and

population

densities

of

Kankakee,

Grundy,

and

Kendall

Counties

are

significantly

lower.

Factor

4:

Traffic

and

commuting

patterns

hi

ffi

dC

Ta

e

4.

Tra

Ie

an

ommutmg

Patterns

County

State

2005

Number

Percent

Number

Percent

Recommended

VMT

Commuting

to

Commuting

to

Commuting

Commuting

Nonattainment?

(10'

mil

any

violating

any

violating

into

statistical

into

statistical

counties

counties

area

area

Cook,IL

Yes

35294

2,113930

89

2,352,t20

99

Lake

IN

No

4588

t93610

93

206,350

99

WiII,IL

Yes

4,605

185,690

77

239,340

99

Porter

IN

No

I

677

25470

35

70940

98

DuPa.e

IL

Yes

8802

161940

35

464,630

99

Kane,IL

Yes

3,517

36,290

19

190,780

99

5

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

PM2.5

NAAQS

are

shown

in

boldface.

All

counties

in

this

table

are

highly

integrated

into

the

Chicago

area.

Factor

5:

Growth

rates

and

patterns

Table

5

below

shows

population,

population

growth,

VMT

and

VMT

growth

for

counties

that

are

included

in

the

Chicago

area.

Counties

are

listed

in

descending

order

based

on

VMT

growth

between

1996

and

2005.

Table

5.

Population

and

YMT

Growth

and

Percent

Chan

e.

County

Population

Population

%

2005

YMT

YMT

%

change

(2005)

change

(2000-05)

(10'

mil

(1996-05)

Kane

IL

483,208

18

3,517

364

McHenry,IL

304,701

16

2104

196

Kendall

IL

79597

44

678

166

Will,IL

642,625

26

4605

135

Lake,IL

704,086

9

6,016

82

DuPage,IL

931,219

3

8802

43

Grundv,IL

43736

16

623

30

Porler,

IN

157,408

7

1,677

10

Lake

IN

491

706

1

4588

0

Cook,IL

5,303,943

-I

35,294

-14

The

growth

rates

are

not

expected

to

yield

significant

changes

in

the

distribution

of

population

in

the

area,

so

this

factor

did

not

significantly

influence

the

decision-making

process.

Factor

6:

Meteorology

(weather/transport

patterns)

The

pollution

rose

for

the

Chicago

area

is

provided

in

the

map

above.

Winds

on

high

concentration

days

predominantly

come

from

the

southwest

and

southeast,

but

it

is

appropriate

to

include

counties

in

all

directions

trom

the

violations.

Factor

7:

Geography/topography

(mountain

ranges

or

other

air

basin

boundaries)

The

Chicago

area

does

not

have

any

geographical

or

topographical

barriers

significantly

limiting

air-pollution

transport

within

its

air

shed.

Therefore,

this

factor

did

not

playa

significant

role

in

the

decision-making

process.

Factor

8:

Jurisdictional

boundaries

(e.g.,

existing

PM

and

ozone

areas)

6

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

Townships

in

Grundy

County,

and

Oswego

Township

in

Kendall

County.

Designating

a

nonattainment

area

matching

these

boundaries

will

facilitate

planning.

Factor

9:

Level

of

control

of

emission

sources

The

emission

estimates

on

Table

I

include

any

control

strategies

implemented

by

the

States

in

the

Chicago

area

before

2005

that

may

influence

emissions

of

any

component

of

PM25

emissions

(i.e.,

total

carbon,

S02,

NOx,

and

crustal

PM

2

.

s

).

Review

for

the

Davenport-Moline-Rock

Island

Metropolitan

Statistical

Area

Discussion:

The

Davenport-Moline-Rock

Island

area

is

currently

designated

attainment

for

PM2.s.

A

monitor

in

Davenport

(Scott

County)

is

showing

violations

of

the

standard.

Illinois

recommended

including

no

part

of

Illinois

in

the

nonattainment

area.

EPA

reviewed

relevant

information

for

the

four

counties

in

the

metropolitan

statistical

area

and

for

surround

ing

counties.

EPA

believes

that

the

nonattainment

area

should

include

Rock

Island

County

in

Illinois.

Rock

Island

County

has

moderate

emissions

that

commonly

are

blown

toward

the

violating

monitor

is

Scott

County.

We

also

believe

that

sufficient

commuting

occurs

between

Rock

Island

County

and

Scott

County

that

Rock

Island

County

must

be

considered

an

integral

part

of

the

Davenport

area.

EPA

recognizes

that

emissions

in

close

proximity

to

the

monitor

may

make

an

important

contribution

to

the

violations.

Indeed,

EPA

recognizes

the

possibility

that

reduction

of

the

emissions

close

to

the

monitor

may

suffice

to

address

the

violation.

Nevertheless,

our

obligation

under

Clean

Air

Act

section

107

in

defining

a

non

attainment

area

is

to

identifY

the

area

that

is

violating

the

standard

and

the

area

that

is

contributing

to

the

violation.

The

area

that

contributes

to

the

violation

is

then

included

in

the

planning

area

evaluated

for

measures

for

attaining

the

standard.

Even

if

the

state

already

suspects

that

its

control

strategy

will

focus

on

sources

in

the

immediate

vicinity

of

the

violating

monitor,

EPA

must

apply

a

nonattainment

designation

to

the

entire

area

that

contributes

to

the

violation,

such

that

the

SIP

planning

will

address

the

entire

contributing

area.

Furthermore,

the

available

evidence

suggests

that

local

emissions

contribute

only

a

fraction

of

the

concentrations

in

Davenport.

A

much

larger

fraction

of

the

concentrations

in

Davenport

arise

from

emissions

farther

from

the

monitor.

EPA

believes

that

an

important

component

of

these

concentrations

arises

from

a

contribution

from

emissions

throughout

the

Quad

Cities

area.

