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) 296-6024
2

Contents

INTRODUCTION ...............................................................................................................................3

NONATTAINMENT BOUNDARY DEVELOPMENT...................................................................................5

TECHNICAL EVALUATION

FACTOR 1: EMISSIONS DATA..................................................................................................6

FACTOR 2: LEVEL OF CONTROL OF EMISSIONS SOURCES.......................................................9

FACTOR 3: AIR QUALITY DATA............................................................................................10

FACTOR 4: METEOROLOGY...................................................................................................12

FACTOR 5: JURISDICTIONAL BOUNDARIES...........................................................................14

FACTOR 6: POPULATION DENSITY AND DEGREE OF URBANIZATION...................................14

FACTOR 7: GEOGRAPHY/TOPOGRAPHY................................................................................16

FACTOR 8: EXPECTED GROWTH............................................................................................16

AIR DISPERSION MODELING........................................................................................... 17

RECOMMENDATION ..........................................................................................................................18

APPENDIX A. Salina Air Emissions Reductions Projects – Exide – Letter 1/24/2011

APPENDIX B. Air Quality Dispersion Modeling Report for Determination of Lead 

Nonattainment Area Extent – ENVIRON for Exide Technologies

APPENDIX C. Monitoring Data

LIST OF TABLES

Table 1. Air Emissions of Lead for Exide Technologies - Salina 2005–2010....................................7

Table 2. Known current sources of lead air emissions within 20 km of the lead monitor 

sited near Exide Technologies - Salina..................................................................................8

Table 3. Estimated Air Emissions of 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..........16

Table 6. Population of Saline County, Kansas 2001–2010................................................................17

Table 7. Maximum Three-Month Average Lead in Air Concentrations for Modeled Receptors

from LEADPOST..................................................................................................................18

LIST OF FIGURES

Figure 1. All known current sources of lead air emissions 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.............13

Figure 5. Wind rose for lead NAAQS exceedance days in 2010 for the Salina Municipal 

Airport, Salina, Kansas.........................................................................................................14

Figure 6. City limits and 2010 Census tracts for Salina, Kansas.......................................................15

Figure 7. Maximum Modeled Average Lead Concentrations and KDHE Proposed

Nonattainment Area..............................................................................................................19
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Introduction

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 lead 

NAAQS rule establishes 0.15 micrograms per cubic meter (μg/m3) 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/m3 are rounded to 0.15 μg/m3 and are still in compliance, 

while concentrations equal to or above 0.155 μg/m3 are rounded to 0.16 μg/m3 and represent 

a violation of the standard. It should be noted that compliance with the previous, much 

higher standard of 1.5 μg/m3 was based on a calendar quarterly average. Previous to the 

2008 rule’s lowering of the lead standard, Kansas had no known areas with exceedances 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 transported 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 the 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 nonattainment 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 Parkinson 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 requirements 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 monitors 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.
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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 the 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. All other counties are currently attainment/unclassifiable. 

The final lead ambient air monitoring requirements, published December 27, 2010, are 

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

follows:

Source-oriented 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 require the use of the most recent 3-year period 

for determination of compliance. 

Population (―non-source‖)-oriented monitors

o Lead monitoring is required in large urban areas with a population of 

500,00 0 people or more at 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 additional 

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), the Kansas 

Department of Health and Environment (KDHE) proposed two source-oriented monitor 

locations, one at each of the Exide Technologies facilities in Salina and Kansas 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 2008 

through 2010 inventories, the only Kansas source with lead emissions higher 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 lead
5

nonattainment 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) 

discusses 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 determination. 

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 that 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 identified 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 influencing the development of a nonattainment boundary are 

listed below.

1. Emissions data*

2. Level of control of emissions sources

3. Air 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 analysis supports such a 

determination (73 FR 67033). An area-specific analysis may be supported by results from 
6

an air quality simulation by dispersion modeling (73 FR 67034). An area larger than the 

presumptive county nonattainment boundary may also be recommended 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: Emissions 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 the 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 

smelters, and metal mines. As 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 highest near lead sources. Further, lead 

concentration decreases markedly with distance from the source. According 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 approximately 10 times less than the typical concentrations

near the source (http://www.epa.gov/airtrends/2007/report/trends_report_full.pdf). An 

example of the degree to which lead concentration decreases 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 concentrations 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/aviation/memo-selc-airport-mon-stdy.pdf). 

