### DEPARTMENT of

### ENVIRONMENT and NATURAL RESOURCES PMB 2020 JOE FOSS BUILDING 523 EAST CAPITOL PIERRE, SOUTH DAKOTA 57501·3182 denr.sd.gov October 15,2009

Ms. Carol Rushin Acting Regional Administrator US EPA Region 8 1595 Wynkoop Street Denver, CO 80202-1129
RE: Proposed AreaDesignations for the 2008 revised Lead Standard
Dear Ms. Rushin:
Thank you for your letter asking Governor Rounds to provide the Environmental Protection Agency (EPA) withrecommendations for designation ofareas ofthe state for the October 15, 2008 revised lead National AmbientAir Quality Standard. Governor Rounds has delegated the authorityto determine and submit designations for SouthDakotato the Secretaryofthe SouthDakotaDepartment ofEnvironment and Natural Resources (DENR). Therefore, Iam submittingthe proposed designations on the Governor's behalf.
As provided by Section 107(d) (l) (A) ofthe CleanAirAct, Ipropose that all counties in SouthDakotabe designated in attainment for the 2008 revised lead standard (See Attachment 1). Iproposethe designations for the following reasons:

• DENRreviewed 2008 Toxic Release Inventoryreport ofairquality emission. Data received from the facilities in SouthDakotainthe 2008 Toxic Release Inventory report shows that all facilities have yearly emission ofless than one ton ofleadper year. Therefore, the potential to exceedthe national standard remains low from facilities in the state (See Attachment 2).

• DENRreviewed past air monitoring data collected in the state to determine proposed county designations. Two types ofairmonitoring datawere found in the EPAAir Quality System database for lead. The first type was lead concentrations analyzed from total suspendedparticulates samples. The reported quarterly lead averages are all less than the revised standard. Followingthe removal ofmost ofthe lead from gas and becausethe potential was low for finding lead concentrations greaterthan the national standard, the DENRclosed down the last lead monitoring site in 1994.• The second type has data from PM2.5 samples analyzed for lead concentrations taken in the Badlands and Wind Cave National Parks and the PM2.5 speciation sampling site in SiouxFalls, SouthDakota. Lead concentration analyzed from the PM2.5 samples provide a good indicator ofpollutioncoming from combustion sources. All sample concentrationsreported inthe EPA Air Quality System database are less thanthe revised lead standard.

• Air quality emissions oflead are low in South Dakota. Duringthe years when leaded gas was sold, DENRoperated monitoring sitestesting for lead concentrations. None ofthe data collected in those years exceededthe lead standard. The combinationof the state's lowpopulation, small numberoffacilities, and low lead emissions from those facilities keeps the ambient air quality concentrations belowthe lead standard. Currently, the onlytesting for lead concentrations is the chemical speciationofPM2.5 samples collected at the Badlands and Wind CaveNational Parks and a site in Sioux Falls.
Thankyou for allowing South Dakotato propose designations for the 2008 revised lead standard. Ifyou have questions on this notice, please contactBrian Gustafson at 605-773­ 3151 for more information.

StevenM. Pirner Secretary
Enclosures

cy: Callie Videtich, EPA Region 8

## Attachment 1

SouthDakotaCountyDesignations
Lead StandardSouth Dakota
- Lead Standard

Designated Area Designation Type Aurora County Attainment Beadle County Attainment Bennett County Attainment Bon Homme County Attainment Brookings County Attainment Brown County Attainment Brule County Attainment Buffalo County Attainment Butte County Attainment Campbell County Attainment Charles County Attainment ClarkCounty Attainment Clay County Attainment Codington County Attainment Corson County Attainment Custer County Attainment Davison County Attainment Day County Attainment Deuel County Attainment Dewey County Attainment Douglas County Attainment Edmunds County Attainment Fall River County Attainment FaulkCounty Attainment Grant County Attainment Gregory County Attainment Haakon County Attainment Hamlin County Attainment Hand County Attainment Hanson County Attainment Harding County Attainment Hughes County Attainment Hutchinson County AttainmentDesignated Area Designation Type Hyde County Attainment Jackson County Attainment Jerauld County Attainment Jones County Attainment Kingsbury County Attainment Lake County Attainment Lawrence County Attainment Lincoln County Attainment Lyman County Attainment Marshall County Attainment McCook County Attainment McPherson County Attainment Meade County Attainment Mellette County Attainment Miner County Attainment Minnehaha County Attainment Moody County Attainment Pennington County Attainment Perkins County Attainment Potter County Attainment I-­

Roberts County Attainment Sanborn County Attainment Shannon County Attainment Spink County Attainment Stanley County Attainment Sully County Attainment Todd County Attainment Tripp County Attainment Turner County Attainment Union County Attainment Walworth County Attainment Yankton County Attainment Ziebach County Attainment

## Attachment 2

Toxic Release Inventory 2008 DataToxic Release Inventory Database 2008 Air emissions inventory for Lead Chemical Fugitive Stack Name Emissions Emissions Totals Company Name City Year Pounds Pounds Pounds Anqus-Palm Industries, Inc. Watertown 2008 Lead 0.00 0.00 0.00 Banner Engineering Corporation Aberdeen 2008 Lead 0.00 0.00 0.00 Banner Enqineerinq Corporation Huron 2008 Lead 0.00 0.00 0.00 Black Hills Corporation

- Ben French Pow Rapid City 2008 Lead 0.03 8.00 11.03 DTS Incorporated Tea 2008 Lead 0.00 0.00 0.00 Daktronics, Inc

- Sioux Falls Sioux Falls 2008 Lead 0.20 4.10 4.30 Daktronics, Inc. Brookinqs 2008 Lead 0.20 4.30 4.50 Electronic Systems Inc Sioux Falls 2008 Lead 0.00 0.00 0.00 GCC Dacotah Rapid City 2008 Lead 1.96 56.60 58.56 Graco, Inc. Minneapolis 2008 Lead 2.00 0.00 2.00 Hi Roller Conveyors Sioux Falls 2008 Lead 0.00 0.00 0.00 L & M RADIATOR YANKTON 2008 Lead 0.00 1.00 1.00 Pace Manufacturing, Inc. Brandon 2008 Lead 0.00 0.00 0.00 Star Circuits. Inc. Brookinqs 2008 Lead 0.00 0.00 0.00 Starmark, Inc. Sioux Falls 2008 Lead 0.00 0.07 0.07 The Freeman Company Aviation Mfg Grp AMG Yankton 2008 Lead 0.00 0.00 0.00 Ultramax Ammunition Rapid City 2008 Lead 0.00 0.00 0.00
3M Health Care-Brookings Plant Brookinqs 2008 Lead Compounds 0.00 0.00 0.00 Lead Big Stone Power Plant

- Ottertail Big Stone City 2008 Compounds 9.70 75.80 87.90
John Morrell & Company Sioux Falls 2008 Lead Compounds 0.00 4.39 687.89 Lead OEM Worldwide Watertown 2008 Compounds 0.00 0.00 0.00

J Lead Pete Lien & Sons, Inc. Rapid City 2008 Compounds 1.90 0.22 2.12