John R. Kasich, Governor 

Mary Taylor, Lt. Governor 

Scott J. Nally, Director 

OCT 2,9 2013 

Ms. Susan Hedman 

Regional Administrator 

U.S. EPA Region 5 

77 W. Jackson Blvd. 

Chicago, IL 60604 

Re: lead Redesignation Request and Maintenance Plan for the 2008 lead 

Standard for the Partial logan County Area 

Dear Administrator Hedman: 

I am writing to formally request a redesignation to attainment of the partial Logan 

County area (Sections 27, 28, 33 and 34 of Lake Township) with respect to the 2008 

lead standard. The enclosed submittal combines the redesignation request and the 

required maintenance plan for this area. 

Monitoring of existing air quality indicates that the 2008 National Ambient Air Quality 

Standard (NAAQS) for lead has been attained throughout this area based on 2010-2012 

air quality data. There was only one source of lead emissions in this area, Daido. Daido 

was a producer of bearing sleeves for the automotive industry. In June of 2009, the 

Daido facility permanently shutdown all lead operations. Emissions projections indicate 

that current controls, existing State rules, existing federal rules, and Ohio's PSD 

program will be more than sufficient to maintain the NAAQS indefinitely into the future 

as no new sources of lead emissions are expected in this area. These programs will, 

therefore, constitute the attainment and maintenance plan for the partial Logan County 

area. 

Ohio EPA notified the public of the draft and the opportunity to provide comments on 

August 21, 2013. The public hearing for this package was held on September 25, 2013 

in Bellefontaine, Ohio. No comments were received and no testimony was provided. 

This submittal consists of one ( 1) hard copy of the required documentation. An exact 

duplicate electronic version of the submittal in PDF format is available at 

http://www.epa.ohio.gov/dapc/SIP!Iead.aspx under the heading "Redesignations and 

Maintenance Plans." 

50 West Town Street o Suite 700 o P.O. Box 1049 o Columbus, OH 43216~1049 

www.epa.ohio.gov • (614)644-3020 • (614)644-3184 (fax) 
If you have questions, please contact Jennifer Van Vlerah in our Division of Air Pollution 

Control at (614) 644-3696. 

Sincerely, 

~ Scott J. Nally 

Director 

Enclosure 
REDESIGNATION REQUEST AND

MAINTENANCE PLAN FOR

THE PARTIAL LOGAN COUNTY,

OH ANNUAL LEAD

NONATTAINMENT AREA

Logan County, 

Ohio

Prepared by:

Ohio Environmental Protection Agency

Division of Air Pollution Control

September 2013
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TABLE OF CONTENTS

Chapter One

Introduction ..................................................................................................................................... 1

Geographical description and background..................................................................................... 2

Status of air quality.......................................................................................................................... 2

Chapter Two

Requirements for redesignation...................................................................................................... 3

Chapter Three

LEAD monitoring............................................................................................................................. 7

Annual LEAD NAAQS..................................................................................................................... 7

Ambient data quality assured.......................................................................................................... 8

Three complete years of data ......................................................................................................... 9

Commitment to continue monitoring............................................................................................. 10

Chapter Four

Emission inventory........................................................................................................................ 11

Base year inventory ...................................................................................................................... 11

Emission projections ..................................................................................................................... 11

Demonstration of maintenance..................................................................................................... 12

Permanent and enforceable emissions reductions ...................................................................... 12

Provisions for future update.......................................................................................................... 13

Chapter Five

Control measures and regulations................................................................................................ 14

Marginal nonattainment areas to implement RACM and RACT................................................... 14

Show Reasonable Further Progress (RFP).................................................................................. 14

Emission inventories ..................................................................................................................... 15

Implementation of past SIP revisions ........................................................................................... 15

New source review provisions ..................................................................................................... 15

Assurance of continued controls .................................................................................................. 16

Chapter Six

Contingency measures ................................................................................................................. 17

Commitment to revise plan ........................................................................................................... 17

Commitment for contingency measures ....................................................................................... 17

Potential contingency measures................................................................................................... 18

List of LEAD, SO2, and NOx sources ............................................................................................ 19

Chapter Seven

Public participation........................................................................................................................ 20

Chapter Eight

Conclusions................................................................................................................................... 21
FIGURES

Figure 1 Map of the partial Logan County, OH- nonattainment area and monitor 

location.................................................................................................................... 8

TABLES

Table 1 Monitoring data for the partial Logan County, OH Area for 2010 – 2012............... 9

Table 2 Partial Logan County, OH Lead Emission Inventory Totals for Base 

Year 2005, Attainment Year 2010, and Projected 2015 and 2025 (tpy) .............. 12

APPENDICES

A Air Quality System (AQS) Data

B Public Participation Documentation
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REDESIGNATION REQUEST AND MAINTENANCE PLAN FOR

THE PARTIAL LOGAN COUNTY, OH ANNUAL LEAD

NONATTAINMENT AREA

CHAPTER ONE

Introduction

The Clean Air Act (CAA), as amended, requires each State with areas failing to 

meet the annual lead National Ambient Air Quality Standards (NAAQS) to 

develop State Implementation Plans (SIPs) to expeditiously attain and maintain 

the standards. The United States Environmental Protection Agency (U.S. EPA) 

revised the NAAQS for lead on November 12, 2008 (73 FR 66964). It replaced 

the existing annual lead standard of 1.5 micrograms per cubic meter (μg/m3) 

with a lower annual standard set at 0.15 μg/m3. The new lead standard is 

measured as a rolling three-month average (not to be exceeded) of the monthly

mean concentrations, which is evaluated over a three-year period.

On November 22, 2010, U.S. EPA promulgated the initial lead nonattainment 

areas designations for the lead standard, which became effective on December 

31, 2010. Section 191 of the CAA Amendments require states with lead

nonattainment areas to submit a plan within eighteen months of the effective 

date of the designations (November 22, 2008) detailing how the lead standard 

will be attained by December 31, 2015. However, for this area, Ohio attained the 

standard prior to the date this attainment demonstration was required (June 30, 

2012); therefore, the requirement to submit an attainment demonstration is 

waived. Ohio EPA submitted a clean data request to U.S. EPA on May 14, 2012 

and a revised request on April 19, 2013 so that U.S. EPA could formally 

acknowledge attainment of the area. Regardless of any clean data determination

by U.S. EPA, states must still submit redesignation requests and maintenance 

plans in order for any area to officially be redesignated back to attainment. This 

submittal satisfies that requirement.

Section 107(d)(3)(E) of the CAA allows states to request nonattainment areas to 

be redesignated to attainment provided certain criteria are met. The following 

are the criteria that must be met in order for an area to be redesignated from 

nonattainment to attainment: 

i) A determination that the area has attained the lead standard.

ii) An approved State Implementation Plan (SIP) for the area 

under Section 110(k).

iii) A determination that the improvement in air quality is due to 

permanent and enforceable reductions in emissions resulting 
2

from implementation of the SIP and other federal 

requirements.

iv) A fully approved maintenance plan under Section 175(A).

v) A determination that all Section 110 and Part D requirements 

have been met. 

