1 Eagan, Minnesota Technical Support Document

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Definition of important terms used in this document :

1) Designated “unclassifiable” – an area where EPA could not determine if there w as a violation of the 2008 lead NAAQS or a contribution to a violation in a nearby area, because there was insufficient air quality data for both 2006-200 8 and 2007-2009 and where additional monitoring data for 2010 could not result in a diff erent designation.

2) Designated “attainment” – an area which EPA has determined, based on the m ost recent 3 years of certified air quality data from 2006-2008 or 2007-2009, has no violations of the 2008 lead NAAQS during 36 consecutive valid 3-month site means; and which EPA has further

determined does not contribute to a violation of th e 2008 lead NAAQS in a nearby area and that additional monitoring data from 2010 could not resu lt in a different designation.

3) Designated “nonattainment” area – an area which EPA has determined, based on a State recommendation and/or on the technical analysis inc luded in this document, has a violation of the 2008 lead NAAQS during the most recent 3 consec utive years of quality-assured, certified air quality data.

4) Prior nonattainment area – an area that is currently designated as nonattainme nt or maintenance for the 1978 lead NAAQS (including both current nonattainment 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 design value exceeds 0 .15 micrograms per cubic meter (ug/m3). As described in Appendix R of part 50, a violation can be based on either Pb-TSP or Pb-PM10 data and only 3 months of data a re necessary to produce a valid violating design value.

7) 1978 lead NAAQS – 1.5 μg/m 3 , National Ambient Air Quality Standard for lead pr omulgated in 1978. Based on Pb-TSP indicator and averaged ov er a calendar quarter.

8) 2008 lead NAAQS – 0.15 μg/m 3 , National Ambient Air Quality Standard for lead promulgated in 2008. Based on Pb-TSP indicator and a 3-month rolling average. Pb-PM10 data may be used in limited instances, including to show nonattainment.2 MINNESOTA Area Designations For the 2008 Lead National Ambient Air Quality Standards EPA has revised the level of the primary (health-ba sed) standard from 1.5 micrograms per cubic meter (μg/m3) to 0.15 μg/m3 measured as total suspe nded particles (TSP). EPA has revised 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, EP A must designate as “nonattainment” those areas that violate the NAAQS and those nearby areas that contribute to violations. The table below identifies the partial county in Mi nnesota that EPA is designating as

“nonattainment” for the 2008 lead National Ambient Air Quality Standard (2008 lead NAAQS).

Area (listed alphabetically) Minnesota

Recommended

Nonattainment

Counties EPA’s Designated

Nonattainment

Counties Nonattainment

Area for 1978 Lead NAAQS

Eagan Dakota (partial) Dakota (partial) Eagan (par tial)

Table 1: Minnesota Nonattainment Area for the 2008 Lead NAAQS

Technical Analysis for Eagan

Introduction

This technical analysis for Eagan identifies the pa rtial county with a monitor that violates the 2008 lead NAAQS and evaluates nearby counties for c ontributions to lead concentrations in the

area. EPA has evaluated these counties based on th e weight of evidence of the following factors recommended in previous EPA guidance:

• Air quality in potentially included versus excluded areas;

• Emissions and emissions-related data in areas poten tially included versus excluded from the nonattainment area, including population data, growth rates, and patterns and emissions controls;

• Meteorology (weather/transport patterns);

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

• Jurisdictional boundaries (e.g., counties, air dist ricts, reservations, etc.); and

• Any other relevant information submitted to or coll ected by EPA (e.g., modeling where done appropriately).3 Figure 1: Eagan, Minnesota State Recommended Nonatt ainment Area (Office of Air Quality and Planning Standards - OAQ PS)

Figure 1 is a map of the area analyzed showing the locations and design values of air quality monitors in the area, and the counties surrounding any violating air quality monitors. Source data is also labeled in Figure 1 with the following guidelines: if the source emitted 0.5 or more tons, the symbol, name of the facility, and emissio ns are labeled; if the source emitted 0.1 – 0.5 tons, only the symbol and emissions are labeled; an d if the source emitted less than 0.05 tons, only the symbol is shown. 1 Emissions in Eagan and the surrounding areas will be discussed in the section addressing emissions in Dakota. The loc ation of the detailed area in relation to the remainder of the State is shown in the bottom right corner of the figure.

