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Technical Support Do cument

Definition of important t erms used in this document:

1) Designated “unclassifiable”

– an area where EPA could not determine if there was a

violation of the 2008 Lead national ambient air quality standard ( NAAQS ) or a contribution to a

violation in a nearby area, because t here was insufficient air quality data for both 2006

- 2008 and

2007

- 2009 and where additional monitoring data for 2010 could not result in a different designation

.

2) Designated “attainment”

– an area which EPA has determined

, base d on the most 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

determine d does not contribute to a violation of the 2008 Lead NAAQS in a nearby area and that additional monitoring data from 2010 could not result in a different designation

.

3 ) Designated nonattainment area

– an area which EPA has determined

, based on a State

recommendation and/ or on the technical analys is included in this document

, has a violation of

the 2008 Lead NAAQS during the most recent three consecutive years of quality

- assured, certified air quality data.

4 ) Prior nonattainment area

– an area that is currently designated as nonattainment or

ma intenance 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 ai r monitor whose design value exceed s 0.15 micrograms per cubic meter ( μ g/m 3 ) . As described in Appendix R of part 50, a violation can be based on either

lead

- total suspended particles ( Pb

- TSP ) or Pb

- PM10 data and only three months of data are

necessary to p roduce a valid violating design value.

7 ) 19 78 Lead NAAQS

– 1

. 5 μg/m 3

, N ational Ambient Air Quality Standard for lead promulgated in 1978. Based on Pb

- TSP indicator and averaged over a calendar quarter.

8 ) 2008 Lead NAAQS

- 0. 1 5 μg/m 3

, National Ambient Air Quality Standard for lead promulgated in 2008

. Based on Pb

- TSP indicator and a three

- month rolling average. Pb

- PM 10 data may be used in limited instances

, including to show nonattainment.2 T ennessee Area Designations f

or the

2008 Lead Nationa l Ambient Air Quality Standard s 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 national ambient air quality standard ( NAAQS ) and those nearby areas that contribu te to violations. The table below identifies the counties or portions

of counties (or tribal areas) in Tennessee that EPA is designat ing “nonattainment” for the 200 8

lead national ambient air quality standard (2008 Lead NAAQS)

.

Table 1 : Area Designati on

Area (listed alphabetically) Tennessee

Recommended

Nonattainment

Counties EPA’s Designated

Nonattainment

Counties Nonattainment

area for 19 78 Lead NAAQS

Bristol, Tennessee Sullivan (partial) Sullivan (partial) No

Technical analysis for Bristol, Tenn essee

Introduction

Th is technical analysis for the Bristol Area identifies a portion of Sullivan C ounty with a monitor

that violate s the 2008 Lead NAAQS and evaluates nearby counties (if appropriate) 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 previous EPA guidance :

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

- related data in areas potentially inclu ded 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 bou ndaries (e.g., counties, air districts, reservations, etc.) ; and Any other relevant information submitted to or collected by EPA (e.g., modeling where done appropriately)

.3

Figure 1: Sullivan County Area of Bristol, Tennessee

Figure 2: Bristol, Tennessee Area and Surrounding Counties4

Figure s 1 and 2 are map s of the area analyzed showing the location and design value of the air quality monitor s in the area, the counties surrounding the violating air quality monitor

, and Tennessee’s recommended “nonattainment” boundary

. The violating monitor in the Bristol Area is located in Sullivan County in close proximity to Exide Technologies, shown in Figure 1.

The Bristol Area was not designated nonattainment for the 1978 Lead NAAQS. For each revision to a NAAQS EPA is required to conduct a separate designation action, which may result in the same or a different nonattainment boundary.

On October 16, 2009

, the State of Tennessee provided EPA with their original recommendation that a portion of Sullivan County

, be designated as “nonattainment” for the 2008 Lead NAAQS

b ased on air quality data from 2006

- 2008

. Specifically, Tennessee recommended that an area located within a 1.0 kilometer (km) radius surrounding the Universal Tr ansverse Mercator (UTM) coordinates of 4042923 meters E ast (E) , 386267 meters N orth (N)

, Z one 17, which surrounds the Exide Technologies facility, be designated nonattainment. The ir recommendation

was based on data from Federal Reference Method or Federal Equivalent Method monitors

located in the S tate

. On June 8 , 2010, Tennessee revised their recommendation based on recent modeling that had been conducted by the State. The revised recommendation from Tennessee

was for an area located within a 1. 2 5 km ra dius surrounding the UTM coordinates 40429 23 meters E, 386 267 meters N, Z one 17, which surrounds the Exide Technologies facility, to be designated nonattainment.