This document addresses each of these requirements, and provides additional 

information to support continued compliance with the annual lead standard.

Geographical Description and Background

The current partial Logan County nonattainment area is located in just west of 

central Ohio and includes a portion of the city of Bellefontaine and an area 

surrounding the violating monitor located near the facility Daido1. This area is 

shown in Figure 1 under Chapter Three.

Daido was a producer of bearing sleeves for the automotive industry. In June of 

2009, the Daido facility permanently shutdown all lead operations.

This document is intended to support Ohio’s request that the partial Logan 

County nonattainment area be redesignated from nonattainment to attainment 

for the annual lead standard. 

Status of Air Quality

Lead complete quality-assured ambient air quality monitoring data for the most 

recent three (3) years, 2010 through 2012, demonstrate that the air quality has 

met the NAAQS for the annual lead standard in this nonattainment area. The 

NAAQS attainment, accompanied by decreases in emission levels discussed in 

Chapter Four, supports a redesignation to attainment for the partial Logan 

County area based on the requirements in Section 107(d)(3)(E) of the CAA as 

amended.

 

1

This area includes sections 27, 28, 33 and 34 of Lake Township
3

CHAPTER TWO

Requirements for Redesignation

U.S. EPA has published detailed guidance in a document entitled Procedures for

Processing Requests to Redesignate Areas to Attainment (redesignation 

guidance), issued September 4, 1992, to Regional Air Directors. The 

redesignation request and maintenance plan are based on the redesignation 

guidance, supplemented with additional guidance received from staff of U.S. 

EPA Region 5.

Below is a summary of each redesignation criterion as it applies to the partial 

Logan County area.

i.) Attainment of the standard (CAA Section 107(d)(3)(E)(i)) 

There are two components involved in making this demonstration.

The first component relies on ambient air quality data. The data 

that are used to demonstrate attainment should be the product of 

ambient monitoring that is representative of the area of highest 

concentration. The data should be collected and quality-assured in 

accordance with 40 CFR 58 and recorded in the Air Quality 

System (AQS)in order for it to be available to the public for review.

The second component relies upon supplemental U.S. EPAapproved air quality modeling. While no modeling is required for 

redesignating nonattainment areas, the redesignation guidance 

states it is “generally necessary” for lead redesignations in order to 

evaluate comprehensively sources’ impacts and to determine the 

areas of expected high concentrations based upon current 

conditions. Because the only source of lead emissions in the 

nonattainment area was Daido, and Daido has since been

permanently shutdown, this modeling is not necessary.

ii.) Permanent and enforceable improvement in air quality (CAA Section 

107(d)(3)(E)(iii))

The state must be able to reasonably attribute the improvement in 

air quality to emission reductions which are permanent and 

enforceable. The state should estimate the percent reduction 

achieved from federal measures as well as control measures that 

have been adopted and implemented by the state.

It was not necessary for Ohio to adopt or implement control 

measures for this nonattainment area because the only source of 

lead emissions, Daido, permanently shutdown. 

.
4

Chapters Four and Five discuss this requirement in more detail.

iii.) Section 110 and Part D requirements (CAA Section 107(d)(3)(E)(v))

For purposes of redesignation, a state must meet all requirements 

of Section 110 and Part D that were applicable prior to submittal of 

the complete redesignation request.

Subpart 1 of Part D consists of general requirements applicable to 

all areas which are designated nonattainment based on a violation 

of the NAAQS. Subpart 5 of Part D consists of more specific 

requirements applicable to lead. 

i.) Section 110(a) requirements

Section 110(a) of Title I of the CAA contains the general 

requirements for a SIP. Section 110(a)(2) provides that the 

implementation plan submitted by a state must have been 

adopted by the state after reasonable public notice and 

hearing, and that, among other things, it must include 

enforceable emission limitations and other control 

measures, means or techniques necessary to meet the 

requirements of the CAA; provide for establishment and 

operation of appropriate devices, methods, systems and 

procedures necessary to monitor ambient air quality; 

provide for implementation of a source permit program to

regulate the modification and construction of any stationary 

source within the areas covered by the plan; include 

provisions for the implementation of Part C, prevention of 

significant deterioration (PSD) and Part D, NSR permit 

programs; include criteria for stationary source emission 

control measures, monitoring, and reporting; include 

provisions for air quality modeling; and provide for public 

and local agency participation in planning and emission 

control rule development. In Ohio’s October 12, 2011

infrastructure SIP submission, Ohio verified that the State 

fulfills the requirements of Section 110(a)(2) of the Act.

Section 110(a)(2)(D) also requires State plans to prohibit 

emissions from within the State which contribute 

significantly to nonattainment or maintenance areas in any 

other State, or which interfere with programs under Part C 

to prevent significant deterioration of air quality or to 

achieve reasonable progress toward the national visibility 

goal for Federal class I areas (national parks and 

wilderness areas). In order to assist States in addressing 

their obligations regarding regionally transported pollution,

Ohio EPA has adopted and implemented the various major 
5

programs related to the interstate transport of pollution. 

OAC Chapters 3745-16 (Stack Height Requirements), 

3745-103 (Acid Rain Permits and Compliance), 3745-14 

(Nitrogen Oxides – Budget Trading Program), and 3745-

109 (Clean Air Interstate Rule) all address Congressional 

and U.S.EPA concerns over the transport of emissions of 

regulated pollutants beyond our State borders. Ohio has 

also responded to requests by the States of Indiana and 

West Virginia to implement revisions to OAC Chapter 3745-

18 (Hamilton County and Jefferson County) to alleviate 

modeled violations due, in part, to sources in Ohio. 

Additionally, all new major sources and major modifications 

in the state are subject to PSD and NNSR program to help 

achieve the lead standard.

Based upon U.S. EPA’s “Guidance on SIP Elements 

Required Under Sections 110(a)(1) and (2) for the 2008 

Lead (Pb) National Ambient Air Quality Standards 

(NAAQS)” (draft as of 6/17/11), the physical properties of 

lead prevent lead emissions from experiencing the same 

travel or formation phenomena as PM2.5 or ozone. Lead

concentrations sharply decrease with the distance from a 

lead source. Only large sources in close proximity to state 

boundaries could contribute significantly to nonattainment 

in, or interfere with maintenance by, any other state.

This nonattainment area is not in close proximity to Ohio’s 

border and the only source of lead emissions, Daido, is 

now permanently shutdown. Therefore, lead sources in this 

area do not contribute significantly to nonattainment, or 

interfere with maintenance, of the NAAQS in another state, 

or interfere with measures required to prevent significant 

deterioration of air quality. 

ii.) Section 172(c) requirements

This Section contains general requirements for 

nonattainment plans. The requirements for reasonable 

further progress, identification of certain emissions 

increases, and other measures needed for attainment will 

not apply for redesignations because they only have 

meaning for areas not attaining the standard. The 

requirements for an emission inventory will be satisfied by 

the inventory requirements of the maintenance plan. 

