## Technical Support Document for the Recommendation of

Nonattainment Boundaries in Kansas for the 2008 Lead National Ambient Air Quality Standard



# May 10, 2011

Department of Health and Environment

Division of Environment

Bureau of Air (785) 29 6

- 60242 Contents

INTRODUCTION

.......... ........................ ...................................... ...... ............................. .. .................. 3

N ONATTAINMENT B OUNDAR Y D EVELOPMENT

.................. ........................... .......... ...... ..... ... ............. . 5

T ECHNICAL E VALUATION

F ACTOR 1: E MISSIONS D ATA

... ............................................................................. ... ...............6

F ACTOR 2: L EVEL OF C ONTROL OF E MISSIONS S OURCES

................. .............. ..... ...... .............9

F ACTOR 3: A IR Q UALITY D ATA

....................................................................... ...... .. ........... ..10

F ACTOR 4: M ETEOROLOGY

...................................................... ................ .................... ... ...... 12

F ACTOR 5: J URISDICTIONAL B OUNDARIES

......................................... .................... . ... .......... 14

F ACTOR 6: P OPULATION D ENSITY AND D EGREE OF U RBANIZATION

....... .... .......... ..... ......... 14

F ACTOR 7: G EOGRAPHY /T OPOGRAPHY

................. .. ... ........................................... .... ........... 16

F ACTOR 8: E XPECTED G ROWTH

.................................. ................ ............................ .... .......... 16

A IR D ISPERSION M ODELING

........................................................... .... ............... ... .... ...... 17

R ECOMMENDATION

............. ...... .......................................................................................... .. ........... 18 APPENDIX A. Salina Air Emissions Reductions Projects

– Exide

– Letter 1/24/2011 APPENDIX B. Air Quality Dispersion Modeling Report for Determination of Lead

Non a ttainment Area Extent

– ENVIRON for Exide Technologies APPENDIX C. Monitoring Data

L IST OF T ABLES Table 1. Air Emissions of Lead for Exide Technologies

- Salina 2005

– 2010

.... . . ............... ..... ......... . 7

T able 2

. Known current sources of lead air emissions within 20 km of the lead monitor

s ited near Exide Technologies

- Salina

........ .............................. ............................ ... ............. 8

T able 3

. Estimated Air Emissions o f Lead for Metlcast Products 2005

– 2010

..... ........ ..... ...... ...........9

Table 4. Three

- month rolling averages of lead concentrations at the Exide Technology

- Salina monitor, Saline County, Kansas

.. ......................................... .... ........ ...12 Table 5. 2010 population and population density by census tract for Saline County, Kansas

. .. ...... . 1 6 Table 6. Population of Saline County, Kansas 2001

– 2010

........................... ................ .......... .... .......1 7

Table 7. Maximum Three

- Mont h Average Lead in Air Concentrations for Modeled Receptors

from LEADPOST

.... ..... ....................................................................................................... ..1 8

L IST OF F IGURES Figure 1. All known current sources of lead air e missions within 20 km of KDHE monitor sited near Exide Technologies

- Salina Figure 2

... ...................................................... .... .......8 Figure 2. Lead monitor site at Exide Technologies

- Salina facility

.................................... . ...... .......11 Figure 3. Wind rose for 1999

- 2009 for the Salina Municipal Airport, Salina, Kansas

.......... ........ ....13 Figure 4. Wind rose for 2010 (all days) for the Salina Municipal Airport, Salina, Kansas

......... ....1 3 Figure 5. Wind rose for lead NAA QS exceedance days in 2010 for the Salina Municipal Airport, Salina, Kansas

................................................................................................ .. .......1 4 Figure 6. City limits and 2010 Census tracts for Salina, Kansas

......... ................................. ...... .......1 5 Figure 7. Maximum Modeled Average Lead Concentrations and KDHE Proposed

Nonattainment Area

.................... ...... ...... ............................................................................. . 193

In troduction

On October 15, 2008, the U.S. Environmental Protection Agency (EPA) promulgated a revision to the National Ambient Air Quality Standard (NAAQS) for lead, and on November 12, 2008 published the rule in the Federal Register at 73 FR 66964

. The le ad NAAQS rule establishes 0.15 micrograms per cubic meter (μg/m 3 ) as the primary and secondary standard for lead (see http://www.epa.gov/air/lead/standards.html ) . Compliance with the 2008 standard is determined by calculating the monthly average of the lead concentrations at each monitor and averaging that value with the prior two months ’ averages (e.g. 3

