1

Bellefontaine, Ohio Technical Support Document

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Definition of important terms used in this document: 

1) Designated “unclassifiable” – an area where EPA could not determine if there was a 

violation of the 2008 lead NAAQS or a contribution to a violation in a nearby area, because there 

was insufficient air quality data for both 2006-2008 and 2007-2009 and where additional 

monitoring data for 2010 could not result in a different designation. 

2) Designated “attainment” – an area which EPA has determined, based on the most recent 3 

years of certified air quality data from 2006-2008 or 2007-2009, has no violations of the 2008 

lead NAAQS during 36 consecutive valid 3-month site means; and which EPA has further 

determined does not contribute to a violation of the 2008 lead NAAQS in a nearby area and that 

additional monitoring data from 2010 could not result in a different designation. 

3) Designated “nonattainment” area – an area which EPA has determined, based on a State 

recommendation and/or on the technical analysis included in this document, has a violation of 

the 2008 lead NAAQS during the most recent 3 consecutive years of quality-assured, certified air 

quality data. 

4) Prior nonattainment area – an area that is currently designated as nonattainment or 

maintenance for the 1978 lead NAAQS (including both current nonattainment areas and 

maintenance areas). 

5) Recommended nonattainment area – an area a State or Tribe has recommended to EPA be 

designated as nonattainment.

6) Violating monitor – an ambient air monitor whose design value exceeds 0.15 micrograms per 

cubic meter (μg/m3). As described in Appendix R of part 50, a violation can be based on either 

Pb-TSP or Pb-PM10 data and only 3 months of data are necessary to produce a valid violating 

design value. 

7) 1978 lead NAAQS – 1.5 μg/m3

, National Ambient Air Quality Standard for lead promulgated 

in 1978. Based on Pb-TSP indicator and averaged over a calendar quarter. 

8) 2008 lead NAAQS – 0.15 μg/m3

, National Ambient Air Quality Standard for lead 

promulgated in 2008. Based on Pb-TSP indicator and a 3-month rolling average. Pb-PM10 data 

may be used in limited instances, including to show nonattainment. 
2

OHIO 

Area Designations For the 

2008 Lead National Ambient Air Quality Standards 

EPA has revised the level of the primary (health-based) standard from 1.5 micrograms per cubic 

meter (μg/m3) to 0.15 μg/m3 measured as total suspended particles (TSP). EPA has revised the 

secondary (welfare-based) standard to be identical in all respects to the primary standard.

Pursuant to section 107(d) of the Clean Air Act, EPA must designate as “nonattainment” 

those areas that violate the NAAQS and those nearby areas that contribute to violations. 

The table below identifies the partial county in Ohio that EPA is designating as “nonattainment” 

for the 2008 National Ambient Air Quality Standard for lead (2008 lead NAAQS). 

Area (listed 

alphabetically) 

Ohio Recommended 

Nonattainment 

Counties 

EPA’s Designated 

Nonattainment 

Counties 

Nonattainment 

Area for 1978 

Lead NAAQS 

Bellefontaine Logan (partial) Logan (partial) NA 

Table 1: Ohio Nonattainment Areas for the 2008 Lead NAAQS 

Technical Analysis for Bellefontaine

Introduction 

This technical analysis for Bellefontaine identifies the partial county with a monitor that violates 

the 2008 lead NAAQS and evaluates nearby counties for contributions to lead concentrations in 

the area. EPA has evaluated these counties based on the weight of evidence of the following 

factors recommended in previous EPA guidance: 

• Air quality in potentially included versus excluded areas; 

• Emissions and emissions-related data in areas potentially included versus excluded from 

the nonattainment area, including population data, growth rates, patterns, and emissions 

controls; 

• Meteorology (weather/transport patterns); 

• Geography/topography (mountain ranges or other air basin boundaries); 

• Jurisdictional boundaries (e.g., counties, air districts, reservations, etc.); and 

• Any other relevant information submitted to or collected by EPA (e.g., modeling where 

done appropriately). 
3

Figure 1: Bellefontaine, Ohio State Recommended Nonattainment Area 

(Office of Air Quality and Planning Standards - OAQPS) 