Chapters Four and Five discuss this requirement in more 

detail.
6

iii.) Conformity

The state must work with U.S. EPA to show that its SIP 

provisions are consistent with the Section 176(c)(4) 

conformity requirements. The redesignation request should 

include conformity procedures, if the state already has 

these procedures in place. If a state does not have 

conformity procedures in place at the time that it submits a 

redesignation request, the state must commit to follow U.S. 

EPA’s conformity regulation upon issuance, as applicable.

Furthermore, in U.S. EPA’s final rule it was stated that In 

light of the elimination of lead additives from gasoline, 

transportation conformity does not apply to the lead

NAAQS [ 73 FR 67043]. 

iv.) Maintenance plans (CAA Section 107(d)(3)(E)(iv))

Section 107(d)(3)(E) stipulates that for an area to be redesignated, 

U.S. EPA must fully approve a maintenance plan that meets the 

requirements of Section 175(A). The maintenance plan will 

constitute a SIP revision and must provide for maintenance of the 

relevant NAAQS in the area for at least 10 years after 

redesignation. Section 175(A) further states that the plan shall 

contain such additional measures, if any, as may be necessary to 

ensure such maintenance.

In addition, the maintenance plan shall contain such contingency 

measures as the Administrator deems necessary to ensure 

prompt correction of any violation of the NAAQS. At a minimum, 

the contingency measures must include a requirement that the 

state will implement all measures contained in the nonattainment 

SIP prior to redesignation.

States seeking redesignation of a nonattainment area should 

consider the following provisions:

a) attainment inventory;

b) maintenance demonstration;

c) monitoring network;

d) verification of continued attainment; and

e) contingency plan.

Chapter Six discusses this requirement in more detail.
7

CHAPTER THREE

LEAD MONITORING

CAA Section 107(d)(3)(E)(i)

Requirement 1 of 4

A demonstration that the NAAQS for annual lead, as published in 40 CFR 50.12, 

has been attained.

Background

There is one monitor measuring lead concentrations in this 

nonattainment area. The monitor is operated by Ohio EPA 

Division of Air Pollution Control, Northwest District Office. A listing 

of the design values from 2010 through 2012 are shown in Table 

1. The location of the monitoring site for this nonattainment area is 

shown on Figure 1. 
8

Demonstration

Figure 1 - Map of the partial Logan County, OH- nonattainment area and 

monitor location 

Requirement 2 of 4

Ambient monitoring data quality assured in accordance with 40 CFR 58.10, 

recorded in the U.S. EPA air quality system (AQS) database, and available for 

public view.

Demonstration

Ohio EPA has quality assured all data shown in Appendix A in 

accordance with 40 CFR 58.10 and all other federal requirements. Ohio 

EPA has recorded the data in the AQS database and, therefore, the data 

are available to the public.

Requirement 3 of 4

In accordance with 40 CFR Part 50, Appendix R, the lead NAAQS is met at a 

monitoring site when the identified design value is valid and less than or equal to 

0.15 μg/m3. A lead design value that meets the NAAQS ( i.e. , 0.15 μg/m3or 

less), is considered valid if it encompasses 36 consecutive valid 3-month site 

means (specifically for a 3-year calendar period and the two previous months). 
9

For sites that begin monitoring lead after this rule is effective but before January 

15, 2010, lead design values that meets the NAAQS will be considered valid if it 

encompasses at least 34 consecutive valid 3-month means (specifically 

encompassing only the 3-year calendar period). This is the case for this 

monitoring site as demonstrated, and discussed in detail, in Ohio EPA’s April 19, 

2013 clean data request.

Background

Table 1 shows the monitoring data for the 3-year calendar period 

of 2010-2012 that were retrieved from the U.S. EPA AQS. Also 

included are monitoring data collected and analyzed to date for 

the 2013 year. 

Demonstration

Table 1 - Monitoring data for the partial Logan County, OH Area 

for 2010 – 2012

Site

Location

City

3-month 

period

(unless 

noted)

Three-month rolling average 

(ug/m3)

2010 2011 2012 2013

39-091-0006

Richard Ave. – Daido 

Facility

Bellefontaine

Jan Only 0.005 0.004 0.004 0.003

Feb Only 0.004 0.003 0.003 0.002

Jan -Mar 0.006 0.003 0.003 0.002

Feb-Apr 0.006 0.003 0.003 0.002

Mar-May 0.005 0.003 0.003 0.002

Apr-Jun 0.004 0.003 0.003

May-July 0.003 0.003 0.004

Jun-Aug 0.003 0.003 0.003

July-Sept 0.004 0.003 0.003

Aug-Oct 0.004 0.005 0.003

Sept-Nov 0.004 0.005 0.003

Oct-Dec 0.004 0.004 0.003

Sites with one or more months of a 

composite analysis missing in any 

three-month period.

Source: U.S. EPA Air Quality System (AQS); http://www.epa.gov/ttn/airs/airsaqs/index.htm

A design value is considered valid only when minimum datacompleteness requirements are met. 

There is incomplete data for the 3-month means for January to March 

2012 and February to April 2012 periods. Data for these periods did not 

meet the 75% capture criteria because only three of five samples were 

collected in both February and March of 2012. In each case, the missed 
10

samples resulted in data capture of less than 75%, for the 3-month mean 

periods but greater than 50% of the required monthly collections. 

Therefore, Ohio EPA performed a conservative substation analysis in 

accordance with 40 CFR Part 50, Appendix R, Section (4)(c)(ii)(B) 

showing passing design values for these periods. This analysis was 

detailed in Ohio EPA’s April 19, 2013 clean data request. 

The design values calculated for the partial Logan County area

demonstrate that the annual lead NAAQS has been attained. The area's 

design values have remained consistently low since the permanent 

shutdown of the Daido facility. 

Requirement 4 of 4

A commitment that once redesignated, the state will continue to operate an 

appropriate monitoring network to verify the maintenance of the attainment 

status.

Demonstration

Ohio EPA commits to continue monitoring lead levels at this site

indicated in Figure 1 and Table 1. Ohio EPA will consult with U.S. 

EPA Region 5 prior to making changes to the existing monitoring 

network, should changes become necessary in the future. Ohio 

EPA will continue to quality assure the monitoring data to meet the 

requirements of 40 CFR Part 58 and all other federal 

requirements. Ohio EPA will enter all data into AQS on a timely 

basis in accordance with federal guidelines.
11

CHAPTER FOUR

EMISSION INVENTORY

CAA Section 107(d)(3)(E)(iii)

U.S. EPA’s redesignation guidance requires the submittal of a comprehensive 

inventory of lead emissions representative of the year when the area achieves 

attainment of the annual lead air quality standard. Ohio also must demonstrate 

that the improvement in air quality between the year that violations occurred and 

the year that attainment was achieved is based on permanent and enforceable 

emission reductions. Other emission inventory related requirements include a 

projection of the emission inventory to a year at least 10 years following 

redesignation; a demonstration that the projected level of emissions is sufficient 

to maintain the annual lead standard; and a commitment to provide future 

updates of the inventory to enable tracking of emission levels during the 10-year 

maintenance period.