While

the

impact

of

Rock

Island

County

appears

to

be

7

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

nonattainment

area.

Figure

2

is

a

map

of

the

counties

in

the

area

and

other

relevant

information

such

as

the

locations

and

design

values

of

air

quality

monitors,

the

metropolitan

area

boundary.

Iowa

did

not

make

formal

recommendations,

and

Illinois

recommended

that

no

Illinois

counties

be

included,

so

this

map

shows

no

state

recommended

nonattainment

area

.

Iowa

~ar

Figure

2

Wa~en

"

Illinois

•

State

IE!CClfTIII'leOOlion

br

nonanainmeo1

EJ

Stale

~tioo

tor

partial

nonattaimnefll

Stale

rec:ornmend.alion

for

a

dflI'ereflt

metrO

aru

MoniIoI'

Yiola':ing

24.1'

...

PM2.5

NMOS

(preilTWl.

~2001

design

values)

Mon.101

attaining

24.hf

PM2.5

NMOS

(Pfelimil,

2005-2001

desgn

values)

Mon:101

vioIa:ing

24-hr

PM2.5

NMOS

(Pfeimrl

~2007

ioc:ompIete

design

values)

N<Ilion<IIhighways

c::::::J

2006

Core

Baseij

Stmtical

Afeil

~

PM2.5

Nonanairunenl

fvea

(1997

NMOS)

_

All

PM2.S

Nona!lainmenl

Areas

(1997

NMOS)

r+--I

NonanainmenllMalrtenance

Area

~

for

8-hour

O:one

l8J

EGUwlthlOOllW

emissilns

>

5.000

Ionslyear

in

2002

@

Other

Point

SCuce

with

total

CAP

emissOls>

5,000

tonslyear

in

2002

-

ContribWng

emr"sS'&lsteore

(40

units)

Factor

1:

Emissions

data

Table

1

shows

emissions

of

PM

2

.

5

components

(given

in

tons

per

year)

and

the

CESs

for

potentially

contributing

counties

in

the

Quad

Cities

area.

Counties

are

listed

in

descending

order

by

CES.

Table

I.

PM,.,

24-hour

Component

Emissions,

and

CESs.

8

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

Clinton,IA

No

52

2,711

354

2,357

11,506

13,217

11,503

4,870

Rock

Island,

IL

No

27

932

269

663

2,169

6,140

7,359

664

Hemv,IL

No

7

1,273

252

1,021

268

6,648

3,431

2,805

Mercer,IL

No

4

793

149

644

133

1,120

1,469

1,026

Rock

Island

County

has

a

substantial

fraction

of

the

area's

emissions.

Factor

2:

Air

quality

data

The

24-hour

PM

2

.

5

design

values

for

counties

in

the

Quad

Cities

area

are

shown

in

Table

2.

Table

2.

Air

Ouality

Data

County

State

Design

Values

Design

Values

Recommended

2004-06

2005-07

Nonattainment?

(~g/m])

(~g/m])

Scott,IA

No

recommendation

32

37

Rock

Island

IL

No

30

31

Henry,IL

No

Mercer

IL

No

Muscatine,

IA

No

recommendation

34

36

Clinton,

IA

No

recommendation

34

32

For

purposes

of

its

review,

EPA

used

data

available

from

the

Chemical

Speciation

Network

and

the

Interagency

Monitoring

of

Protected

Visual

Environments

(IMPROVE)

network

to

estimate

the

composition

of

fine

particle

mass

on

days

with

the

highest

fine

particle

concentrations.

On

high

concentration

days

during

cold

weather

months

in

this

area,

EPA

found

on

average

a

total

urban

contribution

of7.1

/lg/m

3

,

consisting

of2.0

/lg/m

3

of

sulfate,

2.5

/lglm

3

of

nitrate,

2.3

/lglm

3

of

organic

particles,

and

0.3

/lglm

3

of

miscellaneous

inorganic

particulate.

On

high

concentration

days

during

warm

weather

months

in

this

area,EPA

found

on

average

a

total

urban

contribution

of4.3

/lglm

3

,

consisting

of3.9

/lglm

3

of

sulfate

and

0.4

/lglm

3

of

organic

particulate

emissions.

These

estimates

were

used

for

weighting

of

the

emissions

of

different

pollutants

in

calculating

the

contributing

emissions

scores.

Factor

3:

Population

density

and

degree

of

urbanization

(including

commercial

development)

Table

3

shows

the

2005

population

for

each

county

in

the

area

being

evaluated,

as

well

as

the

population

density

for

each

county

in

that

area.

Population

data

give

an

indication

of

9

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

Density

(pop!sq

mil

Scott,IA

No

recommendation

161,170

345

Rock

Island

1L

No

147,454

327

Henrv,lL

No

50508

61

Mercer,IL

No

16,840

30

Muscatine,

IA

No

recommendation

42,567

95

Clinton,lA

No

recommendation

49,744

70

Rock

Island

County

has

a

substantial

fraction

of

the

area's

population.

Other

Illinois

counties

have

substantially

lower

populations.

Factor

4:

Traffic

and

commuting

patterns

Table

4.

Traffic

and

Commuting

Patterns

County

State

2005

Number

Percent

Number

Percent

Recommended

YMT

Commuting

to

Commuting

to

Commuting

Commuting

Nonattainmenl?

(10'

mil

any

violating

any

violating

into

into

counties

counties

statistical

statistical

area

area

No

Scott,

IA

recommendation

1614

61500

79

74020

95

Rock

Island

IL

No

1,313

14,240

20

67530

97

Henrv,lL

No

695

1,870

8

22,340

91

Mercer,lL

No

135

1,200

15

6,570

85

No

C1inton,IA

recommendation

423

2610

II

3600

15

No

Muscatine,

fA

recommendation

372

17,330

85

1,060

5

The

listing

of

counties

on

Table

4

reflects

a

ranking

based

on

the

number

of

people

commuting

to

other

counties.