- month rolling average). When calculating the 3

- month average, concentrations below 0.155 μg/m 3 are rounded to 0.15 μg/m 3 and are still in complian ce, while concentrations equal to or above 0.155 μg/m 3 are rounded to 0.16 μg/m 3 and represent a violation of the standard. It should be noted that compliance with the previous , much higher standard of 1.5 μg/m 3 was based on a calendar quarterly average. P revious to the

2008 rule ’ s lowering of the lead standard, Kansas had no known areas with exce e dances for

lead.

Note concerning lead: Lead is a pollutant that, for industrial sources, is primarily emitted from: (1) the combustion of fuel that contains lead ; (2) the manufacture or processing of materials, including recycled materials, that contain lead (e.g., batteries); or (3) the

conversion of lead ore into refined lead. Since lead is a dense material that is emitted as particulate matter and is not transp orted significant distances like most other air pollutants, the impact from lead sources is usually in close proximity to the emission source.

As provided under Clean Air Act Subparagraph 107(d)(1)(A), the governor of each state is required to submit to t he EPA a recommendation regarding the attainment status of all areas within that state. Each area (or portion thereof) of the state shall be designated as:
nonattainment for areas that do not meet the NAAQS or contain sources that

contribute to nonattainme nt in a nearby area that does not meet the NAAQS;
attainment for areas that meet the NAAQS; or

unclassifiable for areas that cannot be classified attainment or nonattainment based

on available information.

In a letter dated September 29, 2009, Governor P arkinson submitted to EPA a recommendation that all areas in the state be classified as being unclassifiable relative to the lead standard. At that time, no lead monitors were in operation in the state.

When EPA revised the lead NAAQS it also revised requ irements for lead monitoring, including provisions requiring an expansion of the lead monitoring network. A phased approach for monitor deployment was provided. In the first phase, air quality agencies were required to deploy, by January 1, 2010, lead moni tors in areas known or suspected of violating the NAAQS. An emissions

- based threshold was established as a component to assist in determining monitor deployment. Sources with lead emissions of 1 ton / yr were to have a monitor sited nearby. This requirement could be waived if it could be demonstrated (through modeling) that ambient air impacts from the source would not exceed 50% of the NAAQS.4

An administrative petition was filed with EPA seeking a review of the 1.0 ton/yr threshold. EPA granted the petition and proposed to revise the threshold to 0.5 ton/yr. On December 27, 2010, EPA finalized revisions to the monitoring requirements, lowering the source emissions threshold from 1.0 to 0.5 ton/yr. Should additional sources require monitoring as

a result of t he lower threshold, the monitors must be operational by December 27, 2011.

Saline County is the single area within Kansas under consideration for nonattainment of the lead NAAQS . A ll other counties are currently attainment/ unclassifiable.

T he final le ad ambient air monitoring requirements

, published December 27 , 2010

, are summarized at http://www.epa.gov/oaqps001/lead/pdfs/Leadmonitoring_FS.pdf , and are as follow s:
Source

- orie nted monitors

o Air quality monitors should be placed near any industrial facility that emits 0.5 tons per year or more of lead.

o Any new monitors located near an emissions source must be operational no later than December 27, 2011.

o Source

- oriented monitors r equire the use of the most recent 3

- year period for determination of compliance

. P opulation ( ― non

- source ‖ )

- oriented monitors

o Lead monitoring is required in large urban areas with a population of 500,00 0 people or more a t multi

- pollutant ambient monitoring sites
(known as the NCore network).

o Lead monitoring at these sites will begin January 1, 2012. Airport

- oriented monitors

o EPA is maintaining a 1.0 ton/ yr lead emission threshold for airports.
However, EPA is requiring a 1

- year monitoring study of 15 additi onal airports (beyond those currently required to monitor at the existing 1.0 ton/ yr emission threshold).