The comprehensive inventory includes emissions of lead from point sources. 

Ohio does not have area, mobile, non-road, or marine/air/rail sources of lead 

emissions that contribute to nonattainment. The only point source of emissions 

in this nonattainment area was the Daido facility.

Requirement 1 of 5

A comprehensive emission inventory of lead sources completed for the base 

year.

Background

The point source data are taken from U.S. EPA National 

Emissions Inventory (NEI) reporting program. The period

coincides with nonattainment air quality in the partial Logan 

County nonattainment area. 

Demonstration

The 2005 NEI is used as the base year for the purpose of this 

submittal and was submitted to U.S. EPA with Ohio’s lead 

nonattainment area recommendations submitted on October 5, 

2009. The detailed lead emission inventory information for the 

partial Logan County area is provided in Table 2 under 

Requirement Three of this Chapter. 

Requirement 2 of 5

A projection of the emission inventory to a year at least 10 years following 

redesignation.
12

Demonstration

Ohio EPA prepared a comprehensive future year inventory for the 

partial Logan County area. See Requirement 3 of 5 under 

Requirement Three of this Chapter.

Requirement 3 of 5

A demonstration that the projected level of emissions is sufficient to maintain the 

lead standard.

Background

In consultation with U.S. EPA, Ohio EPA selected the year 2025

as the maintenance year for this redesignation request. This 

document contains projected emissions inventories for 2015 and 

2025. 

Maintenance is demonstrated when the future-year (2025) 

projected emission totals are below (or at in the case of zero 

emissions) the 2010 attainment year totals.

Demonstration

Table 2 – Partial Logan County, OH Lead Emission Inventory Totals 

for Base Year 2005, Attainment Year 2010, and Projected 2015 and 

2025 (tpy) 

Source 2005

Base

2010

Attainment

2015 

Interim

2025

Maintenance

Safety 

Margin

Daido 0.0035 0 0 0 0

TOTAL 0.0035 0 0 0 0

As shown in the table above (Table 2), lead emissions in the 

nonattainment area are projected to decrease to zero tpy by 2025 

due to the permanent shutdown of Daido in June 2009.

Furthermore, the 2008 NEI2shows that lead emissions for the 

entire Logan County are very low, at 0.003 tpy. Daido is also not 

identified in the 2008 NEI as a lead emissions source. 

Requirement 4 of 5

A demonstration that improvement in air quality between the year violations 

occurred and the year attainment was achieved is based on permanent and 

enforceable emission reductions and not on temporary adverse economic 

 

2

https://www.google.com/fusiontables/DataSource?docid=16gJi7ePu_IX_2Hyu46sp7sFdu4cOP9_Zb3x

3Zks#rows:id=1
13

conditions or unusually favorable meteorology.

Background

Ambient air quality data from all monitoring sites indicate that air quality

met the NAAQS for lead in 2010-2012. U.S. EPA’s redesignation 

guidance (p 9) states: “A state may generally demonstrate maintenance 

of the NAAQS by either showing that future emissions of a pollutant or its 

precursors will not exceed the level of the attainment inventory, or by 

modeling to show that the future mix of sources and emissions rates will 

not cause a violation of the NAAQS.”

Demonstration

Due to the permanent shutdown of Daido in June of 2009, emissions of 

lead in the area have been zero since the attainment year. Daido is 

identified in Ohio EPA’s records as permanently shutdown, and therefore, 

operations could not resume without Daido being considered a new 

source and subject to new source review provisions. No additional 

sources of lead are expected in the future. In the event a future source of 

lead may install in the area in the future, all relevant requirements at that 

time would be required, including new source review permitting. This 

ensures maintenance of the lead standard into the future. 

Requirement 5 of 5

Provisions for future annual updates of the inventory to enable tracking of the 

emission levels, including an annual emission statement from major sources.

Demonstration

In Ohio, major point sources in all counties are required to submit 

air emissions information annually, in accordance with U.S. EPA’s 

Consolidated Emissions Reporting Rule (CERR). Ohio EPA 

prepares a new periodic inventory for all lead sources every three 

years. This lead inventories will be prepared for future years as 

necessary to comply with the inventory reporting requirements 

established in the CFR. Emissions information will be compared 

to the 2005 base year and the 2025 projected maintenance year 

inventory to assess emission trends, as necessary, and to assure 

continued compliance with the annual lead standard.
14

CHAPTER FIVE

CONTROL MEASURES AND REGULATIONS

CAA Section107 (d)(3)(E)(ii), 107(d)(3)(iv), and 107(d)(3)(E)(v)

Requirement 1 of 6

Section 172(c)(1) of the 1990 Clean Air Act Amendments requires states with

nonattainment areas to implement RACM and RACT.

Background

Section 172(c)(1) of the 1990 Clean Air Act Amendments requires 

states with nonattainment areas to submit a SIP providing for 

implementation of all reasonably available control measures

(RACM) as expeditiously as practicable (including such reductions 

in emissions from existing sources in the area as may be obtained 

through the adoption, at a minimum, of reasonable available 

control technology (RACT)).

U.S. EPA’s final rule stated it is appropriate to set a threshold for 

RACT analysis at 0.5 tpy. 

Demonstration

The Daido facility emissions never exceeded the threshold of 0.5 

tpy, necessitating a RACT analysis. In addition, Daido 

permanently shutdown prior to when any RACT analysis would 

have been required.

Requirement 2 of 6

Section 172(c)(2) of the 1990 CAA Amendments requires attainment 

demonstration SIPs for nonattainment areas to show reasonable further 

progress (RFP). 

Background

U.S. EPA’s final rule expected that RFP for lead nonattainment 

areas should be met by strict adherence to an ambitious 

compliance schedule which should periodically yield significant 

emissions reductions, and to the extent appropriate, linear 

progress.

Demonstration

Because Daido permanently shutdown in June of 2009, RFP has 

been met.
15

Requirement 3 of 6

Section 172(c)(3) requires states to submit a comprehensive inventory of actual 

emissions.

Background

Section 172(c)(3) requires states to submit a comprehensive 

inventory of actual emissions in the area, including the 

requirement for periodic revisions as determined necessary. 40 

CFR 51.1008 requires such inventory to be submitted within three 

years of designation and requires a baseline emission inventory 

for calendar year 2002 or other suitable year to be used for 

attainment planning.

