EPA 

John R. Kasich, Governor 

Mary Taylor, Lt. Governor 

Scott J. Nally, Director 

APR 1 9 2013 

Ms. Susan Hedman 

Regional Administrator 

U.S. EPA Region 5 

77 W. Jackson Blvd. 

Chicago, IL 60604 

Re: Revised Clean Data Showing Attainment of the Lead National Ambient Air 

Quality Standard for the Logan County Nonattainment Area in the State of 

Ohio 

Dear Administrator Hedman: 

On May 14, 2012, Ohio EPA submitted a clean data request for the above referenced 

nonattainment area. That request was based upon 2009 to 2011 lead monitoring data 

certified in U.S. EPA's Air Quality System (AQS). Today, Ohio EPA is submitting a 

revised clean data request based upon 201 0 to 2012 lead monitoring data certified in 

U.S. EPA's Air Quality System (AQS). The Logan County nonattainment area is 

continuing to attain the 2008 lead standard of 0.15 ~g/m . 

In October 2009 Ohio EPA submitted our "2008 Revised Lead Standard Recommended 

Designations and Nonattainment Boundaries" recommendation. At that time Ohio 

recommended that partial areas of Cuyahoga, Fulton and Logan Counties be 

designated as nonattainment for the lead standard. U.S. EPA approved our 

recommendation on November 22, 2010 (75 FR 71 033) with an effective date of 

December 31, 2010. 

The partial nonattainment boundary for Logan County includes sections 27, 28, 33 and 

34 of Lake Township near the Daido facility located in the City of Bellefontaine (Figure 

1 ). In June of 2009, the Daido faci lity permanently shut down all lead operations and 

since that time there has been a clear downward trend in lead emissions. 

50 West Town Street • Suite 700 • P.O. Box 1049 • Co lumbus, OH 43216-1049 

www.epa.ohio.gov • (614) 644-3020 • (614) 644-3184 (fax) 
Logan County Revised Clean Data Request- Lead 

Page 2 

Figure 1. Logan County Partial Nonattainment Area 

The Daido facility, through a contractor, historically operated four monitors recording 

lead levels and reporting monthly composite sampling results to Ohio EPA. When the 

2008 lead standard was promulgated, 24-hour average monitoring was required 

beginning in January of 2010 in accordance with 40 CFR Part 50, Appendix R. The site 

used monthly composite samples before January 2010. 

Beginning January 1, 2010 the Ohio EPA Southwest District Office monitoring staff took 

over operation of site 39-091-0006 in Bellefontaine in Logan County in accordance with 

Appendix R (approved via the 2010 monitoring plan). For the reasons discussed below, 
Logan County Revised Clean Data Request - Lead 

Page 3 

Ohio EPA believes it is appropriate to treat the operation of the monitor as of January 1, 

2010, as the operation of a new monitor. 

The previous operator was an environmental contractor for Daido. Support for the lead 

sampling site then became the role of the Ohio EPA Division of Air Pollution Control -

Groveport Field Office. Ohio EPA purchased material and constructed a new ground 

sampler platform that was delivered and installed at the site. That platform was set on a 

slightly different location from the previously used elevated platform. A new TSP 

sampler was purchased and installed at the site. New calibration requirements became 

effective in January 201 0 and were employed for the new sampler. A new laboratory for 

analysis of the lead concentrations and a new analytical lead method became effective 

in January 2010. 

A new PQAO site agreement was signed between Ohio EPA's Northwest District Office 

(NWDO) and Southwest District Office so that the site would share a collocated site with 

NWDO located in Delta, Ohio (in Fulton County) as per the PQAO guidance. That 

agreement was expected to become effective January 1, 2010. Subsequently, Ohio 

EPA signed a new lease and Occupancy Agreement with the landowner of the site. 

Monitoring data for the 2010 to 2012 period now demonstrates attainment. The 2008 

lead NAAQS are considered met when the identified design value is both valid and less 

than 0.15 ug/m3

. 

Table 1. Air Quality Data: 2010 to 2012 

Site 

Location 

City 

39-091-0006 

Richard Ave. - Daido 

Facil ity 

Bellefontaine 

Three-month rolling average 

(ug/m3

) 

3-month 

period 2010 2011 2012 

Nov -Jan 0.005 0.004 0.004 

Dec-Feb 0.005 0.003 0.003 

Jan -Mar 0.006 0.004 0.003 

Feb-Apr 0.006 0.003 0.003 

Mar-May 0.006 0.003 0.003 

Apr-Jun 0.004 0.003 0.003 

May-July 0.004 0.003 0.004 

Jun-Aug 0.004 0.003 0.003 

July-Sept 0.004 0.003 0.003 

Aug-Oct 0.004 0.005 0.003 

Sept-Nov 0.004 0.005 0.003 

Oct-Dec 0.004 0.004 0.003 

Sites with one or more months of a 

composite analysis missing in any 

three-month period. 
Logan County Revised Clean Data Request - Lead 

Page 4 

A design value is considered valid only when minimum data-completeness 

requirements are met. 