The

percentage

of

Rock

Island

County

commuters

commuting

into

Scott

County,

Iowa,

is

moderate

but

sufficient

to

view

Rock

Island

County

as

integrated

into

a

Quad

Cities

area.

Factor

5:

Growth

rates

and

patterns

Table

5

below

shows

population,

population

growth,

YMT

and

YMT

growth

for

counties

that

are

included

in

the

Quad

Cities

area.

Counties

are

listed

in

descending

order

based

on

YMT

growth

between

1996

and

2005.

Table

5.

population

and

YMT

Growth

and

Percent

Change.

Location

Population

Population

2005

YMT

YMT

(2005)

%

change

(10'

mil

%

change

(2000-051

(1996-20051

Muscatine

fA

42567

2

372

43

Clinton,lA

49,744

-I

423

39

10

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

Factor

6:

Meteorology

(weather/transport

patterns)

The

pollution

rose

for

the

Quad

Cities

area

is

provided

in

the

map

above.

The

pollution

rose

for

this

area

suggests

that

Rock

Island

County

is

upwind

of

Davenport

on

most

high

concentration

days.

Factor

7:

Geography/topography

(mountain

ranges

or

other

air

basin

boundaries)

The

Quad

Cities

area

does

not

have

any

geographical

or

topographical

barriers

significantly

limiting

air-pollution

transport

within

its

air

shed.

Therefore,

this

factor

did

not

playa

significant

role

in

the

decision-making

process.

Factor

8:

Jurisdictional

boundaries

(e.g.,

existing

PM

and

ozone

areas)

Bi-State

Regional

Commission

represents

the

Metropolitan

Planning

Organization

(MPO)

for

urbanized

area

transportation

planning

in

the

Quad

Cities

area.

The

MPO

serves

Henry,

Mercer,

and

Rock

Island

Counties

in

Illinois

and

Scott

and

Muscatine

Counties

in

Iowa.

Its

web

site

is:

www.bistateonline.org.This

suggests

that

the

MPO

is

already

engaged

in

multi-county

planning,

which

would

facilitate

multi-county

SIP

planning.

Factor

9:

Level

of

control

of

emission

sources

The

emission

estimates

on

Table

I

include

any

control

strategies

implemented

by

the

States

in

the

Quad

Cities

area

before

2005

that

may

influence

emissions

of

any

component

ofPM

25

emissions

(i.e.,

total

carbon,

S02,

NOx,

and

crustal

PM

2s

).

Review

for

the

Paducah-Mayfield

Combined

Statistical

Area

The

only

monitor

in

the

Paducah-Mayfield

area

is

in

McCracken

County,

Kentucky.

Kentucky

requested

concurrence

on

several

claims

that

elevated

concentrations

were

attributable

to

exceptional

events,

in

particular

due

to

wildfires.

EPA

reviewed

this

request,

denied

some

of

these

claims,

and

concluded

that

the

Paducah

area

is

violating

the

24-hour

PM2.s

standard.

The

Paducah-Mayfield

combined

statistical

area

includes

one

county

in

Illinois:

Massac

County.

This

county

has

a

relatively

high

fraction

of

the

emissions

in

the

area,

and

the

winds

commonly

blow

from

Massac

County

into

McCracken

County

on

high

11

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

that

this

information

may

not

be

reflected

in

this

analysis.

EPA

will

consider

additional

information

on

emission

controls

in

making

final

designation

decisions.

In

cases

where

specific

plants

already

have

installed

emissioncontrols

or

plan

to

install

such

controls

in

the

near

future,

EPA

requests

additional

information

on:

-

the

plant

name,

city,

county,

and

township

-

identification

of

emission

units

at

the

plant,

fuel

use,

and

megawatt

capacity

-

identification

of

emission

units

on

which

controls

will

be

installed,

and

units

on

which

controls

will

not

be

installed

-

identification

of

the

type

of

emission

control

that

has

been

or

will

be

installed

on

each

unit,

the

date

on

which

the

control

device

became

/

will

become

operational,

and

the

emission

reduction

efficiency

ofthe

control

device

-

the

estimated

pollutant

emissions

for

each

unit

before

and

after

implementation

of

emission

controls

-

whether

the

requirement

to

operate

the

emission

control

device

will

be

federally

enforceable

by

December

2008,

and

the

instrument

by

which

federal

enforceability

will

be

ensured

(e.g.

through

source-specific

SIP

revision,

operating

permit

requirement,

consent

decree)

In

the

designation

process

for

the

1997

PM2.5

standards,

in

some

cases

EPA

identified

a

nearby

county

as

contributing

to

a

violating

monitor,

and

it

was

determined

that

a

very

high

percentage

of

the

county's

emissions

came

from

a

large

power

plant.

In

certain

cases,

EPA

concluded

that

only

the

portion

of

the

county

including

the

source

with

the

contributing

emissions

needed

to

be

designated

as

nonattainment.

If

Illinois

believes

that

a

similar

situation

exists

for

Massac

County,

the

State

should

provide

EPA

the

necessary

information

to

demonstrate

that

the

source

dominates

the

overall

county

emissions

and

to

identify

a

reasonable

partial

county

boundary.

In

its

designations

for

the

1997

standards,

EPA

included

portions

of

counties

in

a

number

of

cases

in

which

large

sources

dominated

the

emissions

from

the

county,

such

that

EPA

concluded

that

the

relevant

portion

of

the

county

was

the

only

portion

of

the

county

that

contributed

to

the

violations.

