Technical Support Document 

for 

Recommended Nonattainment Boundaries in Michigan 

for the 

Lead National Ambient Air Quality Standard 

December 2010 

Michigan Department of 

Natural Resources and Environment 

Air Quality Division 
ii

TABLE OF CONTENTS 

Page No.

Designation Recommendation ................................................................................................... 1 

Introduction................................................................................................................................. 1 

Nonattainment Area Boundary Analysis..................................................................................... 3 

TABLES

Table 1 Geographic Coordinates of Recommended Lead Nonattainment 

 Area in Belding, MI................................................................................................... 2 

Table 2 Summary of 24-Hour Lead Levels in Belding, MI .................................................... 5 

Table 3 2008 Lead Emissions Inventory for Ionia County, MI .............................................. 6 

FIGURES

Figure 1 Map of Recommended Lead Nonattainment Area in Belding, MI .......................... 2 

Figure 2 Recommended Nonattainment Area Boundaries with Modeled 3-Month 

 Rolling Average Lead Impacts................................................................................ 3 

Figure 3 Belding, MI Lead Monitor ........................................................................................ 4 

Figure 4 Belding, MI Air-lead Levels (2010 Data) ................................................................. 4 

Figure 5 Location of Belding, MI ........................................................................................... 7 

Figure 6 Wind Rose Using Data from the Grand Rapids Monroe St. Site ............................ 9 

Figure 7 Mueller Industries – Belding, MI 3-Month Rolling Average (2005-2009) – 

 Lead Impacts.......................................................................................................... 10 

Figure 8 Average Concentration by Wind Direction (Jan 2010-Aug 2010).......................... 11 
1

Technical Support Document for 

Recommended Nonattainment Boundaries in Michigan 

for the Lead National Ambient Air Quality Standard 

Designation Recommendation 

The Michigan Department of Natural Resources and Environment (DNRE) is amending the state’s 

lead designation recommendation of October 9, 2009, to add a recommendation for a nonattainment 

area in the city of Belding. This recommendation is due to new ambient air quality data indicating that 

the lead National Ambient Air Quality Standard (NAAQS) has been exceeded at a source-oriented 

ambient air monitor sited in Ionia County. The proposed boundary of the nonattainment area is in the 

immediate vicinity of the lead emitting source and is described in detail in this document. 

Introduction 

On October 15, 2008, the U.S. Environmental Protection Agency (EPA) revised the lead NAAQS to 

provide increased protection from adverse health effects associated with exposure to lead. Numerous 

research studies have linked lead exposure to adverse health effects, as well as impacts on IQ, 

learning and behavior in children. 

The primary lead NAAQS was strengthened by the EPA from 1.5 micrograms per cubic meter (μg/m3

) 

set in 1978, to a level of 0.15 μg/m3. The revised lead standard is measured as the concentration of 

lead in Total Suspended Particulates (TSP). The EPA also modified how attainment with this standard 

is determined. The averaging time was changed from a calendar quarterly average to a rolling threemonth average period with a maximum form that is evaluated over a three-year period. In addition, 

the EPA strengthened the secondary lead standard to provide increased protection against adverse 

public welfare effects associated with impacts on organisms and ecosystems. The secondary 

standard is identical to the primary standard. In conjunction with changing the lead NAAQS, the EPA 

required an improved lead monitoring network with source-oriented monitors located near facilities 

emitting more than one ton per year (tpy) of lead and non-source-oriented monitors in urban areas 

with populations greater than 500,000 people. 

Section 107(d) of the Clean Air Act (CAA) governs the process for area designations. Following the 

promulgation of a new or revised standard, the CAA requires the Governor to recommend initial 

designations of the attainment status for all areas of the State. Areas can be designated as 

nonattainment (does not meet, or contributes to a nearby area that does not meet the NAAQS), 

attainment (meets the NAAQS), or unclassifiable (cannot be classified based on available data). 

On October 9, 2009, the DNRE recommended that the counties of Wayne, Kent, Washtenaw, 

Genesee, and Missaukee be designated as attainment for the new lead NAAQS based on the most 

recent data from lead monitors in the state. The DNRE recommended that the remainder of the state 

be considered unclassifiable. 

