1 Delta, Ohio Technical Support Document

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Definition of important terms used in this document :

1) Designated “unclassifiable” – an area where EPA could not determine if there w as a violation of the 2008 lead NAAQS or a contribution to a violation in a nearby area, because there was insufficient air quality data for both 2006-200 8 and 2007-2009 and where additional monitoring data for 2010 could not result in a diff erent designation.

2) Designated “attainment” – an area which EPA has determined, based on the m ost recent 3 years of certified air quality data from 2006-2008 or 2007-2009, has no violations of the 2008 lead NAAQS during 36 consecutive valid 3-month site means; and which EPA has further

determined does not contribute to a violation of th e 2008 lead NAAQS in a nearby area and that additional monitoring data from 2010 could not resu lt in a different designation.

3) Designated “nonattainment” area – an area which EPA has determined, based on a State recommendation and/or on the technical analysis inc luded in this document, has a violation of the 2008 lead NAAQS during the most recent 3 consec utive years of quality-assured, certified air quality data.

4) Prior nonattainment area – an area that is currently designated as nonattainme nt or maintenance for the 1978 lead NAAQS (including both current nonattainment areas and maintenance areas).

5 ) Recommended nonattainment area – an area a State or Tribe has recommended to EPA be designated as nonattainment.

6) Violating monitor – an ambient air monitor whose design value exceeds 0 .15 micrograms per cubic meter (ug/m3). As described in Appendix R of part 50, a violation can be based on either Pb-TSP or Pb-PM10 data and only 3 months of data a re necessary to produce a valid violating design value.

7) 1978 lead NAAQS – 1.5 μg/m 3 , National Ambient Air Quality Standard for lead pr omulgated in 1978. Based on Pb-TSP indicator and averaged ov er a calendar quarter.

8) 2008 lead NAAQS – 0.15 μg/m 3 , National Ambient Air Quality Standard for lead promulgated in 2008. Based on Pb-TSP indicator and a 3-month rolling average. Pb-PM10 data may be used in limited instances, including to show nonattainment.2 OHIO Area Designations For the 2008 Lead National Ambient Air Quality Standards EPA has revised the level of the primary (health-ba sed) standard from 1.5 micrograms per cubic meter (μg/m3) to 0.15 μg/m3 measured as total suspe nded particles (TSP). EPA has revised the secondary (welfare-based) standard to be identical in all respects to the primary standard.

Pursuant to section 107(d) of the Clean Air Act, EP A must designate as “nonattainment” those areas that violate the NAAQS and those nearby areas that contribute to violations. The table below identifies the partial county in Oh io that EPA is designating as “nonattainment” for the 2008 lead National Ambient Air Quality Stan dard (2008 lead NAAQS).

Area (listed alphabetically) Ohio Recommended

Nonattainment

Counties EPA’s Designated

Nonattainment

Counties Nonattainment

Area for 1978 Lead NAAQS Delta Fulton (partial) Fulton (partial) NA

Table 1: Ohio Nonattainment Area for the 2008 Lead NAAQS

Technical Analysis for Delta

Introduction

This technical analysis for Delta identifies the pa rtial county with a monitor that violates the 2008 lead NAAQS and evaluates nearby counties for c ontributions to lead concentrations in the

area. EPA has evaluated these counties based on th e weight of evidence of the following factors recommended in previous EPA guidance:

• Air quality in potentially included versus excluded areas;

• Emissions and emissions-related data in areas poten tially included versus excluded from the nonattainment area, including population data, growth rates, and patterns and emissions controls;

• Meteorology (weather/transport patterns);

• Geography/topography (mountain ranges or other air basin boundaries);

• Jurisdictional boundaries (e.g., counties, air dist ricts, reservations, etc.); and

• Any other relevant information submitted to or coll ected by EPA (e.g., modeling where done appropriately).3 Figure 1: Delta, Ohio State Recommended Nonattainme nt Area (Office of Air Quality and Planning Standards - OAQ PS)

Figure 1 is a map of the area analyzed showing the locations and design values of air quality monitors in the area, and the counties surrounding any violating air quality monitors. Source data is also labeled in Figure 1 with the following guidelines: if the source emitted 0.5 or more tons, the symbol, name of the facility, and emissio ns are labeled; if the source emitted 0.1 – 0.5 tons, only the symbol and emissions are labeled; an d if the source emitted less than 0.05 tons, only the symbol is shown. 1 Emissions in Delta and the surrounding areas will be discussed in the section addressing emissions in Fulton County. The location of the detailed area in relation to the remainder of the State is shown in the bottom right corner of the figure.