Based on EPA's technical analysis described below, EPA is designat ing the entire portion of

S ullivan County in Tennessee, located within a 1

. 2 5 km radius surrounding the UTM coordinates

40429 23 meters E, 386 2 6 7 meters N, Z one 17, which surrounds the Exide Technologies facility,

a s nonattainment for the 2008 Lead NAAQS

, as the Bristol nonattainment area
, based upon currently available information

. Th is county is listed above in Table 1

.

Detailed Assessment

Air Q uality D ata

This factor considers the l ead design values (in μg/m 3 ) for air q uality monitors in Sullivan County in the Bristol A

rea and the surrounding area based on data for the 200 7

- 200 9 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 f or 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 days in the 3

- month period. A l ead design value that does not meet th e 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 years in order to have a valid violating design value; a site could

mo nitor just three months and still produce a valid (violating) design value

.5

The 2008 Lead NAAQS design values for Sullivan County in the Bristol A rea are shown in

Table 2

.

Table 2 : Air Quality Data
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 )

Sullivan County,

TN Sullivan

County (partial) 471633001 0.26 0.26

471633002 0.08 0.08

471633003 0.11 0.11

Monito rs in Bold have the highest design value in the respective county.

Sullivan County shows one monitor violating the 2008 Lead NAAQS

. Therefore some area in this county and possibly additional areas in surrounding counties must be designated

nonattainment

. However, the 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 and other relevant inform ation.

The violating monitor located in Sullivan County is located in close proximity to Exide Technologies, 364 Exide Drive, in Bristol, Tennessee. The monitoring objective, according to the EPA monitor locator, is source

- oriented . The emissions from E xide Technologies will be discussed in the corresponding section below.

Emissions and Emissions

- Related Data

Evidence of l ead emissions sources surrounding 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 l ead and population 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 national inventory available when these data were compiled for the designations process in 2009. See http://www.epa.gov/ttnchie1/net/2005inventory.html

. EPA recognize s that for certa in 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 informatio n on emissions and emission controls in

their comments to EPA

. Tennessee and Eastman Chemical Company confirmed the 2005 NEI

emissions data were incorrect for Eastman Chemical Company , and provide d the actual 2008

emissions for the facility. For the rest of the Bristol Area , EPA relied on the 2005 NEI emissions

data. States were given the opportunity to provide additional information regarding source emissions prior to EPA’s final action on designations. Tennessee did not provide any new

information. D ata considered for the final designation are provided in Table 3 below.6

Table 3 shows total emissions of l ead (given in tons per year (tpy) ) for violating and potentially contributing counties in the Bristol A rea with s ources emitting (or anticipate to co ntribute) greater than 0. 1 tpy of lead according to the 2005 NEI

.

There are approximately 20,000 airport facilities in the U.S. at which leaded aviation gasoline is consumed. To evaluate the potential impact of emissions at and near these facilities, EP A recommends that States use the draft 2008 NEI. Data for airport facilities in Sullivan County which use leaded aviation gasoline are included in Table 4.

Table 3 : Lead Emissions
County Facility in State

Recommended

Nonattainment

Area ? Facility Name Facility Location 2005 NEI (tpy)

Sullivan County, TN Yes Exide Technologies 364 Exide Drive,

Bristol 0. 78

No Eastman Chemical Co,

Tennessee Operations 100 North Eastman Road, Kingsport 0. 30

According to the 2005 NEI data, Sullivan County has t wo sou rces emitting at or above 0.1 tpy

. The greatest emitter of lead in the County is Exide Technologies. Eastman Chemical Company was also considered, but is located approximately 23 km from the violating monitor. Based on the distance from the violating mo nitor, EPA believes that Eastman does not influence the

ambient l ead levels at the monitor.

Table 4: Airport Facilities Using Leaded Aviation Gas in Sullivan County

C ity Facility Name Type 2008 draft NEI (tpy) Distance to Violating

Monitor (k

ilometers )

Bristol Tri Cities Regional Airport 0.16 13.46

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

0 .1 tpy or more. T he State has not provided analyses (such as air quality modeling) to examine the pot ential impact of these ai rports on the violating monitor

.