Figure 1 is a map of the area analyzed showing the locations and design values of air quality 

monitors in the area, and the counties surrounding any violating air quality monitors. Source 

data is also labeled in Figure 1 with the following guidelines: if the source emitted 0.5 or more 

tons, the symbol, name of the facility, and emissions are labeled; if the source emitted 0.1 – 0.5 

tons, only the symbol and emissions are labeled; and if the source emitted less than 0.05 tons, 

only the symbol is shown.1

 Emissions in Bellefontaine and the surrounding areas will be 

discussed in the section addressing emissions in Logan County. The location of the detailed area 

in relation to the remainder of the State is shown in the bottom right corner of the figure.

 

1

 Emissions greater than 0.05 tpy round up to 0.1 tpy, and they are marked with the symbol and the emissions value. 

* Sources that are not labeled emitted less 

than 0.05 tpy. 
Copyrighted page(s) have been removed from 

this document. 

Please contact the EPA Docket Center, Public 

Reading Room to view this document. 

Address: 

1301 Constitution Ave, NW 

Room 3334 

Washington, DC 20004 

Telephone: 

202-566-1744 

Fax: 

202-566- 9744 

Email: 

docket-customerservice@epa.gov
5

Detailed Assessment

Air Quality Data 

This factor considers the lead design values (in μg/m3

) for air quality monitors in Logan County 

in Bellefontaine and the surrounding area based on data for the 2006-2008 and 2007-2009 

period. A monitor’s design value indicates whether that monitor attains a specified air quality 

standard. The 2008 lead NAAQS are met at a monitoring site when the identified design value is 

valid and less than or equal to 0.15 μg/m3. A design value is only valid if minimum data 

completeness criteria are met. A lead design value that meets the NAAQS is generally 

considered valid if it encompasses 36 consecutive valid 3-month site means (specifically for a 3-

year calendar period and the 2 previous months). For this purpose, a 3-month site mean is valid 

if valid data were obtained for at least 75 percent of the scheduled monitoring days in the 3-

month period. A lead design value that does not meet the NAAQS is considered valid if at least 

one 3-month mean that meets the same 75 percent requirement is above the NAAQS. That is, a 

site does not have to monitor for 3 full calendar years in order to have a valid violating design 

value; a site could monitor just 3 months and still produce a valid (violating) design value. 

County State 

Recommended 

Nonattainment? 

Monitor Name Monitor Air 

Quality 

System ID 

Monitor Location Lead Design 

Value, 

2006-2008 

(μg/m3) 

Lead Design 

Value, 

2007-2009 

(μg/m3) 

Logan, 

Ohio 

Yes Main St. – 

Daido 

Facility 

Bellefontaine 

390910005 1229 S Main St. 

(40.34278, 

-83.76028) 

0.27 NA* 

Logan, 

Ohio 

Yes Greenwood - 

Daido 

Facility 

Bellefontaine 

390910008 1215 Greenwood 

St. 

0.18 0.18 

Logan, 

Ohio 

Yes Superior – 

Daido 

Facility 

Bellefontaine 

390910003 1222 Superior 

St. 

(40.34394, 

-83.75610) 

0.12 0.12 

Logan, 

Ohio 

Yes Superior – 

Daido 

Facility 

Bellefontaine 

390910007 1205 Superior 

St. 

(40.34394, 

-83.75610) 

0.24 0.24 

Logan, 

Ohio 

Yes Richard 

Ave. – Daido 

Facility 

Bellefontaine 

390910006 320 Richard 

Ave. 

(40.34147, 

-83.75868) 

0.26 0.26 

Monitors in bold have the highest 2006-2008 and/or 2007-2009 design value in the respective county. Latitudes and longitudes 

have been provided at the sites where the AQS provided addresses are incorrect. *This monitor was replaced by the Greenwood 

St monitor in November of 2006. 