In October 2009, Ohio recommended that a portion of Fulton County be designated as nonattainment for the 2008 lead NAAQS based on air quality data from 2006-2008. Their

recommendation was based on data from Federal Refer ence Method (FRM) or Federal Equivalent Method (FEM) monitors located in the Sta te. Chris Korleski, Director of the Ohio Environmental Protection Agency (Ohio EPA), submitt ed the State’s recommendation to EPA in a letter dated October 5, 2009.

Based on EPA’s technical analysis described below, EPA is designating portions of Fulton County in Ohio as nonattainment for the 2008 lead N AAQS as part of the Delta nonattainment area based upon currently available information. T his county is listed above in Table 1.

1 Emissions greater than 0.05 tpy round up to 0.1 tp y, and they are marked with the symbol and the emis sions value. * Sources that are not labeled emitted less than 0.05 tpy.4

Detailed Assessment

Air Quality Data

This factor considers the lead design values (in μg /m 3 ) for air quality monitors in Fulton County in Delta and the surrounding area based on data for the 2006-2008 and 2007-2009 period. A monitor’s design value indicates whether that monit or attains a specified air quality standard. The 2008 lead NAAQS are met at a monitoring site wh en the identified design value is valid and less than or equal to 0.15 μg/m 3 . A design value is only valid if minimum data com pleteness criteria are met. A lead design value that meets t he NAAQS is generally considered valid if it encompasses 36 consecutive valid 3-month site means (specifically for a 3-year calendar period and the 2 previous months). For this purpose, a 3- month site mean is valid if valid data were obtained for at least 75 percent of the scheduled m onitoring days in the 3-month period. A lead design value that does not meet the NAAQS is consid ered valid if at least one 3-month mean that meets the same 75 percent requirement is above the NAAQS. That is, a site does not have to monitor for 3 full calendar years in order to have a valid violating design value; a site could monitor just 3 months and still produce a valid (vi olating) design value.

County State

Recommended

Nonattainment? Monitor Name Monitor Air Quality System ID Monitor Location Lead Design Value,

2006-2008 (μg/m 3 ) Lead Design

Value,

2007-2009 (μg/m 3 )
Fulton,

Ohio Yes Bunting Bearing Facility

Delta 390510001 200 Van Buren St. (41.57598, -83.99571) 0.69 0.69

Monitor in bold has the highest 2006-2008 and 2007- 2009 design value in the respective county. Latitu des and longitudes have been provided at the monitoring site; the coordinat es in AQS are slightly mis-located. The design val ue of 0.69 μg/m 3 was obtained using data from January of 2007; the data for November of 2006 and December of 2006 was non-r eference, and could not be used for the design value calculation. Table 2: Delta, Ohio and Surrounding Areas Air Qual ity Data

The 2008 lead NAAQS design values for Fulton County in Delta and the su rrounding area are shown in Table 2, and Fulton County shows a violati on of the 2008 lead NAAQS. Therefore some area in this county and possibly additional ar eas in surrounding counties must be designated nonattainment. The absence of a violati ng monitor alone is not a sufficient reason to eliminate nearby counties as candidates for nonatta inment status. Each area has been evaluated based on the weight of evidence of these factors an d other relevant information.

According to EPA’s monitor locator, 2 the monitor located at 200 Van Buren St. (AQS ID 390510001) has an objective of determining the high est concentration for lead. This monitor is in very close proximity to Bunting Bearings LLC (Bu nting Bearings). The location of this monitor will be discussed in the section addressing emissions for Fulton County.

