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Cleveland, 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. 
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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 will designate 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 

Cleveland Cuyahoga (partial) Cuyahoga (partial) NA 

Table 1: Ohio Nonattainment Area for the 2008 Lead NAAQS 

Technical Analysis for Cleveland

Introduction 

This technical analysis for Cleveland 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, 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). 
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Figure 1: Cleveland, 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 Cleveland and the surrounding areas will be discussed 

in the section addressing emissions in Cuyahoga 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.

 

1

 Emissions greater than 0.05 tpy round up to 0.1 tpy, and they are marked with the symbol and the emissions value. 
Copyrighted page(s) have been removed from 

this document. 

Please contact the EPA Docket Center, Public 

Reading Room to view this document. 

Address: 

1301 Constitution Ave, NW 

Room 3334 

Washington, DC 20004 

Telephone: 

202-566-1744 

Fax: 

202-566- 9744 

Email: 

docket-customerservice@epa.gov
5

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

Table 1. 

Detailed Assessment

Air Quality Data 

This factor considers the lead design values (in μg/m3) for air quality monitors in Cuyahoga 

County in Cleveland 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) 

Cuyahoga, 

Ohio 

Yes E 56th Ferro 390350049 E 56th St. 

(41.446667, -

81.651111) 

0.17 0.17 

St. Tikhon* 390350038 2547 St. Tikhon St. 

(41.476944, -

81.681944) 

0.02 0.02 

Fire Station 

4* 

390350042 3136 Lorain St. 

(41.482222, -

81.708889) 

0.03 0.03 

Grant Rd 

Ferro 

390350050 Grant Rd. 

(41.4425, -

81.64917) 

0.05 0.05 

MM South* 390350061 West Side of 3rd St. 

(41.472222, -

81.675278) 

0.04 0.04 

 

Monitor in bold have the highest 2006-2008 and 2007-2009 design value in the respective county. Latitudes and longitudes were 

provided by Ohio EPA in their submittal. *These monitors are in Cuyahoga County, but are not in the State recommended 

nonattainment area. Refer to Figure 3 below for their locations. 

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

The 2008 lead NAAQS design values for Cuyahoga County in Cleveland and the surrounding 

area are shown in Table 2, and Cuyahoga 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 
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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 on E. 56th St. (AQS ID 390350049) 

has an objective of determining the highest concentration for lead. This monitor is in very close 

proximity to Ferro Corporation (Ferro Corp). The location of this monitor, as well as the other 4 

in the county, will be discussed in the section addressing emissions for Cuyahoga County. 

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 Cleveland 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 

Cleveland 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. 

 

2

 http://www.epa.gov/air/data/geosel.html. 
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County 

Facility in State 

Recommended 

Nonattainment 

Area? Facility Name 

2005 

NEI (tpy) Location City 

Cuyahoga 

County, Ohio No 

American Spring 

Wire Corp. 1.2 26300 Miles Rd. 

Bedford 

Heights 

Cuyahoga 

County, Ohio No I. Schumann and Co. 0.6 

22500 Alexander 

Rd. 

Oakwood 

Village 

Cuyahoga 

County, Ohio No 

Victory White Metal 

Co. 0.5 6100 Roland Ave. Cleveland 

Cuyahoga 

County, Ohio No 

Federal Metal Co. 

 0.2 7250 Division St. 

Oakwood 

Village 

Cuyahoga 

County, Ohio No 

Republic Metals 

 0.2 7930 Jones Rd. Cleveland 

Cuyahoga 

County, Ohio 

No Morgan Electro 

Ceramics 0.1 232 Forbes Rd. Bedford 

Cuyahoga 

County, Ohio 

No

ISG Cleveland Inc. 0.1 3060 Eggers Ave. Cleveland 

Cuyahoga 

County, Ohio 

No

TDE Group Inc. 0.1 28850 Aurora Rd. Solon 

Cuyahoga 

County, Ohio 

No Cleveland Thermal 

LLC 0.1 1921 Hamilton Ave. Cleveland 

Cuyahoga 

County, Ohio 

No

HI TECMETAL Inc 0.1 

1177 Marquette 

Ave. Cleveland 

Cuyahoga 

County, Ohio 

No Nettleton Steel 

Treating Company 0.1 1371 E. 45th St. Cleveland 

Cuyahoga 

County, Ohio 

No

Sherwood 0.1 1201 W. 65th St. Cleveland 

Cuyahoga 

County, Ohio 

No T & B Foundry 

Company 0.1 2469 E. 71st St. Cleveland 

 

Cuyahoga County 

Total Lead Emissions 3.7* 

Table 3: Cleveland, Ohio and Surrounding Areas Lead Emissions for Stationary Sources 

Total lead emissions for Cuyahoga 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. 