Table 2: Bellefontaine, Ohio and Surrounding Areas Air Quality Data

The 2008 lead NAAQS design values for Logan County in Bellefontaine and the surrounding 

area are shown in Table 2, and Logan County shows a violation of the 2008 lead NAAQS. 

Therefore some area in this county and possibly additional areas in surrounding counties must be 
6

designated nonattainment. It should be noted that the monitor on Main St. (AQS ID 390910005) 

was replaced by the monitor at 1215 Greenwood St. in November of 2006. This re-siting has no 

effect on the presence of violations at other nearby monitors or violations that occurred after the 

re-siting occurred. 

The absence of a violating monitor alone is not a sufficient reason to eliminate nearby counties 

as candidates for nonattainment status. Each area has been evaluated based on the weight of 

evidence of these factors and other relevant information. 

According to EPA’s monitor locator,2

 the monitor located at 1229 Main St. (AQS ID 

390910005) has an objective of determining the highest concentration for lead. This monitor is 

in very close proximity to Daido Metal Bellefontaine LLC (Daido Metal). As previously 

mentioned, this monitor was replaced by the monitor located at 1215 Greenwood St. (AQS ID 

390910008) in November of 2006. In addition, there were 3 other monitors in operation between 

2006 and 2008 in close proximity to Daido Metal. The locations of these monitors will be 

discussed in the section addressing emissions for Logan County. 

Emissions and Emissions-Related Data 

Evidence of lead emissions sources surrounding a violating monitor are an important factor for 

determining whether a nearby area is contributing to a monitored violation. For this factor, EPA 

evaluated county level emission data for lead and population data. 

Emissions 

Emissions data were derived from the 2005 National Emissions Inventory (NEI), version 2, 

which is the most up-to-date version of the national inventory available when these data were 

compiled for the designations process in 2009. See

http://www.epa.gov/ttnchie1/net/2005inventory.html. EPA recognizes that for certain counties, 

emissions may have changed since 2005. For example, certain large sources of emissions in or 

near this area may have installed emission controls or otherwise significantly reduced emissions 

since 2005. Some States provided updated information on emissions and emission controls in 

their comments to EPA. Ohio did not provide updated emissions information, therefore EPA 

relied on the 2005 NEI emissions data. These data are provided in Table 3. 

Table 3 shows total emissions of lead given in tons per year (tpy) for violating and potentially 

contributing counties in and around Bellefontaine and sources emitting (or anticipate to 

contribute) 0.1 ton per year or greater of lead according to the 2005 NEI. The county that is part 

of the Bellefontaine nonattainment area for the 2008 lead NAAQS is shown in boldface. 

There are approximately 20,000 airport facilities in the U.S. at which leaded aviation gasoline is 

consumed. To evaluate the potential impact of emissions at and near these facilities, EPA 

recommends that States use the draft 2008 NEI. These data are provided in Table 4, and contain 

the facilities emitting (or anticipate to contribute) 0.1 ton per year or greater of lead according to

the draft 2008 NEI. 

 

2

 http://www.epa.gov/air/data/geosel.html. 
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County 

Facility in State 

Recommended 

Nonattainment 

Area? Facility Name 

2005 NEI 

(tpy) Location City 

Logan 

County, Ohio Yes 

Daido Metal 

Bellefontaine LLC 0.1 

1215 Greenwood 

St. Bellefontaine 

 

Logan County 

Total Lead 

Emissions 0.2* 

Table 3: Bellefontaine, Ohio and Surrounding Areas Lead Emissions for Stationary Sources 

* Total lead emissions for Logan County were calculated by adding the 2005 NEI data for facilities not using leaded 

aviation gas (stationary sources) to the 2008 Draft NEI data for facilities using aviation gas. Sources with emissions 

below 0.1 tpy were included in this final calculation. 

City Facility Name Type 

2008 Draft 

NEI (tpy) 

Distance to NA 

area (km) 

NA NA NA NA NA 

Table 4: Bellefontaine, Ohio and Surrounding Areas Lead Emissions for Leaded Aviation Gas Facilities 

There are no individual facilities using leaded aviation gasoline in or around Bellefontaine that 

have emissions of, or greater than, 0.1 ton per year. Additionally, there are no facilities using 

leaded aviation gasoline in the entirety of Logan County, Ohio that have emissions of, or greater 

than, 0.1 ton per year. 