Demonstration

The 2005 comprehensive inventory was submitted to U.S. EPA 

with Ohio’s lead recommended designations document submitted 

on October 5, 2009. Emissions for this area were taken from U.S. 

EPA’s NEI.

Ohio also updates its inventory in accordance with U.S. EPA’s 

CERR rule (i.e. emissions statements). Ohio EPA submitted its 

emissions statement SIP on March 18, 1994 which was approved 

by U.S. EPA on October 13, 1995 (59 FR 51863). As discussed in 

Chapter 4 (Requirement 4), Ohio EPA submits, and commits to 

submit, emission inventories (statements) every three years. 

Requirement 4 of 6

Evidence that control measures required in past lead SIP revisions have been 

fully implemented.

Demonstration

There are no past control measures required in Ohio’s SIP for this 

area. 

Requirement 5 of 6

Acceptable provisions to provide for new source review.

Background

Ohio has a longstanding and fully implemented New Source 

Review (NSR) program. This is addressed in OAC Chapter 3745-

313. The Chapter includes provisions for the Prevention of 

Significant Deterioration (PSD) permitting program in OAC rules 

3745-31-01 to 3745-31-20. Ohio's PSD program was conditionally 

approved on October 10, 2001 (66 FR 51570) and received final 

 

3 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx
16

approval on January 22, 2003 (68FR 2909) by U.S. EPA as part of 

the SIP.

Demonstration

Any facility that is not listed in the 2005 emission inventory, or for 

the closing of which credit was taken in demonstrating attainment, 

will not be allowed to construct, reopen, modify, or reconstruct 

without meeting all applicable NSR requirements. Once the area 

is redesignated, Ohio EPA will implement NSR through the PSD 

program.

Requirement 6 of 6

Assure that all existing control measures will remain in effect after redesignation 

unless the State demonstrates through modeling that the standard can be 

maintained without one or more control measures.

Demonstration

Ohio commits to maintaining the existing control measures after 

redesignation. 

Ohio, through Ohio EPA’s Legal office, has the legal authority and 

necessary resources to actively enforce any violations of its rules 

or permit provisions. After redesignation, it intends to continue 

enforcing all rules that relate to the emission of lead in the partial 

Logan County area.
17

CHAPTER SIX

CONTINGENCY MEASURES

CAA Section 107(d)(3)(E)(v)

Requirement 1 of 4

A commitment to submit a revised plan eight years after redesignation.

Demonstration

Ohio hereby commits to review its maintenance plan eight years 

after redesignation, as required by Section 175(A) of the CAA.

Requirement 2 of 4

A commitment to expeditiously enact and implement additional contingency 

control measures in response to exceeding specified predetermined levels 

(triggers) or in the event that future violations of the ambient standard occur.

Demonstration

Ohio hereby commits to adopt and expeditiously implement 

necessary corrective actions in the following circumstances:

Warning Level Response:

A warning level response shall be prompted whenever a lead 3-

month rolling average concentration of 0.135 μg/m3occurs within 

the maintenance area. A warning level response will consist of a 

study to determine whether the lead value indicates a trend toward 

higher lead values. The study will evaluate whether the trend, if 

any, is likely to continue and, if so, the control measures 

necessary to reverse the trend taking into consideration ease and 

timing for implementation as well as economic and social 

considerations. Implementation of necessary controls in response 

to a warning level response trigger will take place as expeditiously 

as possible, but in no event later than 12 months from the 

conclusion of the most recent calendar year. 

Should it be determined through the warning level study that 

action is necessary to reverse the noted trend, the procedures for 

control selection and implementation outlined under “action level

response” shall be followed.

Action Level Response:

An action level response shall be prompted whenever a two-year 

average of the 3-month rolling average concentration of 0.143

μg/m3or greater occurs within the maintenance area. A violation 

of the standard (any 3-month rolling average over a 36-month 
18

rolling average period (3-calendar years plus the preceding 2 

months) exceeds 0.15 μg/m3) shall also prompt an action level 

response. In the event that the action level is triggered and is not 

found to be due to an exceptional event, malfunction, or 

noncompliance with a permit condition or rule requirement, Ohio 

EPA in conjunction with the entity(ies) believed to be responsible 

for the exceedance will evaluate additional control measures 

needed to assure future attainment of the NAAQS for annual lead. 

In this case, measures that can be implemented in a short time 

will be selected in order to be in place within 18 months from the 

close of the calendar year that prompted the action level. Ohio 

EPA will also consider the timing of an action level trigger and 

determine if additional, significant new regulations not currently 

included as part of the maintenance provisions will be 

implemented in a timely manner and will constitute our response.

Control Measure Selection and Implementation

Adoption of any additional control measures is subject to the 

necessary administrative and legal process. This process will 

include publication of notices, an opportunity for public hearing, 

and other measures required by Ohio law for rulemaking or 

permitting. 

If a new measure/control is already promulgated and scheduled to 

be implemented at the federal or State level, and that 

measure/control is determined to be sufficient to address the 

upward trend in air quality, additional local measures may be 

unnecessary. Furthermore, Ohio will submit to U.S. EPA an 

analysis to demonstrate the proposed measures are adequate to 

return the area to attainment. 

Requirement 3 of 4

A list of potential contingency measures that would be implemented in such an 

event.

Demonstration

Contingency measures to be considered will be based on an 

analysis of the suspected cause of the elevated lead levels from 

the entity(ies) suspected to be contributing to the elevated levels. 

Measures may include improvements in existing control devices, 

addition of secondary control devices or improvements in 

housekeeping and maintenance, among other measures. It is not 

possible to fully develop an appropriate list of contingency 

measures until the cause of the elevated levels is known. Any 

contingency measures implemented will require a compliance plan 

and expeditious compliance timeline from the entity(ies) involved. 
19

No contingency measure shall be implemented without providing 

the opportunity for full public participation during which the relative 

costs and benefits of individual measures, at the time they are 

under consideration, can be fully evaluated.

Requirement 4 of 4

A list of lead sources potentially subject to future additional control

requirements.

Demonstration

Ohio EPA does not expect any future lead sources in this area. As 

discussed elsewhere in this document, any new source planning 

to locate in this area would be a point source that would be subject 

to the new source review program.
20

CHAPTER SEVEN

PUBLIC PARTICIPATION

Ohio published notification for a public hearing and solicitation for public 

comment concerning the draft redesignation petition and maintenance plan in 

the widely distributed county publication on August 21, 2013. 

The public hearing to receive comments on the redesignation request was held 

on September 25, 2013 in Bellefontaine, Ohio. The public comment period 

closed on September 25, 2013. Appendix B includes a copy of the public notice, 

and the transcript from the public hearing.
21

CHAPTER EIGHT

CONCLUSIONS

The partial Logan County annual lead nonattainment area has attained the 2008

annual NAAQS for lead and complied with the applicable provisions of the 1990

Amendments to the CAA regarding redesignations of leadnonattainment areas. 

