1 Technical Support Document

PUERTO RICO Area Designations For the

2008 Lead National Ambient Air Quality Standard s

EPA has set the level of the prim ary (health

- based) standard at 0.1 5 micrograms per cu bic meter (μg/m3) measured as total suspended p articles (TSP). EPA has set the secondary (welfare

based) standard to be identical in all respects to the primary standard.

Pursuant to section 107(d) of the Clean Air Act, EPA must designate as “nonattainment”

those areas that violate the National Ambient Air Quality Standards ( NAAQS ) and those nearby areas that contribute to violations. The table below identifies the countie s 1 or portions

of counties in the C ommonwealth of Puerto Rico that EPA is designating “nonattainment” for

the 200 8 lead national ambient air quality standard (2008 Lead NAAQS)

.

Table 1

Area Puerto Rico Recommended Nonattainment County EPA’s Designated Nonattainment County
Arecibo, Puerto Rico Arecibo, Puerto Rico (partial) Arecibo , Puerto Rico (partial)

Technical A nalysis for Arecibo, Puerto Rico

Introduction

Th is technical analysis for the Arecibo , Puerto Rico Area identifies a monitor in Arecibo County

that violate s the 2008 Lead NAAQS and evaluates nearby counties for contributions to lead

concentrations in the area. EPA has evaluated these counties based on the weight of evidence of the following factors recommended in prev ious ly issued EPA guidance :

Air quality in potentially included versus excluded areas ; Emissions and emissions

- related data in areas potentially included versus excluded from

the nonattainment area , including population data

, growth rates and patterns and emissions controls; Meteorology (weather/transport patter n s) ; Geography/topography (mountain ranges or other air basin boundaries) ; Jurisdictional boundaries (e.g., counties, air districts, reservations, etc.) ; and Any other relevant information submit ted to or collected by EPA.

1 For these purposes EPA considers the municipios of Puerto Rico to be equivalent to counties and for consistency and convenience will use the term “county.”2

Figure 1: Sources in Arecibo County, Puerto Rico

Figure 1 is a map of the area analyzed showing the location of t he air quality violating monitor in the area, Puerto Rico and EPA’s recommended “nonattainment” boundary, an d the counties surrounding the vi olating air quality monitor . The violating monitor is located in Arecibo County in close proximity to The Battery Recycling Company, shown in Figure 1.

On October 14, 2009

, Pedro J. Nieves Miranda, Chairman of Puerto Rico Environmental Quality Board, recommended that San Juan be designated as attainment, the Arecibo area be designated

unclassifiable , and for the rest of Puerto Rico be designated unclassifiable/attainment for the

2008 Lead NAAQS b ased on air quality data from 2006

- 2008

. His recommendation was based

on data from a Federal Reference Method ( FRM ) monitor located in the C ommonwealth

. EPA understands the recommendation for unclassifiable designation for the “Arecibo area” to refer to

Arecibo Coun ty

. Puerto Rico’s August 15, 2011 letter on Lead Designation for Arecibo revised

its recommendation based on recent 2010 data from a FRM monitor that had been operated by

the Commonwealth showing a violation of the 2008 Lead NAAQS

. The revised

recommendation is for the area within the 4 km radius which surrounds The Battery Recycling Company facility in the Arecibo County to be designated nonattainment.

Based on EPA's technical analysis described below, EPA is designating a port ion of Arecibo County in Puerto Rico a s nonattainment for the 2008 Lead NAAQS

, based upon currently

available information

. This county is listed above in Table 1

. Puerto Rico provided modeling

results that showed a 4 km radius of The Battery Recycling Company in Arecibo County t hat could be impacted with daily high lead concentrations. In addition, Puerto Rico modeled monthly violations that extend ed up to 2 km fr om the source. In order to be conservative , based3

on the modeling, Puerto Rico recommended the nonattainment in Arecibo to include the area within the 4 km radius of the source.