Using 0.2 ton per year as the total lead emissions for Logan County, EPA observes that the 

emissions from Daido Metal account for 50 percent of all lead emissions in the county. 

Although the facility has shut down as of June 2009, Ohio EPA will continue to monitor for lead 

at the Richard Ave. site (AQS Site ID 390910006). In addition to the existing source oriented 

monitoring network, 4 new source oriented sites in Ohio were operational as of January 2010: 

American Spring Wire (Cuyahoga County), Nucor Steel (Marion County), Timken Company 

Canton Bearing (Canton County), and Ellwood Engineering Castings (Hubbard, County).
Copyrighted page(s) have been removed from 

this document. 

Please contact the EPA Docket Center, Public 

Reading Room to view this document. 

Address: 

1301 Constitution Ave, NW 

Room 3334 

Washington, DC 20004 

Telephone: 

202-566-1744 

Fax: 

202-566- 9744 

Email: 

docket-customerservice@epa.gov
9

County State 

Recommended 

Nonattainment? 

2008 

Population 

2008 

Population 

Density 

(pop/sq mi) 

Population 

Change 

2000-2008 

Population % 

Change 

2000-2008 

Logan, Ohio Yes 46,220 99 204 0 

Table 5: Population Data for Logan County, Ohio 

[Source of data: U.S. Census Bureau estimates for 2008 

(http://www.census.gov/popest/datasets.html) and estimation of the area of U.S. counties] 

EPA has considered the population growth rate for this area and does not believe that it affects 

the boundary recommendation.

Emissions Controls

Under this factor, the existing level of control of emission sources is taken into consideration. 

The emissions data used by EPA in this technical analysis and provided in Table 3 represent 

emissions levels taking into account any control strategies implemented in Bellefontaine before 

2005 on stationary sources. EPA has received additional information on emissions reductions 

resulting from controls put into place since 2005. 

Ohio EPA highlighted several regulations that apply to the entire State that assist in reducing the 

potential impact on lead concentrations. These rules include restriction of emissions of fugitive 

dust, control of visible particulate emissions from stationary sources, and restrictions on 

particulate emissions from industrial processes. Additionally, Daido Metal has permanently shut 

down as of June 2009. The facility started decreasing its overall production in the summer of 

2008 due to the declining automotive industry, and there have been no violations of the 2008 

lead NAAQS since the 3 month time period ending in May 2007. With the shutdown of the 

Daido Metal, lead emissions and monitored concentrations in Logan County are not expected to 

increase. Ohio EPA will continue to monitor for lead at the Richard Ave. site. 

Meteorology (weather/transport patterns) 

For this factor, EPA considered data from National Weather Service instruments and other 

meteorological monitoring sites in the area. Historical wind direction frequencies collected 

between 1960 and 1992 are included in Figure 4 and Table 6. These data may provide evidence 

of the potential for lead emissions sources located upwind of a violating monitor to contribute to 

ambient lead levels at the violation location. Ohio EPA provided wind roses for Logan County 

in their submittal, and they are shown in Figure 5 and Figure 6. The graphical representations 

from these figures corroborate the data from the National Weather Service. 
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Figure 4: Historical Wind Direction Frequencies for Logan County, Ohio 

Figure 4 is a 3-dimensional bar chart that shows the wind frequencies in 8 directions for the 4 

seasons. These data are taken from 1960-1992 Solar and Meteorological Surface Observation 

Network information issued jointly by the U.S. Department of Commerce: National Climatic 

Data Center and the U.S. Department of Energy: National Renewable Energy Laboratory. The 

chart frequencies reflect the directions from which the winds come. 
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Logan County