If

Illinois

believes

this

is

the

case

in

Massac

County,

for

example

if

Illinois

believes

that

only

a

single

township

containing

the

Joppa

Steam

plant

contributes

to

violations

in

Paducah,

Illinois

should

provide

the

information

necessary

to

support

this

view.

EPA

also

examined

information

for

other

Illinois

counties

around

the

Paducah-

Mayfield

area.

These

other

counties

have

relatively

low

emissions,

and

no

other

factor

warrants

their

inclusion

in

the

Paducah-Mayfield

nonattainment

area.

12

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

Missouri

"

Illinois

.......

Kentucky

~

""!"'"

""~

C"!'"

'>?'

""!!'"

r"ill

""'!'"

G,,_

.....

""""',

Tennessee

l!I~r~bparWi~

Sta:!

~Iora~

metroarta

MonO:lr

W::il¥.rg

24«

PUl.5

NAAOS

(p'eiTWI.

2lXlS-2001

cIesign

vakJes)

McInilDr

aIWWlg

2:.«

Pl.!2.5

AAo\QS

(pl'd1WI.

2lXlS-2007

de'sqI

vMIts)

Uonilor

'o'lClIattlg

244w

PU2.5

NMOS

(prei'nirL

2IXlS-2007

~

design

vales)

N

.....

-.,.

Cl

2O'lS

CorrQned

Stat:s:aI

Ate,

~

PM2.5

NonallWlmett

Alea

(1991

NMOS)

AI

PM2.S

NonattainmenI

AIm;

-

(1997NAAOS)

r+--i

NonatlaM'let\tJ'Mai'I1enanc:e

Area

""""---+-'

lor

a-n:u

<>tone

EGU

wi1110Ul

CAP

181

t/M$iOn$

;>

5.000

10Mtye~

in

2002

Ol!ler

Poill

Source

witllOlJI

CAP

\&I

en'lIS$IOI'lS

»

5.000

1MSfye3f

in

2002

-

ContmltJng

EmlssloM

SCOIe

liO

~

,

Figure

3

Factor

1:

Emissions

data

Table

I

shows

emissions

of

PM2.S

components

(given

in

tons

per

year)

and

the

CESs

for

potentially

contributing

counties

in

the

Paducah

area.

Counties

are

listed

in

descending

order

by

CES.

dCES

E.

T

bl

I

PM

24

h

C

ae

'.5

-

our

omponent

miSSions,

an

s.

County

State

CES

PM2.5

PM

2

.5

PM

25

SO,

NOx

VOCs

NH,

Recommended

emissions

emissions

emissions

(lpy)

(tpy)

(tpy)

(tpy)

Nonattainment?

total

carbon

other

(tov)

(tov)

(tov)

McCracken

KY

No

100

I

339

293

1,046

38,956

24803

6661

366

Massac

IL

No

66

1958

159

1,799

26,884

12,369

2,612

417

Graves

KY

No

6

797

278

520

413

1,735

1,867

2,538

Ballard,

KY

No

5

596

140

456

927

2,785

1,661

855

Livingston,

KY

No

3

318

121

197

337

2

155

1,200

239

13

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

The

24-hour

PM

25

design

values

for

counties

in

the

Paducah

area

are

shown

in

Table

2.

The

design

value

of

McCracken

County,

Kentucky

is

above

the

2006

PM

25

standard.

There

is

no

PM

2

.

5

air

quality

data

for

the

other

area

counties.

Table

2.

Air

Quality

Data

County

State

Design

Values

Design

Values

Recommended

2004-06

2005-07

Nonattainment?

(~g1ml)

(~g1m])

McCracken,

KY

No

33

36

Massac

IL

No

Graves,

KY

No

Ballard,

KY

No

Livineston

KY

No

For

purposes

of

its

review,

EPA

used

data

available

from

the

Chemical

Speciation

Network

and

the

Interagency

Monitoring

of

Protected

Visual

Environments

(IMPROVE)

network

to

estimate

the

composition

offine

particle

mass

on

days

with

the

highest

fine

particle

concentrations.

On

high

concentration

days

during

cold

weather

months

in

this

area,

EPA

found

on

average

a

total

urban

contribution

of4.3

llg/m

3

,

consisting

of

0.9

llg/m

3

of

sulfate,

2.2

llg!m

3

of

nitrate,

1.2

llg/m

3

of

organic

particles,

and

no

miscellaneous

inorganic

particulate.

On

high

concentration

days

during

warm

weather

months

in

this

area,

EPA

found

on

average

a

total

urban

contribution

of5.2

llg!m

3

,

consisting

of3.0

llg!m

3

of

sulfate

and

2.211g!m

3

of

organic

particulate

emissions.

These

estimates

were

used

for

weighting

of

the

emissions

of

different

pollutants

in

calculating

the

contributing

emissions

scores.

Factor

3:

Population

density

and

degree

of

urbanization

(including

commercial

development)

Table

3

shows

the

2005

population

for

each

county

in

the

area

being

evaluated,

as

well

as

the

population

density

for

each

county

in

that

area.

Population

data

give

an

indication

of

whether

it

is

likely

that

population-based

emissions

might

contribute

to

violations

of

the

24-hour

PM2.5

standards.

Table

3.

Population

County

State

2005

2005

Recommended

Population

Population

Nonanainment?

Density

(pop/sq

mil

McCracken

KY

No

64,690

241

Massac,lL

No

15,225

63

Graves

KY

No

37,650

68

Ballard

KY

No

8,262

30

14

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

P

ffi

dC

T

bl

a

e

4.

Tra

IC

an

ammutme:

attems

County

State

2005

Number

Percent

Number

Percent

Recommended

VMT

Commuting

to

Commuting

to

Commuting

Commuting

Nonattainment?

