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 was 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 2006-2008 and 2007-2009 and where additional 

monitoring data for 2010 could not result in a different designation. 

2) Designated “attainment” – an area which EPA has determined, based on the most 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 the 2008 lead NAAQS in a nearby area and that 

additional monitoring data from 2010 could not result 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 included in this document, has a violation of 

the 2008 lead NAAQS during the most recent 3 consecutive years of quality-assured, certified air 

quality data. 

4) Prior nonattainment area – an area that is currently designated as nonattainment 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 are necessary to produce a valid violating 

design value. 

7) 1978 lead NAAQS – 1.5 μg/m3

, National Ambient Air Quality Standard for lead promulgated 

in 1978. Based on Pb-TSP indicator and averaged over a calendar quarter. 

8) 2008 lead NAAQS – 0.15 μg/m3

, 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-based) standard from 1.5 micrograms per cubic 

meter (μg/m3) to 0.15 μg/m3 measured as total suspended 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, EPA 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 Ohio that EPA is designating as “nonattainment” 

for the 2008 lead National Ambient Air Quality Standard (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 partial county with a monitor that violates the 

2008 lead NAAQS and evaluates nearby counties for contributions to lead concentrations in the 

area. EPA has evaluated these counties based on the 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 potentially 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 districts, reservations, etc.); and 

• Any other relevant information submitted to or collected by EPA (e.g., modeling where 

done appropriately). 
3

Figure 1: Delta, Ohio State Recommended Nonattainment Area 

(Office of Air Quality and Planning Standards - OAQPS) 

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 emissions are labeled; if the source emitted 0.1 – 0.5 

tons, only the symbol and emissions are labeled; and 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 Reference Method (FRM) or Federal 

Equivalent Method (FEM) monitors located in the State. Chris Korleski, Director of the Ohio 

Environmental Protection Agency (Ohio EPA), submitted 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 NAAQS as part of the Delta nonattainment 

area based upon currently available information. This county is listed above in Table 1. 

 

1

 Emissions greater than 0.05 tpy round up to 0.1 tpy, and they are marked with the symbol and the emissions 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/m3) 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 monitor attains a specified air quality standard. 

The 2008 lead NAAQS are met at a monitoring site when the identified design value is valid and 

less than or equal to 0.15 μg/m3. A design value is only valid if minimum data completeness 

criteria are met. A lead design value that meets the 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 monitoring days in the 3-month period. A lead 

design value that does not meet the NAAQS is considered 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 (violating) design value. 

County State 

Recommended 

Nonattainment? 

Monitor Name Monitor Air 

Quality 

System ID 

Monitor Location Lead Design 

Value, 

2006-2008 

(μg/m3) 

Lead Design 

Value, 

2007-2009 

(μg/m3) 

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. Latitudes and longitudes have 

been provided at the monitoring site; the coordinates in AQS are slightly mis-located. The design value of 0.69 μg/m3 was 

obtained using data from January of 2007; the data for November of 2006 and December of 2006 was non-reference, and could 

not be used for the design value calculation. 

Table 2: Delta, Ohio and Surrounding Areas Air Quality Data

The 2008 lead NAAQS design values for Fulton County in Delta and the surrounding area are 

shown in Table 2, and Fulton County shows a violation of the 2008 lead NAAQS. Therefore 

some area in this county and possibly additional areas in surrounding counties must be 

designated nonattainment. The absence of a violating monitor alone is not a sufficient reason to 

eliminate nearby counties as candidates for nonattainment status. Each area has been evaluated 

based on the weight of evidence of these factors and 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 highest concentration for lead. This monitor is 

in very close proximity to Bunting Bearings LLC (Bunting 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 violating monitor are an important factor for 

determining whether a nearby area is contributing to a monitored violation. For this factor, EPA 

evaluated county level emission data for lead and population 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 national 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 information on emissions and emission controls in 

their comments to EPA. Ohio did not provide updated 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 sources emitting (or anticipate to contribute) 0.1 

ton per year or greater of lead according to the 2005 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 in the U.S. at which leaded aviation gasoline is 

consumed. To evaluate the potential impact of emissions at and near these facilities, EPA 

recommends that States use the draft 2008 NEI. These data are provided in Table 4, and contain 

the facilities emitting (or anticipate to contribute) 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 Emissions for Stationary Sources 

* Total lead emissions for Fulton County were calculated 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. Sources with emissions 

below 0.1 tpy were included in this final calculation. 
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 Emissions for Leaded Aviation Gas Facilities 

There are no individual facilities using leaded aviation 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 emissions data from this facility is .03 tpy. 

In addition to Northstar Bluescope Steel, LLC, there are 3 sources in Fulton County listed in the 

2005 NEI database: Multi-Cast Corp, Sauder Woodworking Cogeneration Facility, and Bunting 

Bearings. Bunting Bearings is the most likely source of the elevated lead concentrations in 

Fulton County, and Figure 3 above shows the location of the monitor for which the last 4 digits 

of the AQS have been included. For reference, please 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, respectively. 