City Facility Name Type 

2008 Draft 

NEI (tpy) 

Distance to NA 

area (km) 

Cleveland Cleveland-Hopkins Intl Airport 0.5 16.9 

Cleveland Burke Lakefront Airport 0.2 7.15 

Cleveland Cuyahoga County Airport 0.1 17.4 

Table 4: Cleveland, Ohio and Surrounding Areas Lead Emissions for Leaded Aviation Gas Facilities 

According to 2005 NEI data, Cuyahoga County has 7 sources emitting at or above 0.1 ton per 

year. The greatest emitter of lead in the county is American Spring Wire Corporation, and a 

source-oriented monitor was scheduled to begin operation in January 2010. 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, monitors at Victory White Metal Company and I. 
Copyrighted page(s) have been removed from 

this document. 

Please contact the EPA Docket Center, Public 

Reading Room to view this document. 

Address: 

1301 Constitution Ave, NW 

Room 3334 

Washington, DC 20004 

Telephone: 

202-566-1744 

Fax: 

202-566- 9744 

Email: 

docket-customerservice@epa.gov
10

County State 

Recommended 

Nonattainment? 

2008 

Population 

2008 

Population 

Density 

(pop/sq mi) 

Population 

Change 

2000-2008 

Population % 

Change 

2000-2008 

Cuyahoga, 

Ohio Yes 1,283,925 2,799 -108,186 -8 

Table 5: Population Data for Cuyahoga 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 Cleveland before 

2005 on stationary sources. EPA has received additional information on emissions reductions 

resulting from controls put into place since 2005. 

Ohio EPA highlighted 2 State regulations that assist in reducing the potential impact on lead 

concentrations in Cuyahoga County. These regulations are included in Ohio Administrative 

Code (OAC) 3745-17-12 and 3745-17-06. The regulations contained in OAC 3745-17-06 

address a source that has now been permanently shut down, and OAC 3745-17-12 provides more 

stringent requirements for particulate emissions from specific air contaminant sources in 

Cuyahoga County. Ohio EPA also 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 5 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 2 wind roses for Cuyahoga 

County in their submittal, and they are shown in Figure 6 and Figure 7. The graphical 

representations from these figures corroborate the data from the National Weather Service. 
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Figure 5: Historical Wind Direction Frequencies for Cuyahoga County, Ohio 

Figure 5 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. 
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Cuyahoga County

Wind Frequencies 

Frequency as a % 

Seasonal Wind 

Directions 

8.36 WINWINDFNNE 

4.25 WINWINDFENE 

5.10 WINWINDFESE 

9.39 WINWINDFSSE 

27.11 WINWINDFSSW 

24.08 WINWINDFWSW 

14.63 WINWINDFWNW 

7.08 WINWINDFNNW 

17.58 SPRWINDFNNE 

5.84 SPRWINDFENE 

6.40 SPRWINDFESE 

10.46 SPRWINDFSSE 

21.34 SPRWINDFSSW 

14.49 SPRWINDFWSW 

13.17 SPRWINDFWNW 

10.72 SPRWINDFNNW 

17.34 SUMWINDFNNE 

4.61 SUMWINDFENE 

4.03 SUMWINDFESE 

9.78 SUMWINDFSSE 

29.81 SUMWINDFSSW 

15.95 SUMWINDFWSW 

9.26 SUMWINDFWNW 

9.22 SUMWINDFNNW 

9.68 AUTWINDFNNE 

4.65 AUTWINDFENE 

5.76 AUTWINDFESE 

12.86 AUTWINDFSSE 

30.54 AUTWINDFSSW 

17.71 AUTWINDFWSW 

11.41 AUTWINDFWNW 

7.38 AUTWINDFNNW 

Table 6: Historical Wind Frequency Data as Percents for Cuyahoga County, Ohio 

As shown in Figure 5 and Table 6, the period with the highest wind frequency occurs in the 

autumn months, with winds blowing from the south 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. There also 

appears to be a sizeable frequency of winds from the north northeast in all seasons. 
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Figure 6: Wind Rose at Cleveland/Hopkins International Airport (Ohio EPA) 

Figure 7: Wind Rose at Toledo/Express Airport (Ohio EPA) 
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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 Cleveland and the 

surrounding area. 