(10.

mil

any

violating

any

violating

into

into

statistical

counties

counties

statistical

area

area

McCracken,

KY

No

832

24,200

84

26,830

93

Graves,

KY

No

435

2,350

15

\2,880

83

Massac,IL

No

225

\,950

30

5,860

90

Livingston

KY

No

\74

\

770

4\

3,580

82

Ballard,

KY

No

\02

1290

35

3,380

92

The

listing

of

counties

on

Table

4

reflects

a

ranking

based

on

the

number

of

people

commuting

to

other

counties.

A

modest

number

of

people

from

Massac

County

commute

into

McCracken

County.

Factor

5:

Growth

rates

and

patterns

Table

5

below

shows

population,

population

growth,

YMT

and

YMT

growth

for

counties

that

are

included

in

the

Paducah

area.

Counties

are

listed

in

descending

order

based

on

YMT

growth

between

1996

and

2005.

Ch

h

dP

dVMTG

T

bl

5

PI'

ae.

oou

atlon

an

roW!

an

ercent

ane:e.

County

Population

Population

2005

VMT

VMT

(2005)

%

change

(10.

mil

%

change

(2000-05)

(1996-2005)

McCracken

KY

64,690

-\

832

26

Massac,IL

\5,225

I

225

25

Graves,

KY

37,650

2

435

2\

Ballard

KY

8,262

-1

102

\2

Livingston,

KY

9,783

0

174

56

The

growth

rates

are

not

expected

to

change

the

population

distribution

of

the

area

significantly

during

the

SIP

planning

time

horizon.

Factor

6:

Meteorology

(weather/transport

patterns)

A

pollution

rose

for

the

Paducah

area

is

provided

in

the

map

above.

Both

the

pollution

roses

and

the

trajectory

frequency

information

suggest

that

emissions

from

the

full

range

of

directions,

including

from

the

direction

of

Massac

County,

contribute

to

PM2.5

on

high

concentration

days

in

Paducah.

Factor

7:

Geography/topography

(mountain

ranges

or

other

air

basin

boundaries)

15

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

The

Paducah

maintenance

area

from

its

former

one-hour

ozone

designation

was

comprised

of

Livingston

and

Marshall

Counties

in

Kentucky.

No

portion

oflllinois

was

in

the

Paducah

ozone

nonattainment

area.

Factor

9:

Level

of

control

of

emission

sources

The

emission

estimates

on

Table

I

include

any

control

strategies

implemented

by

the

States

in

the

Paducah

area

before

2005

that

may

influence

emissions

of

any

component

of

PM2.5

emissions

(i.e.,

total

carbon,

S02,

NOx,

and

crustal

PM

2

.5).

Review

for

the

Saint

Louis

Combined

Statistical

Area

Discussion:

EPA

reviewed

relevant

information

for

the

nine

counties

(including

four

counties

in

Illinois)

partly

or

fully

within

the

area

designated

nonattainment

for

the

1997

standards

as

well

as

for

surrounding

counties.

There

are

violating

monitors

in

Madison

County.

Illinois

recommended

a

definition

of

the

nonattainment

area

for

the

2006

standards

that

is

similar

to

the

boundaries

that

were

established

for

the

1997

standards,

including

Madison,

Monroe

and

St.

Clair

Counties

along

with

a

portion

of

Randolph

County.

Illinois

recommended

that

the

nonattainment

area

for

the

2006

standards

differ

from

the

nonattainment

area

for

the

1997

standards

by

the

exclusion

of

the

portion

of

Baldwin

Township

in

Randolph

County

that

is

west

of

the

Kaskaskia

River.

EPA

concurs

with

Illinois's

recommendation

to

include

Madison,

Monroe,

and

St.

Clair

Counties

in

the

St.

Louis

nonattainment

area.

However,

EPA

believes

that

all

of

Baldwin

Township

of

Randolph

County

should

be

included

as

well.

The

mostimportant

factor

influencing

this

judgment

is

the

factor

relating

to

jurisdictional

boundaries.

The

inclusion

of

a

full

township

will

make

nonattainment

requirements

easier

to

administer,

since

information

on

emissions

and

source

locations

are

more

readily

available

on

a

township

basis

than

with

respect

to

a

specially

defined

subset

of

the

township.

Furthermore,

EPA

believes

that

establishment

of

a

nonattainment

area

that

fully

matches

the

non

attainment

area

established

for

the

1997

standards

would

simplify

nonattainment

planning

by

assuring

that

identical

requirements

apply

for

an

identical

area.

At

the

same

time,

as

addressed

in

more

detail

in

our

documentation

of

our

designations

for

the

1997

standards,

Baldwin

Township

contains

almost

all

of

the

emissions

and

therefore

makes

almost

the

entirety

of

the

contribution

of

Randolph

County

to

the

violations,

so

that

a

designation

of

just

Baldwin

Township

as

nonattainment

will

suffice

to

address

the

contribution

of

this

portion

ofthe

area.

16

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

effective

NOx

control

equipment.

EPA

welcomes

any

further

relevant

information

that

Illinois

may

have.

EPA

will

consider

additional

information

on

emission

controls

in

making

final

designation

decisions.

In

cases

where

specific

plants

already

have

installed

emission

controls

or

plan

to

install

such

controls

in

the

near

future,

EPA

requests

additional

information

on:

-

the

plant

name,

city,

county,

and

township

-

identification

of

emission

units

at

the

plant,

fuel

use,

and

megawatt

capacity

-

identification

of

emission

units

on

which

controls

will

be

installed,

and

units

on

which

controls

will

not

be

installed

-

identification

of

the

type

of

emission

control

that

has

been

or

will

be

installed

on

each

unit,

the

date

on

which

the

control

device

became

/

will

become

operational,

and

the

emission

reduction

efficiency

of

the

control

device

-

the

estimated

pollutant

emissions

for

each

unit

before

and

after

implementation

of

emissioncontrols

-

whether

the

requirement

to

operate

the

emission

control

device

will

be

federally

enforceable

by

December

2008,

and

the

instrument

by

which

federal

enforceability

will

be

ensured

(e.g.

through

source-specific

SIP

revision,

operating

permit

requirement,

consent

decree)

EPA

reviewed

the

relevant

information

for

other

counties

within

the

combined

statistical

area

as

well

as

counties

adjacent

to

the

combined

statistical

area

in

order

to

determine

the

appropriate

nonattainment

area.