Wind Frequencies 

Frequency as a % 

Seasonal Wind 

Directions 

8.36 WINWINDFNNE 

5.34 WINWINDFENE 

9.56 WINWINDFESE 

10.41 WINWINDFSSE 

21.78 WINWINDFSSW 

16.09 WINWINDFWSW 

19.48 WINWINDFWNW 

8.99 WINWINDFNNW 

11.60 SPRWINDFNNE 

8.23 SPRWINDFENE 

11.71 SPRWINDFESE 

10.30 SPRWINDFSSE 

19.24 SPRWINDFSSW 

12.36 SPRWINDFWSW 

15.82 SPRWINDFWNW 

10.75 SPRWINDFNNW 

12.80 SUMWINDFNNE 

8.84 SUMWINDFENE 

9.62 SUMWINDFESE 

10.30 SUMWINDFSSE 

23.05 SUMWINDFSSW 

14.56 SUMWINDFWSW 

11.24 SUMWINDFWNW 

9.58 SUMWINDFNNW 

10.27 AUTWINDFNNE 

6.48 AUTWINDFENE 

10.80 AUTWINDFESE 

13.04 AUTWINDFSSE 

23.44 AUTWINDFSSW 

12.59 AUTWINDFWSW 

13.65 AUTWINDFWNW 

9.73 AUTWINDFNNW 

Table 6: Historical Wind Frequency Data as Percents for Logan County, Ohio 

As shown in Figure 4 and Table 6, the period with the highest wind frequency occurs in the 

autumn months, with winds blowing from the south southwest. With the consistently strong 

representation of winds from a variation of the west in all seasons, special care must be made 

when determining the nonattainment boundary to the east of the violating monitor. 
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Figure 5: Wind Rose at Columbus International Airport (Ohio EPA) 

Figure 6: Wind Rose at Dayton International Airport (Ohio EPA) 
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Geography/topography (mountain ranges or other air basin boundaries) 

The geography/topography analysis evaluates the physical features of the land that might have an 

effect on the air shed and, therefore, on the distribution of lead over Bellefontaine and the 

surrounding area. 

The Bellefontaine area does not have any geographical or topographical barriers significantly 

limiting air pollution transport within its air shed. Therefore, this factor did not play a significant 

role in determining the nonattainment boundary. 

Jurisdictional boundaries 

Existing jurisdictional boundaries may be helpful in articulating a boundary for purposes of 

nonattainment designations, and for purposes of carrying out the governmental responsibilities of 

planning for attainment of the 2008 lead NAAQS and implementing control measures. These 

existing boundaries may include an existing nonattainment or maintenance area boundary, a 

county or township boundary, a metropolitan area boundary, an air management district, or an 

urban planning boundary established for coordinating business development or transportation 

activities. 

In EPA’s August 21, 2009 guidance memorandum, “Area Designations for the 2008 revised 

Lead National Ambient Air Quality Standard,” EPA reiterated that the presumptive boundary for 

each nonattainment area should be the county containing the violating monitor. This concept 

was first introduced in the guidance for the 1978 lead NAAQS designations, and is described in 

the 1992 General Preamble (57 FR 13549). This same presumptive boundary guidance was 

addressed most recently in the final rulemaking for the 2008 lead NAAQS (73 FR 66964). EPA 

observed, however, that States have the flexibility in their recommendations to deviate from the 

presumptive county boundary to portions of the county containing the violating monitor, stating 

that any “nonattainment area boundaries that deviate from presumptive county boundaries should 

be supported by an assessment of several factors...,” all of which have been discussed already in 

this document, except for jurisdictional boundaries. 

For the Bellefontaine area, there are several jurisdictional boundaries that can be considered. 

Logan County belongs to the Bellefontaine micropolitan statistical area, and the Ohio EPA 

Central Office and Ohio EPA Southwest District Office are responsible for air quality planning 

within all areas of Logan County. As a result, air quality planning efforts to address the 

impending lead nonattainment area in Bellefontaine should not be problematic; it should be 

noted that the final rulemaking for the 2008 lead NAAQS (73 FR 66964) specifically addressed 

transportation conformity by stating, “In light of the elimination of lead additives from gasoline, 

transportation conformity does not apply to the lead NAAQS.” Lastly, Ohio EPA has 

recommended that the nonattainment area be defined by well-known and major roads which 

coincide with sections 27, 28, 33, and 34 of Lake Township. 
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Other Relevant Information

EPA received additional relevant information from Ohio for establishing the nonattainment area 

boundary for Bellefontaine. This information will be discussed below. 

