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 w as 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 2006-200 8 and 2007-2009 and where additional monitoring data for 2010 could not result in a diff erent designation.

2) Designated “attainment” – an area which EPA has determined, based on the m ost 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 th e 2008 lead NAAQS in a nearby area and that additional monitoring data from 2010 could not resu lt 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 inc luded in this document, has a violation of the 2008 lead NAAQS during the most recent 3 consec utive years of quality-assured, certified air quality data.

4) Prior nonattainment area – an area that is currently designated as nonattainme nt 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 a re necessary to produce a valid violating design value.

7) 1978 lead NAAQS – 1.5 μg/m 3 , National Ambient Air Quality Standard for lead pr omulgated in 1978. Based on Pb-TSP indicator and averaged ov er a calendar quarter.

8) 2008 lead NAAQS – 0.15 μg/m 3 , 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-ba sed) standard from 1.5 micrograms per cubic meter (μg/m3) to 0.15 μg/m3 measured as total suspe nded 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, EP A 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 Oh io 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 identifie s the partial county with a monitor that violates the 2008 lead NAAQS and evaluates nearby counties f or contributions to lead concentrations in
the area. EPA has evaluated these counties based o n 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 poten tially 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 dist ricts, reservations, etc.); and

• Any other relevant information submitted to or coll ected by EPA (e.g., modeling where done appropriately).3 Figure 1: Bellefontaine, Ohio State Recommended Non attainment Area (Office of Air Quality and Planning Standards - OAQ PS)

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 emissio ns are labeled; if the source emitted 0.1 – 0.5 tons, only the symbol and emissions are labeled; an d if the source emitted less than 0.05 tons, only the symbol is shown. 1 Emissions in Bellefontaine and the surrounding ar eas will be discussed in the section addressing emissions in Lo gan 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 tp y, and they are marked with the symbol and the emis sions value. * Sources that are not labeled emitted less than 0.05 tpy.

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Detailed Assessment

Air Quality Data

This factor considers the lead design values (in μg /m 3 ) 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 monitori ng site when the identified design value is valid and less than or equal to 0.15 μg/m 3 . 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 v alid 3-month site means (specifically for a 3- year calendar period and the 2 previous months). F or 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 me et the NAAQS is considered valid if at least one 3-month mean that meets the same 75 percent req uirement is above the NAAQS. That is, a site does not have to monitor for 3 full calendar y ears 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/m 3 ) Lead Design

Value,
2007-2009 (μg/m 3 ) 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. L atitudes and longitudes have been provided at the sites where the AQS provi ded addresses are incorrect. *This monitor was rep laced 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 add itional areas in surrounding counties must be6

designated nonattainment. It should be noted that the monitor on Main St. (AQS ID 390910005) was replaced by the monitor at 1215 Greenwood St. i n November of 2006. This re-siting has no effect on the presence of violations at other nearb y monitors or violations that occurred after the re-siting occurred.

The absence of a violating monitor alone is not a s ufficient 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 inform ation.

According to EPA’s monitor locator, 2 the monitor located at 1229 Main St. (AQS ID 390910005) has an objective of determining the high est concentration for lead. This monitor is in very close proximity to Daido Metal Bellefontain e 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. T he locations of these monitors will be discussed in the section addressing emissions for L ogan County.

Emissions and Emissions-Related Data

Evidence of lead emissions sources surrounding a vi olating monitor are an important factor for determining whether a nearby area is contributing t o a monitored violation. For this factor, EPA evaluated county level emission data for lead and p opulation 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 nationa l 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 informati on on emissions and emission controls in their comments to EPA. Ohio did not provide update d 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 a nd sources emitting (or anticipate to contribute) 0.1 ton per year or greater of lead acc ording to the 2005 NEI. The county that is part
of the Bellefontaine nonattainment area for the 200 8 lead NAAQS is shown in boldface

.

There are approximately 20,000 airport facilities i n the U.S. at which leaded aviation gasoline is consumed. To evaluate the potential impact of emis sions at and near these facilities, EPA
recommends that States use the draft 2008 NEI. The se data are provided in Table 4, and contain the facilities emitting (or anticipate to contribut e) 0.1 ton per year or greater of lead according to
the draft 2008 NEI.

