Re: Pb designations modeling comments/questions

Sarah VanderWielen to

:

Mary Portanova

Cc

:

Andy Chang, Michael Compher, "Hunter, Jennifer", Randall Robinson

From: "Sarah VanderWielen" <Sarah.VanderWielen@epa.state.oh.us>

To: Mary Portanova/R5/USEPA/US@EPA

Cc: Andy Chang/R5/USEPA/US@EPA, Michael Compher/R5/USEPA/US@EPA, "Hunter,

Jennifer" <Jennifer.Hunter@epa.state.oh.us>, Randall Robinson/R5/USEPA/US@EPA

Hi Mary, 

Below are responses to the questions on the lead modeling submitted for the Lead NAAQS 

designations. 

Please let Jennifer Hunter know if you have any additional questions (I will be out of the office 

until June 2, 2010). 

Thanks, 

Sarah 

Sarah VanderWielen

Meteorologist

Ohio EPA

Division of Air Pollution Control

50 W. Town Street 

Columbus, Ohio 43215

Phone - 614-644-3632

Please consider the environment before printing this email. 

>>> <Portanova.Mary@epamail.epa.gov> 5/6/2010 12:13 PM >>>

Sarah, here is some of what we sent to Tyler Fox's group at HQ when they

requested info on how the State designations modeling had been done.

This refers to the Pb designation modeling for Logan and Fulton

Counties. Perhaps you can address some of the points here. The intent

of these comments were to address the question, "Was the modeling done
in accordance with App W?" Ideally, where there is spotty source

information, the modeling should use conservative estimates where

possible, and explain/justify the estimates. Thanks for rechecking the

source locations; it's good to know that those were just typoes in the

table, not in the model runs.

I've also attached part of the draft TSDs with HQ's comments on the

modeled sources.

Logan Co/Bellefontaine

The Daido area source emission rate was higher than the NEI, but the

source of the data was not identified.

- Ohio used three sources of information regarding emissions: NEI, TRI and Ohio's FER 

(Fee emissions report). Typically the FER is used to populate the NEI; however we have 

found that post FER reporting, changes have been made for unknown reasons. Ohio 

worked extensively with the companies, USEPA (Motria) and others to develop accurate 

numbers for each facility. When necessary Ohio submitted corrections to USEPA to these 

numbers (e.g., if the NEI was too high). But in the end, the analysis of who should receive 

a monitor, who should be modeled for the need, or who was out was based solely on the 

worst case emissions. And subsequently, all modeling conducted was based again on the 

worst case numbers. In some cases when we began working with the individual companies 

that were to be modeled and requesting emissions rate/stack heights, etc.; rates would not 

always match the total actual TPY. Because of the tight time frame for submittal; Ohio 

chose not to spend more time working out the details of the rates if they were 

overestimating emissions. Ohio felt this would result in a more conservative approach that 

would result in a larger boundary if anything. It should be noted that the modeled plume 

boundary was extensively smaller than the boundary requested.

Three other Pb sources were identified. One was modeled as an area

source because the State believed its lead emissions come from an area

source. Actual source info was not provided. Building data was used as

the area source size. The modeled emission rate matched the tpy data of

the 2005 NEI and 2005 TRI.

-Quincy: the vast majority of lead emissions (which are minor in themselves from this 

facility which is located nearly 12 miles west of Daido) are fugitive (>95%). The fugitive 

sources are :

The other much more minor source of lead is from the following:
Which is controlled by a fabric filter baghouse. It should also be noted that Quincy is 

"inactive" as of 3/5/10. They have chosen not to permanently shutdown but before 

resuming operations or selling the company they would need to re-contact Ohio EPA.

The other two sources (two Honda facilities) were modeled as single

point sources. Ohio had stack information for the lead-emitting sources

at one facility. This information was averaged to create a single point

source. Analysis gave no information on the actual stacks or how the

averaging was done. The other facility did not provide stack

information to Ohio, so the stack data for the other Honda facility was

used. The analysis provides no further justification for this. (See

attachment for HQ comments re the source information given in NEI.)

Ohio was relying on Ohio's own internal databases and direct contact with the facilities for 

emission source information. Ohio did not realize stack information was available in the 

NEI. Recently reported information shows that for the Honda transmission company the 

stack is 45' (NEI showed 42) and account for about 54% of the NEI emssions (remaining 

fugitive). For the Honda East Liberty plant the stacks are between 85-90 (NEI showed 70) 

and account for about 27% of the NEI emissions. Ohio used 88 ft as the stack height for 

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

available information at that time. Honda Transmissions is about 10 miles NW of Daido 

while Honda East Liberty is about 10 miles East. Winds are predominantly out of the SW. 

Given the distance, wind pattern and low emissions of the two Honda sources, it is 

extremely unlikely any changes to stack heights would change any impact, also considering 

the offseting affect of applying 75% of the Honda East Liberty emissions as fugitive area 

source emissions. 

Were Pb emission rates also averaged?