In its Kansas Ambient Air Monitoring Plan for Airborne Lead (Pb) document ( http://www.epa.gov/region7/air/quality/pdf/ks_revisedleadplan_2009.pdf ), t he Kansas Department of H ealth and Environment (KDHE) proposed two source

- oriented monitor locations, one at each of the Exide Technologies facilities in Salina and Kan sas City, as well as an airport monitor at Wichita Mid

- Continent Airport

. This proposal has been superseded by the final lead ambient air monitoring requirements so that

, based on 20 08 through 2010 inventories, the only Kansas source with lead emissions hi gher than the 0.5 ton threshold is the Exide Technologies

- Salina lead acid battery manufacturing facility. The highest lead emissions value for the Exide Technologies

- Kansas City facility during the period 2008 to 2010 was 340 lbs (0.17 ton), in 2008. The most recent lead emissions

value for the Wichita Mid

- Continent Airport is 584 lbs (0.29 ton), based on EPA ’ s estimate for the 2008 National Emissions Inventory.

The purpose of this document is to provide EPA with a recommended geographic lead5

nonattai nment boundary around the Exide Technologies

- Salina facility, and the appropriate technical justification for that boundary.

Nonattainment Boundary Development

For monitors that do not meet the lead NAAQS, the lead NAAQS preamble (73 FR 66964)

discuss es a presumptive boundary for nonattainment areas. This presumptive boundary is defined as the perimeter of the county containing the violating monitor. However, defining a presumptive nonattainment boundary does not constitute a binding or rigid determina tion. Deviations may be appropriate or necessary, for example, to ensure the nonattainment area includes not just the sources that are causing the NAAQS violation, but also nearby sources that may contribute to the NAAQS violations.

Lead is a pollutant th at is associated with direct emissions from sources and does not readily participate in chemical reactions occurring in the atmosphere. With the elimination of leaded gasoline, lead emissions have been reduced dramatically, and the largest sources

of lead are typically associated with emissions from stationary sources. With these facts in
mind, it is recognized that there will be cases where the appropriate boundary is smaller than the presumptive county boundary.

In the preamble to the lead NAAQS

, EPA ide ntified eight subjects, or factors, for states to consider as they develop recommendations for nonattainment boundaries. No additions or changes were made to the factors in subsequent guidance provided by EPA on August 21, 2009 ( ― Area Designations for the 2008 Revised Lead National Ambient Air Quality

Standards

, ‖ William T. Harnett, EPA). Should a state choose to deviate from the presumptive boundary, EPA consistently recommends that states conduct an eight

- factor analysis. These eight factors influenc ing t he development of a nonattainment boundary are

listed below.

1. Emissions data*

2. Level of control of emissions sources

3. Ai r quality data*

4. Meteorology

5. Jurisdictional boundaries

6. Population density and degree of urbanization

7. Geography/topography

8. Expected growth ( including extent, pattern and rate of growth)

* In areas potentially included versus excluded

As stated in the lead NAAQS rule: ― At the revised standard level, EPA expects stationary

sources to be the primary contributor to violations of the NAAQS ‖ (73 FR 67032). The

final rule also discusses situations for which a single source is causing a NAAQS violation, and that a state may well be able to define a nonattainment boundary that is smaller than the presumptive boundary, provided that the area

- specific ana lysis supports such a determination (73 FR 67033). An area

- specific analysis may be supported by results from6

an air quality simulation by dispersion modeling (73 FR 67034). An area larger than the presumptive county nonattainment boundary may also be reco mmended should additional sources or influencing factors outside the county be causing or contributing to the NAAQS

violation. As the secondary standard was revised to be identical in all respects to the primary lead standard, it is expected that all areas will have the same designation and boundary for each standard.

The details of the eight

- factor analysis are discussed below, followed by a discussion of the dispersion modeling results used to develop the recommended nonattainment boundary.

Factor 1: Em issions Data Lead is a metal found naturally in the environment as well as in manufactured products and can be emitted into the air in the form of particles small enough to stay suspended in the air, known as total suspended particulates. Lead emitted to t he air can be inhaled directly or ingested after it settles onto surfaces or soil. EPA recommends that proposed nonattainment designations for the 2008 lead NAAQS reflect not only the areas of measured violations, but also the nearby areas that contribute to measured violations. The highest levels of lead in air are commonly found near lead smelters. Additional point sources of lead include

cement

, glass , and lead acid battery manufacturing plants, iron and steel foundries, copper

smelt ers
, and metal mines

. A s well , ambient lead is emitted from the combustion of leaded aviation gasoline ( ― avgas ‖ ) in non

- commercial small planes.