In January 2010, additional source-oriented and population-oriented monitoring sites were established 

to comply with the new monitoring requirements. The new source-oriented monitor in the city of 

Belding, Michigan, east of Mueller Industries, indicates levels of lead exceeding the new lead 

standard. As a result, the DNRE is recommending a nonattainment designation for an area in Belding. 

The recommended boundary of the nonattainment area is based on a combination of factor analysis 

and dispersion modeling. 

The recommended area is bounded by the geographic coordinates listed in Table 1 and depicted 

graphically in Figure 1. Figure 2 shows the modeled impact of Mueller Industries emissions in 

conjunction with the DNRE recommended nonattainment area boundaries. 
2

Table 1 

Geographic Coordinates of Recommended Lead Nonattainment 

Area in Belding, MI 

Point Location X_UTM16N Y_UTM16N X_Longitude Y_Latitude 

South East Corner 645424.57 4772988.55 -85.2130771 43.0956705 

South West Corner 643850.91 4772995.77 -85.2324027 43.0960358 

Ellis Ave Btw Ranny and 10th 643845.83 4773805.82 -85.2322553 43.1033277 

Ellis Ave and Bridge Street 644204.45 4773820.43 -85.2278464 43.1033911 

Ellis Ave and Earle Street 644184.69 4774270.74 -85.2279722 43.1074479 

North East Corner 645384.03 4774301.35 -85.2132313 43.1074942 

Figure 1 

Map of Recommended Lead Nonattainment Area in Belding, MI 
3

Nonattainment Area Boundary Analysis 

Monitored Air Quality 

The federal lead regulations issued in November 2008 required states to determine if monitoring for 

airborne lead was necessary near sources emitting one ton or more per year. Four facilities in 

Michigan were emitting lead at this level. Subsequent modeling as described in DNRE’s 2010 Air 

Monitoring Network Review predicted that the impact from Mueller Industries was greater than one 

half the lead NAAQS. The predicted impact from the other three sources did not exceed this level. 

Lead monitoring in close proximity to Mueller Industries began in January 2010. A high volumetric 

filter based monitor was installed approximately 60 yards to the east of the facility in a residential 

neighborhood (Figure 3). The monitor has detected levels of lead with a three-month average as high 

as 0.28 μg/m3

, which violates the new NAAQS set at 0.15 μg/m3 (Figure 4 and Table 2). The monitor 

data has been quality assured and submitted to the EPA’s Air Quality System. 

Figure 2 

Recommended Nonattainment Area Boundaries with Modeled 

3-Month Rolling Average Lead Impacts 
4

Figure 3 

Belding, MI Lead Monitor 

Figure 4 

Belding, MI Air-lead Levels (2010 Data) 

0

0.05

0.1

0.15

0.2

0.25

0.3

JanMarMarMayMayJulJulSep

ug/m3
5

Table 2 

Summary of 24-Hr Lead Levels in Belding, MI

* Expressed to four significant figures using truncation at local conditions. Updated 12/08/2010