Detailed Assessment

Air Q uality D ata

This factor considers the l ead design values (in μg/m 3 ) for air quality monitors in Are cibo County and the surrounding area based on data for the 20 10 period. A monitor’s design value indicates whether that monitor attains a specified air quality standard. The 2008 Lead NAAQS

are met at a monitoring site when the identified design value is valid and less than or equal to

0.15 μg/m

3

. A design value is only valid if minimum data completeness criteria are met. A l ead design value that meets the NAAQS is generally considered valid if it encompasses 36

consecutive valid 3

- month site means (specifically for a 3

- year calendar period and the two previous months)

. For this purpose, a 3

- month site mean is valid if valid data were obtained for at least 75 percent of the scheduled monitoring day s in the 3

- month period. A l ead design value that does not meet the NAAQS is considered valid if at least one 3

- month mean that meets the same 75 percent requirement is above the NAAQS. That is, a site does not have to monitor for three full calendar yea rs in order to have a valid violating design value; a site could monitor just three months and still produce a valid (violating) design value

.

The 2008 Lead NAAQS design values for Arecibo County and surrounding area are shown in

Table 2

.

Table 2

. Air Quality Data County Puerto Rico

Recommended

Nonattainment? Monitor

Name Monitor Air

Quality System ID Monitor

Location Lead Design

Value,

200 7

– 200 9 2
(μg/m 3 ) Lead Design Value,

2008

– 20 10 2
(μg/m 3 )

Arecibo County,

PR Yes Arecibo 720130001 Victor

Santoni

Cordero N/A 0. 245

Arecibo County shows a violation of the 2008 Lead NAAQS

. Therefore some area in Arecibo County and possibly additional areas in surrounding counties must be designated nonattainment

. T he absence of a violating monitor alone is not a sufficient reason to eliminate nearby counties

as candidates for nonattainment status. E ach area has been evaluated based on the weight of

evidence of the eight factors collectively combined into five like groupings and other relevant

infor mation.

The violating monitor located in Arecibo County is located in close proximity to The Battery Recycling Company, Road No. 2 km 72.2 Barrio Cambalache in Arecibo, Puerto Rico. The monitoring objective, accor ding to the EPA monitor locator report is “ source

- oriented ” . The

2 Note: Monitoring did not start at this site until January 1, 2010.4

emissions from The Battery Recycling Company will be discussed in the corresponding section

below.

Emissions and Emissions

- Related Data

Evidence of lead emissions sources in the vicinity of a violating monitor are an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA evaluated county level emission data for lead and any growth in lead emitting activities

.

Emissions

Emissio ns data for lead sources were derived from the 2008 National Emissions Inventory

. See http://www.epa.gov/ttn/chief/net/2008inventory.html#inventorydoc

. Some States and

Co mmonwealth provided updated information on emissions and emission controls in their

comments to EPA. Puerto Rico has provided updated 2009 emissions inventory information for

the industrial sources

. These data are provided in Table 3. The data provided by Puerto Rico

was the most current emission information available at the time of their submittal. EPA recognize s that we have no information on any emissions increases that may have occurred since

200 9 . For example, certain large sou rces of emissions in or near this area may have installed emission controls or otherwise significantly reduced emissions since 200 9

.

Table 3 shows total emissions of lead sources emitting greater than 0.1 tons per year for the violating county according to the Puerto Rico 2009 Emissions Inventory. The airport located in Arecibo County emi t s less than 0.1 tons per year of lead based on 2008 NEI emissions inventory, and therefore, is not included in this table. P otentially contributing counties in and ar ound the

Arecibo area were also evaluated. However, there are no s ources that can potentially emit

greater than 0. 1 ton per year of lead in neighboring counties

.

Table 3

. Lead Emissions [Puerto Rico 2009 Supplied] County Facility

Located in

Puerto Rico

Recommended

Nonattainment

Area ? Facility

– Total

Air Emissions [Information Source] (tons per year) Facility

Location Distance

from monitoring

site Total County

Lead

Emissions (tons per year)

Arecibo County,

PR Yes The Battery Recycling Company 1.22 tpy Road No. 2,

km 72.2,

Barrio Cambalache,

Arecibo 388 meters

1.385 tpy PREPA

Cambalache

Combustion

Turbine Plant 0.165 tpy PR 681, km

0.5, Arecibo 1.5

kilometers5

Population Data , Growth Rates, and Patterns

Table 4 shows the 200 8 population for the county being evaluated

. These data help assess the extent to which the concentration of human activities in the area and concentration of population

oriented commercial development may indicate emissions

- based activity contributing to elevated ambient lead levels. This may include ambient lead contributions from activities that would disturb lead that has been deposited on the ground or on other surfaces. Re

- entrainment of historically deposited lead typically is not reflected in the emissions inventory

.