2 http://www.epa.gov/air/data/geosel.html.7

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 calculat ed by adding the 2005 NEI data for facilities not u sing leaded aviation gas (stationary sources) to the 2008 Draft NEI data for facilities using aviation gas. Sourc es with emissions below 0.1 tpy were included in this final calculati on.

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 avi ation gasoline in or around Bellefontaine that have emissions of, or greater than, 0.1 ton per yea r. Additionally, there are no facilities using leaded aviation gasoline in the entirety of Logan C ounty, 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 o f 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 Enginee ring Castings (Hubbard, County).

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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 2 008 (http://www.census.gov/popest/datasets.html) and es timation of the area of U.S. counties]

EPA has considered the population growth rate for t his 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 an alysis and provided in Table 3 represent emissions levels taking into account any control st rategies implemented in Bellefontaine before 2005 on stationary sources. EPA has received addit ional 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 rul es include restriction of emissions of fugitive dust, control of visible particulate emissions from stationary sources, and restrictions on particulate emissions from industrial processes. A dditionally, Daido Metal has permanently shut down as of June 2009. The facility started decreas ing 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 concentra tions in Logan County are not expected to
increase. Ohio EPA will continue to monitor for le ad 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. Histo rical 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. Ohi o 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 Na tional Weather Service.10 Figure 4: Historical Wind Direction Frequencies for Logan County, Ohio

Figure 4 is a 3-dimensional bar chart that shows th e 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. Depa rtment of Commerce: National Climatic Data Center and the U.S. Department of Energy: Nati onal Renewable Energy Laboratory. The chart frequencies reflect the directions from which the winds come.11 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 t he highest wind frequency occurs in the autumn months, with winds blowing from the south so uthwest. With the consistently strong representation of winds from a variation of the wes t in all seasons, special care must be made when determining the nonattainment boundary to the east of the violating monitor.12 Figure 5: Wind Rose at Columbus International Airp ort (Ohio EPA)

Figure 6: Wind Rose at Dayton International Airport (Ohio EPA)13

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

The geography/topography analysis evaluates the phy sical features of the land that might have an effect on the air shed and, therefore, on the distr ibution of lead over Bellefontaine and the surrounding area.

The Bellefontaine area does not have any geographic al or topographical barriers significantly limiting air pollution transport within its air she d. Therefore, this factor did not play a significa nt role in determining the nonattainment boundary.

Jurisdictional boundaries

Existing jurisdictional boundaries may be helpful i n articulating a boundary for purposes of nonattainment designations, and for purposes of car rying out the governmental responsibilities of planning for attainment of the 2008 lead NAAQS and implementing control measures. These existing boundaries may include an existing nonatta inment or maintenance area boundary, a county or township boundary, a metropolitan area bo undary, an air management district, or an urban planning boundary established for coordinatin g 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 re iterated that the presumptive boundary for each nonattainment area should be the county contai ning the violating monitor. This concept was first introduced in the guidance for the 1978 l ead 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 coun ty containing the violating monitor, stating that any “nonattainment area boundaries that deviat e 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 juris dictional boundaries that can be considered. Logan County belongs to the Bellefontaine micropoli tan statistical area, and the Ohio EPA
Central Office and Ohio EPA Southwest District Offi ce 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 N AAQS (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 lea d 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 T ownship.14

Other Relevant Information

EPA received additional relevant information from O hio for establishing the nonattainment area boundary for Bellefontaine. This information will be discussed below.

The procedure for defining the perimeter of the non attainment 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 show ing exceedances of the standard. Instead, Ohio EPA took a hybrid approach, using the AERMOD d ispersion model in conjunction with historic data. Ohio EPA used the modeling output f rom 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 un der, predict the monitored values. Ohio EPA applied the Krige algorithm for spatial interpolati on of modeled concentrations and drawing of isopleths. Ohio EPA used 0.145 μg/m 3 as the “pre-correction factor” bounding isopleth, as this value shows attainment of the NAAQS. The process o f expanding the nonattainment area boundary using the “correction factor” follows.