2 http://www.epa.gov/air/data/geosel.html.5

Emissions and Emissions-Related Data

Evidence of lead emissions sources surrounding a vi olating monitor are an important factor for determining whether a nearby area is contributing t o a monitored violation. For this factor, EPA evaluated county level emission data for lead and p opulation data.

Emissions

Emissions data were derived from the 2005 National Emissions Inventory (NEI), version 2, which is the most up-to-date version of the nationa l inventory available when these data were compiled for the designations process in 2009. See http://www.epa.gov/ttnchie1/net/2005inventory.html. EPA recognizes that for certain counties, emissions may have changed since 2005. For example , certain large sources of emissions in or near this area may have installed emission controls or otherwise significantly reduced emissions since 2005. Some States provided updated informati on on emissions and emission controls in their comments to EPA. Ohio did not provide update d emissions information, therefore EPA

relied on the 2005 NEI emissions data. These data are provided in Table 3.

Table 3 shows total emissions of lead given in tons per year (tpy) for violating and potentially contributing counties in and around Delta and sourc es emitting (or anticipate to contribute) 0.1 ton per year or greater of lead according to the 20 05 NEI. The county that is part of the Delta nonattainment area for the 2008 lead NAAQS is shown in boldface

.

There are approximately 20,000 airport facilities i n the U.S. at which leaded aviation gasoline is consumed. To evaluate the potential impact of emis sions at and near these facilities, EPA

recommends that States use the draft 2008 NEI. The se data are provided in Table 4, and contain the facilities emitting (or anticipate to contribut e) 0.1 ton per year or greater of lead according to

the draft 2008 NEI.

County Facility in State

Recommended

Nonattainment Area? Facility Name 2005 NEI (tpy) Location City

Fulton County, Ohio No Northstar Bluescope Steel, LLC 0.3 6767 County Road 9 Delta Fulton County

Total Lead

Emissions 0.3* Table 3: Delta, Ohio and Surrounding Areas Lead Emi ssions for Stationary Sources * Total lead emissions for Fulton County were calcula ted by adding the 2005 NEI data for facilities not using leaded aviation gas (stationary sources) to the 2008 Draft NEI data for facilities using aviation gas. Sourc es with emissions below 0.1 tpy were included in this final calculati on.6

City Facility Name Type 2008 Draft NEI (tpy) Distance to NA

area (km)

NA NA NA NA NA Table 4: Delta, Ohio and Surrounding Areas Lead Emi ssions for Leaded Aviation Gas Facilities

There are no individual facilities using leaded avi ation gasoline in or around Delta that have emissions of 0.1 tpy or greater. The facility with the largest 2008 draft NEI data is Fulton County Airport in Wauseon, Ohio. The 2008 emission s data from this facility is .03 tpy.

In addition to Northstar Bluescope Steel, LLC, ther e are 3 sources in Fulton County listed in the 2005 NEI database: Multi-Cast Corp, Sauder Woodwork ing Cogeneration Facility, and Bunting Bearings. Bunting Bearings is the most likely sour ce of the elevated lead concentrations in Fulton County, and Figure 3 above shows the locatio n of the monitor for which the last 4 digits of the AQS have been included. For reference, plea se refer to Table 2 for the coordinates of this monitor; the corrected coordinates provided by Ohio EPA were used to construct this map. The monitor is approximately 270’ away from the center of the facility. Both points have been marked in Figure 3 by a yellow pin and red star, re spectively.

Although Bunting Bearings is thought to be responsi ble for the elevated monitored lead readings in the Delta area, EPA observes that discussion abo ut Northstar Bluescope Steel, LLC, is appropriate in this section, as well as the section addressing other relevant information. There is not a monitor in close proximity to Northstar Blues cope Steel, LLC, nor are there immediate plans to place a monitor in close proximity to the facility; current monitoring requirements mandate source oriented monitors to be placed at fa cilities emitting 1.0 tpy or greater. EPA has taken comment on a proposal to lower the emissions threshold for monitoring requirements from 1.0 ton per year to 0.5 ton per year (74 FR 69050). If the final rulemaking requires monitors at sites that emit 0.5 ton per year or greater of lead , Northstar Steel, LLC may still not exceed the threshold required for monitoring. EPA discusses b elow the available information regarding whether the nonattainment area surrounding the Bunt ing Bearings facility should be extended to encompass Northstar Bluescope Steel, LLC.

