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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX

75 Hawthorne Street

San Francisco, CA 94105-3901

JUN 122013

OFFICE OF THE

REGIONAL ADMINISTRATOR

The Ilonorable Janice K. Brewer

Governor of Arizona

1700 West Washington Street

Phoenix, Arizona 85007

Dear Governor Brewer:

I am writing to notify you that available lead monitoring data indicate that the air quality designation for

the hayden area, which is currently designated unclassifiable, should be revised to nonattainment for the

2008 lead national ambient air quality standards (NAAQS).

Reducing levels of lead pollution is an important part of the U.S. Environmental Protection Agency’s

(EPA) commitment to a clean, healthy environment. Lead exposure can cause a range of adverse health

effects, most notably in children. Exposures to low levels of lead early in life have been linked to effects

on Intelligence Quotient, learning, memory, and behavior. In order to ensure that public health and

welfare are protected, the EPA revised the lead NAAQS on October 15, 2008, lowering it from the 1.5

micrograms per cubic meter (ig/m 3level set in 1978 to a level of 0.15 ig/m 3.See 73 FR 66964. An

area violates the revised standards if any arithmetic 3-month mean concentration is greater than

0.1 5tg/m 3.

On December 15, 2009, in accordance with the process set out in CAA section 107(d)(1). Arizona

submitted its recommended designations for the revised standard to the EPA. At that time, preliminary

monitoring data indicated that the Hayden area, within which Asarco is the single significant source of

lead emissions, was violating the new standard. You recommended that the EPA delay designating the

Hayden area based on a written commitment from Asarco to improve its control of lead emissions. You

further recommended that the EPA promulgate a nonattainment designation for the Hayden area if,

despite Asarco’s etforts, the area continued to violate the lead NAAQS on or after March 2010.

Subsequently. the Arizona Department of Environmental Quality (ADEQ) recommended that, if the

EPA were to determine that monitored concentrations in the area were exceeding the standard, the EPA

should follow your recommendation to promulgate a lead nonattainment area with boundaries identical

to the Hayden sulfur dioxide nonattainment area boundaries with respect to State lands. The EPA

designated an area with the boundaries you recommended as unclassifiable because data indicating

violations of the 2008 lead NAAQS in the Hayden area were still preliminary at the time of final

designation.

In her November 8, 2011 letter informing you of the EPA’s decision to designate the Hayden area

unclassihable. EPA Administrator Lisa Jackson advised you that, should we subsequently determine that

the lead standards are being violated, we would initiate the process to redesignate the Hayden area to

nonattainment. Quality assured, certified monitoring data now available indicate that three—month rolling

average values violated the lead standards for February-April, March-May. and April-June 2012, leading

Printed on ReycIed Paper
us to conclude that the designation of the Hayden area should be revised to nonattainment. See

Enclosure -2012 Pb Design Values, ADEQ’s Globe Highway Monitor (AQS ID 04-007-1002).

Under section 107(d)(3)(B) of the Clean Air Act, your recommendation for the area (or areas) you

consider to be appropriate for redesignation is due 120 days after you receive this letter. The EPA’s

guidance regarding the factors to consider when establishing nonattainment area boundaries is included

in the November 12, 2008 Federal Register notice that finalized revisions to the lead NAAQS. See 73

FR 66964 at 67032. The EPA may make modifications to the recommended designations and

boundaries as it deems necessary (CAA section 107(d)(1)). If we believe modifications are appropriate,

we will notify you at least 60 days prior to taking any final action, which will provide an opportunity for

you to comment on any changes that the EPA proposes to your recommendation.

A state with an area that is redesignated to nonattainment is required to submit to EPA within 1 8 months

a state implementation plan demonstrating how the area will attain the lead standards as expeditiously as

practicable, but no later than five years after designation.

We look forward to continuing to work with you and your staff to ensure appropriate designations and

area boundaries are established, and to assist your staff with the development of a plan that will help

realize the public health protections intended by the standards. Your air quality staff may contact

Deborah Jordan, Air Division Director, at (415) 947-8715 or Colleen McKaughan, Associate Air

Division Director, at (520)498-0118 if they need additional information.

Sincerely,

dBl.ieifeld

Enclosure

cc: 1-lenry Darwin, Director, Arizona Department of Environmental Quality

Eric Massey, Air Director, Arizona Department of Environmental Quality

Don Gabrielson, Director, Pinal County Air Pollution Control District

2
Enclosure

2012 Pb Design Values (DV5), ADEQ’s Globe Highway Monitor (AQS ID 04-007-1002)

3-month period 2012 DVs

Nov-Dec-ian 0.07

Dec-ian-Feb 0.14

ian-Feb-Mar 0.15

Feb-Mar-Apr 0.20

Mar-Apr-May 0.16

Apr-May-iun 0.20

May-Jun-iul 0.15

Jun-Jul-Aug 0.14

Jul-Aug-Sep 0.12

Aug-Sep-Oct 0.11

Sept-Oct-Nov 0.09

Oct-Nov-Dec 0.06

*O3ta pulled from AO.S on June 5, 2013

The lead NAAQS is violated when the design value (the three-month rolling average of ambient lead

concentrations) exceeds 0.15 mg/rn 3.