1 Emissions greater than 0.05 tpy round up to 0.1 tp y, and they are marked with the symbol and the emis sions value. * Sources that are not labeled emitted less than 0.05 tpy.

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Federal Equivalent Method (FEM) monitors located in the State. Paul Eger, Commissioner of the Minnesota Pollution Control Agency (MPCA), subm itted the State’s recommendation to EPA in a letter dated October 15, 2009.

Based on EPA’s technical analysis described below, EPA is designating the same partial county as previously designated for the 1978 lead NAAQS as nonattainment for the 2008 lead NAAQS as part of the Eagan nonattainment area, based upon currently available information. This county is listed above in Table 1.

Detailed Assessment

Air Quality Data

This factor considers the lead design values (in μg /m 3 ) for air quality monitors in Dakota County in Eagan and the surrounding area based on data for the 2006-2008 and 2007-2009 period. A monitor’s design value indicates whether that monit or attains a specified air quality standard. The 2008 lead NAAQS are met at a monitoring site wh en 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 com pleteness criteria are met. A lead design value that meets t he NAAQS is generally considered valid if it encompasses 36 consecutive valid 3-month site means (specifically for a 3-year calendar period and the 2 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 m onitoring days in the 3-month period. A lead design value that does not meet the NAAQS is consid ered 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 3 full calendar years in order to have a valid violating design value; a site could monitor just 3 months and still produce a valid (vi olating) design value.

County State

Recommended

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

2006-2008 (μg/m 3 ) Lead Design

Value,

2007-2009 (μg/m 3 )
Dakota,

Minnesota Yes Eagan, MN Gopher

Resource Corporation 270370465 149 th and

Yankee Doodle

Rd. 0.70 0.70

Monitor in bold has the highest 2006-2008 and 2007- 2009 design value in the respective county.

Table 2: Eagan, Minnesota and Surrounding Areas Air Quality Data

Dakota County shows a violation of the 2008 lead NA AQS. Therefore some area in this county and possibly additional areas in surrounding counti es must be designated nonattainment. However, the absence of a violating monitor alone i s 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 these factors and other relev ant information.6

According to EPA’s monitor locator, 2 the monitor located at 149 th and Yankee Doodle Rd. (AQS ID 270370465) has an objective for determining the highest concentration of lead. This monitor is in close proximity to Gopher Resource Corporatio n (GRC). GRC is a secondary lead smelter, and the emissions from this facility will be discus sed in the section addressing emissions in Dakota County. There are 5 other lead monitors in Dakota County, the closest of which is 4.83 miles away from GRC. The AQS ID for this monitor i s 270370423, and the design value for this monitor for 2006 – 2008 is 0.005 μg/m 3 , or 1/30 th of the NAAQS.

Emissions and Emissions-Related Data

Evidence of lead emissions sources surrounding a vi olating monitor are an important factor for determining whether a nearby area is contributing t o a monitored violation. For this factor, EPA evaluated county level emission data for lead and p opulation data.

Emissions

Emissions data were derived from the 2005 National Emissions Inventory (NEI), version 2, which is the most up-to-date version of the nationa l inventory available when these data were compiled for the designations process in 2009. See http://www.epa.gov/ttnchie1/net/2005inventory.html. EPA recognizes that for certain counties, emissions may have changed since 2005. For example , certain large sources of emissions in or near this area may have installed emission controls or otherwise significantly reduced emissions since 2005. Some States provided updated informati on on emissions and emission controls in their comments to EPA. Minnesota did not provide u pdated emissions information, therefore EPA relied on the 2005 NEI emissions data, which ar e provided in Table 3.

Table 3 shows total emissions of lead given in tons per year (tpy) for violating and potentially contributing counties in and around Eagan and sourc es emitting (or anticipate to contribute) 0.1 ton per year of lead or more according to the 2005 NEI. The county that is part of the Eagan nonattainment area for the 2008 lead NAAQS is shown in boldface

.