The existing source oriented monitoring network 3 in Ohio was expanded in January 2010 with

the addition of 4 new source oriented sites: Americ an Spring Wire (Cuyahoga County), Nucor Steel (Marion County), Timken Company Canton Bearin g (Canton County), and Ellwood Engineering Castings (Hubbard, County).

Population Data, Growth Rates, and Patterns

Table 5 shows the 2008 population for each county i n the area being evaluated, as well as the population density for each county in that area. T hese data help assess the extent to which the

concentration of human activities in the area and c oncentration of population-oriented commercial development may indicate emissions-based activity contributing to elevated ambient lead levels. This may include ambient lead contrib utions from activities that would disturb lead

3 Daido Metal Bellefontaine in Logan County shut dow n in June 2009, but Ohio EPA will continue to monit or for lead at the Richard Ave. site (AQS 390910006).7

that has been deposited on the ground or on other s urfaces. Re-entrainment of historically deposited lead is not reflected in the emissions in ventory.

County State

Recommended

Nonattainment? 2008

Population 2008

Population Density (pop/sq mi) Population

Change

2000-2008 Population %

Change

2000-2008

Fulton, Ohio Yes 42,485 104 351 1 Table 5: Population Data for Fulton County, Ohio

[Source of data: U.S. Census Bureau estimates for 2 008 (http://www.census.gov/popest/datasets.html) and es timation of the area of U.S. counties]

EPA has considered the population growth rate for t his area and does not believe that it affects the boundary recommendation.

Emissions Controls

Under this factor, the existing level of control of emission sources is taken into consideration. The emissions data used by EPA in this technical an alysis and provided in Table 3 represent emissions levels taking into account any control st rategies implemented in Delta before 2005 on stationary sources. EPA has received additional in formation on emissions reductions resulting from controls put into place since 2005.

Ohio EPA highlighted several regulations that apply to the entire State that assist in reducing the potential impact on lead concentrations. These rul es include restriction of emissions of fugitive dust, control of visible particulate emissions from stationary sources, and restrictions on particulate emissions from industrial processes.

Meteorology (weather/transport patterns)

For this factor, EPA considered data from National Weather Service instruments and other meteorological monitoring sites in the area. Histo rical wind direction frequencies collected between 1960 and 1992 are included in Figure 4 and Table 6. These data may provide evidence of the potential for lead emissions sources located upwind of a violating monitor to contribute to

ambient lead levels at the violation location. Ohi o EPA provided a wind rose for Fulton County in their submittal, and it is shown in Figure 5. T he graphical representation from this figure

corroborates the data from the National Weather Ser vice.8 Figure 2: Historical Wind Direction Frequencies for Fulton County, Ohio

Figure 4 is a 3-dimensional bar chart that shows th e wind frequencies in 8 directions for the 4

seasons. These data are taken from 1960-1992 Solar and Meteorological Surface Observation Network information issued jointly by the U.S. Depa rtment of Commerce: National Climatic Data Center and the U.S. Department of Energy: Nati onal Renewable Energy Laboratory. The chart frequencies reflect the directions from which the winds come.