No complex chemistry is needed to form lead or lead compounds in the ambient air; therefore, concentrations of lead are typically h ighest near lead sources. Further, lead concentration decreases markedly with distance from the source. A ccording to EPA’s last published Latest Findings on National Air Quality report, lead concentrations for sites that

are not near a source of lead are a pproximately 10 times less than the typical concentration s near the source ( http://www.epa.gov/airtrends/2007/report/trends_report_full.pdf ). An example of t he degree to which lead co ncentration decrease s with distance in ambient air is

characterized in the EPA memo Selection of Airports for the Airport Monitoring Study : ―The Santa Monica airport monitoring study... reported a three

- to four

- fold decrease in

ambient lead concentr ations over a distance of 80 meters between two monitors sited to evaluate the lead gradient downwind from the runway‖ ( http://www.epa.gov/otaq/regs/nonroad/aviati on/memo

- selc

- airport

- mon

- stdy.pdf ).

As stated above, t here is one point source in Kansas that emits lead above the 0.5 ton

threshold : Exide Technologies

- Salina (Exide), in Saline County. Exide manufactures lead acid batteries for automobile, truck, a nd marine applications. F acility lead emissions were

calculated to be 2.17 tons (4

, 340 lbs) for calendar year 2010. This value was based upon stack test data that the facility uses for its annual compliance demonstration as a Class II permit

- by

- rule source (i.e., with actual emissions less than 50% of major source thresholds). Table 1 shows Exide ’ s lead emissions for years 200 5

– 2010.7 Table 1

. Air Emissions of Lead for Exide Technologies

- Salina 200 5

– 2010

Year Lead Air Emissions

tons lbs

2005 3.08 6,160

2006 3.12 6,240

2007 3.31 6,620

2008 2.25 4,500

2009 2.15 4,300

2010 2.17 4,340

A compliance inspection report in Exide’s file contains a not e that the Salina facility was

― running four shifts 24/7 ‖ in 2007, the year corresponding to the peak in lead emissions in

Table 1 . This impl ies that the facility was operating at full capacity at that time , the de facto physical maximum facility emissions of 3.31 tons of lead , even before installation of any new permitted controls

.

Based on the most rece nt data available from the Kansas Emissions Inventory (KEI)

, communications with local air emissions sources, compliance demonstrations, the 2008 National Emissions Inventory (NEI), and EPA’s Toxics Release Inventory (TRI ), there are

10 additional known ai r sources of lead within 20 kilometers of the lead monitor near Exide in Saline County (Figure 2 below) . Th ree of these facilities, Philips Lighting

, Great Plains Mfg.

- Salina, and Great Plains Mfg.

- Kipp, ha d reported lead emissions in the past (40 lbs for Philips Lighting in 2009 , 688 lbs for Great Plains Mfg.

- Salina in 2009, and 2 lbs for

Great Plains

- Kipp in 2008 ), but by inventory year 2 0 10 ha d modified their operations

such that their lead emissions are now zero or close to zero ; therefore, thes e sources have not been considered for this analysis

.

Table 2 lists the current known lead sources within 20 km of the Exide monitor with most

recent actual emissions greater than zero , along with the latest available emissions values

and the sources ’ dis tance and relative direction from the monitor. Figure 1 displays the geographical distribution of the same. The KDHE has not identified any upwind sources of lead in or around Saline County that would influence a nonattainment boundary drawn

around the Exi de facility and nearby monitor. F ugitive lead emissions, should there be any, would be associated with resuspension of previously deposited lead, most likely from emissions from the Exide facility, and will be contained to safe concentrations within the

re commended nonattainment boundary according to air dispersion modeling results.8 Table 2 . Known current sources of lead air emissions within 20 km

of the lead monitor sited near Exide Technologies

– Salina

Source Lead
Emissions (lbs) Year Sourc e Distance (km) Relative

Direction

Exide Technologies

- Salina 4

, 340 2010 Compliance

demonstration 0.1 S

Metlcast Products ( 3 electric
induction furnace s ) 283 2010 KEI and

calculation using AP

- 42 0.4 N

Salina Municipal Solid Waste
Landfill (waste oil b urner) 6.0 2010 Calculation using AP

- 42 7.7 WSW

Salina Regional Health Center (heliport) 0.70 2008 NEI 6.3 N

Burger’s Valley Airport 0.99 2008 NEI 18.6 NW

J Roesner Airport 0.14 2008 NEI 15.8 ENE
Salina Municipal Airport 334 2008 NEI 4.1 WNW