Daido Metal is believed to be the predominantly res ponsible source for elevated lead concentrations in Bellefontaine; however, source in formation from lead sources at the facility were not provided to Ohio EPA due to the shutdown o f 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 a nd Honda Transmission Manufacturing facilities were modeled as single point sources usi ng 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 em ission source. As the Honda Transmission Manufacturing facility did not provide stack inform ation to Ohio EPA, Ohio EPA used the averaged source parameters for the East Liberty fac ility for the Honda Transmission Manufacturing Facility. Lead source information fo r Quincy Castings was not provided to Ohio EPA, but it is believed that it is an area source a nd 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 Qu incy Castings facilities were not included in the t able addressing lead emissions in Logan County because t he numbers for these facilities were well under 0.1 tpy.15

Table 7: Bellefontaine and Surrounding Area Emissio ns 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 Met al 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 althou gh the 2005 NEI and 2005 TRI emissions data
for Daido Metal Bellefontaine LLC are listed as 0.1 21 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 accu rate emissions for each facility; but in the end, analysis of monitor placement and modeled faci lities 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 correcti on factor calculations.

As previously mentioned, Ohio EPA used a correction factor to account for any under or over reporting from the modeled concentrations. Ohio ch ose to examine the months listed below in Table 8 because they represented the highest modele d 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 concentratio ns are expressed as μg/m 3 , and dividing
eliminates the units in both the dividend and divis or. As 0.145μg/m 3 is the pre-correction factor ispoleth, 0.145 μg/m 3 / 2.184 yields 0.0664 μg/m 3 ; this can be more easily represented as 66.4 nanograms/m 3 , or 66.4 ng/m 3 . Therefore, the final isopleth defining the propo sed nonattainment area is 66.4 ng/m 3

.

The area encompassed by this isopleth is shown by t he 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/m 3 . Ohio EPA
has added an additional buffer between the nonattai nment area obtained by performing the isopleth analysis and the final State recommended n onattainment 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 explai ned 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 Parame ters (Ohio EPA)

EPA modelers have reviewed the analysis for the Bel lefontaine 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 dimen sions as the basis for area source modeling.

• The receptor spacing used by Ohio EPA differs sligh tly from the guidance which suggests 100 meters.

• No background concentration was added to the modeli ng; 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 observa tions 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 “inacti ve” as of March 5, 2010, but is choosing not to permanently shut down. The facilit y would have to re-contact Ohio EPA prior to resuming operations or selling the company

.

• Regarding the 2 Honda facilities, Ohio EPA relied o n its own internal databases and
internal contact with the facilities for the emissi on 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 us ed 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 Tra nsmission facility is about 10 miles northwest of Daido Metal while Honda East Liberty i s 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

significant19

Metal. Winds are predominantly out of the southwes t, 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 cons idering the offsetting effect of applying 75 percent of the Honda East Liberty emiss ions as fugitive area source
emissions. The lead emissions from these facilitie s 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 anal ysis and that the meteorological
data were from 1984-1988.

• Regarding the receptor resolution, Ohio EPA observe d 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 mode led concentration, with Quincy Castings contributing 0.05 percent of the maximum m odeled concentration.

EPA concludes that although the modeling performed by Ohio EPA may not meet the requirements for an attainment demonstration, the a ir dispersion modeling performed for Fulton County showing the 66.4 ng/m 3 isopleth obtained from the correction factor calcu lation in relationship to the entire State recommended nonatt ainment 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 vio lation of the 2008 lead NAAQS, based on 2006-2008 and 2007-2009 air quality data. Daido Me tal is located in Bellefontaine, and accounts for 50 percent of all lead emissions in Lo gan County. The cumulative process of this factors analysis in conjunction with the relevant a ir 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: s ections 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 NAA QS.

On June 15, 2010, EPA communicated to Ohio that we were proposing to adopt the State’s recommended nonattainment designation and boundarie s 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 Sta te recommendations for lead nonattainment areas. In the same notice, EPA started a public co mment period with an end date of August 16, 2010. EPA did not receive any public comments germ ane to the nonattainment designation and boundaries for the Bellefontaine area, nor did we r eceive any additional information from the
State.20

Accordingly, EPA has determined that the portions o f 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 A rea (OAQPS)