Documentation to that effect is contained herein. Ohio EPA has prepared a 

redesignation request and maintenance plan that meet the requirements of 

Section 110 (a)(1) of the 1990 CAA. 

Based on this presentation, the partial Logan County annual leadnonattainment 

area meets the requirements for redesignation under the CAA and U.S. EPA

guidance. Ohio has performed an analysis that shows the air quality 

improvements are due to permanent and enforceable measures. Furthermore, 

because the only source of lead emissions in this area has permanently 

shutdown, Ohio can ensure continued compliance (maintenance) with the 

standard with an increasing margin of safety.

The State of Ohio hereby requests that the partial Logan County annual lead

nonattainment area be redesignated to attainment simultaneously with U.S. EPA

approval of the maintenance plan provisions contained herein.
This page left intentionally blank
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

RAW DATA REPORT

Report Request ID: 1126624 Report Code: AMP350 Aug. 20, 2013

Selection Criteria Page 1

User ID: IDA

State County City Site Parameter POC AQCR UAR CBSA CSA

EPA

Region Method Duration Begin Date End Date

39 091 0006

GEOGRAPHIC SELECTIONS

PROTOCOL SELECTIONS

Parameter

Classification Parameter Method Duration

CRITERIA

CRITERIA

ALL

ALL

14129

14129

14128

14128

7

C

7

C

SELECTED OPTIONS

RAW DATA EVENTS

DAILY STATISTICS

UNITS

MERGE PDF FILES

INCLUDE NULLS

Option Type Option Value

INCLUDE EVENTS

MAXIMUM

REPORTED

YES

YES

SORT ORDER

1

2

3

4

5

Order Column

STATE_CODE

COUNTY_CODE

SITE_ID

PARAMETER_CODE

POC

GLOBAL DATES

2010

Start Date End Date

01 01 06 30 2013

Tribal

Code

APPLICABLE STANDARDS

Standard Description
RAW DATA REPORT Aug. 20, 2013

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 1 of 10

(14128) Lead (TSP) LC Non-FRM/FEM

(39) Ohio

CAS NUMBER: 7439-92-1

SITE ID: 1 39-091-0006 POC:

AQCR: (177) NORTHWEST OHIO

COUNTY: (091) Logan

CITY: (05130) Bellefontaine

LONGITUDE: -83.7585

LATITUDE: 40.341467

LOCATION SETTING: URBAN AND CENTER CITY

SITE ADDRESS: 320 RICHARD

LAND USE: RESIDENTIAL

SITE COMMENTS: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES

MONITOR COMMENTS:

PROBE HEIGHT: 3

ELEVATION-MSL: 377

(0000) NOT IN AN URBAN AREA UTM NORTHING:

UTM EASTING:

URBANIZED AREA:

UTM ZONE:

SUPPORT AGENCY: (0810) Ohio EPA, Southwest District Office

MONITOR TYPE: SLAMS

COLLECTION AND ANALYSIS METHOD: (110) Hi-Vol ICAP SPECTRA (ICP-MS); 0.45

REPORT FOR: 2010

DURATION:

UNITS:

MIN DETECTABLE: PQAO: (0810) Ohio EPA, Southwest District Office

COMPOSITE DATA

Micrograms/cubic meter (LC)

.00045

VALUE EX DATA

MONTHLY COMPOSITE OF 24-HOUR SAMPLES

NUMBER

SAMPLES

SAMPLE

PERIOD

1

2

3

4

5

6

7

8

9

10

11

12

 .00486 

 .00446 

 .00716 

 .00495 

 .00354 

 .00315 

 .00375 

 .00352 

 .00439 

 .00356 

 .00495 

 .00279 

5

4

5

5

4

5

5

5

5

5

5

5

Note: Qualifier codes with regional 

 concurrence are shown in upper case,

 and those without regional review

 are shown in lower case. An asterisk

 ("*") indicates that the region has

 reviewed the value and does not concur

 with the qualifier.

STATE:
RAW DATA REPORT Aug. 20, 2013

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 2 of 10

(14128) Lead (TSP) LC Non-FRM/FEM

(39) Ohio

CAS NUMBER: 7439-92-1

SITE ID: 3 39-091-0006 POC:

AQCR: (177) NORTHWEST OHIO

COUNTY: (091) Logan

CITY: (05130) Bellefontaine

LONGITUDE: -83.7585

LATITUDE: 40.341467

LOCATION SETTING: URBAN AND CENTER CITY

SITE ADDRESS: 320 RICHARD

LAND USE: RESIDENTIAL

SITE COMMENTS: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES

MONITOR COMMENTS:

PROBE HEIGHT: 3

ELEVATION-MSL: 377

(0000) NOT IN AN URBAN AREA UTM NORTHING:

UTM EASTING:

URBANIZED AREA:

UTM ZONE:

SUPPORT AGENCY: (0810) Ohio EPA, Southwest District Office

MONITOR TYPE: SLAMS

COLLECTION AND ANALYSIS METHOD: (110) Hi-Vol ICAP SPECTRA (ICP-MS); 0.45

REPORT FOR: 2011

DURATION:

UNITS:

MIN DETECTABLE: PQAO: (0810) Ohio EPA, Southwest District Office

COMPOSITE DATA

Micrograms/cubic meter (LC)

.0075

VALUE EX DATA

MONTHLY COMPOSITE OF 24-HOUR SAMPLES

NUMBER

SAMPLES

SAMPLE

PERIOD

1

2

3

4

5

6

7

8

9

10

11

12

 .00383 

 .00275 

 .00403 

 .00312 

 .00245 

 .00359 

 .00316 

 .00302 

 .00336 

 .00771 

 .00305 

 .00229 

4

5

5

5

4

5

5

6

5

5

5

5

Note: Qualifier codes with regional 

 concurrence are shown in upper case,

 and those without regional review

 are shown in lower case. An asterisk

 ("*") indicates that the region has

 reviewed the value and does not concur

 with the qualifier.