Silers Pl ane Valley Airport 0.87 2008 NEI 11.9 NE

Figure 1 . All known current sources of lead air emissions within 20 km of KDHE monitor sited near Exide Technologies

– Salina9

Metlcast Products Metlcast Products operates a gray iron casting facility usin g three electric induction furnaces. Based on its reported annual production of gray iron, lead emissions may be estimated using an emission factor of 0.0545 lbs of lead per ton of iron produced, which is the midpoint for the range of values of 0.009

- 0.100 given in Table 12.10

- 5 in AP

- 42. The wind rose in Figure 5, which displays the wind direction for the days in 2010 the Exide monitor exceeded 0.15 μg/m 3 , suggests that no source to the north of the monitor was responsible for any of the exceedances. Metlc ast’s location close by the monitor, however, points to its being included within the nonattainment boundary for the purposes of this

determination.

Table 3 shows Metlcast’s gray iron production and estimated lead emissions for years

2005

– 2010.

Table 3

. Estimated Air Emissions of Lead for Metlcast Products 200 5

– 2010

Year Tons gray metal produced Est. lbs lead

2005 6,330 345

2006 5,788 315

2007 5,510 300

2008 8,142 444

2009 4,586 250

2010 5,190 283

Saline County Airports/Heliport

In the 2008 Natio nal Emissions Inventory, EPA estimated the Salina Municipal Airport’s annual lead emissions to be 334 lbs (Table 2). The center of the airport’s very long (12,300 ft) main north

- south runway is located approximately 2.0 km north and 3.4 km west of the

Exid e facility. Due to the strong southerly nature of winds in the region, the lead emissions from this airport are not expected to impact the Exide lead monitor to any significant degree. Therefore, the lead emissions from the Salina Municipal Airport were no t included in determining the nonattainment boundary in this study. Likewise, due to the very low lead emissions values, relatively northern locations, and relatively great distances, the remaining three airports and heliport in Saline County were also not included in determining the nonattainment boundary.

Factor 2: Level of Control of Emissions Sources Exide Technologies

- Salina This facility is classified as a synthetic minor source, and has a Class II operating permit issued January 15, 2004, authoriz ing Exide Technologies to operate pursuant to K.A.R. 28

- 19

- 564 (Class II operating permits; permits

- by

- rule; sources with actual emissions less than 50 percent of major source thresholds).10

In a January 24, 2011 letter to KDHE (Appendix A) , Matthew Spenc er, EHS Manager at the Salina facility summarized control activities since 2006 as follows:

1. Five

- year project commenced April 2006 to replace the 10 oxide mills. Project included replacement of oxide mills, associated baghouses, and the addition of

HEPA f ilters for each source. Current status: Oxide mills #1 and #2 completed September 2006 Oxide mills #3 and #4 completed July 2009 Oxide mills #5 and #6 completed October 2010 Oxide mills #7 and #8 replacement commenced January 2011

2. Replaced baghouse #3 Sept ember 2009

3. Replaced baghouse #2 November 2010

4. Replacement of baghouse #4 commenced January 2011

5. Planned activities indicated in the letter are to:

Replace oxide mills #9 and #10 Replace baghouse #5

Relocate oxide mill diverter valves to lower level in vent ilated, enclosed building Upgrade ball mill ventilation

Metlcast Products Lead emissions for Metlcast have been estimated using the midpoint of a range of emission factor values given in AP

- 42. Metlcast is subject to the 2008 National Emission Standard

fo r Hazardous Air Pollutants for Iron and Steel Foundries Area Sources, or ZZZZZ MACT
standard, which calls for the removal nationwide of lead

- containing components in scrap metal used by foundries ―to the extent practicable

. ‖ This area source MACT standard arguably has had and will in future years have the effect of lowering Metlcast’s lead

emissions below the AP

- 42

- based estimated values

.

Factor 3: Air Quality Data

In general , determining if an area is either meeting or violating a NAAQS requires the

calcu lation of a metric referred to as a design value. For many NAAQS pollutants, three years of data are required before a design value can be determined. The lead NAAQS design value is based upon a 3

- year period, but since it utilizes a 3

- month rolling averag e, 38 months of data (the most recent 3

- year period plus two previous months) are required.