Fulton County Wind Frequencies

**Frequency as a % Seasonal Wind** 

**Directions**

**6.27 WINWINDFNNE** 

**8.97 WINWINDFENE** 

**7.28 WINWINDFESE** 

**6.22 WINWINDFSSE** 

**19.02 WINWINDFSSW** 

**27.73 WINWINDFWSW** 

**16.40 WINWINDFWNW** 

**8.11 WINWINDFNNW** 

**8.38 SPRWINDFNNE** 

**15.35 SPRWINDFENE** 

**10.74 SPRWINDFESE** 

**7.14 SPRWINDFSSE** 

**15.24 SPRWINDFSSW** 

**16.76 SPRWINDFWSW** 

**16.73 SPRWINDFWNW** 9 **9.65 SPRWINDFNNW** 

**9.08 SUMWINDFNNE** 

**10.10 SUMWINDFENE** 

**8.47 SUMWINDFESE** 

**7.13 SUMWINDFSSE** 

**21.01 SUMWINDFSSW** 

**21.17 SUMWINDFWSW** 

**13.73 SUMWINDFWNW** 

**9.30 SUMWINDFNNW** 

**7.79 AUTWINDFNNE** 

**8.21 AUTWINDFENE** 

**8.09 AUTWINDFESE** 

**9.16 AUTWINDFSSE** 

**21.05 AUTWINDFSSW** 

**20.61 AUTWINDFWSW** 

**15.72 AUTWINDFWNW** 

**9.36 AUTWINDFNNW**  Table 6: Historical Wind Frequency Data as Percents for Fulton County, Ohio

As shown in Figure 4 and Table 6, the period with t he highest wind frequency occurs in the winter months, with winds blowing from the west sou thwest. With the consistently strong representation of winds from a variation of the wes t in all seasons, special care must be made when determining the nonattainment boundary to the east of the violating monitor.10 Figure 3: Wind Rose at Toledo Express Airport (Ohi o EPA)

Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the phy sical features of the land that might have an effect on the air shed and, therefore, on the distr ibution of lead over Delta and the surrounding

area.

The Delta area does not have any geographical or to pographical barriers significantly limiting air-pollution transport within its air shed. There fore, this factor did not play a significant role i n determining the nonattainment boundary.

Jurisdictional boundaries

Existing jurisdictional boundaries may be helpful i n articulating a boundary for purposes of nonattainment designations, and for purposes of car rying out the governmental responsibilities of planning for attainment of the lead NAAQS and imple menting control measures. These existing boundaries may include an existing nonattainment or maintenance area boundary, a county or township boundary, a metropolitan area boundary, an air management district, or an urban planning boundary established for coordinating busi ness development or transportation activities.

In EPA’s August 21, 2009 guidance memorandum, “Area Designations for the 2008 revised Lead National Ambient Air Quality Standard,” EPA re iterated that the presumptive boundary for11

each nonattainment area should be the county contai ning the violating monitor. This concept was first introduced in the guidance for the 1978 l ead NAAQS designations, and is described in the 1992 General Preamble (57 FR 13549). This same presumptive boundary guidance was addressed most recently in the final rulemaking for the 2008 lead NAAQS (73 FR 66964). EPA observed, however, that States have the flexibility in their recommendations to deviate from the presumptive county boundary to portions of the coun ty containing the violating monitor, stating that any “nonattainment area boundaries that deviat e from presumptive county boundaries should be supported by an assessment of several factors... ,” all of which have been discussed already in this document, except for jurisdictional boundaries

.

For the Delta area, there are several jurisdictiona l boundaries that can be considered. Fulton County is part of the Toledo micropolitan statistic al area, and the Ohio EPA Central Office and Ohio EPA Northwest District Office are responsible for air quality planning within all areas of Fulton County. As a result, air quality planning e fforts to address the impending lead nonattainment area in Delta should not be problemat ic; it should be noted that the final rulemaking for the 2008 lead NAAQS (73 FR 66964) sp ecifically addressed transportation conformity by stating, “In light of the elimination of lead additives from gasoline, transportation conformity does not apply to the Lead NAAQS.” Last ly, Ohio EPA has recommended that the nonattainment area be defined by well-known and maj or roads which coincide with sections 12 and 13 of York Township and sections 7 and 18 of Sw an Creek Township.

Other Relevant Information

EPA received additional relevant information from O hio for establishing the nonattainment area boundary for Delta. This information will be discu ssed below.

The technique of spatial interpolation for defining the perimeter of the nonattainment boundary was found to be inapplicable for Delta due to prese nce of only 1 monitor. Instead, Ohio EPA took a hybrid approach, using the AERMOD dispersion model in conjunction with historic data. Ohio EPA used the modeling output from AERMOD to ge nerate concentration gradients throughout the area, while the monitored data was u sed to generate the ratio of actual/modeled

concentration values. These ratios can serve as “c orrection factors” to adjust for any systematic tendency of the model to over, or under, predict th e monitored values. Ohio EPA applied the Krige algorithm for spatial interpolation of modele d concentrations and drawing of isopleths. Ohio EPA used 0.145 μg/m 3 as the “pre-correction factor” bounding isopleth, as this value shows attainment of the NAAQS. The process of expa nding the nonattainment area boundary using the “correction factor” follows.