The procedure for defining the perimeter of the nonattainment boundary which involves spatial 

interpolation of historic monitor data was found to be inapplicable for Bellefontaine due to the 

unsuitable number and distribution of monitors showing exceedances of the standard. Instead, 

Ohio EPA took a hybrid approach, using the AERMOD dispersion model in conjunction with 

historic data. Ohio EPA used the modeling output from AERMOD to generate concentration 

gradients throughout the area, while the monitored data was used to generate the ratio of 

actual/modeled concentration values. These ratios can serve as “correction factors” to adjust for 

any systematic tendency of the model to over, or under, predict the monitored values. Ohio EPA 

applied the Krige algorithm for spatial interpolation of modeled concentrations and drawing of 

isopleths. Ohio EPA used 0.145 μg/m3

 as the “pre-correction factor” bounding isopleth, as this 

value shows attainment of the NAAQS. The process of expanding the nonattainment area 

boundary using the “correction factor” follows. 

Daido Metal is believed to be the predominantly responsible source for elevated lead 

concentrations in Bellefontaine; however, source information from lead sources at the facility 

were not provided to Ohio EPA due to the shutdown of the facility. Ohio EPA therefore 

modeled the entire facility as an area source, and the property dimensions were used as the size 

of the area source. The Honda East Liberty Plant and Honda Transmission Manufacturing 

facilities were modeled as single point sources using data from the 2005 NEI. Stack information 

from lead sources were provided to Ohio EPA by the Honda East Liberty facility, and this 

information was averaged to create a single lead emission source. As the Honda Transmission 

Manufacturing facility did not provide stack information to Ohio EPA, Ohio EPA used the 

averaged source parameters for the East Liberty facility for the Honda Transmission 

Manufacturing Facility. Lead source information for Quincy Castings was not provided to Ohio 

EPA, but it is believed that it is an area source and it was modeled as such. Building dimensions 

provided to Ohio EPA served as the size of the area source. 3 Emissions data used for the 

modeling analysis is included in Table 7. Surface meteorological data from Columbus, Ohio and 

upper air data from Dayton, Ohio were determined to be representative of Logan County. 

 

3

 It should be noted, however, that the Honda and Quincy Castings facilities were not included in the table 

addressing lead emissions in Logan County because the numbers for these facilities were well under 0.1 tpy. 
15

Table 7: Bellefontaine and Surrounding Area Emissions Data Used by Ohio EPA for Modeling Analysis 

Correspondence with Ohio EPA between May 5-6, 2010, confirmed that in Table 7, the 

coordinates for Quincy Castings, Inc. and Daido Metal Bellefontaine LLC are reversed. The 

correct coordinates for Quincy Castings, Inc. are -83.9726, 40.29898, and the correct coordinates 

for Daido Metal Bellefontaine LLC are -83.7598, 40.34411. Ohio EPA ascertained that the 

errors associated with the coordinates were purely typographical; the modeling was performed 

for the right facilities. EPA observed that although the 2005 NEI and 2005 TRI emissions data 

for Daido Metal Bellefontaine LLC are listed as 0.121 tpy, the maximum modeled value is listed 

at 0.1447 tpy. Ohio EPA clarified this discrepancy on May 7, 2010, by explaining that it relies 

on a fee emissions report (FER) to populate the NEI; however, data in the FER has been found to 

change after even after reporting to NEI. Ohio EPA stated that it works extensively with the 

companies, EPA, and others to develop the most accurate emissions for each facility; but in the 

end, analysis of monitor placement and modeled facilities was based on worst case emissions. 

As a result, the modeling performed for Daido Metal Bellefontaine LLC was conducted based on 

these worst case emissions; this approach was found to be the more conservative, i.e., it results in 

a larger nonattainment boundary due to the correction factor calculations. 

