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KANSAS

EPA’s Area Designations for the 

2008 Lead National Ambient Air Quality Standards

Introduction

EPA has revised the level of the primary (health-based) standard from 1.5 micrograms per cubic 

meter (μg/m3) to 0.15 μg/m3 measured as total suspended 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, EPA must designate as “nonattainment”

those areas that violate the NAAQS and those nearby areas that contribute to violations. 

The table below identifies the portions of a county in Kansas that EPA proposes to designate 

“nonattainment” for the 2008 lead national ambient air quality standard (2008 Lead NAAQS). 

Table 1. Kansas Lead NAAQS Nonattainment Areas

Area

Kansas Recommended 

Nonattainment County

EPA’s Designated 

Nonattainment Counties

Nonattainment 

area for 1978 

Lead NAAQS

Saline

County

Saline County (partial) defined 

as:

North - Schilling Rd

South – Water Well Rd

East – 1⁄4 mile west of S. Ohio St.

West - 9th St.

Saline County (partial) defined 

as:

North - Schilling Rd

South – Water Well Rd

East – 1⁄4 mile west of S. Ohio St.

West - 9th St.

None

Technical Analysis for Saline County, Kansas Nonattainment Area

This technical analysis for portions of Saline County identifies the area with a monitor that 

violates the 2008 Lead NAAQS and evaluates nearby sources for contributions to lead 

concentrations in ambient air in the area. EPA has evaluated the county based on the weight of 

evidence of the following factors recommended in 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/pollutant transport patterns);

Jurisdictional boundaries (e.g., counties, municipalities, political subdivisions of the state, 

etc.); and

Other relevant information submitted to or collected by EPA.
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Figure 1 is a map of the area analyzed depicting the location and design value of the air quality 

monitor measuring a violation of the 2008 Lead NAAQS in Saline County, Kansas, and the 

potential sources of lead concentrations to ambient air which may be contributing to the violating 

monitor. 

On May 10, 2011, the State of Kansas recommended that portions of Saline County, Kansas, be 

designated as “nonattainment” for the 2008 Lead NAAQS based on air quality data from 2010. 

The Kansas Department of Health and Environment’s (KDHE’s) recommended boundaries for 

the nonattainment area are depicted in Figure 2 (KDHE 2011). 

Based on EPA's technical analysis described below, EPA is designating portions of Saline 

County as nonattainment for the 2008 Lead NAAQS, based upon currently available 

information. 

1. Air Quality Data 

This factor considers the lead design value (in μg/m3) for the air quality monitor in Salina, Saline

County, Kansas, and the surrounding area based on data collected by the KDHE from February 

to December 2010. A monitor’s design value indicates whether that monitor attains a specified 

air quality standard; in this case the 2008 Lead NAAQS the level of which is 0.15 μg/m3. The 

design value for the monitor in Saline County is shown in Table 2. 

Table 2. Saline County Air Quality Data

County

State

Recommended

Nonattainment?

Monitor Air 

Quality System 

ID

Monitor

Name Monitor 

Location

Lead Design 

Value

2010

(μg/m3)

Saline Yes ID # 20-169-0004 Exide Monitor

ID #201690004

304 E. Ave B

(38.77643, -

97.60739) 0.42

A violation of the 2008 Lead NAAQS for the monitor listed in Table 2 above was measured by a 

monitor in Saline County, Kansas. Therefore some area in the county and possibly additional 

areas in surrounding counties must be designated nonattainment. The absence of a violating 

monitor alone is not a sufficient reason to eliminate nearby counties as candidates for 

nonattainment status. Each area has been evaluated based on the weight of evidence of the eight 

factors (collectively combined into five like groupings) and other relevant information.
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Figure 1. Saline County, Kansas, Lead NAAQS Violating Monitor 
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Figure 2. State Recommended Lead NAAQS Nonattainment Area

Source: “Technical Support Document for the Recommendation of Nonattainment Boundaries in Kansas for the 2008 Lead 

National Ambient Air Quality Standard,,” Kansas Department of Health and Environment, May 10, 2011.
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The violating monitor is depicted in Figure 3 below. The violating monitor is a Federal 

Equivalent Method (FEM) monitor in the predominant downwind direction, on the north side of 

the Exide Technologies (Exide) fence line. Ambient air monitoring began at the Exide facility 

because the facility reports lead emissions over one ton per year (tpy), which was the threshold 

for monitoring established in the 2008 Lead NAAQS Final Rule (73 FR 67062). Data from the 

monitor have been collected and are reported through December 2010 in Table 3 below. As 

Table 3 indicates, the monitor violated the standard in five rolling 3 month periods in 2010.

