UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX 75 Hawthorne Street San Francisco, CA 94105·3901

November 16, 2010 OFFICE OF THE REGIONAL ADMINISTRATOR

The HonorableJanice K. Brewer Governor ofArizona 1700 West Washington Phoenix, AZ 85007

Dear Governor Brewer:

I am writing to let you know that the Environmental Protection Agency (EPA) has decided not to designate Hayden, Arizona as a nonattainment area for the national ambient air quality standards (NAAQS) for lead (Pb) at this time. EPA will delay the final designation ofthe Hayden area for one year. Thank you for providinginfonnation during ourdecision process.
On October 15, 2008, EPA substantially strengthened the NAAQS for lead. The level of the 2008 lead standards, set at 0.15 micrograms per cubic meter, is 10 times tighter than the previous standards. In conjunction with strengthening the lead standards to protectpublic health, EPA improved the existing lead monitoringnetwork by requiring monitors to be placed in areas with sources such as industrial facilities that emit one ton ormore per year oflead and at other sites. EPA will be finalizing changes to the requirements for population-based monitors in the coming months.

The Clean AirActrequires EPA to complete the initial designation process within two years ofestablishing a new orrevised NAAQS. EPA mayextend the designation process byup to one year ifthe Administratorhas insufficient infonnation to make these designations. Because the expanded lead monitoring network will provide additional data for consideration next year, EPA decided to complete the lead designations in two rounds. In the first round, which is being finalized today, EPA is designating as nonattainment any area that is violating the 2008 lead standards based on data from the pre-2010 monitoring network. For all other areas, EPA is extending the deadline for designations by up to one year so that data from the newly deployed monitors can be considered in making appropriate designation decisions. Hayden, Arizona will be part ofthis second round. EPA will complete the second round oflead designations no later than October 15,2011.

OnJune 14, 2010, I sent a letter infonningyou that EPA intended to designate the Hayden area nonattainment for the lead NAAQS, based on a violation recorded at a Superfund monitor located nearby. We have reviewed your response letter ofAugust 12,2010 in which you explained that the State ofArizonabelieves that a nonattainment designation for lead in the Hayden area is unwarranted at present. We have also considered your comments about the air quality data on which we were relying for ourdesignation.

Prinud on Rl'cyc/td PapaBased on our evaluation ofthe monitoring data issues raised by commenters, we have determined that we do not have sufficient information to warrant a nonattainment designation for the Hayden area at this time. As further explained in the Response to Comments document, which canbe viewed at http://www.epa.gov/leaddesignations/, the July

- September 2008 data that we obtained from the Hayden Maintenance Buildingmonitor did not fully satisfy applicable requirements for data used for comparisons with the lead NAAQS.

We are, therefore, delaying our designation ofthe Hayden areauntil the second round. As noted above, the second round ofdesignations will be completed no later than October 15, 2011. EPA will evaluate data from the new state-operated lead monitors along with otherpertinent information in our designation ofthe Hayden area at that time. IfEPA intends to make a nonattainment designation for the Hayden area, EPA will also reevaluate the appropriate nonattainment areaboundaries. As we mentioned to you in ourJune 14,2010 letter, anyupdates you maywish to make to yourdesignation recommendation for the Hayden area orother areas in Arizona should be submitted byDecember 15, 2010. We will notify you ofourpreliminary response to yourrecommendations no later than June]7, 2011 and will provide an opportunity for public comment.

We note that the State's installation ofthe Hayden and Miami source-oriented monitors
was delayed and ratherthan beginningoperation on January 1,2010, as required, these monitors haveonlyrecentlybegun operation. As aresult, a limited amount ofdata from the new monitors will be available to inform the second round ofdesignations. Followingthe initial designations undertherevised lead NAAQS, attainment and unclassifiable areas found to be newly violating the NAAQS, ornonattainment areas that compile a record ofclean data, are subject to redesignation in accordance with Clean Air Act.

We look forward to continuing to work with you and your staffto develop area designations. Your air quality staffmaywish to contact DeborahJordan, AirDivision Director at 415-947-8715 orColleen McKaughan, Associate Air Division Director at 520-498-0118. Sincerely,

ared Blumenfeld Regional Administrator

cc: Benjamin H. Grumbles, Director, Arizona Department ofEnvironmental Quality NancyWrona, SeniorPolicy Advisorto the Director, Arizona Department of Environmental Quality Eric Massey, Director, Air Quality Division, Arizona Department of Environmental Quality Don Gabrielson, Director, Pinal County Air Quality Control District