** NAAQS = 0.15 ug/m3 as a rolling 3 month average. 

*** WD shown if wind is from 1 direction for 8hr or more. Otherwise, see Belding Met Summary Sheet 

Date Avg WS, 

mph WD*** 24-Hr Lead 

Value*, ug/m3 NAAQS** Monthly Avg 3 Mo Avg 

1/02/10 no met avail 0.04735 0.15 0.09350 

1/08/10 4 NNW, N, 0.02713 0.15 

1/14/10 9 SW, WSW, 0.03434 0.15 

1/20/10 5 

ENE, E, 

NE 0.00906 0.15 

1/26/10 10 WSW, W, 0.3496 0.15 

2/01/10 2 SW, SW, 0.03047 0.15 0.2025 

2/07/10 2 E, ENE, 0.009812 0.15 

2/13/10 5 

WNW, 

WNW, 0.5787 0.15 

2/19/10 5 WSW, W, 0.3383 0.15 

2/25/10 6 

NW, NNW, 

WNW 0.05544 0.15 

3/03/10 2 

N, NNE, 

NNE 0.02818 0.15 0.02368 0.10657 

3/09/10 2 E, ESE, 0.02424 0.15 

3/15/10 3 NNE, N, 0.02818 0.15 

3/21/10 3 ENE, NE, 0.01798 0.15 

3/27/10 4 

ESE, SSE, 

SE 0.01984 0.15 

4/02/10 6 

SW, S, 

SSW 0.0286 0.15 0.2645 0.164 

4/08/10 9 

WNW, SW, 

SW 1.033 0.15 

4/14/10 4 SE, SE, E 0.0120 0.15 

4/20/10 2 WSW, W, 0.2342 0.15 

4/26/10 5 NNE, NE, 0.0147 0.15 

5/02/10 3 N, , 0.1590 0.15 0.3609 0.216 

5/08/10 12 NW, WSW, 1.219 0.15 

5/14/10 9 WSW, W, 0.2966 0.15 

5/20/10 1 SE, SE, 0.03139 0.15 

5/26/10 1 

ESE, ESE, 

ESE 0.09832 0.15 

6/01/10 2 

SSW, 

SSW, 0.1491 0.15 0.2264 0.284 

6/07/10 2 W, NW, 0.3541 0.15 

6/13/10 2 W, W, 0.1209 0.15 

6/19/10 7 

WSW, W, 

SW 0.4629 0.15 

6/25/10 2 SW, , 0.04510 0.15 

7/01/10 1 NE, , 0.0817 0.15 0.1540 0.247 

7/07/10 3 WSW, , 0.15 

7/13/10 2 ENE, E, 0.02224 0.15 

7/19/10 2 WNW, , 0.4512 0.15 

7/25/10 1 NNE, N, 0.06077 0.15 
6

Date Avg WS, 

mph WD*** 24-Hr Lead 

Value*, ug/m3 NAAQS** Monthly Avg 3 Mo Avg 

7/31/2010 2 E, ENE, 0.06815 0.15 

8/06/10 4 W, WNW, 1.155 0.15 0.4131 0.2645 

8/12/10 1 NE, WNW, 0.15 

8/18/10 3 WSW, , 0.1120 0.15 

8/24/10 1 ENE, , 0.3645 0.15 

8/30/10 2 

WSW, 

SSW, 0.0210 0.15 

9/05/10 5 WSW 0.1821 0.15 0.0752 0.2141 

9/11/10 3 E, E 0.01431 0.15 

9/17/10 1 variable 0.01653 0.15 

9/23/10 no data no data 0.01072 0.15 

9/29/10 no data no data 0.1524 0.15 

Lead Emissions 

The DNRE’s 2008 emissions inventory for Ionia County shows two stationary sources reporting lead 

emissions in Ionia County (Table 3). Mueller Industries, formerly Extruded Metals, reported 1,685.080 

pounds (lbs) of lead emissions in 2008. Ventra Ionia Main, LLC, formerly Meridian Automotive 

Systems, reported emissions of 0.040 lbs. Historically, Riverside Correctional Facility has emitted lead 

but has ceased operation. 