There are approximately 20,000 airport facilities i n the U.S. at which leaded aviation gasoline is consumed. To evaluate the potential impact of emis sions at and near these facilities, EPA

recommends that States use the draft 2008 NEI. The se data are provided in Table 4, and contain the facilities emitting (or anticipate to contribut e) 0.1 ton per year or more of lead according to

the draft 2008 NEI.

2 http://www.epa.gov/air/data/geosel.html.7

County Facility in State

Recommended Nonattainment Area? Facility Name 2005 NEI (tpy) Location City

Dakota,

Minnesota Yes Gopher Resource Corporation 3.2 3385 S. Highway 149 Eagan

Dakota,

Minnesota No Rosemount Aerospace Inc -

Burnsville 0.6 14300

Judicial Rd. Burnsville

Dakota,

Minnesota No Endres Processing

LLC 0.3 13420

Courthouse

Blvd. Rosemount

Dakota,

Minnesota No Seneca

Wastewater

Treatment Plant 0.1 3750 Plant Rd. Eagan

Dakota,

Minnesota No Flint Hills

Resources LP 0.1 12555 Clark

Rd. Rosemount Dakota County

Total Lead

Emissions 4.8* Table 3: Eagan, Minnesota and Surround Areas Lead E missions for Stationary Sources * Total lead emissions for Dakota County were calcula ted by adding the 2005 NEI data for facilities not using leaded aviation gas to the 2008 Draft NEI data for facilities using aviation gas. Sources with emissi ons below 0.1 tpy were included in this final calculation.

City Facility Name Type 2008 Draft NEI (tpy) Distance to NA

area (km)
Minneapolis Airlake Airport 0.2 22.13

South St Paul South St Paul Muni-Richard E

Fleming Field Airport 0.1 5.06 Table 4: Eagan, Minnesota and Surrounding Areas Lea d Emissions for Leaded Aviation Gas Facilities

According to the 2005 NEI data, there are 5 sources that emit 0.1 ton per year or greater of lead. The greatest of these is GRC, which EPA observes ac counts for 3.2 tons out of 4.8 tons, or 66.7 percent of all lead emissions in Dakota County (ref er to Table 3). In addition to continued monitoring at GRC, 2 new monitors commenced operati on in January 2010 at, or in close proximity to, stationary sources. These sites incl ude: Federal Cartridge Company - Anoka (Anoka County) and Grede-St Cloud Inc (Stearns Coun ty). EPA has taken comment on a proposal to lower the emissions threshold for monit oring requirements from 1.0 ton per year to 0.5 ton per year (74 FR 69050). If the final rulem aking requires monitors at sites that emit 0.5 ton per year or greater of lead, a monitor at Rosem ount Aerospace, Inc may be required in the

future. 3 Lastly, recent stack testing at Dotson Company In c (Blue Earth County) shows much lower emissions that previously thought, and MPCA i ntends to apply for a waiver under final promulgation of revisions to monitoring requirement s (74 FR 69050).

3 Communication with MPCA staff in April 2010 indica tes that the most recent emissions inventory data f or Rosemount Aerospace is in actuality, only 0.01 tpy.

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County State

Recommended

Nonattainment? 2008

Population 2008

Population Density (pop/sq mi) Population

Change

2000-2008 Population %

Change

2000-2008

Dakota,

Minnesota Yes 392,755 672 34,905 10

Table 5: Population Data for Dakota County, Minneso ta

[Source of data: U.S. Census Bureau estimates for 2 008 (http://www.census.gov/popest/datasets.html) and es timation of the area of U.S. counties]

EPA has considered the population growth rate for t his area and does not believe that it affects the boundary recommendation.

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 an alysis and provided in Table 3 represent emissions levels taking into account any control st rategies implemented in Eagan before 2005 on stationary sources. EPA has received additional in formation on emissions reductions resulting from controls put into place since 2005.