Bristol Motor Speedway is located in Sullivan County (but not within the recommended boundary)

, and was considered in this analysis as a potential source of lead emissions. The

National Associatio n for Stock Car Auto Racing (NASCAR) currently uses a special unleaded

fuel that w as developed and w as used by the start of the 2008 season as a result of its partnership

with EP A and its fuel supplier, Sunoco. While NASCAR racing is the primary activity ongoing at Bristol Motor Speedway, there are other racing events that may currently use leaded fuel.

EPA notes that the last monitored violation at the Sullivan County mo nitors occurred in January 2008; however, there appears to be no obvious correlation between monitored violations at the Exide facility and major events at Bristol Motor Speedway, prior to or since the removal of

leaded fuel for NASCAR events.7

Population Data

Table 5 shows the 200 8 population for each county in the area that was evaluat ed, as well as the population density for each county in that 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 a ctivity contributing to elevated ambient

l ead levels . This may include ambient lead contributions from activities that would disturb lead that has been deposited on the ground or on other surfaces. Reentrainment of historically deposited l ead is not refl ected 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

Sullivan County,

Tennessee Sullivan County

( partial) 153,900 358 981 1

[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]

Growth rates and patte rns

This factor considers population growth from 2000 to 2008. A county with rapid population growth is generally an integral part of an urban area and likely to be contributing to lead concentrations in the area. Sullivan County had a one percent pop ulation change du ring the eight year time period

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

Emissions Controls

Under this factor, the existing level of control of emiss ion sources is taken into consideration. The emissions data used by EPA in this technical analysis and provided in Table 2 represent emissions levels taking into acco unt any control strategies implemented in the Bristol A rea before 2005 on stationary sour ces. The Exide facility is a newer facility than most lead sources, constructed new and commencing operation in 1994 in an enclosed structure for the purpose of new battery manufacturing new batteries. EPA has not received any additional information on

e missions reductions resulting from controls put into place since 2005.

Meteorology (weather/transport patterns)

For this factor, EPA considered data from National Weather Service (NWS) instruments and other meteorological monitoring sites in the area , us ually associated with major airport operation

. A three

- dimensional bar chart shows the wind frequencies in eight directions, for the four8

seasons, based on thirty two years of historical data 1 for the Bristol Area . These historical data may provide evide nce of the potential for lead emissions sources located upwind of a violating monitor to contribute to ambient lead levels at the violating monitor location, in the season of the

violation.

Figure 3 : Historic Wind Direction Frequency in each of Four Seasons for Sullivan County,

Tennes s ee

As seen in Figure 3 above, the predominant wind direction during th e Winter and Spring is originating from the West/Southwest ( WSW )

, while in the Summer and Autumn it is from the

East/N ortheast ( ENE )

, indicating that special consideration must be applied when determining

the northeastern and southwestern boundaries of t he nonattainment area. This figure shows that elevated pollution levels may be attributed to wind directions originatin g from the WSW and

ENE.

For each air quality monitoring site, EPA also developed a “ wind rose,” which provides information about how wind speed and direction are distributed at the NWS monitoring station during the 30

- year time period. The “spokes” on the diagram indicate the frequency of winds blowing FROM a particular direction. The length of a spoke shows the amount of time (in percentage) that the wind blows from that direction. Each concentric doted

- line circle on the diagram represents increasin g frequencies as you move out from the center. The spokes also

1 This data was taken from 1960

- 1992 Solar and Meteorological Surface Observation Network information issued jointly by the U.S. Department of Commerce: National Climatic Data Center and the U.S. Department of Energy: National Renewable Energy Laboratory.9

provide information about the speed of the winds blowing from that direction. Each spoke is broken into discrete frequency categories that are color

- coded to indicate the percentage of time

t hat wind speeds are within that category (e.g., for winds blowing from the East, approximately

two percent of the time the wind speeds are between 2.1

– 3.6 meters/second (m/s) ).

Figure 4: Bristol Wind Rose; Bristol/Tri

- City Airport

Annual Wind Ro se

– 30 years (1961

- 1990)

Figure 4 provides an annual wind rose diagram for the Bristol Area

. The wind rose was generated from 30 years (1961

- 1990) of wind speed and wind direction data collected at the NWS meteorological monitoring station located at th e Bristol/Tri

- City Airport (NWS Station # 13877). This station has the most representative long

- term record of wind data for the Bristol

A rea, including the lead monitoring site.