Sangamon

County

has

moderate

emissions

but

is

rarely

upwind

on

days

with

elevated

24-hour

PM

2

.

5

concentrations.

Other

Illinois

counties

in

or

near

the

combined

statistical

area

have

relatively

low

emissions,

and

no

other

factor

warranted

inclusion

of

the

counties

in

the

nonattainment

area.

Figure

4

is

a

map

of

the

counties

in

the

area

and

other

relevant

information

such

as

the

locations

and

design

values

of

air

quality

monitors,

the

metropolitan

area

boundary,

and

the

counties

recommended

as

nonattainment

by

the

states.

17

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

Missouri

.u

•

~

PLl2.S~Aru

(1997

NMOS)

AlPM2.S~""'US

-

(1iiI

NMOS)

o+--i---""

~

b'S-Nu0ZlN

EGUwil:tI_CAP

o

tmISSions

~

5.000

\CItlSIyNf

i'l2002

@

or...

Pont

Sourt:e

_IIQI

CAP

emissclns

>

5.000

IOlIS1)oHf

'"

2002

-

Col'Iriluting

Emissions

Scote

tlO

II'I!!J

..----,.,..--:'

.'

,

Figure

4

Factor

1:

Emissions

data

Table

1

shows

emissions

of

PM

2

.

5

components

(given

in

tons

per

year)

and

the

CES

for

potentially

contributing

counties

in

the

St.

Louis

area.

Counties

that

are

part

of

the

St.

Louis

nonattainment

area

for

the

1997

PM2.5

NAAQS

are

shown

in

boldface.

Counties

are

listed

in

descending

order

by

CES.

dCES

E

T

bl

I

PM

24

h

C

ae.

,.5

-

our

om

onent

miSSIons,

an

County

State

CES

PM,.5

PM

Z

.

5

PM

1

.

5

SO,

NOx

VOCs

NH,

Recommended

emissions

emissions

emISSIons

(tpy)

(tpy)

(tpy)

(tpy)

Nonattainment?

total

carbon

other

(toy)

(toy)

(toy)

Madison

IL

Yes

100

4945

1

148

3796

27320

19373

15676

1,393

St.

Louis

MO

No

55

4221

1,707

2513

29966

55605

54,821

2,954

St.

Louis

City

No

48

1686

625

1060

12171

24,702

20647

439

St.

Clair

IL

Yes

22

1496

487

1,009

2,142

10,233

10,869

1,281

St.

Charles,

MO

No

17

3,694

619

3,075

54

561

20773

12,419

1,182

Jefferson

MO

No

16

2945

824

2121

45574

16722

9273

493

RandolDh

IL

Partial

9

2505

306

2,199

24605

9384

2.331

993

Montgomery,IL

No

7

2463

263

2200

41,131

12122

2,789

1,055

Franklin,

MO

No

5

2812

621

2,190

56,767

15595

5748

1818

Monroe.

IL

Yes

5

744

235

508

293

3,057

2,529

654

Clinton,IL

No

5

923

206

717

506

2,982

2,919

2,890

The

great

majority

of

the

emissions

are

in

the

existing

nonattainment

area.

18

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

Recommended

2004-06

2005-07

Nonattainment?

(ltgl

m

')

(ltg

/m

')

Madison,IL

Yes

39

39

St.

Louis,

MO

No

32

34

St.

Louis

Citv.

MO

No

34

35

St.

Clair,

IL

Yes

33

34

St.

Charles,

MO

No

32

33

Jefferson,

MO

No

32

34

Randolph,

IL

Partial

27

30

Franklin

MO

No

Monroe

IL

Yes

Montgomery,lL

No

Clinton,lL

No

For

purposes

of

its

review,

EPA

used

data

available

from

the

Chemical

Speciation

Network

and

the

Interagency

Monitoring

of

Protected

Visual

Environments

(IMPROVE)

network

to

estimate

the

composition

offine

particle

mass

on

days

with

the

highest

fine

particle

concentrations.

On

high

concentration

days

during

cold

weather

months

in

this

area,

EPA

found

on

average

a

total

urban

contribution

of

12.1

Ilg/m3,

consisting

of2.2

Ilg/m3

of

sulfate,

9.1

Ilg/m3

of

organic

particles,

and

0.8

Ilg/m3

of

miscellaneous

inorganic

particulate.

On

high

concentration

days

during

warm

weather

months

in

this

area,

EPA

found

on

average

a

total

urban

contribution

of7.1

Ilg/m3,

consisting

of

3.3

Ilg/m3

of

sulfate

and

3.8

Ilg/m3

of

organic

particulate

emissions.

These

estimates

were

used

for

weighting

of

the

emissions

of

different

pollutants

in

calculating

the

contributing

emissions

scores.

.

Thus,

Madison,

SI.

Clair,

and

Monroe

Counties,

Illinois,

are

violating

the

standard.

The

air

quality

data

also

help

evaluate

the

relative

importance

of

emissions

of

different

pollutants

in

determining

what

additional

counties

contribute

to

the

violations.

Factor

3:

Population

density

and

degree

of

urbanization

(including

commercial

development)

Table

3

shows

the

2005

population

for

each

county

in

the

area

being

evaluated,

as

well

as

the

population

density

for

each

county

in

that

area.

