UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 

REGION IX
 

75 Hawthorne Street
 

San Francisco, CA 94105·3901
 

November 16, 2010 OFFICE OF THE 

REGIONAL ADMINISTRATOR 

The Honorable Janice K. Brewer 

Governor of Arizona 

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 of the 

Hayden area for one year. Thank you for providing infonnation during our decision 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 protect public health, 

EP A improved the existing lead monitoring network by requiring monitors to be placed in areas 

with sources such as industrial facilities that emit one ton or more 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 Air Act requires EPA to complete the initial designation process within two 

years of establishing a new or revised NAAQS. EPA may extend the designation process by up 

to one year if the Administrator has 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 of this second round. EPA will complete the second round of lead designations no later 

than October 15,2011. 

On June 14, 2010, I sent a letter infonning you 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 of August 12,2010 in which you 

explained that the State of Arizona believes 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 our designation. 

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Based on our evaluation of the 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 can be viewed at http://www.epa.gov/leaddesignations/, the July - September 2008 data 

that we obtained from the Hayden Maintenance Building monitor did not fully satisfy applicable 

requirements for data used for comparisons with the lead NAAQS. 

We are, therefore, delaying our designation of the Hayden area until the second round. As 

noted above, the second round of designations will be completed no later than October 15, 2011. 

EPA will evaluate data from the new state-operated lead monitors along with other pertinent 

information in our designation of the Hayden area at that time. If EP A intends to make a 

nonattainment designation for the Hayden area, EPA will also reevaluate the appropriate 

nonattainment area boundaries. As we mentioned to you in our June 14,2010 letter, any updates 

you may wish to make to your designation recommendation for the Hayden area or other areas in 

Arizona should be submitted by December 15, 2010. We will notify you of our preliminary 

response to your recommendations no later than June] 7, 2011 and will provide an opportunity 

for public comment. 

We note that the State's installation of the Hayden and Miami source-oriented monitors 

was delayed and rather than beginning operation on January 1,2010, as required, these monitors 

have only recently begun operation. As a result, a limited amount of data from the new monitors 

will be available to inform the second round of designations. Following the initial designations 

under the revised lead NAAQS, attainment and unclassifiable areas found to be newly violating 

the NAAQS, or nonattainment areas that compile a record of clean data, are subject to 

redesignation in accordance with Clean Air Act. 

We look forward to continuing to work with you and your staff to develop area 

designations. Your air quality staff may wish to contact Deborah Jordan, Air Division Director at 

415-947-8715 or Colleen McKaughan, Associate Air Division Director at 520-498-0118. 

Sincerely, 

ared Blumenfeld 

Regional Administrator 

cc:	 Benjamin H. Grumbles, Director, Arizona Department of Environmental Quality 

Nancy Wrona, Senior Policy Advisor to 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