MPCA included a comprehensive description of action items that were taken at GRC in 2009. These action items included emissions and procedure control measures for the blast furnace penthouse, the material transfer room, and the afte rburner tower. The cost of the reductions project (as of October 2009) was $2,250,000, and in cluded the addition of 2 new negative pressure units, hoods, and enclosures. EPA is curr ently reviewing the permit associated with this project. It is MPCA’s intention to submit the deta ils of this project as a SIP pending final permit issuance. GRC is also in the process of addressing several other smaller priority action items pertaining to kettle combustion vents, roadways, th e warehouse and plastics building, the maintenance shop, and other various housekeeping is sues. A description of remediation work performed at GRC from 1994 to 2008 was also include d in MPCA’s submittal.

Meteorology (weather/transport patterns)

For this factor, EPA considered data from National Weather Service instruments and other meteorological monitoring sites in the area. Histo rical wind direction frequencies collected between 1960 and 1992 are included in Figure 5 and Table 6. These data may provide evidence of the potential for lead emissions sources located upwind of a violating monitor to contribute to

ambient lead levels at the violation location.10 Figure 4: Historical Wind Direction Frequencies for Dakota County, Minnesota

Figure 4 is a 3-dimensional bar chart that shows th e wind frequencies in 8 directions for the 4

seasons. These data are taken from 1960-1992 Solar and Meteorological Surface Observation Network information issued jointly by the U.S. Depa rtment of Commerce: National Climatic Data Center and the U.S. Department of Energy: Nati onal Renewable Energy Laboratory. The chart frequencies reflect the directions from which the winds come.11 Dakota County Wind Frequencies

**Frequency as a % Seasonal Wind** 

**Directions**

**8.43 WINWINDFNNE** 

**5.45 WINWINDFENE** 

**10.33 WINWINDFESE** 

**10.47 WINWINDFSSE** 

**14.40 WINWINDFSSW** 

**13.85 WINWINDFWSW** 

**22.16 WINWINDFWNW** 

**14.91 WINWINDFNNW** 

**13.30 SPRWINDFNNE** 

**9.59 SPRWINDFENE** 

**15.17 SPRWINDFESE** 

**13.28 SPRWINDFSSE** 

**13.07 SPRWINDFSSW** 

**8.07 SPRWINDFWSW** 

**13.64 SPRWINDFWNW** 

**13.88 SPRWINDFNNW** 

**9.89 SUMWINDFNNE** 

**6.64 SUMWINDFENE** 

**12.70 SUMWINDFESE** 

**16.36 SUMWINDFSSE** 

**20.61 SUMWINDFSSW** 

**11.04 SUMWINDFWSW** 

**13.03 SUMWINDFWNW** 

**9.71 SUMWINDFNNW** 

**10.08 AUTWINDFNNE** 

**5.12 AUTWINDFENE** 

**11.19 AUTWINDFESE** 

**15.10 AUTWINDFSSE** 

**18.31 AUTWINDFSSW** 

**10.67 AUTWINDFWSW** 

**16.57 AUTWINDFWNW** 

**12.96 AUTWINDFNNW**  Table 6: Historical Wind Frequency Data as Percents for Dakota County, Minnesota

As shown in Figure 5 and Table 6, the period with t he highest wind frequency occurs in the winter months, with winds blowing from the west nor thwest. With the consistently strong representation of winds from the west northwest, an d a variation of the west in all seasons, special care must be made when determining the nona ttainment boundary to the east of the violating monitor.12

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

The geography/topography analysis evaluates the phy sical features of the land that might have an effect on the air shed and, therefore, on the distr ibution of lead over Eagan and the surrounding

area.

The Eagan area does not have any geographical or to pographical barriers significantly limiting air pollution transport within its air shed. There fore, this factor did not play a significant role i n determining the nonattainment boundary.

Jurisdictional boundaries

Existing jurisdictional boundaries may be helpful i n articulating a boundary for purposes of nonattainment designations, and for purposes of car rying out the governmental responsibilities of planning for attainment of the lead NAAQS and imple menting control measures. These existing boundaries 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 busi ness development or transportation activities.