As stated above, there 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, and marine applications. Facility 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 2005–2010. 
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Table 1. Air Emissions of Lead for Exide Technologies - Salina 2005–2010

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 note 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 implies 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 recent 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 air sources of lead within 20 kilometers of the lead monitor near Exide 

in Saline County (Figure 2 below). Three of these facilities, Philips Lighting, Great Plains 

Mfg. - Salina, and Great Plains Mfg. - Kipp, had 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 2010 had modified their operations 

such that their lead emissions are now zero or close to zero; therefore, these 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’ distance 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 Exide facility and nearby monitor. Fugitive 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 

recommended 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 Source

Distance

(km)

Relative 

Direction

Exide Technologies - Salina 4,340 2010 Compliance 

demonstration 0.1 S

Metlcast Products (3 electric 

induction furnaces)

283 2010

KEI and 

calculation 

using AP-42

0.4 N

Salina Municipal Solid Waste 

Landfill (waste oil burner) 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 Plane 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 – Salina
9

Metlcast Products

Metlcast Products operates a gray iron casting facility using 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/m3, suggests that no source to the north of the monitor was 

responsible for any of the exceedances. Metlcast’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 2005–2010

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 National 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 

Exide 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 not 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, authorizing 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 Spencer, 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 filters 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 September 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 ventilated, 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 

for 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 

calculation 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 average, 

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 lead standard is based 

upon a 3-month rolling average, which is not to exceed 0.15 μg/m3. A single 3-month 

rolling average over the 0.15 μg/m3level constitutes a violation of the standard. 

Determining that an area has attained the lead standard requires a lead 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. The Exide lead 
11

monitor is located approximately 100 meters north of the property boundary of Exide 

Technologies in Saline County, as shown in Figure 2.

Figure 2. Lead monitor site at Exide Technologies - Salina facility

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 μg/m3standard is needed to violate the lead NAAQS.

Based upon the data available at this time (February 2010–February 2011), 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 July–September 2010, at 

0.42 μg/m3. 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, Kansas

Time Period

3-Month Rolling 

Average (μg/m3)

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 0.15 no

Nov-Jan 2011 0.08 no

Dec-Feb 2011 0.09 no

Factor 4: Meteorology

Like all localities 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 

humidity 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 meteorological 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 Salina 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 of 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/m3. Note 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 well 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 air quality regulatory programs for Saline County. Since there 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 boundaries conform to the modeled extent of significant 

lead emissions, KDHE proposes to base the lead nonattainment boundary on the results of 

air dispersion modeling on the Exide facility 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 2010 (http://factfinder2.census.gov/). Figure 6 shows the census tracts 

used for the 2010 Census (magenta) along with the Salina city limits (turquoise). 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, Kansas
16

Table 5. 2010 population and population density

by census tract for Saline County, Kansas

Geographic Area Population Land Area (km2) Density (persons/km2)

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 residential 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 businesses (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 160 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, lies within the Smoky Hills ecoregion. 

Salina does not have significant topographic features that affect lead pollution transport;

therefore, topography is not considered a significant factor in defining the boundary of this

lead nonattainment area.

Factor 8: Expected Growth

Salina is a characteristically small Midwestern city with modest growth. Since 2001, 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 2001–

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 Dispersion 

Modeling Report for 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):

Adjust stack heights for stack-tip downwash

Use upper-bound concentration estimates for sources influenced by building 

downwash from super-squat buildings

Incorporate effects of elevated terrain

Employ the calms processing routine

Employ the missing data processing routine

Use of Actual Versus Allowable Emissions

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 using 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 long 
18

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

Paragraphs 3.3 and 3.4 of Appendix B discuss the methodology used to apply the 

recommended 0.01 μg/m3lead background concentration to the maximum 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 concentration 

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 from 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 

Height 

(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 4,292,100.0 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 Concentrations 

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/m3. The figure also 

shows Exide’s proposed nonattainment boundary as a rectangle encompassing the

standard’s 0.15 μg/m3isopleth 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/m3isopleth 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 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.

Figure 7. Maximum Modeled Average Lead Concentrations and

KDHE Proposed Nonattainment Area