Table 3. 3-Month Rolling Averages for Lead

Saline County Ambient Air Monitor

Dates 3-Month Rolling Average

(μg/m3)

2008 Lead NAAQS Violation

Feb – Apr 2010 0.10

Mar – May 2010 0.10

Apr – Jun 2010 0.11

May – Jul 2010 0.23 X

Jun – Aug 2010 0.32 X

Jul – Sep 2010 0.42 Maximum

Aug – Oct 2010 0.35 X

Sep – Nov 2010 0.27 X

Oct – Dec 2010 0.15 X
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Figure 3. Location of Saline County Ambient Air Monitor for Lead

Source: “Technical Support Document for the Recommendation of Nonattainment Boundaries in Kansas for the 2008 Lead 

National Ambient Air Quality Standard,,” Kansas Department of Health and Environment, May 10, 2011.

2. Emissions and Emissions-Related Data

Evidence of lead emissions sources in the vicinity of a violating monitor is 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 

since the date represented by those emissions data.
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As mentioned above, the Exide facility in Salina, Kansas, reports lead emissions greater than 1.0 

tpy. The facility manufactures lead acid batteries for automobiles, trucks, and watercraft. Lead 

emissions result from breaking open used batteries, re-melting the lead, and reformulating new 

batteries. The lead is released in particulate form and generally captured within building 

structures or by air pollution control equipment; however, some lead particulates escape to the 

ambient air, depending on the degree of facility process enclosures and the efficiency of air 

pollution control equipment. Historic lead emissions from the Exide facility are as follows:

Year Lead Emissions (tpy)

2005 3.08

2006 3.12

2007 3.31

2008 2.25

2009 2.15

2010 2.17

The 2010 lead emission data above are based on stack test data (KDHE 2011). KDHE reports 

that a compliance inspection noted that the facility was operating at full capacity in 2007, the 

year the facility reported the highest lead emissions. It should also be noted that in a letter dated 

January 24, 2011, from Exide to KDHE, the facility lists a number of air emission control 

projects that have occurred from 2005 to the present which have likely resulted in reduced lead 

emissions from the maximum reported in 2007. The letter has been included as Appendix A to 

KDHE’s TSD (KDHE 2011). Those projects are discussed in greater detail in Section 5 below.

Table 4 below shows total emissions of lead for sources greater than 0.1 tons per year (tpy) in 

and around the recommended Saline County nonattainment area. Emissions data were generally 

derived from the 2008 National Emissions Inventory, version 1.5 (NEI08V1.5) except as 

otherwise noted. NEI08V1.5 was the most current version of the national inventory available in 

2011 when these data were compiled for the designations process

(http://www.epa.gov/ttn/chief/net/2008nei_v1/lead_facility_v1_5_final.xls). As footnoted in the 

table, AP-42 was used to calculate emissions for one of the facilities. AP-42, Compilation of Air 

Pollutant Emission Factors (http://www.epa.gov/ttnchie1/ap42/), is the primary reference for

EPA's emission factor information. An emissions factor is a representative value that attempts 

to relate the quantity of a pollutant released to the atmosphere with an activity associated with 

the release of that pollutant. Emission factors in AP-42 have been developed and compiled from 

source test data, material balance studies, and engineering estimates. This reference is used to 

estimate emissions from facilities when no stack test data are available. The total lead emissions 

for Saline County listed in Table 4 below were derived from EPA’s TRI database. Facilities are 

required by the Emergency Planning and Community Right-to-Know Act (EPCRA), 42 U.S.C. 

11001 et seq. (1986), to report emissions for regulated air toxics, which includes lead, to this 

database. The 2.4 tpy estimate for total county emissions provided in Table 4 below was derived 

by adding up all the lead emissions reported for all facilities in Saline County reporting to the 

TRI database, including “de minimis” sources.
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Table 4. Lead Emissions for Saline County, Kansas

Facility Facility – Total Air Emissions 

(tpy)

Facility in State

Recommended Nonattainment Area?

