“More Protection, Less Process” www.dep.state.fl.us Additional Modeling and Monitoring Information for Hillsborough County
As discussed in the department’s October letter, the conditions that caused previous violations of the National Ambient Air Quality Standard (NAAQS) for lead in Hillsborough County no longer exist. The secondary lead smelter responsible for high ambient c oncentrations in the past (the former Gulf Coast Recycling facility) has essentially been demolished and is being rebuilt from the ground up by new owners. The new facility, EnviroFocus Technologies, when complete later this year, will be the best control led lead recycling facility in the U.S., with multiple controls on its process operations, including operating within a total enclosure under negative pressure. All of the EnviroFocus control measures are embodied in the federally enforceable air construc tion permit enclosed with the October letter. The air m odeling results referenced in that permit show that the maximum impact of the EnviroFocus facility is predicted to be approximately 50% of the standard and would occur at the fence line of the facility. We have reasonable assurance that the new EnviroFocus facility will not cause or contribute to a violation of the revised lead standard.
Figure 1 (attached) is an aerial view / map show ing the location of the EnviroFocus facility (dark blue) relative to nearby ambient monitoring sites and airports

. Figure 2 is a closer view of the facility locale. To verify that the new facility will not cause or contribute to any violation of the lead NAAQS, the Hillsborough County Environmental Protection Commissi on will continue to operate the two current lead monitoring sites located 0.2 kilometers south and 0.4 kilometers north of the center of the facility (labeled “ CSX ” and “ Patent, ” respectively , on the map s ) . In addition, the

co unty recently began operating two new monitoring sites located 0.3 kilometers northwest and 0.9 kilometers north of the facility (labeled “ EFS ” and “ Kenly, ” respectively) . The data from all of the se monitors will be collected in accordance with state and federal quality assurance requirements and submitted to DEP and EPA . The primary reason for continuing the current designation of unclassifiable is to provide time for this network of four monitors t o collect data representative of the changed conditions in the area.
Figures 1 and 2 also show some modeling results based on the EnviroFocus permi t application. The model output, which includes all point sources in the immediate area and an assumed neg ligible background concentration, was post

- processed to show the maximum one

- month average concentration for each receptor site in the area for the “worst” modeled year (2004), a conservative approximation of the three

- month average upon which the lead sta ndard is based. The outer border of the light pink area in the figures represents a modeled concentration of 0.0 15 micrograms per cubic meter (ug/m3 ) , or 10 % of the NAAQS level . T he outer border of the light blue area in Figure 2 represents a modeled con centration of 0.0075 ug/m3 , or 5% of the NAAQS level

. This figure shows that a t a distance of 1.5 kilometers (red circle) from the center of the current unclassifiable area , the predicted concentrations drop to approximately 5% ofthe NAAQS level

. As further illustration of the extremely localized nature of these

impacts , a lead monitor ( “Tessy” ) was operated from 1998 to 2002 at a location approximately two kilometers north of the old Gulf Coast Recycling facility and did not record any concentrations that would have exceeded the revised lead standard (see table below)

.

Criteria Site Parameter Interval L0571074 PB 001d

Report Created:04/28/2010 15:35 Lead (12128 [25 °C]; 14129 [LC]) Units: μg/m 3

Site:L0571074

- Co H2O Dept Maint. Facility County :Hillsborough AQ S Monitor ID:12

- 057

- 1074

- 12128

- 1

Year 1 st Max 2 nd Max Quarterly Averages (#Valid Observations) Annual Max 3 Month Rolling Average 38 Month Max 3

Month Rolling Average #

Avgs > 0.15 1 st Quarter 2 nd Quarter 3 rd Quarter 4 th Quarter
1998 .50 (05/17) .40 (02/22) 0.07* [10] 0.07 [14] 0.04 [14] 0.00 [16] 0.09 (07/1998) 0.09 (07/1998) ¶ 0

1999 .40 (05/30) .20 (01/18) 0.02 [15] 0.07 [13] 0.02 [15] 0.00 [15] 0.10 (07/1999) 0.10 (07/1999) ¶ 0

2000 .20 (04/24) .10 (01/01) 0.03 [16] 0.01 [15] 0.02 [15] 0.00 [15] 0.04 (02/2000) 0.10 (07/1999) ¶ 0
2001 .30 (01/19) .20 (01/07) 0.06 [15] 0.02 [16] 0.02 [15] 0.00 [12] 0.05 (01/2001) 0.10 (07/1999) 0 * There was insufficient data to produce a valid average. ¶ Data substitution was done when computing 3

- month rolling averages, since there was insufficient data to produce a valid average. Finally, we u nderstand that EPA may have concerns about the possible impact of the EnviroFocus facility on lead concentrations at two nearby general aviation airfields. The locations of these airfields relative to the new EnviroFocus facility are shown on Figure 1. T he same modeling that pr edicts ambient lead concentrations to drop to about 5% of the lead NAAQS at a distance of about 1.5 kilometers from center of the unclassifiable area also predicts that the impact of the facility at both the Peter O. Knight and Vandenberg (Tampa Executive) airports would drop to well less than 1 % of the lead NAAQS. There is simply no interaction of lead impacts from the EnviroFocus facility with these airports that would warrant a designation of nonattain ment.

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