Although Bunting Bearings is thought to be responsible for the elevated monitored lead readings 

in the Delta area, EPA observes that discussion about 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 Bluescope 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 facilities 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 below the available information regarding 

whether the nonattainment area surrounding the Bunting Bearings facility should be extended to 

encompass Northstar Bluescope Steel, LLC. 

The existing source oriented monitoring network3

 in Ohio was expanded in January 2010 with 

the addition of 4 new source oriented sites: American Spring Wire (Cuyahoga County), Nucor 

Steel (Marion County), Timken Company Canton Bearing (Canton County), and Ellwood 

Engineering Castings (Hubbard, County). 

Population Data, Growth Rates, and Patterns

Table 5 shows the 2008 population for each county in the area being evaluated, as well as the 

population density for each county in that area. These data help assess the extent to which the 

concentration of human activities in the area and concentration of population-oriented 

commercial development may indicate emissions-based activity contributing to elevated ambient 

lead levels. This may include ambient lead contributions from activities that would disturb lead 

 

3

 Daido Metal Bellefontaine in Logan County shut down in June 2009, but Ohio EPA will continue to monitor for 

lead at the Richard Ave. site (AQS 390910006). 
7

that has been deposited on the ground or on other surfaces. Re-entrainment of historically 

deposited lead is not reflected in the emissions inventory. 

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 2008 

(http://www.census.gov/popest/datasets.html) and estimation of the area of U.S. counties] 

EPA has considered the population growth rate for this 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 analysis and provided in Table 3 represent 

emissions levels taking into account any control strategies implemented in Delta before 2005 on 

stationary sources. EPA has received additional information 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 rules 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. Historical 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. Ohio EPA provided a wind rose for Fulton County 

in their submittal, and it is shown in Figure 5. The graphical representation from this figure 

corroborates the data from the National Weather Service. 
8

Figure 2: Historical Wind Direction Frequencies for Fulton County, Ohio 

Figure 4 is a 3-dimensional bar chart that shows the 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. Department of Commerce: National Climatic 

Data Center and the U.S. Department of Energy: National 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 the highest wind frequency occurs in the 

winter months, with winds blowing from the west southwest. With the consistently strong 

representation of winds from a variation of the west 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 (Ohio EPA) 

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

The geography/topography analysis evaluates the physical features of the land that might have an 

effect on the air shed and, therefore, on the distribution of lead over Delta and the surrounding 

area. 

The Delta area does not have any geographical or topographical barriers significantly limiting 

air-pollution transport within its air shed. Therefore, this factor did not play a significant role in 

determining the nonattainment boundary. 

Jurisdictional boundaries 

Existing jurisdictional boundaries may be helpful in articulating a boundary for purposes of 

nonattainment designations, and for purposes of carrying out the governmental responsibilities of 

planning for attainment of the lead NAAQS and implementing 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 business 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 reiterated that the presumptive boundary for 
11

each nonattainment area should be the county containing the violating monitor. This concept 

was first introduced in the guidance for the 1978 lead 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 county containing the violating monitor, stating 

that any “nonattainment area boundaries that deviate 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 jurisdictional boundaries that can be considered. Fulton 

County is part of the Toledo micropolitan statistical 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 efforts to address the impending lead 

nonattainment area in Delta should not be problematic; it should be noted that the final 

rulemaking for the 2008 lead NAAQS (73 FR 66964) specifically addressed transportation 

conformity by stating, “In light of the elimination of lead additives from gasoline, transportation 

conformity does not apply to the Lead NAAQS.” Lastly, Ohio EPA has recommended that the 

nonattainment area be defined by well-known and major roads which coincide with sections 12 

and 13 of York Township and sections 7 and 18 of Swan Creek Township. 

Other Relevant Information

EPA received additional relevant information from Ohio for establishing the nonattainment area 

boundary for Delta. This information will be discussed below. 

The technique of spatial interpolation for defining the perimeter of the nonattainment boundary 

was found to be inapplicable for Delta due to presence 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 generate concentration gradients 

throughout the area, while the monitored data was used to generate the ratio of actual/modeled 

concentration values. These ratios can serve as “correction factors” to adjust for any systematic 

tendency of the model to over, or under, predict the monitored values. Ohio EPA applied the 

Krige algorithm for spatial interpolation of modeled concentrations and drawing of isopleths. 

Ohio EPA used 0.145 μg/m3

 as the “pre-correction factor” bounding isopleth, as this value 

shows attainment of the NAAQS. The process of expanding the nonattainment area boundary 

using the “correction factor” follows. 

Bunting Bearings is believed to be the predominantly responsible source for the elevated lead 

concentrations in Delta, and all sources at this facility were modeled individually. The source 

parameters for this modeling are identical to the ones 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/OhioLeadMonitoring.pdf. 
12

The Multi-Cast Corporation, Northstar Bluescope Steel, and Sauder Woodworking Cogeneration 

facilities were modeled as single point sources using 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 source. Stack information from lead sources 

provided to Ohio EPA by the Sauder Woodworking Cogeneration 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 height for similar sources at the facility. 