Exide Technologies 2.17 1

Yes

Metlcast Products 0.142 Yes

Salina Municipal Airport 0.173 No

Total County Lead Emissions 

(tpy) 2.44

1

– Based on 2010 stack testing

2 

– 2010 Kansas Emissions Inventory (KEI) and AP-42 calculation

3

– 2008 National Emissions Inventory Version 1 (NEI08V1)

4

– Toxic Release Inventory (TRI), 2008

The Metlcast Products (Metlcast) facility is located to the north of the Exide facility, near the 

violating lead monitor. The Metlcast facility uses three electric induction furnaces to cast gray 

iron. The scrap metal used to produce the gray iron most likely has varying amounts of lead, 

depending on the source of the scrap. When heated, the lead is driven off the molten metal in the 

form of particulates. Elemental lead and lead compounds in the form of particulates are captured 

by the facility’s air pollution control equipment; however, some lead-contaminated particulates 

escape to the ambient air. Lead emissions from this facility were estimated by KDHE using AP42. 

There is one airport facility in Saline County with aircraft using leaded aviation gas that emits 

0.1 tpy or more, the Salina Municipal Airport listed in Table 4 above. The state did not provide

analyses (such as air quality modeling) to examine the potential impact of the airport on the 

violating monitor.

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1

There are approximately 20,000 airport facilities in the U.S. at which leaded aviation gasoline is consumed. 

Leaded aviation gasoline is used almost exclusively in piston-engine aircraft. Emissions data from the 2008 

National Emissions Inventory version 1 (NEI08V1) is the most accurate depiction for the airport facilities in the 

United States, and NEI08V1 data was used in evaluating emissions from these facilities.
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3. Population Data, Growth Rates and Patterns 

Table 5 shows the 2008 population for Saline County, Kansas, which includes the proposed 

nonattainment area. 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 5. Population Data

County State Recommended 

Nonattainment?

2008 

Population

2008

Population 

Density 

(pop/sq mi)

Population 

Change

2000-2008

Population

% Change 

2000-2008

Saline County, 

Kansas

Yes, partial 54,657 76 1,012 2

Source: U.S. Census Bureau estimates for 2008 (http://www.census.gov/popest/datasets.html) 

This factor considers population growth for 2000-2008 in the area considered for the 

nonattainment designation. Table 5 above shows population and population growth for Saline 

County, Kansas. All population data is from the U.S. Census Bureau 

http://www.census.gov/popest/counties/CO-EST2008-popchg2000_2008.html. 

Population in Saline County grew a modest 2%. Population growth is not expected to correlate 

with increases in lead emissions. Significant changes in industrial activity within the county that 

would cause an increase in area lead concentrations are difficult to predict, but are not 

anticipated. EPA has considered the population growth rate for this area and does not believe 

that it affects the boundary determination.

4. 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 4 above

represent emissions levels taking into account any control strategies implemented on stationary 

sources in Saline County before 2008. 

The Exide facility is classified as a “synthetic minor” source and has a Class II operating permit 

issued by the State of Kansas on January 15, 2004. From 2006 to the present, Exide has 

implemented or is in progress on a number of updates to the facility’s air pollution control 

equipment. The updates are summarized in a January 24, 2011, letter to KDHE which is 

Attachment A to its TSD (KDHE 2011). From 2006 to the present, air pollution control 

equipment upgrades conducted or in progress include replacement of 10 oxide mills, associated 
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baghouses, and the addition of High Efficiency Particulate Air (HEPA) filters for each source; 

and baghouse replacements for the #2, #3 and #4 baghouses. Although this information was not 

considered as a part of the boundary recommendation, planned activities at the Exide facility 

include replacement of two more oxide mills, replacement of baghouse #5; relocation of the 

oxide mill diverter valves to a ventilated, enclosed building; and an upgrade to the ball mill 

ventilation.

As discussed above, KDHE estimated lead emissions for the Metlcast facility which lies to the 

north of the Exide facility and the violating lead air monitor. The Metlcast facility is subject to 

the 2008 National Emission Standard for Hazardous Air Pollutants (NESHAP) for Iron and Steel 

Foundries Area Sources, promulgated at 40 CFR Part 63, subpart ZZZZZ, which contains control 

requirements for reducing the lead content of foundry charge materials. These requirements are

expected to reduce future lead air emissions from the facility.