STATE:
RAW DATA REPORT Aug. 20, 2013

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 3 of 10

(14128) Lead (TSP) LC Non-FRM/FEM

(39) Ohio

CAS NUMBER: 7439-92-1

SITE ID: 3 39-091-0006 POC:

AQCR: (177) NORTHWEST OHIO

COUNTY: (091) Logan

CITY: (05130) Bellefontaine

LONGITUDE: -83.7585

LATITUDE: 40.341467

LOCATION SETTING: URBAN AND CENTER CITY

SITE ADDRESS: 320 RICHARD

LAND USE: RESIDENTIAL

SITE COMMENTS: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES

MONITOR COMMENTS:

PROBE HEIGHT: 3

ELEVATION-MSL: 377

(0000) NOT IN AN URBAN AREA UTM NORTHING:

UTM EASTING:

URBANIZED AREA:

UTM ZONE:

SUPPORT AGENCY: (0810) Ohio EPA, Southwest District Office

MONITOR TYPE: SLAMS

COLLECTION AND ANALYSIS METHOD: (110) Hi-Vol ICAP SPECTRA (ICP-MS); 0.45

REPORT FOR: 2012

DURATION:

UNITS:

MIN DETECTABLE: PQAO: (0810) Ohio EPA, Southwest District Office

COMPOSITE DATA

Micrograms/cubic meter (LC)

.0075

VALUE EX DATA

MONTHLY COMPOSITE OF 24-HOUR SAMPLES

NUMBER

SAMPLES

SAMPLE

PERIOD

1

2

3

4

5

6

7

8

9

10

11

12

 .00351 

 .00267 

 .00331 

 .00216 

 .00441 

 .0037 

 .00236 

 .00331 

 .00241 

 .00341 

 .00336 

 .00343 

4

4

3

5

5

4

5

5

4

5

5

5

Note: Qualifier codes with regional 

 concurrence are shown in upper case,

 and those without regional review

 are shown in lower case. An asterisk

 ("*") indicates that the region has

 reviewed the value and does not concur

 with the qualifier.

STATE:
RAW DATA REPORT Aug. 20, 2013

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 4 of 10

(14128) Lead (TSP) LC Non-FRM/FEM

(39) Ohio

CAS NUMBER: 7439-92-1

SITE ID: 3 39-091-0006 POC:

AQCR: (177) NORTHWEST OHIO

COUNTY: (091) Logan

CITY: (05130) Bellefontaine

LONGITUDE: -83.7585

LATITUDE: 40.341467

LOCATION SETTING: URBAN AND CENTER CITY

SITE ADDRESS: 320 RICHARD

LAND USE: RESIDENTIAL

SITE COMMENTS: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES

MONITOR COMMENTS:

PROBE HEIGHT: 3

ELEVATION-MSL: 377

(0000) NOT IN AN URBAN AREA UTM NORTHING:

UTM EASTING:

URBANIZED AREA:

UTM ZONE:

SUPPORT AGENCY: () Not Found

MONITOR TYPE: SLAMS

COLLECTION AND ANALYSIS METHOD: (110) Hi-Vol ICAP SPECTRA (ICP-MS); 0.45

REPORT FOR: 2013

DURATION:

UNITS:

MIN DETECTABLE: PQAO: (0810) Ohio EPA, Southwest District Office

COMPOSITE DATA

Micrograms/cubic meter (LC)

.0075

VALUE EX DATA

MONTHLY COMPOSITE OF 24-HOUR SAMPLES

NUMBER

SAMPLES

SAMPLE

PERIOD

1

2

3

4

5

 .00252 

 .00211 

 .00282 

 .0025 

 .00174 

5

5

5

5

5

Note: Qualifier codes with regional 

 concurrence are shown in upper case,

 and those without regional review

 are shown in lower case. An asterisk

 ("*") indicates that the region has

 reviewed the value and does not concur

 with the qualifier.

STATE:
RAW DATA REPORT Aug. 20, 2013

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 5 of 10

(14129) Lead (TSP) LC

(39) Ohio

CAS NUMBER: 7439-92-1

SITE ID: 1 39-091-0006 POC:

AQCR: (177) NORTHWEST OHIO

COUNTY: (091) Logan

CITY: (05130) Bellefontaine

LONGITUDE: -83.7585

LATITUDE: 40.341467

LOCATION SETTING: URBAN AND CENTER CITY

SITE ADDRESS: 320 RICHARD

LAND USE: RESIDENTIAL

SITE COMMENTS: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES

MONITOR COMMENTS:

PROBE HEIGHT: 3

ELEVATION-MSL: 377

(0000) NOT IN AN URBAN AREA UTM NORTHING:

UTM EASTING:

URBANIZED AREA:

UTM ZONE:

SUPPORT AGENCY: (0810) Ohio EPA, Southwest District Office

MONITOR TYPE: SLAMS

COLLECTION AND ANALYSIS METHOD: (110) Hi-Vol ICAP SPECTRA (ICP-MS); 0.45

REPORT FOR: 2010 DURATION:

UNITS:

PQAO: (0810) Ohio EPA, Southwest District Office MIN DETECTABLE:

24 HOUR

Micrograms/cubic meter (LC)

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

 .00484 

 .00539 

 .00676 

 .00895 

 .00352 

NO.:

MAX:

MEAN:

5

.00895

.005892

 .00641 

 BB

 BB

 .00555 

 .00602 

 .00631 

 .00693 

 .00328 

 .0183 

 .00703 

 .00907 

 .00391 

 .00775 

 .00696 

 .00349 

 .00314 

 AV

 .00486 

 .0053 

 .00594 

 .0042 

 .00355 

 .003 

 .00397 

 .00476 

3

.00641

.005993

5

 .0183

 .00837

5

.00907

.006236

4

 .0059

 .00481

5

 .005

 .0039

0 0 0 0 0 0

ANNUAL OBSERVATIONS: 27 ANNUAL MEAN: .0059 ANNUAL MAX: .018

Note: Qualifier codes with regional concurrence are shown in upper case, and those without

 regional review are shown in lower case. An asterisk ("*") indicates that the region

 has reviewed the value and does not concur with the qualifier.

Day JANUARY FEBRUARY MARCH APRIL MAY JUNE JULY AUGUST SEPTEMBER OCTOBER NOVEMBER DECEMBER

MONTH

STATE:
RAW DATA REPORT Aug. 20, 2013

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 6 of 10

(14129) Lead (TSP) LC

(39) Ohio

CAS NUMBER: 7439-92-1

SITE ID: 1 39-091-0006 POC:

AQCR: (177) NORTHWEST OHIO

COUNTY: (091) Logan

CITY: (05130) Bellefontaine

LONGITUDE: -83.7585

LATITUDE: 40.341467

LOCATION SETTING: URBAN AND CENTER CITY

SITE ADDRESS: 320 RICHARD

LAND USE: RESIDENTIAL

SITE COMMENTS: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES

MONITOR COMMENTS:

PROBE HEIGHT: 3

ELEVATION-MSL: 377

(0000) NOT IN AN URBAN AREA UTM NORTHING:

UTM EASTING:

URBANIZED AREA:

UTM ZONE:

SUPPORT AGENCY: (0810) Ohio EPA, Southwest District Office

MONITOR TYPE: SLAMS

COLLECTION AND ANALYSIS METHOD: (192) Hi-Vol Inductively Coupled PlasmaREPORT FOR: 2010 DURATION:

UNITS:

PQAO: (0810) Ohio EPA, Southwest District Office MIN DETECTABLE:

24 HOUR

Micrograms/cubic meter (LC)

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

NO.:

MAX:

MEAN:

0

 AQ

 AQ

 .00845 

 .00335 

 .00371 

 .00416 

 .00404 

 .00341 

 .00664 

 .00453 

 .00351 

 .00517 

 .00759 

 .00323 

 .00383 

 .00444 

 .00302 

 .005 

 .0038 

 .00626 

 .0026 

 .00683 

 .00736 

 .00611 

 .00271 

 .00437 

 .00199 

 .00378 

 .00398 

 .00405 

 .00295 

0 0 0 0 0 4

.00845

.004918

5

.00664

.004426

5

.00759

.004852

5

 .006

 .0041

5

.00736

.005476

5

.00405

.003350

ANNUAL OBSERVATIONS: 29 ANNUAL MEAN: .0045 ANNUAL MAX: .008

Note: Qualifier codes with regional concurrence are shown in upper case, and those without

 regional review are shown in lower case. An asterisk ("*") indicates that the region

 has reviewed the value and does not concur with the qualifier.