As previously mentioned, Ohio EPA used a correction factor to account for any under or over 

reporting from the modeled concentrations. Ohio chose to examine the months listed below in 

Table 8 because they represented the highest modeled concentration over a 3-year period. 
16

 

Table 8: Correction Factors for Logan County (Ohio EPA) 

As shown in Table 8, the highest correction factor is 2.184; this correction factor is unitless 

because both the monitored and modeled concentrations are expressed as μg/m3, and dividing 

eliminates the units in both the dividend and divisor. As 0.145μg/m3 is the pre-correction factor 

ispoleth, 0.145 μg/m3 / 2.184 yields 0.0664 μg/m3

; this can be more easily represented as 66.4 

nanograms/m3, or 66.4 ng/m3. Therefore, the final isopleth defining the proposed nonattainment 

area is 66.4 ng/m3. 

The area encompassed by this isopleth is shown by the yellow box in Figure 7. All areas outside 

of the yellow box have been modeled to show a lead impact of less than 66.4 ng/m3

. Ohio EPA 

has added an additional buffer between the nonattainment area obtained by performing the 

isopleth analysis and the final State recommended nonattainment area. The final State 

recommended nonattainment area is shown by the red outline, and once again, encompasses 

sections 27, 28, 33, and 34 of Lake Township. 
17

Figure 7: Isopleth Analysis for Logan County (Ohio EPA) 

Information supporting Ohio EPA’s modeling analysis is provided in Table 9 and Table 10. 

Some of this information has been previously explained in detail. 

Source Characterization 

Fugitives 

Modeled? Stack Parameters Comments 

Daido Metal Area No Area Source 

Quincy Castings Area No Area Source 

Honda 

Transmission Point No 

Averaged from 

Honda East 

Liberty 

Facility did not provide info 

to Ohio EPA; 2005 NEI 

data identical to Honda East 

Liberty 

Honda East Liberty Point No Averaged Point 

Table 9: Bellefontaine Area Source Characterization (Ohio EPA) 
18

Table 10: Bellefontaine Area Source Modeling Parameters (Ohio EPA) 

EPA modelers have reviewed the analysis for the Bellefontaine area and have the following 

observations: 

• Ohio EPA had little detailed information about the sources. 

• The concept of using a correction factor to expand the nonattainment boundary is 

unusual, but it is possible that more comprehensive source data might have resulted in the 

same outcome. 

• Although the NEI data for the 2 Honda facilities is identical, averaging the parameters 

from 1 facility to represent the parameters for the other could be unrealistic. 

• Ohio EPA used building dimensions or property dimensions as the basis for area source 

modeling. 

• The receptor spacing used by Ohio EPA differs slightly from the guidance which 

suggests 100 meters. 

• No background concentration was added to the modeling; Ohio EPA stated that adding a 

background concentration was not added because all surrounding sources were included 

in the modeling. 

On May 7, 2010, Ohio EPA responded to EPA’s observations by providing the following points: 

• Ohio EPA pointed out that Quincy Castings, located nearly 12 miles west of Daido 

Metal, has very small amounts of lead emissions; of these emissions, 95 percent are 

fugitive. Additionally, Quincy Castings is “inactive” as of March 5, 2010, but is 

choosing not to permanently shut down. The facility would have to re-contact Ohio EPA 

prior to resuming operations or selling the company. 

• Regarding the 2 Honda facilities, Ohio EPA relied on its own internal databases and 

internal contact with the facilities for the emission source information. The agency did 

not realize stack information was available in the NEI. Recently reported information 

shows that for the Honda Transmission facility the stack is 45' (NEI showed 42’) and 

account for about 54 percent of the NEI emissions (remaining fugitive). For the Honda 

East Liberty plant the stacks are between 85’ to 90’ (NEI showed 70’) and account for 

about 27 percent of the NEI emissions. Ohio EPA used 88’ as the stack height for both 

facilities because that was the average of the East Liberty stacks for which it had 

available information at that time. The Honda Transmission facility is about 10 miles 

northwest of Daido Metal while Honda East Liberty is about 10 miles east of Daido 

Source 

Emissions 

Used 

Emissions 

Type 

Multiple 

Sources? 