Table 4 . Population Data County State

Recommended

Nonattainment? 2008

Population 2008

Population Density (pop/sq mi) Population

Change

2000

- 2008 Population

% Change

2000

- 2008

Arecibo County,

Puerto

Rico Yes 102,643 801 2,273 2

Source of data: U.S. Census Bureau estimates for 200 8 ( http://www.census.gov/popest/datasets.html ) and estimation

of the area of U.S. Counties

.

EPA has considered the population growth rate for this area and determined it does not affect the nonattainment boundary

.

Emissions Controls

Under this factor, the existing level of control of emission sources is taken into consideration. The emissions data used by EPA in this technical analysis and provided in Table 3 represent emissions levels taking into account any control strategies imple mente d on stationary sources in

the Arecibo area before 2008 . EPA has not received any additional information on emissions reductions resulting from controls put into place since 200 8

. The Battery Recycling Co mpany is currently using one b aghouse with an efficiency of 99.5% for its lead smelting furnace and five molten lead refining kettle burners. The PREPA Cambalache facility is currently not using any control equipment for lead emissions for its three gas turbines.

Meteorology (weather/transport patterns)

For this factor, EPA considered data from National Weather Service instruments and other meteorological monitoring sites in the area. Wind speed and direction were analyzed from August 1992 to August 1993 for a meteorological site located in Ca mbalache, PR.6

Figure 2 : Historic Wind Direction Frequency in each of Four Seasons for Arecibo County,

Puerto Rico

As seen in Figure 2 above, on months with the highest observed lead levels, the prevailing

surface winds were predominant ly from the Northeast/Southeast.

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

The geography/topography analysis evaluates the physical features of the area that might have an effect on the air shed and, therefore, on the distribution of lead over the Arecibo Area. The

terrain area that surrounds the Battery Recycling Company is a flat rural area with some elevated

terrain at approximately 4 km to the southwest/southeast.

Jurisdictional boundaries

Existing jurisdictional boundaries m ay be helpful in articulating a boundary for purposes of nonattainment designations, and for purposes of carrying out the governmental responsibilities of planning for attainment of the lead NAAQS and implementing control measures. These existing

boundari es may include an existing nonattainment or maintenance area boundary, a county or township boundary, a metropolitan area boundary, an air management district, or an urban planning boundary established for coordinating business development or transportatio n activities.

The entire recommended nonattainment area is within Arecibo County

.7

Other Relevant Information

On August 15, 2011, Puerto Rico conducted air dispersion modeling using the EPA recommended model AERMOD for the significant lead emission sources (Battery Recycling Company and PREPA Cambalache). Based on preliminary modeling, Puerto Rico found that the concentrations from PREPA Cambalache were negligible. This modeling showed a maximum 3 month rolling average concentration from P REPA Cambalache of 0.000003 ug/m 3 . This value was so much below the standard that this facility was not included in the final modeling (See Table 3 for lead emissions for the facility). Accordingly, the final modeling only used the lead

emissions from th e Battery Recycling Company.

Modeling combines two of the factors discussed above, meteorology and emissions data, to

estimate the area that would be above the standard. The lead emissions used in the modeling

were recently submitted by the Battery Recy cling during the permit process and were reviewed by the PREQB permit personnel

.

Two types of emission sources were used to model the fugitive emissions, volume and area. The volume source option was used to model the fugitive emissions inside the main process building that the control equipment does not capture. The building was modeled as a volume source

because it is not open completely like an area source. The initial lateral and vertical dimensions of the building and the center coordinates were determined through GPS

. The area source was used to model the emissions generated from the vehicle movement between the carbon, scrap and soda ash storages. A fourteen

- verte x polygon was created covering the area that the facility vehicles transit daily between these storages, approximately 4742 m 2

. This is a conservative scenario but it was the best modeling approximation of these fugitive emissions that could be

use d at th is moment, with the available data.