A characteristic of the lead NAAQS is that a design value is not necessary to determine if an area has violated the standard. The averaging time and form of the le ad standard is based

upon a 3

- month rolling average, which is not to exceed 0.15 μ g/m 3 . A single 3

- month rolling average over the 0.15 μ g/m 3 level constitutes a violation of the standard. Determining that an area has attained the lead standard requires a l ead design value that meets the NAAQS, which requires three years (plus two months) of supporting data.

There is one lead monitor operating in Kansas, sited just to the north of the Exide Technologies

- Salina facility, that has measured a rolling 3

- month average lead concentration that violates the lead NAAQS since its installation in 2010. Th e Exide lead11

monitor is located approximately 1 0 0 meters north of the property boundary of Exide Technologies in Saline County , as shown in F igure 2

.

Figure 2

. L ea d monitor site at Exide Technologies

- Salina facil i ty

The Exide monitor began collecting data in January 2010. Three years of data have not yet been collected and a true design value is not currently available. As discussed above, however, the lack of a design value does not prevent a determination that a violation of the lead NAAQS has occurred. Three consecutive months of data are required before a comparison against the NAAQS can be made; only one 3

- month rolling average above the

0.15 μ g/m

3 standar d is needed to violate the lead NAAQS.

Based upon the data available at this time (February 2010

– February 201 1 ), the Exide

monitor has recorded five 3

- month rolling averages violating the lead NAAQS. The highest

of these 3

- month rolling averages occurred over the period Ju ly

– September 2010, at

0. 42 μ g/m

3

. Table 4 lists the three

- month rolling averages recorded to date

.12 Table 4

. Three

- month rolling averages of lead concentrations

at the Exide Technology

- Salina monitor , Saline County, K ansas

Time Perio d 3

- Month Rolling

Average (μg/m 3 ) NAAQS Violation

Feb

- Apr 2010 0.10 no

Mar

- May 2010 0.10 no Apr

- Jun 2010 0.11 no May

- Jul 2010 0.23 yes

Jun

- Aug 2010 0.32 yes

Jul

- Sep 2010 0.42 yes (max)

Aug

- Oct 2010 0.35 yes Sep

- Nov 2010 0.27 yes

Oct

- Dec 2010 0.1 5 no

Nov

- Jan 2011 0.08 no
Dec

- Feb 2011 0.09 no

Factor 4: Meteorology

Like all loca litie s within the state, Salina experiences hot, humid summers and cold, dry winters. The average temperature in Salina is 55° F (13° C), and the average relative

humidi ty is 64%. Precipitation averages 32.3 inches (820 mm) per year, and snowfall averages 18.4 inches (467 mm) per year. On average, January is the coolest month, July is the warmest month, and May is the wettest month. Over the course of a year, temperatures range from an average low of 19 ° F (

- 7° C) in January to an average high of 93° F (34° C) in July ( http://en.wikipedia.org/wiki/Salina,_Kansas ).

For pollutant dispersion the most important mete orological parameters are wind speed and

wind direction , typically shown in the form of a wind rose. Each vector on a wind rose represents the amount of time the wind blows from one of 16 compass sectors. The length of each vector represents the percentage of time that the wind is blowing from a particular direction. The various colors show the percentage of time that wind from a particular direction is in a particular range of wind speed (knots).

Wind information for Saline County is collected at the Sali na Municipal Airport. Figure 3 is a wind rose generated from data collected for years 1999

– 2009

. Wind information for Saline County for 2010, the only complete year for which lead NAAQS exceedances have been recorded so far, is shown in Figure 4

. According to this information, the predominant

wind directions are south and south

- southeast, with the highest frequency o f winds blowing

from the south.13

Figure 3 . Wind rose for 1999

- 2009 for the Salina Municipal Airport, Salina, Kansas (source: WRPLOT View)

Figure 4 . Wind rose for 2010 (all days) for the Salina Municipal Airport, Salina, Kansas (source: WRPLOT View)14

Figure 5 is a wind rose generated for the 21 days in 2010 the lead monitor near Exide recorded lead concentrations exceeding 0.15 μg/m 3 . Not e the almost total lack of any wind direction with a northerly component, indicating that Exide is essentially the single source responsible for the exceedances recorded.