In EPA’s August 21, 2009 guidance memorandum, “Area Designations for the 2008 revised Lead National Ambient Air Quality Standard,” EPA re iterated that the presumptive boundary for each nonattainment area should be the county contai ning the violating monitor. This concept was first introduced in the guidance for the 1978 l ead NAAQS designations, and is described in the 1992 General Preamble (57 FR 13549). This same presumptive boundary guidance was addressed most recently in the final rulemaking for the 2008 lead NAAQS (73 FR 66964). EPA observed, however, that States have the flexibility in their recommendations to deviate from the presumptive county boundary to portions of the coun ty containing the violating monitor, stating that any “nonattainment area boundaries that deviat e from presumptive county boundaries should be supported by an assessment of several factors...,” all of which have been discussed already in this document, except for jurisdictional boundaries

.

MPCA has recommended that the same portions of Eaga n in Dakota County that were previously designated as nonattainment for the 1978 lead NAAQS (and current maintenance area) be designated as nonattainment for the 2008 lead NAAQS . As EPA performed comprehensive analyses of the nonattainment boundary for the desi gnations under the 1978 lead NAAQS, the current maintenance area is an acceptable reference point. However, the existing maintenance area by itself isn’t a true “jurisdictional boundar y,” as it can be perceived to be artificial. For t he Eagan area, there are several jurisdictional areas that can be considered for this factor. Eagan is located in Dakota County, which is part of the Minn eapolis-St Paul (Twin Cities) 7-county metropolitan area. Specifically, the portion of Ea gan that has been recommended as nonattainment for the 2008 lead NAAQS lies in Distr ict 15 of the Metropolitan Council. As a result, air quality planning efforts to address the impending lead nonattainment area in Eagan should not be problematic; it should be noted that the final rulemaking for the 2008 lead NAAQS (73 FR 66964) specifically addressed transportation conformity by stating, “In light of the elimination of lead additives from gasoline, transp ortation conformity does not apply to the Lead NAAQS.” Lastly, MPCA has recommended the nonattain ment area be enclosed by well-known

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Conclusion

After considering the factors described above, EPA has determined that it is appropriate to include a portion of Dakota County as nonattainment for the 2008 lead NAAQS.

The air quality monitor in Dakota County shows a vi olation of the 2008 lead NAAQS, based on 2006-2008 and 2007-2009 air quality data. GRC is l ocated in the city of Eagan, and this facility accounts for 66.7 percent of all lead emissions in Dakota County; there are no other major lead emitters in close proximity to the violating monito r. The final and consistent outcomes of the emissions control project have not been realized ye t, though there is indication that the rolling 3-month averages have decreased after August 2009. The cumulative process of this factors analysis in conjunction with the other relevant inf ormation that MPCA provided ultimately leads to the final nonattainment area. EPA finds it appr opriate to designate the portions of Dakota County that are encompassed by: Lone Oak Rd. (Count y Rd. 26) to the north, County Rd. 63 to the east, Wescott Rd. to the south, and Lexington A ve. (County Rd. 43) to the west as nonattainment for the 2008 lead NAAQS. Based on th e consideration of all the relevant and available information, as described above, EPA beli eves that the boundaries described herein encompass the entire area that does not meet (or th at contributes to ambient air quality in a nearby area that does not meet) the 2008 lead NAAQS

.

On June 15, 2010, EPA communicated to Minnesota tha t we were proposing to adopt the State’s recommended nonattainment designation and boundarie s for the Eagan area. A subsequent

Federal Register

notice was published on July 8, 2010 (75 FR 39255) , notifying the public that EPA was proposing to take action on State recommend ations for lead nonattainment areas. In the same notice, EPA started a public comment perio d with an end date of August 16, 2010. EPA did not receive any public comments germane to the nonattainment designation and boundaries for the Eagan area, nor did we receive a ny additional information from the State.

Accordingly, EPA has determined that the portions o f Dakota County that are encompassed by: Lone Oak Rd. (County Rd. 26) to the north, County R d. 63 to the east, Wescott Rd. to the south, and Lexington Ave. (County Rd. 43) to the west shou ld be designated as nonattainment for the 2008 lead NAAQS, as seen in Figure 8.17 Figure 8: Eagan, Minnesota Final Nonattainment Area (OAQPS)