Stack information from lead sources for the Multi-Cast facility was not provided to Ohio EPA; 

the averaged source parameters for the Bunting Bearings 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 surface data from Toledo, Ohio National 

Weather Site 94830 and Upper Air data from the Flint, Michigan National Weather Service Site 

14826. Ohio EPA determined that the data from these 2 sites were determined to be 

representative of Fulton County. 

Correspondence with Ohio EPA on May 5-6, 2010, confirmed that in Table 7, the coordinates for 

Bunting Bearings LLC and Sauder Woodworking Cogeneration Facility are slightly inaccurate. 

The correct coordinates for Bunting Bearings LLC are -83.9975, 41.57508, and the correct 

coordinates for Sauder Woodworking Cogeneration Facility are -84.2942, 41.51237. Ohio EPA 

ascertained that the errors associated with the coordinates were purely typographical; the 

modeling was performed for the right facilities. EPA observed that although the 2005 NEI and 

2005 TRI emissions data for Bunting Bearings, LLC are listed as 0.0035 tpy, the maximum 

modeled value is listed at 0.54 tpy. Ohio EPA clarified this discrepancy on May 7, 2010, by 
13

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 reporting 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 placement and modeled facilities was based on worst 

case emissions. As a result, the modeling performed 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 the 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 ratio was computed to be 5.729, and this factor 

is unitless because both the monitored and modeled concentrations are expressed as μg/m3

, and 

dividing eliminates the units in both the dividend and divisor. It was calculated by 0.567 μg/m3 

(the design value) / 0.09897 μg/m3 (modeled value at the same point in time). As 0.145μg/m3 is 

the pre-correction factor ispoleth, 0.145 μg/m3 / 5.729 yields 0.02531 μg/m3; this can be more 

easily represented as 25.31 nanograms/m3, or 25.31 ng/m3. Therefore, the final isopleth defining 

the proposed nonattainment area is 25.31 ng/m3. 

The nonattainment boundary based on the 25.31 ng/m3 isopleth analysis is depicted by the 

yellow pentagon in below in Figure 6. All areas outside of the yellow pentagon have been 

modeled to show a lead impact of less than 25.31 ng/m3. Ohio EPA has added an additional 

buffer between the nonattainment area obtained by performing the isopleth analysis and the final 

State recommended nonattainment area. The final State recommended nonattainment area is 

shown by the red outline, and once again, encompasses sections 12 and 13 of York Township 

and sections 7 and 18 of Swan Creek Township. 

The distance from the center of the Bunting Bearings facility to the western edge of the 

recommended nonattainment area is approximately 1.10 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 recommended nonattainment area (the western edge) is 

approximately 1.6 miles. The distance between Northstar Bluescope Steel, LLC and the monitor 

at Bunting Bearings is approximately 2.75 miles. EPA believes that it is unlikely that lead 

emissions from the Northstar Bluescope Steel, LLC facility 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 the parameters for Northstar Bluescope Steel, 

LLC as an averaged point source in the air dispersion modeling for the Delta area, and the 

emissions data were included in their entirety as coming from the stack; this method presented a 

worst case scenario for the transport of lead because fugitives would not travel as far. The 

isopleth analysis indicates that the expected impact in the western portion of the nonattainment 

area is less than 5.0 ng/m3

, or 0.005 μg/m3. 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 in 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 EPA) 

Table 9: Delta Area Source Modeling Parameters (Ohio EPA) 

EPA modelers have reviewed the analysis for the Delta 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 slightly from the guidance which 

suggests 100 meters. 

• No background concentration was added to the modeling; 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 observations 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, all 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 

significant 
15

• 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 latitude and longitude into UTMs for 

Sauder Woodworking. Ohio EPA believes that this error occurred 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 could be 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 was moved closer to the monitor, it 

should be considered a conservative modeling approach. Even with Sauder 

Woodworking moving closer to the monitor, it still showed very little modeled impact. 

• Ohio EPA observed that emissions from Multi-Cast 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 Bluescope Steel 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 southwest). 

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

• Regarding the AERSURFACE, Ohio EPA clarified that it 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 – 1988. 

• Regarding the receptor resolution, Ohio EPA observed 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 modeled 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 air dispersion modeling performed for Fulton 

County showing the 25.31 ng/m3 isopleth obtained from the correction factor calculation in 

relationship to the entire State recommended nonattainment 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 nonattainment for the 2008 lead NAAQS. 

The air quality monitor in Fulton County shows a violation 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 other 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 modeling that Ohio EPA provided ultimately leads to 

the final nonattainment area. EPA finds it appropriate 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 described 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 boundaries for the Delta area. There was, 

however, a typographical error in this communication where EPA refers to the “Fulton” area. 

Fulton is actually the county, and not the area itself. 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 nonattainment 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 and boundaries for the Delta area, nor did 

we receive any additional information from the State. 

Accordingly, EPA has determined that 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 should be 

designated as nonattainment for the 2008 lead NAAQS, as seen in Figure 7. 
17

Figure 4: Delta, Ohio Final Nonattainment Area (OAQPS)