Figure 5 . Wind rose for lead NAAQS exceedance days in 2010 for the Salina Municipal Airport, Salina, Kansas (source: WRPLOT View)

Factor 5 : Jurisdictional Boundaries The final lead NAAQS rule states: ― In situations where a single source, rather than multiple sources, is causing a NAAQS violation, the EPA believes that a state may wel l be able to

use area

- specific analyses to identify whether a nonattainment area that is smaller than the county boundary is appropriate ‖ (73 FR 67033). The KDHE is the state agency responsible

for a ir quality regulatory programs for Saline County

. Since t here are no known sources of lead in Saline County upwind of the Exide facility, and since neither Saline County’s nor the City of Salina’s jurisdictional boundar ies conform to the modeled extent of significant
lead emissions, KDHE proposes to base the lea d nonattainment boundary on the results of air dispersion modeling on the Exide facili ty alone, using through roads for setting well

defined boundaries.15

Factor 6: Population Density and Degree of Urbanization

The U.S. Census Bureau estimates for the 2010 Census show that 55,606 people lived in

Saline County in 20 10 ( http://factfinder2.census.gov/ ) . Figure 6 shows the census tracts used for the 2010 Census (magenta) along with the Salina city limits (turquois e). Table 5 shows 2010 population and population density values for Saline County by tract number.

Figure 6. City limits and 2010 Census tracts for Salina, Kansas16 Table 5 . 2010 p opulation and population density by census tract for Saline County, Kansas

Geographic Area Population Land Area (km 2 ) Density (persons/km 2 )

Saline County 55,606 1,894.6 29

Census Tract 1 5,598 8.5 662

Census Tract 2 2,643 17.2 153

Census Tract 3 5,734 5.0 1,138

Census Tract 4 3,107 1.8 1,748

Census Tract 5 5,884 3. 4 1,751

Census Tract 6 2,718 36.9 74

Census Tract 7 5,912 6.9 855

Census Tract 8 4,035 32.5 124

Census Tract 9 7,092 4.5 1,594

Census Tract 10 5,201 11.4 455

Census Tract 11 4,034 851.5 5

Census Tract 12 3,648 915.0 4

Note that tract 7, the reside ntial tract immediately to the north of the Exide plant, has a population density of approximately half that of tracts 4, 5, and 9 to the north. Salina ’s

downtown area is located approximately 7 km north of the Exide lead monitor

, with close

to 300 busines ses ( http://salinadowntown.com/ ).

Factor 7: Geography/Topography

Kansas is typified by flat to gently rolling terrain

. The western two

- thirds of the state, which includes Saline County, has a generally flat or undulating surface , with a very gradual increase in elevation westward toward the Rocky Mountains

. Total topographic

relief across the county is only 1 6 0 m , demonstrating the general flatness of the terrain. According to U.S. Department of Agriculture Soil Survey Data, Saline County is characterized by topographic features ranging from level to moderately sloping uplands

. The city of Salina, as well as most of Saline County, lie s within the Smoky Hills ecoregion

. Salin a does not have significant topographic features that affect lead pollution transport ; therefore

, topography is not considered a significant factor in defining the boundar y of th is

lead nonattainment area.

Factor 8: Expected Growth Salina is a characteristically small Midwestern city with mode st growth. Since 200 1 , its population has grown 3. 2 percent; recent job growth is negative, around

- 1.8 % ( http://www.bestplaces.net/city/kansas/salina ). It is reasonable to expect flat to modest growth over the next decade. Table 6 shows Saline County population for years 200 1

– 2010.17 Table 6 . Population of Saline County, Kansas 2001

– 2010

(Source: U.S. Census Bureau)

Year County Population

2001 53,869

2002 53,988

2003 53,738

2004 53,808

2005 53,888

2006 53,914

2007 54,105

2008 54,109

2009 54,364

2010 55,606

Air Dispersion Modeling

Exide Technologies contracted with ENVIRON International Corporation (ENVIRON) to perform air dispersion modeling for its Salina facility in order to assist in the determination of the nonattainment boundary

. ENVIRON’s work product, Air Quality D ispersion Modeling Report f

or Determination of Lead Non

- Attainment Area Extent , is appended to this document as Appendix B

. Please refer to Appendix B for all technical background regarding the modeling portion of this document.