Data for the November to January and December to February three-month rolling 

periods is incomplete due to the lack of sampling in November and December of 2009. 

As noted above, Ohio EPA commenced monitoring at the site beginning January 1, 

2010 in accordance with the requirements for 24-hour sampling. In accordance with 40 

CFR Part 50, Appendix R, Section (4)(a), for sites that begin monitoring lead after this 

rule is effective but before January 15, 2010, a 2010 to 2012 lead design value that 

meets the NAAQS will be considered valid if it encompasses at least 34 consecutive 

valid 3-month means (specifically encompassing only the 3-year calendar period). 

There is also incomplete data for the 3-month means for January to March 2012 and 

February to April 2012 periods. Data for these periods did not meet the 75°/o capture 

criteria because only three of five samples were collected in both February and March 

of 2012. In each case, the missed samples resulted in data capture of less than 75°/o, 

for the 3-month mean periods but greater than 50°/o of the required monthly collections. 

Therefore, Ohio EPA is performing a conservative substation analysis in accordance 

with 40 CFR Part 50, Appendix R, Section (4)(c)(ii)(B). 

Typically, Ohio EPA would perform an imputation and bootstrapping procedure to 

substitute missing monitor values with statistically valid calculated values. This 

procedure, however, is dependent on the availability of a more complete data set from a 

close proximity co-located monitor for which a high degree of correlation can be 

established. This is not the case for this Logan County monitor. Therefore, the 

imputation and bootstrap procedure was not used to substitute missing values. 

Instead, following 40 CFR Part 50, Appendix R, the highest daily value for the months of 

February and March for the 2010 to 2012 time period recorded by monitor 39-091-0006 

were selected as replacements for the missing data, bringing each of the three months 

with missing data to 1 00°/o capture. The highest daily lead concentration for the month 

of February, 0.006 ug/m3

, occurred in 2010, and the highest monthly average 

concentration for the month of March, 0.018 ug/m3

, was observed in 2010. Using these 

values as replacements for all missing data in the months in question, a passing value 

is identified for all 34 consecutive averages in the 2010 to 2012 time period. Thus, 

following 40 CFR Part 50, Appendix R (4)(c)(ii)(B), "below NAAQS level test" criteria, 

the recorded actual monitor values can be used to demonstrate attainment of the 

NAAQS. 
Logan County Revised Clean Data Request - Lead 

Page 5 

Figure 2 shows the time series of monthly average values recorded at site 39-091-0006 

from January of 2008 to December of 2012, as well as a nine-month moving average of 

this time series. 

0.140 

0.120 

-

i 0.100 

6 

... 

"' 

~ 0.080 u 

8 

~ 0.060 

"' ... 

QJ 

> 

<t 

:E 0.040 ... 

6 

~ 

0.020 

0.000 00 

0 

C: 

~ 

~ ~ 00 ~ 9 :! 0 

ci :; C: u a. 

<! ...... 0 ~ <! 

39-091-0006 

9 ~ 0 0 0 0 rl rl 

9 rl rl rl rl rl rl 

:; .... C: ci :; t C: u a. ...... 0 ~ <! ...... 0 ~ <! 

Date 

Figure 2: Monthly average lead concentrations, 2008 through 2012. 

39-091-0006 

9 Month M.A. 

rl rl N ~ N N rl '( rl rl '( 

:; .... C: a. :; .... u ~ u ...... 0 <! ...... 0 

Examination of the moving average clearly demonstrates that the monthly average 

concentrations of lead recorded in this area have been declining steadily, and values 

above 0.100 ug/m3 have not been observed in this area since September of 2008. Also 

clearly demonstrated is the rapid drop in lead concentrations following the shutdown of 

Daido Metals in June of 2009. 

This analysis method is consistent with the method identified in 40 CFR Part 50, 

Appendix R, and the substituted value test confirms that the collected data is sufficient 

to demonstrate attainment of the NAAQS 
Logan County Revised Clean Data Request - Lead 

Page 6 

Therefore, we request U.S. EPA to act in a timely manner to m·ake a formal finding that 

the nonattainment area identified in Figure 1 above is attaining the 2008 lead standard. 

Ohio EPA plans to follow up this letter with requests for redesignation of this 

nonattainment area. 

If you or your staff have any questions or would like additional information, please feel 

free to contact Jennifer Dines at (614) 644-3696. 

Sincerely, 

~ Scott J. Nally 

Director, Ohio Environmental Protection Agency 

cc: Bob Hodanbosi, DAPC 

Jennifer Dines, DAPC