Population

data

give

an

indication

of

whether

it

is

likely

that

population-based

emissions

might

contribute

to

violations

of

the

24-hour

PM

25

standards.

T

bl

3

PI'

ae

oou

atlOn

County

State

2005

2005

Recommended

Population

Population

Nonattainment?

Density

(pop/sQ

mil

19

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

Franklin,

MO

No

98,987

107

Monroe

IL

Yes

31,289

79

Mont~omerv,

IL

No

30,304

43

Clinton

IL

No

36,138

72

Factor

4:

Traffic

and

commuting

patterns

Table

4.

Traffic

and

Commutin~

Patterns

County

State

2005

Number

Percent

Number

Percent

Recommended

VMT

Commuting

Commuting

Commuting

Commuting

Nonattainment?

(10'

mil

to

any

to

any

into

statistical

into

violating

violating

area

statistical

counties

counties

area

SI.

Louis

MO

No

14165

3800

I

493070

99

SI.

Charles,

MO

No

3,185

740

0

147,420

99

St.

Louis

Citv

No

3638

1250

I

139,280

99

Madison

IL

Yes

2318

75490

62

119590

98

St.

Clair

IL

Yes

3,019

7040

6

110870

98

Jefferson

MO

No

2241

490

I

96860

99

Franklin,

MO

No

1,436

ISO

0

43600

97

Clinton,IL

No

378

1,600

9

14760

87

Monroe,IL

Yes

359

420

3

13560

95

Randoloh

IL

Partial

261

180

I

2790

21

Mont~omerv,

IL

No

525

290

2

1,300

10

The

listing

of

counties

on

Table

4

reflects

a

ranking

based

on

the

number

of

people

commuting

to

other

counties.

The

counties

that

are

in

the

nonattainment

area

for

the

1997

PM2.5

NAAQS

are

shown

in

boldface.

These

counties

include

the

areas

most

integrated

into

the

nonattainment

area.

Factor

5:

Growth

rates

and

patterns

Table

5

below

shows

population,

population

growth,

VMT

and

VMT

growth

for

counties

that

are

included

in

the

St.

Louis

area.

Counties

are

listed

in

descending

order

based

on

VMT

change

between

1996

and

2005.

Ch

hd

dVMTG

T

bl

5

PI'

ae.

QOU

atlOo

an

roW!

an

Percent

an

e.

County

Population

Population

2005VMT

VMT

(2005)

%

change

(10'

mil

%

change

f2000-05)

(]

996-2005)

Monroe,IL

31,289

13

359

47

St.

Louis

MO

I

002258

-I

14165

33

St.

Charles,

MO

329606

IS

3185

28

Montgomerv,lL

30304

-I

525

27

Franklin,

MO

98987

5

1

436

19

20

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

significantly

during

the

SIP

planning

time

horizon.

Factor

6:

Meteorology

(weather/transport

patterns)

The

pollution

rose

for

the

SI.

Louis

area

is

provided

in

the

map

above.

Emissions

from

the

southwest

and

southeast

are

most

prone

to

contribute

to

nonattainment.

Factor

7:

Geography/topography

(mountain

ranges

or

other

air

basin

boundaries)

The

SI.

Louis

area

does

not

have

any

geographical

or

topographical

barriers

significantly

limiting

air-pollution

transport

within

its

air

shed.

Therefore,

this

factor

did

not

playa

significant

role

in

the

decision-making

process.

Factor

8:

Jurisdictional

boundaries

(e.g.,

existing

PM

and

ozone

areas)

The

East-West

Gateway

Council

of

Governments

(EWGCC)

is

the

Metropolitan

Planning

Organization

(MPO)

for

the

bi-state

SI.

Louis

area.

EWGCC

webpage:

http://www.ewgatewav.org/

The

Illinois

portion

of

the

Saint

Louis

ozone

nonattainment

area

consists

of

the

following

counties:

Jersey,

Madison,

Monroe,

and

SI.

Clair.

Factor

9:

Level

of

control

of

emission

sources

The

emission

estimates

on

Table

1

include

any

control

strategies

implemented

by

the

States

in

the

SI.

Louis

area

before

2005

that

may

influence

emissions

of

any

component

of

PM

25

emissions

(i.e.,

total

carbon,

S02,

NOx,

and

crustal

PM

2s

).

21

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

guidance

was

sent

to

the

Governor

of

Ohio

as

an

attachment

to

a

letter

dated

July

9,

2007,

requesting

the

State's

recommendations.

The

guidance

identified

nine

factors:

emissions,

air

quality,

population

density

and

degree

of

urbanization,

traffic

and

commuting

patterns,

growth

rates

and

patterns,

meteorology,

geography/topography,

jurisdictional

boundaries,

and

level

of

control

of

emission

sources.

The

Clean

Air

Act

dictates

that

nonattainment

areas

be

defined

to

include

both

areas

that

are

violating

the

standards

and

nearby

areas

that

are

contributing

to

the

violations.

Assessment

of

areas

contributing

to

violations

is

complicated

by

the

multiple

pollutants

that

are

components

of

fine

particulate

matter,

the

variable

significance

of

these

multiple

components,

and

the

complexities

of

photochemical

formation

and

dispersion.

To

facilitate

its

review

of

available

information,

EPA

prepared

a

"Contributing

Emissions

Score"

(CES)

for

each

potentially

violating

county.

EPA

derived

a

CES

for

each

relevant

county

using

information

on

emissions,

air

quality,

and

meteorology.

The

score

for

each

county

is

computed

relative

to

the

highest

scoring

county

in

the

area,

so

that

scores

range

between

0

and

100.

These

scores

represent

an

estimate

of

the

relative

maximum

influence

that

emissions

in

that

County

have

on

a

violating

county.