5. Meteorology

For this factor, EPA considered data from 32 years of National Weather Service average 

frequency of wind direction by season. The data on meteorology are depicted in Figure 4 below. 

These data help depict the potential for lead emissions sources located upwind of a violating 

monitor to contribute to ambient lead levels at the violation location.

Figure 4. Wind Direction Frequencies
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The three-dimensional bar chart above shows the wind frequencies in eight directions for the 

four seasons. The chart frequencies reflect the directions from which the winds come. Based on 

Figure 4, it may be concluded that the wind originates predominately from the south-southwest 

most of the year, but winds originate from the north-northeast about 20% of the time in the 

winter months. 

KDHE obtained meteorological data from the Salina Municipal Airport depicted in Figure 5. 

KDHE’s analysis based on local information indicates that the winds predominantly originate 

from the south and south-southwest, with the highest frequency of winds blowing from the south.

Figure 5. Wind Rose for Days with Monitoring Data in Excess of 0.15 μg/m3in 2010

Source: “Technical Support Document for the Recommendation of Nonattainment Boundaries in Kansas for the 2008 Lead 

National Ambient Air Quality Standard,,” Kansas Department of Health and Environment, May 10, 2011.
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6. Geography/Topography

The geography/topography analysis evaluates the physical features of the land that may have an 

effect on the air shed and, therefore, on the distribution of lead over the proposed Saline County

nonattainment area.

Saline County, Kansas, is characterized by flat to gently rolling terrain. Total topographic relief 

in the county is 160 m. The proposed nonattainment area does not have any geographical or 

topographical barriers significantly limiting air pollution transport within its air shed. Therefore, 

this factor did not play a significant role in determining the nonattainment boundary.

7. Jurisdictional boundaries 

Existing jurisdictional boundaries may be helpful in determining 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 

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 business development or transportation activities.

Only a small portion of the state recommended nonattainment area lies within the jurisdictional 

boundary of the City of Salina, Kansas. The Exide facility and violating monitor lie in Saline 

County. Based on the modeling data which are described in Section 8 below, KDHE 

recommended a nonattainment area that is bounded by major roadways. 

8. Other Relevant Information

EPA received additional information from the state relevant to establish a nonattainment area 

boundary for portions of Saline County, Kansas. As briefly mentioned above, KDHE submitted 

the results of a dispersion model analysis in support of its boundary determination. EPA 

considered this information and conducted an independent analysis in making its boundary 

determination for the Saline County nonattainment area. 

In accordance with the Lead NAAQS Final Rule, the presumptive boundary of the nonattainment 

area is the entire county with a violating monitor. The State and/or EPA may conduct additional 

area-specific analyses that could lead to a departure from the presumptive boundary. 

Boundaries may be recommended on the basis of one or any combination of the following 

techniques in addition to the eight-factor analysis:

Qualitative analysis;

Spatial interpolation of air quality monitoring data; or

Air quality simulation by dispersion modeling.
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KDHE elected to use the results of dispersion modeling for making its boundary 

recommendation to EPA. EPA evaluated the state’s analysis and conducted independent 

verification and analysis as discussed below.

The air dispersion modeling used to inform the state’s recommended nonattainment boundaries 

was conducted by ENVIRON International Corporation (ENVIRON) under contract to Exide. 

The modeling report may be found in Appendix B of KDHE’s TSD (KDHE 2011). ENVIRON

used AERMOD, EPA’s preferred dispersion model for the analysis conducted. The modeling 

was performed using actual facility emissions for “longterm” NAAQS averaging times, e.g., 

annual and quarterly averages of emissions. 

As the isopleths in Figure 2 indicate, the predicted area that exceeds the 0.15 μg/m3 Lead 

NAAQS extends approximately one-third mile to the north and one-fourth mile to the south. 

There is a sharp decrease in the lead concentrations as the distance from the facility increases, as 

would be predicted based on the physical properties of lead. The state-recommended 

nonattainment area is bounded on the north by Schilling Road, on the east by a north-south line 

one quarter mile west of South Ohio Street, on the south by East Water Well Road, and on the 

west by South Ninth Street.