Bunting Bearings is believed to be the predominantl y responsible source for the elevated lead concentrations in Delta, and all sources at this fa cility were modeled individually. The source parameters for this modeling are identical to the o nes used by Ohio EPA as part of their proposed lead monitoring network plan, and building downwash from the facility was included in the modeling. 4

4 http://www.epa.state.oh.us/dapc/ams/plans/OhioLead Monitoring.pdf.12

The Multi-Cast Corporation, Northstar Bluescope Ste el, and Sauder Woodworking Cogeneration facilities were modeled as single point sources usi ng the emissions from Table 7 below. Stack information from lead sources provided to Ohio EPA by the Northstar Bluescope Steel facility were averaged to create a single lead emission sour ce. Stack information from lead sources provided to Ohio EPA by the Sauder Woodworking Coge neration facility were also averaged to create a single lead emission source; however, the stack height itself for the lead source was not provided. Ohio EPA employed a conservative stack h eight for similar sources at the facility.

Stack information from lead sources for the Multi-C ast facility was not provided to Ohio EPA; the averaged source parameters for the Bunting Bear ings facility were used because it was determined that they were the most conservative.

Table 7: Delta and Surrounding Area Emissions Data Used by Ohio EPA for Modeling Analysis

Meteorological data was considered by examining sur face data from Toledo, Ohio National Weather Site 94830 and Upper Air data from the Flin t, Michigan National Weather Service Site

14826. Ohio EPA determined that the data from thes e 2 sites were determined to be representative of Fulton County.

Correspondence with Ohio EPA on May 5-6, 2010, conf irmed that in Table 7, the coordinates for Bunting Bearings LLC and Sauder Woodworking Cogener ation Facility are slightly inaccurate. The correct coordinates for Bunting Bearings LLC ar e -83.9975, 41.57508, and the correct coordinates for Sauder Woodworking Cogeneration Fac ility are -84.2942, 41.51237. Ohio EPA

ascertained that the errors associated with the coo rdinates were purely typographical; the modeling was performed for the right facilities. E PA observed that although the 2005 NEI and 2005 TRI emissions data for Bunting Bearings, LLC a re listed as 0.0035 tpy, the maximum modeled value is listed at 0.54 tpy. Ohio EPA clar ified this discrepancy on May 7, 2010, by13

explaining that it relies on a fee emissions report (FER) to populate the NEI; however, data in the FER has been found to change after even after repor ting to NEI. Ohio EPA stated that it works extensively with the companies, EPA, and others to develop the most accurate emissions for each facility; but in the end, analysis of monitor place ment and modeled facilities was based on worst case emissions. As a result, the modeling performe d for Bunting Bearings, LLC was conducted based on these worst case emissions; this approach was found to be the more conservative, i.e., it results in a larger nonattainment boundary due to t he correction factor calculations.

As previously mentioned, Ohio EPA used a correction factor to account for any under or over reporting from the modeled concentrations. This ra tio was computed to be 5.729, and this factor

is unitless because both the monitored and modeled concentrations are expressed as μg/m 3 , and dividing eliminates the units in both the dividend and divisor. It was calculated by 0.567 μg/m 3
(the design value) / 0.09897 μg/m 3 (modeled value at the same point in time). As 0.14 5μg/m 3 is the pre-correction factor ispoleth, 0.145 μg/m 3 / 5.729 yields 0.02531 μg/m 3 ; this can be more easily represented as 25.31 nanograms/m 3 , or 25.31 ng/m 3 . Therefore, the final isopleth defining the proposed nonattainment area is 25.31 ng/m 3

.

