1 Cleveland, Ohio Technical Support Document

--------------------------------------------------- --------------------------------------------------- ---------------

--------------------------------------------------- --------------------------------------------------- ---------------

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 will designate 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 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 th e partial 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, 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: Cleveland, Ohio State Recommended Nonatta inment 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 Cleveland and the surrounding areas will be discussed in the section addressing emissions in Cuyahoga Cou nty. 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 tp y, and they are marked with the symbol and the emis sions 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.gov5

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

Table 1.

Detailed Assessment

Air Quality Data

This factor considers the lead design values (in μg /m 3 ) 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 monitori ng site when 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 completeness criteria are met. A lead design value that meets the NAAQS is generally considered valid if it encompasses 36 consecutive v alid 3-month site means (specifically for a 3- year calendar period and the 2 previous months). F or 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 me et the NAAQS is considered valid if at least one 3-month mean that meets the same 75 percent req uirement is above the NAAQS. That is, a site does not have to monitor for 3 full calendar y ears 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/m 3 ) Lead Design

Value,

2007-2009 (μg/m 3 ) Cuyahoga,

Ohio Yes E 56 th Ferro 390350049 E 56 th 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 3 rd 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. Latit udes and longitudes were provided by Ohio EPA in their submittal. *These mo nitors are in Cuyahoga County, but are not in the S tate recommended nonattainment area. Refer to Figure 3 below for th eir 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 show s a violation of the 2008 lead NAAQS. Therefore some area in this county and possibly add itional areas in surrounding counties must be designated nonattainment. The absence of a violati ng monitor alone is not a sufficient reason to6

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 on E. 56 th St. (AQS ID 390350049) has an objective of determining the highest concent ration for lead. This monitor is in very close proximity to Ferro Corporation (Ferro Corp). The l ocation of this monitor, as well as the other 4 in the county, will be discussed in the section add ressing emissions for Cuyahoga County.

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 Cleveland and s ources emitting (or anticipate to contribute) 0.1 ton per year or greater of lead according to th e 2005 NEI. The county that is part of the Cleveland nonattainment area for the 2008 lead NAAQ S 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.

2 http://www.epa.gov/air/data/geosel.html.7

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 calcu lated by adding the 2005 NEI data for facilities no t using leaded aviation gas (stationary sources) to the 200 8 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 s ources emitting at or above 0.1 ton per year. The greatest emitter of lead in the county i s American Spring Wire Corporation, and a source-oriented monitor was scheduled to begin oper ation in January 2010. EPA has taken comment on a proposal to lower the emissions thresh old 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, moni tors 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.gov10

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 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 Cleveland before 2005 on stationary sources. EPA has received addit ional information on emissions reductions resulting from controls put into place since 2005.

Ohio EPA highlighted 2 State regulations that assis t in reducing the potential impact on lead concentrations in Cuyahoga County. These regulatio ns are included in Ohio Administrative Code (OAC) 3745-17-12 and 3745-17-06. The regulati ons 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 fr om 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 lea d concentrations. These rules include restriction of emissions of fugitive dust, control of visible p articulate emissions from stationary sources, and restrictions on particulate emissions from industri al 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 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. Ohi o EPA provided 2 wind roses for Cuyahoga County in their submittal, and they are shown in Fi gure 6 and Figure 7. The graphical representations from these figures corroborate the data from the National Weather Service.11 Figure 5: Historical Wind Direction Frequencies for Cuyahoga County, Ohio

Figure 5 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.12 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 t he highest wind frequency occurs in the autumn months, with winds blowing from the south so uthwest. 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. There also appears to be a sizeable frequency of winds from th e north northeast in all seasons.13 Figure 6: Wind Rose at Cleveland/Hopkins Internati onal Airport (Ohio EPA)

Figure 7: Wind Rose at Toledo/Express Airport (Ohio EPA)14

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 Cleveland and the surrounding area.

The Cleveland area does not have any geographical o r topographical barriers significantly limiting air pollution transport within its air she d. Therefore, this factor did not play a significa nt role in 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 for 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 Cleveland area, there are several jurisdict ional boundaries that can be considered. The

Ohio EPA Central Office and Cleveland Division of A ir Quality are responsible for air quality planning within all areas of Cuyahoga County. The N ortheast 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 plan ning efforts to address the impending lead nonattainment area in Cleveland should not be probl ematic; 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 are bound on the west by Washington Park Blvd./Crete Ave./East 49 th St., on the east by E. 71 st St., on the north by Fleet Ave., and on the south by Grant Ave.15

Other Relevant Information

EPA received additional relevant information from O hio for establishing the nonattainment area boundary for Cleveland. This information will be d iscussed 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 conce ntration of 0.145 μg/m 3 as the bounding isopleth because it rounds up to the 0.15 μg/m 3 NAAQS. The violating monitor (AQS ID 390350049) showed 3 different 3-month rolling avera ges 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 EP A's Spatial Averaging Analysis
The months in the “Period” column indicate the thir d month of the rolling 3 month period. The concent rations are all in μg/m 3

The process of defining the nonattainment area boun dary 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/m 3 isopleth on any of the plots. After the plots wer e constructed, Ohio EPA concluded that the October 2008 period was controlling; in other words, the area inside the 0.145 μg/m 3 isopleth was large enough to fully enclose the cor responding isopleth in both of the other plots. The resulting nonattainme nt boundary based on Ohio EPA’s spatial interpolation analysis is shown by the yellow octag onal outline in Figure 8. Any area outside of this octagonal outline has been interpolated to sho w an impact of less than 0.145 μg/m 3 . Ohio

EPA has included a buffer zone between the nonattai nment boundary generated by the isopleth analysis and the final State recommended nonattainm ent area. Please note that the 2 green place

markers at the southwest corner of the State recomm ended nonattainment area are artifacts from the mapping procedure used by Ohio EPA, and do not have an implication on the actual

nonattainment area.16

Figure 8: Cleveland, Ohio State Recommended Nonatta inment 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 nonattainme nt 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 c umulative 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 ar ea. One of the 2 monitors in this area, located slightly north of Ferro Corporation, has mo nitored violations of the 2008 lead NAAQS. Grant Rd Monitor17

The other monitor, slightly to the south of Ferro C orporation, has shown consistent compliance with the 2008 lead NAAQS. When considering the fac tors 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 Wa shington Park Blvd./Crete Ave./East 49 th
St., on the east by East 71 st 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 e ncompass the entire area that does not meet (or that contributes to ambient air quality in a ne arby 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 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 recommend ations for lead nonattainment areas. In the same notice, EPA started a public comment perio d 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 recei ve any additional information from the State.

Accordingly, EPA has determined that the portions o f Cuyahoga County that are bound on the west by Washington Park Blvd./Crete Ave./East 49 th St., on the east by East 71 st St., on the north by Fleet Ave., and on the south by Grant Ave. shoul d be designated as nonattainment for the 2008 lead NAAQS, as seen in Figure 9.

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