Table 3 

2008 Lead Emissions Inventory for Ionia County, MI 

EIYR 

State 

Facility 

Identifier 

(SRN #) Facility Name Location Address City 

Zip 

Code 

Total Pb 

Emissions 

in Lbs 

1999 B1650 EXTRUDED METALS 302 ASHFIELD BELDING 48809 2,420.000 

2000 B1650 EXTRUDED METALS 302 ASHFIELD BELDING 48809 2,140.000 

2001 B1650 EXTRUDED METALS 302 ASHFIELD BELDING 48809 2,024.000 

2002 B1650 EXTRUDED METALS 302 ASHFIELD BELDING 48809 2,149.000 

2003 B1650 EXTRUDED METALS 302 ASHFIELD BELDING 48809 2,113.000 

2004 B1650 EXTRUDED METALS 302 ASHFIELD BELDING 48809 1,964.000 

2005 B1650 EXTRUDED METALS 302 ASHFIELD BELDING 48809 1,857.000 

2006 B1650 EXTRUDED METALS 302 ASHFIELD BELDING 48809 2,053.120 

2007 B1650 MUELLER INDUSTRIES 302 ASHFIELD BELDING 48809 1,754.480 

2008 B1650 MUELLER INDUSTRIES 302 ASHFIELD BELDING 48809 1,685.080 

1998 K2120 

RIVERSIDE CORRECTIONAL 

FACILITY 777 W RIVERSIDE DR IONIA 48846 - 

1999 K2120 

RIVERSIDE CORRECTIONAL 

FACILITY 777 W RIVERSIDE DR IONIA 48846 - 

2000 K2120 

RIVERSIDE CORRECTIONAL 

FACILITY 777 W RIVERSIDE DR IONIA 48846 40.000 

2001 K2120 

RIVERSIDE CORRECTIONAL 

FACILITY 777 W RIVERSIDE DR IONIA 48846 2.000 

2002 K2120 

RIVERSIDE CORRECTIONAL 

FACILITY 777 W RIVERSIDE DR IONIA 48846 2.000 

2003 K2120 

RIVERSIDE CORRECTIONAL 

FACILITY 777 W RIVERSIDE DR IONIA 48846 1.000 
 7 

EIYR 

State 

Facility 

Identifier 

(SRN #) Facility Name Location Address City 

Zip 

Code 

Total Pb 

Emissions 

in Lbs 

2004 K2120 

RIVERSIDE CORRECTIONAL 

FACILITY 777 W RIVERSIDE DR IONIA 48846 1.000 

2205 K2120 

RIVERSIDE CORRECTIONAL 

FACILITY 777 W RIVERSIDE DR IONIA 48846 2.000.

2006 K2120 

RIVERSIDE CORRECTIONAL 

FACILITY 777 W RIVERSIDE DR IONIA 48846 41.500 

1999 N0923 MERIDIAN AUTOMOTIVE SYSTEMS 14 N BEARDSLEY RD IONIA 48846 0.036 

2000 N0923 MERIDIAN AUTOMOTIVE SYSTEMS 14 N BEARDSLEY RD IONIA 48846 0.030 

2001 N0923 MERIDIAN AUTOMOTIVE SYSTEMS 14 N BEARDSLEY RD IONIA 48846 - 

2002 N0923 MERIDIAN AUTOMOTIVE SYSTEMS 14 N BEARDSLEY RD IONIA 48846 - 

2003 N0923 MERIDIAN AUTOMOTIVE SYSTEMS 14 N BEARDSLEY RD IONIA 48846 - 

2004 N0923 MERIDIAN AUTOMOTIVE SYSTEMS 14 N BEARDSLEY RD IONIA 48846 - 

2005 N0923 MERIDIAN AUTOMOTIVE SYSTEMS 14 N BEARDSLEY RD IONIA 48846 - 

2006 N0923 MERIDIAN AUTOMOTIVE SYSTEMS 14 N BEARDSLEY RD IONIA 48846 0.040 

2007 N0923 MERIDIAN AUTOMOTIVE SYSTEMS 14 N BEARDSLEY RD IONIA 48846 0.040 

2008 N0923 VENTRA IONIA MAIN, LLC 14 N BEARDSLEY RD IONIA 48846 0.040 

Population Density and Expected Growth 

The Mueller Industries plant is located at 302 Ashfield in the city of Belding, Michigan, shown in 

Figure 5. Belding is a small community with an estimated 2009 population of 5,668, which is a 

decrease of 3.6 percent since 2000. Belding is located in Ionia County that has an estimated 2009 

population of 62,574. The county is considered to be 43 percent urban and 57 percent rural with 

population density at 109 people per square mile. 

Figure 5 

Location of Belding, MI 
 8 

Geography and Topography 

The area surrounding the Mueller Industries facility is mainly residential with a few parking lots and 

commercial buildings in the near neighborhood. The terrain is gently rolling with forested and farmed 

acreage adjacent to the city. The Flat River runs through the recommended nonattainment area.

Jurisdictional Boundaries 

The entire area being recommended for a nonattainment designation is within the city of Belding. 

Level of Control of Emissions Sources 

Lead is a component of the brass used at Mueller Industries. Lead is emitted during the brass rod 

making process. Processes that emit lead at Mueller Industries have DNRE New Source Review 

(NSR) air use permits that restrict emissions. Primary sources of lead emissions at Mueller Industries 

include the following:

 West Chip Dryer

 East Chip Dryer

 Induction Furnace No. 7

 Induction Furnace No. 8

 Induction Furnace No. 9

The west chip dryer is a rotary kiln that has a design capacity of 10 tons of brass chips per hour. The 

west chip dryer is currently the only chip dryer in operation at the facility. The unit is permitted under 

state NSR permit No. 505-93. Air emissions from the chip dryer are controlled by a multi-clone unit 

followed by a thermal oxidizer and a pre-cooler/wet scrubber. In September 2010, the facility installed 

enhancements to the pre-cooler/wet scrubber to increase its control efficiency. These enhancements 

include the installation of a new spray nozzle system as well as the addition of a de-mister unit.