The facility is under construction and some changes have been made to the main process building and the storage areas that are not seen in the current aerial photos.8

Figure 3: Puerto Rico’s Lead Monthly Modeling C oncentrations, Stack/Volume & Area Source

Puerto Rico provided modeling results that showed a 4 km radius of The Battery Recycling Company in Arecibo County that could be impacted with daily high lead concentrations. In addition, Puerto Rico modeled monthly violations that extended up to 2 km from the source. Accordingly, based on the modeling, Puerto Rico recommended the nonattainment in Arecibo to

include the area within the 4 km radius of the source.

The modeling analysis submitted by P uerto R ico can be found in the docket for the designat ions, PR lead modeling analysis.pdf

.

Conclusion

After considering the factors described above, EPA has determined that it is appropriate to

include a portion of Arecibo County in Puerto Rico as nonattainment fo r the 2008 Lead NAAQS

, specifically the area within four kilometers of the boundaries of the Battery Recycling Company facility

.

EPA based this nonattainment designation determination and boundary on the fact that Arecibo County contains an air quality mo nitor that shows a violation of the 2008 Lead NAAQS, based on 2010 air quality data

, and Puerto Rico’s August 15, 2011 letter on Lead Designation for

Arecibo

. The Battery Recycling Company facility is the largest emissions source located upwind

of the vio lating monitor, and EPA and Puerto Rico believe this facility caused and/or contributed to the violating monitor during the period.

Based on its considerations of all the relevant, available information, as described above, EPA

believes that the boundaries described herein encompass the entire area that does not meet (or that contributes to ambient air quality in a nearby area that does not meet) the 2008 Lead NAAQS.9

Definition of important terms used in this document:

1) Designated “nonattainment ” area

– an area which EPA has determined, based on a State recommendation and/or on the technical analysis included in this document, has violated the 2008 Lead NAAQS , based on the most recent three years of quality assured air quality

monit oring data from 2008

- 2010 including at least one valid three

- month site mean above the level of the 2008 Lead NAAQS, or that contributes to a violation in a nearby area

.

2) Designated “unclassifiable/attainment” area

– an area which EPA has determined d oes not contribute to a violation of the 2008 Lead NAAQS in a nearby area and either: (1) meets the 2008 Lead NAAQS, based on the most recent three years of quality assured air quality monitoring data from 2008

- 2010 including 36 consecutive valid three

- mon th site means (including the last two months of 2007), or (2) has no monitors or has incomplete air quality monitoring data for 2008

- 2010 but has no violations of the 2008 Lead NAAQS.

3) Designated “unclassifiable” area

– an area which EPA has determined cannot be classified on the basis of available information as meeting or violating the 2008 Lead NAAQS, based on the most recent three years of quality assured air quality monitoring data from 2008

- 2010, but for which available monitoring data from the sa me or a recent period indicate a significant likelihood that the area may be violating the 2008 Lead NAAQS.

4) Prior nonattainment area

– an area that was previously designated as nonattainment for the 1978 Lead Standard (including both current nonattainm ent areas and maintenance areas).

5 ) Recommended nonattainment area

– an area a State or Tribe has recommended to EPA be designated as nonattainment.

6) Violating monitor

– an ambient air monitor whose valid design value exceeds 0.15 micrograms per cubic meter (ug/m 3 ). As described in Appendix R of part 50, a violation can be

based on either Lead

- TSP or Lead

- PM 10 data and only three months of data are necessary to produce a valid violating design value.

7) 1978 Lead NAAQS

– 1.5 μg/m 3 , National Ambient A ir Quality Standard for lead promulgated in 1978. Based on Lead

- TSP indicator and averaged over a calendar quarter.

8) 2008 Lead NAAQS

- 0.15 μg /m 3 , National Ambient Air Quality Standard for lead promulgated in 2008. Based on Lead

- TSP indicator and a three

- month rolling average. Lead

PM 10 data may be used in limited instances, including to show nonattainment.