The Cleveland 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 

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 Cleveland area, there are several jurisdictional boundaries that can be considered. The 

Ohio EPA Central Office and Cleveland Division of Air Quality are responsible for air quality 

planning within all areas of Cuyahoga County. The Northeast Ohio Areawide Coordinating 

Agency (NOACA) is the planning agency designated as the Metropolitan Planning Organization 

for the greater Cleveland area. The NOACA region is composed of 5 Counties: Cuyahoga, 

Geauga, Lake, Lorain, and Medina. Air quality planning efforts to address the impending lead 

nonattainment area in Cleveland 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 are bound on the west by 

Washington Park Blvd./Crete Ave./East 49th St., on the east by E. 71st St., on the north by Fleet 

Ave., and on the south by Grant Ave. 
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Other Relevant Information

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

boundary for Cleveland. This information will be discussed below. 

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

was found to be appropriate for the Cleveland area due to the locations and number of lead 

monitors (refer to Table 2). Ohio EPA used a concentration of 0.145 μg/m3

 as the bounding 

isopleth because it rounds up to the 0.15 μg/m3 NAAQS. The violating monitor (AQS ID 

390350049) showed 3 different 3-month rolling averages of lead concentrations above the 

NAAQS. It was decided that those 3 values would be spatially averaged with the readings from 

the other 4 monitors for the identical time period. The 3 time periods and associated 

concentrations are listed below in Table 7. 

Table 7: Periods and Concentrations used in Ohio EPA's Spatial Averaging Analysis 

The months in the “Period” column indicate the third month of the rolling 3 month period. The concentrations are 

all in μg/m3 

The process of defining the nonattainment area boundary involves constructing Krige plots for 

each of the time periods individually, and defining the nonattainment area to be every point 

falling inside the 0.145 μg/m3 isopleth on any of the plots. After the plots were constructed, 

Ohio EPA concluded that the October 2008 period was controlling; in other words, the area 

inside the 0.145 μg/m3

 isopleth was large enough to fully enclose the corresponding isopleth in 

both of the other plots. The resulting nonattainment boundary based on Ohio EPA’s spatial 

interpolation analysis is shown by the yellow octagonal outline in Figure 8. Any area outside of 

this octagonal outline has been interpolated to show an impact of less than 0.145 μg/m3

. Ohio 

EPA has included a buffer zone between the nonattainment boundary generated by the isopleth 

analysis and the final State recommended nonattainment area. Please note that the 2 green place 

markers at the southwest corner of the State recommended nonattainment area are artifacts from 

the mapping procedure used by Ohio EPA, and do not have an implication on the actual 

nonattainment area. 
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Figure 8: Cleveland, Ohio State Recommended Nonattainment Area Spatial Interpolation (Ohio EPA) 

Conclusion

After considering the factors described above, EPA has determined that it is appropriate to 

include a portion of Cuyahoga County as nonattainment for the 2008 lead NAAQS. 

The air quality monitor in Cuyahoga County shows a violation of the 2008 lead NAAQS, based 

on 2006-2008 and 2007-2009 air quality data. The cumulative process of the factors analysis in 

conjunction with the State’s spatial interpolation ultimately leads to the nonattainment area. 

There are no other major sources of lead emissions in the State recommended nonattainment area 

or upwind of the State recommended nonattainment area. One of the 2 monitors in this area, 

located slightly north of Ferro Corporation, has monitored violations of the 2008 lead NAAQS. 

Grant Rd Monitor 
17

The other monitor, slightly to the south of Ferro Corporation, has shown consistent compliance 

with the 2008 lead NAAQS. When considering the factors analysis and the supplemental spatial 

interpolation analysis for the Cleveland area, EPA finds it appropriate to designate the portions 

of Cuyahoga County that are bound on the west by Washington Park Blvd./Crete Ave./East 49th

St., on the east by East 71st St., on the north by Fleet Ave., and on the south by Grant Ave. 

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 Cleveland area. 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 Cleveland area, nor did we receive any additional information from the State. 

Accordingly, EPA has determined that the portions of Cuyahoga County that are bound on the 

west by Washington Park Blvd./Crete Ave./East 49th St., on the east by East 71st St., on the north 

by Fleet Ave., and on the south by Grant Ave. should be designated as nonattainment for the 

2008 lead NAAQS, as seen in Figure 9. 

Figure 9: Cleveland, Ohio Final Nonattainment Area (OAQPS)