Re: Pb designations modeling comments/questions
Sarah VanderWielen to : Mary Portanova

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

From: "Sarah Vander Wi elen" <Sarah.Vander Wi elen@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 question s on the lead modeling submitted for the Lead NAAQS designations. Please let Jennifer Hunter know if you have any additional questions (Iwill be out of the office until June 2, 2010). Thanks, Sarah Sarah VanderWielen Meteorologist Ohio EPA Div ision 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 w ere to address the question, "Was the modeling donein accordance with App W?" I deally , 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 ty poes 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.
Lo gan Co/Bellefontaine The Daido area source emission rate was high er 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 t he 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 p lume 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. B uilding 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 w est 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 le ad

- emitting sources at one facility . This information was averaged to create a single point source. Analy sis 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 sta ck data for the other Honda facility was used. The analy sis 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 t he 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 NE I 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 Ea st 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 em issions 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 AE RSURFACE 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 se asons 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 spa cing might not be a big issue in the case of designations, but there was nodiscussion 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 cou nty 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 v iolations, 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? (L ocal monitoring data was used in the analy sis, 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 TRIemissions. 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 conserv ative, were used for thisfacility . (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 Saude r 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 conserv ative 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 we re 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 inv entory. And also
- we asked USEPA for guidance with respect to this and were told to set the background at 0.