The nonattainment boundary based on the 25.31 ng/m 3 isopleth analysis is depicted by the yellow pentagon in below in Figure 6. All areas ou tside of the yellow pentagon have been modeled to show a lead impact of less than 25.31 ng /m 3 . Ohio EPA has added an additional buffer between the nonattainment area obtained by p erforming the isopleth analysis and the final

State recommended nonattainment area. The final St ate recommended nonattainment area is shown by the red outline, and once again, encompass es sections 12 and 13 of York Township and sections 7 and 18 of Swan Creek Township.

The distance from the center of the Bunting Bearing s facility to the western edge of the recommended nonattainment area is approximately 1.1 0 miles, and the distance to the eastern edge of the recommended nonattainment area from the center of the facility is approximately 0.8

miles. EPA observes that the distance between the center of the Northstar Bluescope Steel, LLC facility and the closest edge of the State recommen ded nonattainment area (the western edge) is approximately 1.6 miles. The distance between Nort hstar Bluescope Steel, LLC and the monitor at Bunting Bearings is approximately 2.75 miles. E PA believes that it is unlikely that lead emissions from the Northstar Bluescope Steel, LLC f acility contribute enough to the monitored violations at Bunting Bearings to warrant including Northstar Bluescope Steel, LLC as part of

the Delta nonattainment area. Ohio EPA included th e parameters for Northstar Bluescope Steel, LLC as an averaged point source in the air dispersi on modeling for the Delta area, and the emissions data were included in their entirety as c oming from the stack; this method presented a worst case scenario for the transport of lead becau se fugitives would not travel as far. The isopleth analysis indicates that the expected impac t in the western portion of the nonattainment area is less than 5.0 ng/m 3 , or 0.005 μg/m 3 . This concentration is less than 1 percent of the monitor design value for this nonattainment area.

Information supporting Ohio EPA’s modeling analysis is provided in Table 8 and Table 9. Some of this information has been previously explained i n detail.14

Source Characterization Fugitives

Modeled? Stack Parameters Comments

Northstar Bluescope Steel, LLC Point No Averaged Point

Multi-Cast Corp Point No Bunting Bearings

Parameters Info not provided to Ohio

EPA; Parameters for Bunting

were used

Sauder Woodworking Cogen Facility Point No Averaged Point Stack height not provided;

Ohio EPA chose conservative stack height based on similar

sources Bunting Bearings Point No Individual Points

Table 8: Delta Area Source Characterization (Ohio E PA)

Table 9: Delta Area Source Modeling Parameters (Ohi o EPA)

EPA modelers have reviewed the analysis for the Del ta area and have the following

observations:

• Ohio EPA had little detailed information about the sources.

• Ohio EPA substituted stack data from 1 facility for another.

• The concept of using a correction factor to expand the nonattainment boundary is unusual, but it is possible that more comprehensive source data might have resulted in the

same outcome.

• The receptor spacing used by Ohio EPA differs sligh tly from the guidance which suggests 100 meters.

• No background concentration was added to the modeli ng; Ohio EPA stated that adding a background concentration was not added because all surrounding sources were included in the modeling.

On May 7, 2010, Ohio EPA responded to EPA’s observa tions by providing the following points:

• Ohio EPA informed us that Northstar Bluescope Steel , LLC has a stack height of 89’, and for the purposes of the air dispersion modeling, al l emissions were assumed to come from

the stack. Source Emissions

Used Emissions

Type Multiple

Sources? Meteorological

Data Receptors Terrain Comments

Northstar Bluescope Steel, LLC 2005 NEI Actual Yes 2 Sites,

1 Sector/

4 Seasons Small but

adequate, 150 m spacing Not

significant

Multi-Cast Corp 2005 NEI Actual Yes 2 Sites,

1 Sector/

4 Seasons Small but

adequate, 150 m spacing Not

significant

Sauder Woodworking Cogen Facility 2005 NEI Actual Yes 2 Sites,

1 Sector/

4 Seasons Small but

adequate, 150 m spacing Not

significant

Bunting Bearings 2005 NEI Actual Yes 2 Sites

1 Sector/

4 Seasons Small but

adequate, 150 m spacing Not

significant15 • Ohio EPA informed us that for the Multi-Cast Corp, the stack height is 48’, and 50 percent of the emissions are coming from the stack, with the remaining 50 percent as fugitives.