The Bristol Area wind rose is consistent with the wind direction bar chart in Figure 3 above and indicates there is a predominant wind that blows from the West and Southwest approximately 23 percent of the time, with a secondary wind peak from the East/Northeast approximately 2110

percent of the time. The wind speeds are less than 3.6 m/s more than 50 percent of the time. It is also important to note that winds are classified as calm (less than 0.5 m/s) approximately 23 percent of the time. The wind rose indicates that lead sources located in West/Southwest and

East/Northeast fro m the monitoring site in the Bristol Area could influence the monitored ambient air concentrations during different time periods. Also, the higher frequency of low to moderate wind speeds would indicate that air emissions sources located closer to the mon itor have a larger influence than those located more distant from the monitor.

EPA considered this historical wind direction and wind speed data to show evidence of the potential transport patterns for lead emissions sources located upwind and/or in close proximity

to that of a violating monitor to contribute to ambient lead levels at the violating monitor.

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

The geography/topography analysis evaluates the physical features of the land t hat might have an effect on the air shed and, therefore, on the distribution of lead over the Bristol A rea

.

The Bristol A

rea does not have any geographical or topographical barriers significantly limiting

air

- pollution transport within its air shed. Ther efore, this factor did not play a significant role in determining the nonattainment boundary.

Jurisdictional boundaries

Existing jurisdictional boundaries may be helpful in articulating a boundary for purposes of nonattainment designations, and for purp oses of carrying out the governmental responsibilities of planning for attainment of the l ead NAAQS and implementing control measures. These existing boundaries may include an existing nonattainment or maintenance area boundary, a county or township bound ary, a metropolitan area boundary, an air management district, or an urban planning boundary established for coordinating business development or transportation activities.

The Bristol Area does not have any jurisdictional boundaries that affect this anal ysis . Therefore, this factor did not play a significant role in determining the nonattainment boundary

Other Relevant Information

Tennessee submitted air quality modeling to support their recommendation of a 1.25 km radius boundary surrounding the Exid e facility on June 2, 2010. Tennessee also revised their recommended boundary on June 8, 2010. The modeling is based on permitted allowable emissions levels, and therefore overpredicts the observed design value at nearby monitors. The

maximum modeled co ncentration is nearly 1.5 μg/m 3 , which is much higher than the 2007

- 2009 design value of 0.26 μg/m 3 . In their revised request, Tennessee expanded the recommended boundary from a radius of 1.0 km around the monitor to 1.25 km around the Exide facility so t hat

all of the modeled values above the level of the l ead standard are contained within the Bristol Area boundary. The maximum modeled l ead value on the outer edge of Tennessee’s modified recommended boundary is 0.12 μg/m 3 , about 20 percent below the stan dard of 0.15 μg/m 311

Conclusion

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

include a portion of Sullivan C ounty in the Bristol nonattainment area for the 2008 Lead NAAQS

. This area is located within a 1. 2 5 k m radius surrounding the UTM coordinates

40429 23 meters E, 386 267 meters N, Z one 17, which surrounds the E xide Technologies facility

,

as recommended by Tennessee

.

EPA is basing this nonattainment designation determination and boundary on the fact th at Sullivan County contains an air quality monitor that shows a violation of the 2008 Lead NAAQS, based on 200 7

- 200 9 air quality data. The Exide Technologies facility is largest emissions source located near the violating monitors, and EPA believes this fa cility caused and/or contributed to the violating monitor during this period. Exide is a newer facility than most lead sources, constructed new and commencing operation in 1994 in an enclosed structure for the purpose of manufacturing new batteries. No o ther lead activities, such as primary or secondary smelting, have occurred at this location. Therefore, historical soil lead contamination in the surrounding area is expected to be less than at other facilities which have been operating12

longer and have ha d higher historical lead emissions from less

- controlled operations. The conservative modeling of emissions from the Exide facility indicate that a boundary within a

1. 2 5 km radius surrounding the UTM coordinates 404292 3 meters E, 386 2 6 7 meters N, Z one 17,

which surrounds the E xide Technologies facility

, is a sufficient distance to encompass the area

that exceed s the l ead NAAQS.

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

believes that the boundaries descr ibed 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.