# 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 Reco mmendation ................................................................................................... 1

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

Nonattainment Area B oundary Analysis..................................................................................... 3

TABLES

Table 1 Geographic Coordinates of Recommended Lead Nonattainment

Area in Beld ing, MI................................................................................................... 2

Table 2 Summary of 24-Hour Le ad Levels in Be lding, MI .................................................... 5

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

FIGURES

Figure 1 Map of Recommend ed Lead Nonattainment Ar ea in Beldi ng, MI .......................... 2

Figure 2 Recommended Nonattainment Area Boundaries with Modeled 3-Month Rolling Average Lead Impacts................................................................................ 3

Figure 3 Belding, MI Lead Moni tor ........................................................................................ 4

Figure 4 Belding, MI Air-l ead 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 Impa cts.......................................................................................................... 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 pr oposed 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 Prot ection Agency (EPA) revised the lead NAAQS to provide increased protection from adverse health effe cts 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 str engthened by the EPA from 1.5 micr ograms per cubic meter (μg/m 3 ) set in 1978, to a level of 0.15 μg/m 3 . The revised lead standard is measured as the concentration of lead in Total Suspended Particulates (TSP). The EP A 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 se condary lead standard to provide increased prot ection against adverse public welfare effects associated with impacts on organisms and ecosystems. The secondary standard is identical to the prim ary standard. In conjunction wi th 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 attain ment for the new lead NAAQS based on the most

recent data from lead monitors in the state. T he 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 m odeled 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 on e 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 M ueller 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 leve ls of lead with a three-month average as high as 0.28 μg/m 3 , which violates the new NAAQS set at 0.15 μg/m 3 (Figure 4 and Table 2). The monitor data has been quality assured and submitt ed 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

JanMar MarMay MayJul JulSep ug/m3

### 5 Table 2 Summary of 24-Hr Lead Levels in Belding, MI

* Expressed to four significant figure s 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 inventor y for Ionia County shows two st ationary sources reporting lead emissions in Ionia County (Table 3). Mueller Indu stries, 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 ASHFI ELD BELDING 48809 2,420.000

2000 B1650 EXTRUDED METALS 302 ASHFI ELD BELDING 48809 2,140.000

2001 B1650 EXTRUDED METALS 302 ASHFI ELD BELDING 48809 2,024.000

2002 B1650 EXTRUDED METALS 302 ASHFI ELD BELDING 48809 2,149.000

2003 B1650 EXTRUDED METALS 302 ASHFI ELD BELDING 48809 2,113.000

2004 B1650 EXTRUDED METALS 302 ASHFI ELD BELDING 48809 1,964.000

2005 B1650 EXTRUDED METALS 302 ASHFI ELD BELDING 48809 1,857.000

2006 B1650 EXTRUDED METALS 302 ASHFI ELD BELDING 48809 2,053.120

2007 B1650 MUELLER INDUSTRIES 302 ASHFI ELD BELDING 48809 1,754.480

2008 B1650 MUELLER INDUSTRIES 302 ASHFI ELD 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 BEARDS LEY RD IONIA 48846 0.036

2000 N0923 MERIDIAN AUTOMOTIVE SYSTEMS 14 N BEARDS LEY 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 BEARDS LEY RD IONIA 48846 0.040

2007 N0923 MERIDIAN AUTOMOTIVE SYSTEMS 14 N BEARDS LEY 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 Ashfie ld 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 Rive r 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. Prim ary 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 desi gn 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 S eptember 2010, the facility installed enhancements to the pre-cooler/wet scrubber to incr ease its control efficiency. These enhancements include the installation of a new spray nozzle sy stem 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 Au gust 9, 2010. The facility has agreed not to restart the dryer unless compliance testing is cond ucted on the unit. The unit is permitted under NSR permit No. 281-86A. Air emissions from the chip dr yer are controlled by a multi-clone unit followed by a thermal oxidizer and a pre-cooler/wet scrubber.

The facility has three electric induct ion furnaces for the melting of br ass. 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 bag house: 60,000 cubic foot per minute (cfm), and west baghouse: 60,000 cfm). The east baghous e is preceded by a cyclone collector.

Air Dispersion Modeling

Air dispersion modeling of lead emissions show t hat all predicted NAAQS exceedances fall within the recommended nonattainment boundary.

The DNRE conducted air di spersion modeling of the Mueller Indus tries lead emissions source using the most current modeling paramet ers 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 no nattainment 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 depicti ng 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 cubi c 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 ar e subject to building downwash and maximum impacts were anticipated near the facility structure. As ex pected, the point of maximum predicted impact was
located a short distance northeast of the stack loca tion and is indicated on the Figure 7 by a red dot (3.36 μg/m 3 ). 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 monito r location is slightly less than 100 meters to the south-southeast of the point of maximum predict ed 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/m 3 . 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/m 3 threshold. Despite this fact, t he DNRE is proposing to extend the nonattainment area beyond the predicted 0.10 ug/m 3 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