As noted above, ENVIRON used annual and quarterly averages of emissions data. EPA believes 

it is more conservative to use a maximum hourly emission rate, rather than annual and quarterly 

averages, given that compliance with the standard is based on monitoring data collected on a 

once every six (1/6) day schedule, and these lead monitoring data are then averaged to obtain 

monthly means. The monthly means from each three month period are averaged to obtain rolling 

three month average data for comparison with the NAAQS. Using annual and quarterly averages

could potentially miss process variations that would be captured in the monthly or three month 

averages. EPA conducted an independent review of ENVIRON’s modeling analysis (Daye 

2011). The results of EPA’s analysis, also using AERMOD, are depicted in Figure 6 below. 

ENVIRON conducted the air modeling using a “background” lead concentration of 0.01 ug/m3

from the Wichita, Kansas, area. EPA analyzed monitored lead concentrations on dates/times in 

2010 when the wind direction was not from Exide toward the monitor (excluding 135 to 225 

degrees) to estimate ambient air lead concentrations not attributable to the Exide facility. 

Significant concentrations of lead were detected during those dates/times. It was determined that 

a “background” value of 0.01 ug/m3is not representative of the lead concentrations not 

attributable to Exide in the area surrounding the violating monitor, indicating that there are other 

possible source(s) of lead associated with the recommended nonattainment area. EPA calculated 

a three-month value for ambient lead concentrations not attributable to Exide of 0.05 ug/m3by 

averaging daily values only when meteorological data indicated hourly northerly winds. EPA 

judges that the most likely source of emissions causing ambient lead concentrations observed at 

the monitors when winds are northerly is the Metlcast facility.

Figure 6 below depicts EPA’s air dispersion modeling, which uses a “background” value of 0.05 

ug/m3to represent the concentrations estimated to be attributable to non-Exide sources, 

specifically the Metlcast facility. Using this “background” value of 0.05 ug/m3instead of 0.01 

ug/m3for the Wichita area, the isopleths representing the level of the Lead NAAQS, 0.15 ug/m3, 
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extend approximately an additional 200 m farther north, but remain within KDHE’s 

recommended nonattainment area boundary. When utilizing EPA’s more conservative 

background of 0.05 ug/m3, the results demonstrate that the boundary encompasses not only the 

predicted nonattainment area, but also provides a margin of safety, including the entire isopleth 

of 0.11 ug/m3. EPA believes that, when using this more conservative approach, the technical 

analysis supports the recommended boundary, and captures the area of predicted nonattainment 

and the contributing sources.

Conclusion

EPA concurs with the state’s recommended boundary of portions of Saline County, Kansas,

(Figure 2) which include the Exide and Metlcast facilities as the nonattainment area for the 2008 

Lead NAAQS. The boundaries of the proposed nonattainment area are defined by major 

roadways surrounding the facilities as follows: 

North - Schilling Rd

South – Water Well Rd

East – 1⁄4 mile west of S. Ohio St.

West - 9th St.

The air quality monitor in Saline County located to the north of the Exide facility and to the 

south of the Metlcast facility shows violations of the 2008 Lead NAAQS based on 2010 air 

quality data. Therefore, a nonattainment designation is required for all or some of Saline

County. The eight-factor analysis and other relevant information, including modeling results, 

supports a partial county designation for Saline County. 

Based on its consideration 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 Pb NAAQS. 
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Figure 6. EPA Air Dispersion Model Results
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References

“Technical Support Document for the Recommendation of Nonattainment Boundaries in Kansas 

for the 2008 Lead National Ambient Air Quality Standard,,” Kansas Department of Health and 

Environment, May 10, 2011.

Daye, Richard; Email correspondence to Stephanie Doolan, EPA Region 7 Air Planning and 

Development Branch, dated May 27, 2011.

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 

monitoring 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 does 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-month 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 same or a recent period indicate a significant 

likelihood that the area may be violating the 2008 Lead NAAQS.

4) Violating monitor – an ambient air monitor whose valid design value exceeds 0.15 

micrograms per cubic meter (ug/m3). As described in Appendix R of 40 CFR part 50, a violation 

can be based on either Pb-TSP or Pb-PM10 data and only three months of data are necessary to

produce a valid violating design value. 

5) 1978 Lead NAAQS – 1.5 μg/m3, National Ambient Air Quality Standard for lead 

promulgated in 1978. Based on Pb-TSP indicator and averaged over a calendar quarter.

6) 2008 Lead NAAQS - 0.15 μg/m3, National Ambient Air Quality Standard for lead 

promulgated in 2008. Based on Pb-TSP indicator and a three-month rolling average. Pb-PM10 

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