ENVIRON modeled the Exide facility using AERMOD, the approved air dispersion model, in its default regulatory mode with the following control options (from Appendix B ):

A djust stack he ights for stack

- tip downwash

U s e upper

- bound concentration estimates for sources influenced by building

downwash from super

- squat buildings

I ncorporat e effects of elevated terrain

E mploy the calms processing routine

E mploy the missing data processing routi ne

Use of A ctual V ersus A llowable E missions In its memo ―Use of Allowable Emissions for National Ambient Air Quality Standards (NAAQS) Impact Analyses Under the Requirements for Prevention of Significant Deterioration (PSD)‖ ( http://www.epa.gov/region7/air/nsr/nsrmemos/naaqs.pdf ), EPA discusses its preference for using allowable emission values for incorporating into air dispersion model inputs, but also discusses its allowance for usin g actual emissions values for ―long term‖ NAAQS averaging times, i.e., annual and quarterly averaging times. As the 2008 lead NAAQS incorporates a rolling 3

- month average, which is slightly more long18

term than a quarterly averaging time, KDHE agreed in its modeling protocol for Exide to
use actual values in its modeling inputs for emission rates

.

Model Post

- Processing

P aragraph s 3.3 and 3.4 of Appendix B discuss the methodology used to apply the recommended 0.01 μg/m 3 lead background concentration to the m aximum monthly concentrations for Exide’s emission sources generated by AERMOD, and process these values via the LEADPOST program into maximum three

- month concentrations for all combined sources ready to input into GIS software for presentation as concentr ation isopleths. In order to help the reader see how these concentration values compare among different receptors, the table ― Maximum Three

- Month Average Lead in Air Concentrations for Modeled Receptors f

rom LEADPOST ,‖ found in the ENVIRON hard copy report ’s companion DVD, is presented below in part.

Table 7 . Maximum Three

- Month Average Lead in Air Concentrations

for Modeled Receptors from LEADPOST

UTMx (Meters) UTMy

(Meters) Receptor

Type Elevation

(Meters) Hill

Height

Scale (Meters) Receptor

Flagpole

He ight (m) Modeled 3

-

Month Average Lead

Concentration (ug/m3) Recommended

Background

Lead

Concentration (ug/m3) 3

- Month

Average Lead
Concentration

with Background (ug/m3) Source

Group Ending

Month

and Year

620,967.9 4,292,889.5 Ambient

Monitor 380.80 380.80 0 0.36 0.01 0.37 ALL Sep 2005

619,560.0 4,293,400.0 Schilling
School 380.15 380.15 0 0.01 0.01 0.02 ALL Aug 2008

621,485.0 4,294,430.0 Coronado

School 378.68 378.68 0 0.02 0.01 0.03 ALL Aug 2005

620,000.0 4,291,700.0 Gridded 381.10 381.10 0 0.01 0.01 0 .02 ALL Oct 2005

620,000.0 4,291,800.0 Gridded 381.10 381.10 0 0.01 0.01 0.02 ALL Oct 2005

620,000.0 4,291,900.0 Gridded 381.10 381.10 0 0.01 0.01 0.02 ALL Dec 2004

620,000.0 4,292,000.0 Gridded 380.92 380.92 0 0.01 0.01 0.02 ALL Aug 2006

620,000.0 4,2 92,100.0 Gridded 381.10 381.10 0 0.01 0.01 0.02 ALL Aug 2006

620,000.0 4,292,200.0 Gridded 381.10 381.10 0 0.01 0.01 0.02 ALL Sep 2006

... ... ... ... ... ... ... ... ... ... ...

Recommendation

Figure 3

- 1 of Appendix B

, Maximum Modeled Three Month Average Lead Concentrati ons and Proposed Non

- Attainment Area, displays the model’s output lead concentration isopleths around the Exide facility at various intervals out to 0.025 μg/m 3 . The figure also shows Exide’s proposed nonattainment boundary as a rectangle encompassing the

standard’s 0.15 μg/m 3 isopleth close by the facility’s property line

— indeed, along the property line on the south and east. In consideration of the use of actual emission rates for modeling as well as for public health reasons

, KDHE proposes to extend the nonattainment boundary to that of a rectangle encompassing the 0.075 μg/m 3 isopleth as shown in Figure

7. In descriptive terms, the proposed area is that region in and south of the City of Salina,19

Kansas bounded on the north by East Schillin g 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

.

Figure 7. Maximum Modeled Average Lead Concentrations and

KDHE Proposed Nonattainment Area