No the lead emissions were not averaged. The total reported amount by Honda was 

modeled (0.0075 tpy)

No information was given about land use characterizations besides "one

sector, four seasons." Did this modeling use the same AERSURFACE run as

in the monitor siting work, and was it the corrected AERSURFACE run, if

it was one where R5 had identified an issue during the monitor siting

process? What year or years of met data were used?

AERSURFACE was run using one sector, four seasons for Logan County. The same 

AERSURFACE file was used in the monitor siting analysis. Met data was from 1984-1988. 

200m receptor spacing is less dense than recommended. (If the selected

boundaries were well beyond the hot spot areas, receptor spacing might

not be a big issue in the case of designations, but there was no
discussion of why 100m resolution was not used or not considered

necessary.)

Ohio feels that 200m spacing, although less dense than recommended, was adequate to 

model the maximum impact from these facilities. When reviewing the modeled results, it 

appears that Daido contributed 99.98% of the maximum modeled concentration. The next 

largest contribution was from Quincy Casting which was 0.05% of the maximum modeled 

concentration. Both Honda plants had little to no impact on the maximum modeled 

concentration. 

As mentioned above, Ohio was very conservative in expanding its boundary beyond the 

impact area. From a big picture perspective - the only other sources of lead in the county 

are E and NW (two Honda - recall also they are 50% or more fugitive) at 0.0075 TPY each 

and a fugitive area source (Quincy) at 0.035 TPY while Daido was modeled at 0.121 TPY 

and Daido no longer operates. A larger area need not be part of the boundary. The entire 

county is comprised of four facilities emitting lead- one permanently shutdown, one idle 

and two with 0.0075 TPY emissions each. Based on the monitor at Daido the last 3-month 

violation was in May 2007. We have seen a drop in monitor values since the June 

shutdown. Here are the 3-month averages from June to October of 2009:

Here is June to October of 2008, while still operating

If this trend continues through May 2010 (the end of this month) we will have three 

complete years of no violations, albeit they aren't calendar years. If there continues to be 

any violations in this area it is likely a result of lead entrained in the dirt.

Background concentrations were not included. Are there monitors that

could have provided background concentrations? (Local monitoring data

was used in the analysis, but in a different way.)

-No we do not have background lead monitors. Background values were not included 

because all lead sources in the are were included in the modeled inventory. And also - we 

asked USEPA for guidance with respect to this and were told to set the background at 0.

 Fulton Co/Delta

Three other sources (other than Bunting Bearing) were included in the

modeling. They were modeled as single point sources using 2005 NEI and

2005 TRI emissions. Stack parameters were averaged for two facilities.

Need some explanation of the stack parameter averaging. There was no

stack information for the fourth facility, so Bunting Bearing stack

parameters, deemed to be the most conservative, were used for this
facility. (conservative is good...no NEI source info available?) Were

fugitives considered? (See also HQ comments in attachment.)

Northstar - West 2 miles - stack 89' (NEI all emissions stack)

Multicast - West (slightly south) 7.5 miles, stack 48' (emissions from stack and fugitive are 

about 50/50 in the NEI)

Sauder - SW over 16 miles - 2 are 80' stacks accounting for 90% of emissions and one 40' 

stack. 

Upon review, it was discovered that a mistake was made when converting the latitude and 

longitude into UTMs for Sauder. It is believe that this error occured because this 

modeling includes some sources in UTM zone 16 and some in UTM zone 17. The 

inventory was converted to a single zone so that modeling can be preformed. As a result of 

this error, Sauder was actually modeled much closer to the Bunting Bearings facility, and 

thus the monitor itself. Because this source was moved closer to the monitor, it should be 

considered a conservative modeling approach. Even with Sauder moving closer to the 

monitor, it still showed very little modeled impact. 

Emissions from Multicast and Sauder are inconsequential considering their distance and 

low levels; however all emissions were modeled as stack so as to provide the most 

conservative estimate of potential impact (fugitive lead emissions are less likely to 

transport such great distances and we had no record (just like the NEI) of fugitive 

sources). Northstar emissions were modeled at about 1/2 that of Bunting and all stack 

(fugitive emissions added into the stack) - this is conservative as if they were modeled as 

fugitive they would have even less opportunity to be transported east (winds 

predominantly out of the SW). 

Were Pb emission rates averaged?

No, the emission rates were not averaged. The maximum emission rates reported were 

modeled for each facility. 

Same question about the surface characteristics and met data.

AERSURFACE was run using one sector, four seasons for Fulton County. The same 

AERSURFACE file was used in the monitor siting analysis. Met data was from 1984-

1988.

Same comment on the receptor resolution, which in this case was 150m.

Ohio feels that 150m spacing, although less dense than recommended, was adequate to 

model the maximum impact from these facilities. When reviewing the modeled results, it 

appears that Bunting Bearing contributed 99.6% of the maximum modeled concentration. 

The next largest contribution was from Sauder which was 0.66% of the maximum 

modeled concentration. Northstar and Multicast had little to no impact on the maximum 

modeled concentration.
Same comment on the background.

-No we do not have background lead monitors. Background values were not included 

because all lead sources in the are were included in the modeled inventory. And also - we 

asked USEPA for guidance with respect to this and were told to set the background at 0.