The east chip dryer is a rotary kiln that has a design capacity of 7.5 tons of brass chips per hour. The 

facility has not operated the east chip dryer since August 9, 2010. The facility has agreed not to 

restart the dryer unless compliance testing is conducted on the unit. The unit is permitted under NSR 

permit No. 281-86A. Air emissions from the chip dryer are controlled by a multi-clone unit followed by 

a thermal oxidizer and a pre-cooler/wet scrubber. 

The facility has three electric induction furnaces for the melting of brass. The furnaces are identified 

as Furnaces No. 7, 8 and 9. Furnaces No. 7 and 8 are permitted under state NSR permit No. 30-83B, 

while Furnace No. 9 is permitted under state NSR permit No. 30-83C. The furnaces are commonly 

controlled by two fabric filter collectors (east baghouse: 60,000 cubic foot per minute (cfm), and west 

baghouse: 60,000 cfm). The east baghouse is preceded by a cyclone collector.

Air Dispersion Modeling 

Air dispersion modeling of lead emissions show that all predicted NAAQS exceedances fall within the 

recommended nonattainment boundary. 

The DNRE conducted air dispersion modeling of the Mueller Industries lead emissions source using 

the most current modeling parameters and associated permitted allowable emission rates. Land use 

and terrain, building wake effect (the effect on local air concentrations and particle deposition resulting 

from air flows around the buildings), and meteorological data were all taken into consideration in 

modeling parameters, resulting in a recommended nonattainment area that includes the entire area 

where concentrations exceeding the NAAQS are predicted. 

A review of the climatological profile from this area (using Grand Rapids data) showed winds are 

primarily from the southwest, as depicted by the wind rose in Figure 6. 
 9 

Figure 6 

Wind Rose using Data from the Grand Rapids 

Monroe St. Site (260810020) 

Figure 7 is the final modeling impact plot depicting lead isopleths based on the permitted or Potentialto-Emit (PTE) emissions of likely operations (i.e. 0.3 lb/hr for the primary chip dryer and 5 

micrograms/dry standard cubic foot from the furnace). Based on the predominant southwest winds, 

maximum 3-month average impacts were expected to fall northeast of the emission sources. 

Additionally, the relatively short facility stacks are subject to building downwash and maximum impacts 

were anticipated near the facility structure. As expected, the point of maximum predicted impact was 

located a short distance northeast of the stack location and is indicated on the Figure 7 by a red dot 

(3.36 μg/m3

). Modeled impacts are based on a 3-month rolling average during 2005-2009 (Grand 

Rapids meteorology data). Map scale is in meters. 
 10 

Figure 7 

Mueller Industries – Belding, MI 

3-Month Rolling Average during 2005-2009 – Lead Impacts
 11 

The required monitor was sited as close to the point of maximum predicted impact as practicable. As 

indicated by the blue star on Figure 7, the monitor location is slightly less than 100 meters to the 

south-southeast of the point of maximum predicted impact. Based on the monitor location, maximum 

impacts to the monitor would be expected when winds are from the west to northwest. This was 

verified by the monitoring data when correlated with the paired wind direction data, as shown in 

Figure 8. As shown in the previous plot (Figure 7), maximum predicted impacts at the monitor location 

would be slightly more than 1.0 ug/m3

. The actual maximum monitored values are less than the 

maximum predicted impact, thus there is an adequate margin of safety for the nonattainment area as 

described by the 0.15 ug/m3

 threshold. Despite this fact, the DNRE is proposing to extend the 

nonattainment area beyond the predicted 0.10 ug/m3 modeled area as an added margin of safety. 

Figure 8 

Average Concentration by Wind Direction

 Jan 2010 - Aug 2010 

0

0.2

0.4

0.6

0.8

1

1.2

0

15

30

45

60

75

90

105

120

135

150

165

180

195

210

225

240

255

270

285

300

315

330

345

Average

Median