Meteorological 

Data Receptors Terrain Comments 

Daido Metal 2005 NEI Actual Yes 

2 Sites, 

1 Sector/ 

4 Seasons 

Adequate, 

200 m 

spacing 

Not 

significant 

Quincy 

Castings 2005 NEI Actual Yes 

2 Sites, 

1 Sector/ 

4 Seasons 

Adequate, 

200 m 

spacing 

Not 

significant 

Honda 

Transmission 2005 NEI Actual Yes 

2 Sites, 

1 Sector/ 

4 Seasons 

Adequate, 

200 m 

spacing 

Not 

significant 

Honda East 

Liberty 2005 NEI Actual Yes 

2 Sites 

1 Sector/ 

4 Seasons 

Adequate, 

200 m 

spacing 

Not 

significant 
19

Metal. Winds are predominantly out of the southwest, and in conjunction with the 

distance and low emissions of the 2 Honda sources, it is extremely unlikely any changes 

to stack heights would change any impact, also considering the offsetting effect of 

applying 75 percent of the Honda East Liberty emissions as fugitive area source 

emissions. The lead emissions from these facilities were not averaged. 

• To clarify the AERSURFACE run of 1 sector/4 seasons, Ohio EPA stated that the same 

AERSURFACE file was used in the monitor siting analysis and that the meteorological 

data were from 1984-1988. 

• Regarding the receptor resolution, Ohio EPA observed that 200m was adequate to model 

the maximum impact from the facilities in question. Specifically, Daido Metals appeared 

to contribute over 99.9 percent of the maximum modeled concentration, with Quincy 

Castings contributing 0.05 percent of the maximum modeled concentration. 

EPA concludes that although the modeling performed by Ohio EPA may not meet the 

requirements for an attainment demonstration, the air dispersion modeling performed for Fulton 

County showing the 66.4 ng/m3

 isopleth obtained from the correction factor calculation in 

relationship to the entire State recommended nonattainment area results in a reasonable boundary 

for the nonattainment area. 

Conclusion

After considering the factors described above, EPA has determined that it is appropriate to 

include a portion of Logan County as nonattainment for the 2008 lead NAAQS. 

The air quality monitor in Logan County shows a violation of the 2008 lead NAAQS, based on 

2006-2008 and 2007-2009 air quality data. Daido Metal is located in Bellefontaine, and 

accounts for 50 percent of all lead emissions in Logan County. The cumulative process of this 

factors analysis in conjunction with the relevant air dispersion modeling that Ohio EPA provided 

ultimately leads to the final nonattainment area. EPA finds it appropriate to designate the 

portions of Logan County that are encompassed by: sections 27, 28, 33, and 34 of Lake 

Township as nonattainment for the 2008 lead NAAQS. Based on the consideration of all the 

relevant, available information, as described above, EPA believes that the boundaries described 

herein encompass the entire area that does not meet (or that contributes to ambient air quality in 

a nearby area that does not meet) the 2008 lead NAAQS. 

On June 15, 2010, EPA communicated to Ohio that we were proposing to adopt the State’s 

recommended nonattainment designation and boundaries for the Bellefontaine area. A 

subsequent Federal Register notice was published on July 8, 2010 (75 FR 39255), notifying the 

public that EPA was proposing to take action on State recommendations for lead nonattainment 

areas. In the same notice, EPA started a public comment period with an end date of August 16, 

2010. EPA did not receive any public comments germane to the nonattainment designation and 

boundaries for the Bellefontaine area, nor did we receive any additional information from the 

State. 
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Accordingly, EPA has determined that the portions of Logan County that are encompassed by: 

sections 27, 28, 33, and 34 of Lake Township should be designated as nonattainment for the 

2008 lead NAAQS, as seen below in Figure 8. 

Figure 8: Bellefontaine, Ohio Final Nonattainment Area (OAQPS)