• Ohio EPA informed us that for Sauder Woodworking, 2 stacks are 80’ and they account for 90 percent of the emissions; there is also a 40 ’ stack. Upon review, it was discovered that a mistake was made when converting the latitud e and longitude into UTMs for Sauder Woodworking. Ohio EPA believes that this er ror occurred because this modeling

includes some sources in UTM zone 16 and some in UT M zone 17. The inventory was converted to a single zone so that modeling could b e performed. As a result of this error, Sauder Woodworking was actually modeled much closer to the Bunting Bearings facility,

and thus the monitor itself. Because this source w as moved closer to the monitor, it should be considered a conservative modeling approa ch. Even with Sauder Woodworking moving closer to the monitor, it still showed very little modeled impact.

• Ohio EPA observed that emissions from Multi-Cast an d 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 d istances and we had no record (just like the NEI) of fugitive sources). Northstar Bluescope Steel emissions were modeled at about 1/2 that of Bunting and all stack (fugitive e missions added into the stack) - this is conservative as if they were modeled as fugitive th ey would have even less opportunity to be transported east (winds predominantly out of the southwest).

• Regarding the emissions rates, Ohio informed us tha t the rates were not averaged.

• Regarding the AERSURFACE, Ohio EPA clarified that i t was run using 1 sector/4 seasons for Fulton County. The same file was used to perform the monitor siting analysis. Meteorological data were from 1984 – 198 8.

• Regarding the receptor resolution, Ohio EPA observe d that 150m spacing was sufficient to model the maximum impact from the facilities in question. Specifically, Bunting Bearings contributed 99.6 percent of the maximum mo deled concentration, and the next largest contributor was from Sauder at 0.66 percent of the maximum modeled

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

concentration.

EPA concludes that although the modeling performed by Ohio EPA may not meet the requirements for an attainment demonstration, the a ir dispersion modeling performed for Fulton County showing the 25.31 ng/m 3 isopleth obtained from the correction factor calcu lation in relationship to the entire State recommended nonatt ainment area results in a reasonable boundary

for the nonattainment area.16

Conclusion

After considering the factors described above, EPA has determined that it is appropriate to designate a portion of Fulton County as nonattainme nt for the 2008 lead NAAQS.

The air quality monitor in Fulton County shows a vi olation of the 2008 lead NAAQS, based on 2006-2008 and 2007-2009 air quality data. Bunting Bearings is located in Delta, and although has very small reported emissions, is thought to be responsible for the elevated lead concentrations in Fulton County. There are no othe r major sources of lead emissions in the State recommended nonattainment area, and the cumulative process of this factors analysis in conjunction with the relevant air dispersion modeli ng that Ohio EPA provided ultimately leads to the final nonattainment area. EPA finds it appropr iate to designate the portions of Fulton County that are encompassed by: sections 12 and 13 of York Township and sections 7 and 18 of Swan Creek Township. Based on the consideration of all the relevant and available information, as described above, EPA believes that the boundaries d escribed herein encompass the entire area that does not meet (or that contributes to ambient air quality in a nearby area that does not meet) the 2008 lead NAAQS.

On June 15, 2010, EPA communicated to Ohio that we were proposing to adopt the State’s recommended nonattainment designation and boundarie s for the Delta area. There was, however, a typographical error in this communicatio n where EPA refers to the “Fulton” area. Fulton is actually the county, and not the area its elf. A subsequent Federal Register notice was published on July 8, 2010 (75 FR 39255), notifying the public that EPA was proposing to take

action on State recommendations for lead nonattainm ent areas. In the same notice, EPA started a public comment period with an end date of August 16 , 2010. EPA did not receive any public comments germane to the nonattainment designation a nd boundaries for the Delta area, nor did we receive any additional information from the Stat e.

Accordingly, EPA has determined that the portions o f Fulton County that are encompassed by: sections 12 and 13 of York Township and sections 7 and 18 of Swan Creek Township should be designated as nonattainment for the 2008 lead NAAQS , as seen in Figure 7.17 Figure 4: Delta, Ohio Final Nonattainment Area (OAQ PS)