The

weight

that

the

CES

plays

in

determining

the

boundaries

of

any

violating

area

varies

from

area

to

area

depending

on

how

well

the

CES

methodology

takes

into

account

characteristics

of

an

area

that

impact

transport

and

dispersion

of

PM

25

and

depending

on

the

significance

of

other

factors.

Briefly,

a

CES

for

each

county

was

derived

by

incorporating

the

following

information

and

variables

that

impact

PM2.5

transport

into

the

screening

approach:

•

Major

PM

2

.

5

components:

total

carbon

(organic

carbon

(OC)

and

elemental

carbon

(EC)),

S02,

NO"

and

inorganic

particles

(crustal).

•

PM

2

.

5

emissions

for

the

highest

(generally

top

5%)

PM

25

emission

days

(herein

called

"high

days")

for

each

of

two

seasons,

cold

(Oct-Apr)

and

warm

(May-Sept)

•

Meteorology

on

high

days

using

the

NOAA

HYSPLIT

model

for

determining

trajectories

of

air

masses

for

specified

days

•

The

"urban

increment"

of

a

violating

monitor,

which

is

the

urban

PM

2

.

5

concentration

that

is

in

addition

to

a

regional

background

PM

2

.

5

concentration,

determined

for

each

PM2.5

component

•

Distance

from

each

potentially

contributing

county

to

a

violating

county

or

counties

A

more

detailed

description

of

the

CES

can

be

found

at

http://www.epa.gov/ttn/naaqs/pm/pm25_2006_tech

i

nfo.html#C.

22

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

carbon),

and

PM

2

.5

emissions

other

(which

includes

inorganic

particles

("crustal"»,

as

well

as

emissions

of

S02

and

NO

x

which

are

precursors

of

secondary

PM

2

.5

components.

Emissions

data

were

derived

from

the

2005

National

Emissions

Inventory

(NEI),

version

I.

See

http://www.epa.gov/ttn/naaqs/pm/pm252006techinfo.html.

EPA

also

used

emissions

and

other

data

to

compute

a

Contributing

Emissions

Score

(CES)

for

each

county

Factor

2:

Air

quality

data

This

factor

considers

the

24-hour

PM

2

.

5

design

values,

in

J.Ig/m

3

,

for

air-quality

monitors

in

counties

in

each

area

based

on

data

for

the

2004-2006

and

2005-2007

periods.

A

monitor's

design

value

indicates

whether

that

monitor

attains

a

specified

air-quality

standard.

The

24-hour

PM

2

.

5

standards

are

met

when

the

3-year

average

of

a

monitor's

98

th

percentile

values

are

35

J.Ig/m

3

or

less.

A

design

value

is

only

valid

if

minimum

data

completeness

criteria

are

met.

EPA

is

only

using

air

quality

data

collected

in

accordance

with

40

CFR

50

Appendix

Land

40

CFR

58.

Factor

3:

Population

density

and

degree

of

urbanization

(including

commercial

development)

The

tables

show

the

2005

population

for

each

county

in

the

area

being

evaluated,

as

well

as

the

population

density

for

each

county

in

the

area.

Population

data

give

an

indication

of

whether

it

is

likely

that

population-based

emissions

might

contribute

to

violations

of

the

24-hour

PM2.5

standards.

Factor

4:

Traffic

and

commuting

patterns

This

factor

considers

the

number

of

commuters

in

each

county

who

drive

to

another

county

within

the

area,

the

percent

of

total

commuters

in

each

county

who

commute

to

other

counties

within

area,

as

well

as

the

total

vehicle

miles

traveled

(VMT)

for

each

county

in

millions

of

miles.

A

county

with

numerous

commuters

is

generally

an

integral

part

of

an

urban

area

and

could

be

an

appropriate

county

for

implementing

mobile-source

emission

control

strategies,

thus

warranting

inclusion

in

the

nonattainment

area.

The

2005

VMT

data

used

for

table

4

and

5

of

the

9-factor

analysis

has

been

derived

using

methodology

similar

to

that

described

in

"Documentation

for

the

final

2002

Mobile

National

Emissions

Inventory,

Version

3,

September

2007,

prepared

for

the

Emission

Inventory

Group,

U.S.

EPA.

This

document

may

be

found

at:

ftp://ftp.epa.gov!Emisl

nventory/2002

finalnei/documentation/mobi

lei,

in

particular

in

the

23

Electronic Filing - Received, Clerk's Office, October 1, 2008

* * * * * PCB 2009-021 * * * * *

---

as

well

as

patterns

of

population

and

VMT

growth.

A

county

with

rapid

population

or

VMT

growth

is

generally

an

integral

part

of

an

urban

area

and

could

be

an

appropriate

county

for

implementing

mobile-source

and

other

emission-control

strategies,

thus

warranting

inclusion

in

the

nonattainment

area.

Factor

6:

Meteorology

(weather/transport

patterns)

For

this

factor,

EPA

considered

data

from

National

Weather

Service

instruments

in

the

area.

Wind

direction

and

wind

speed

data

for

2004-2006

were

analyzed,

with

an

emphasis

on

"high

PM

2

.

5

days"

for

each

of

two

seasons,

an

October-April

"cold"

season

and

a

May-September

"warm"

season.

These

high

days

are

defined

as

days

where

any

FRM

or

FEM

air

quality

monitors

had

24-hour

PM

2

.

5

concentrations

above

95%

on

a

frequency

distribution

curve

ofPM2.5

24-hour

values.

For

each

air

quality

monitoring

site,

EPA

developed

a

"pollution

rose"

to

understand

the

prevailing

wind

direction

and

wind

speed

on

the

days

with

highest

fine

particle

concentrations.

The

figure

identifies

24-hour

PM2.5

values

by

color;

days

exceeding

35

f!g/m

3

are

denoted

with

a

red

or

black

icon.

A

dot

indicates

the

day

occurred

in

the

warm

season;

a

triangle