Day JANUARY FEBRUARY MARCH APRIL MAY JUNE JULY AUGUST SEPTEMBER OCTOBER NOVEMBER DECEMBER

MONTH

STATE:
RAW DATA REPORT Aug. 20, 2013

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 7 of 10

(14129) Lead (TSP) LC

(39) Ohio

CAS NUMBER: 7439-92-1

SITE ID: 1 39-091-0006 POC:

AQCR: (177) NORTHWEST OHIO

COUNTY: (091) Logan

CITY: (05130) Bellefontaine

LONGITUDE: -83.7585

LATITUDE: 40.341467

LOCATION SETTING: URBAN AND CENTER CITY

SITE ADDRESS: 320 RICHARD

LAND USE: RESIDENTIAL

SITE COMMENTS: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES

MONITOR COMMENTS:

PROBE HEIGHT: 3

ELEVATION-MSL: 377

(0000) NOT IN AN URBAN AREA UTM NORTHING:

UTM EASTING:

URBANIZED AREA:

UTM ZONE:

SUPPORT AGENCY: (0810) Ohio EPA, Southwest District Office

MONITOR TYPE: SLAMS

COLLECTION AND ANALYSIS METHOD: (192) Hi-Vol Inductively Coupled PlasmaREPORT FOR: 2011 DURATION:

UNITS:

PQAO: (0810) Ohio EPA, Southwest District Office MIN DETECTABLE:

24 HOUR

Micrograms/cubic meter (LC)

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

 .00367 

 .0032 

 AV

 .00799 

 .00336 

NO.:

MAX:

MEAN:

4

 .0080

 .00456

 .00372 

 .00287 

 .0023 MD

 .00291 

 .00508 

 .0044 

 .00494 

 .00368 

 .00615 

 .00427 

 .00222 

 .00555 

 .00357 

 .00383 

 .00218 MD

 AV

 .00306 

 .00211 MD

 .00484 

 .00219 MD

 .00251 

 .00323 

 .0041 

 .00351 

 .00457 

 .00375 

 .00271 

 .00438 

 .00363 

 .00298 

 .00368 

 .00242 

 .00226 MD

 .00423 

 .00227 

 .00418 

 .00637 

 .00436 

 .00396 

 .00354 

 .00205 MD

 .00395 

 .00294 

 .00399 

 .0265 

 .00276 

 .00727 

 .00224 

 .00209 

 .00355 

 .00216 MD

 .00212 MD

 .00394 

 .00343 

 .00212 MD

 .00293 

5

 .0051

 .00338

5

 .0062

 .00469

5

.00555

.003470

4

.00484

.003050

5

 .0046

 .00358

5

.00438

.003490

6

.00423

.003173

5

.00637

.004056

5

 .0265

 .00803

5

.00727

.003462

5

.00394

.002908

ANNUAL OBSERVATIONS: 59 ANNUAL MEAN: .00398 ANNUAL MAX: .0265

Note: Qualifier codes with regional concurrence are shown in upper case, and those without

 regional review are shown in lower case. An asterisk ("*") indicates that the region

 has reviewed the value and does not concur with the qualifier.

Day JANUARY FEBRUARY MARCH APRIL MAY JUNE JULY AUGUST SEPTEMBER OCTOBER NOVEMBER DECEMBER

MONTH

STATE:
RAW DATA REPORT Aug. 20, 2013

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 8 of 10

(14129) Lead (TSP) LC

(39) Ohio

CAS NUMBER: 7439-92-1

SITE ID: 1 39-091-0006 POC:

AQCR: (177) NORTHWEST OHIO

COUNTY: (091) Logan

CITY: (05130) Bellefontaine

LONGITUDE: -83.7585

LATITUDE: 40.341467

LOCATION SETTING: URBAN AND CENTER CITY

SITE ADDRESS: 320 RICHARD

LAND USE: RESIDENTIAL

SITE COMMENTS: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES

MONITOR COMMENTS:

PROBE HEIGHT: 3

ELEVATION-MSL: 377

(0000) NOT IN AN URBAN AREA UTM NORTHING:

UTM EASTING:

URBANIZED AREA:

UTM ZONE:

SUPPORT AGENCY: (0810) Ohio EPA, Southwest District Office

MONITOR TYPE: SLAMS

COLLECTION AND ANALYSIS METHOD: (192) Hi-Vol Inductively Coupled PlasmaREPORT FOR: 2012 DURATION:

UNITS:

PQAO: (0810) Ohio EPA, Southwest District Office MIN DETECTABLE:

24 HOUR

Micrograms/cubic meter (LC)

.0075

 1

 2

 3

 4

 5

 6

 7

 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

 .00619 

 .00891 MD

 AV

 .00341 

 .00206 MD

NO.:

MAX:

MEAN:

4

.00891

.005143

 .00385 

 .00216 MD

 AG

 AG

 .00218 MD

 .00423 

 AV

 AG

 .00368 

 .00226 

 .00249 

 .00245 

 .00352 

 .00213 MD

 .00208 

 .00264 

 .00705 

 .00437 

 .00422 

 .00613 

 .00272 

 .00314 

 .00585 

 .00428 

 AV

 .0049 

 .00246 MD

 .00257 MD

 .00237 MD

 .00251 MD

 .00284 

 .00486 

 .00261 

 .00442 

 AV

 .004 

 .00312 

 AN

 .0025 MD

 .00259 MD

 .00308 

 .00383 

 .00302 

 .00275 MD

 .00403 

 .00638 

 .00279 

 .00288 

 .00686 

 .00216 MD

 .00416 

 .00221 

 .00274 

 .00368 

 .00607 

 .00396 

3

.00385

.002730

3

.00423

.003390

5

.00352

.002534

5

.00705

.004882

4

.00585

.003998

5

 .0049

 .00296

5

 .005

 .0037

4

 .0031

 .00282

5

.00638

.004002

5

.00686

.003770

5

.00607

.003732

ANNUAL OBSERVATIONS: 53 ANNUAL MEAN: .0037 ANNUAL MAX: .009

Note: Qualifier codes with regional concurrence are shown in upper case, and those without

 regional review are shown in lower case. An asterisk ("*") indicates that the region

 has reviewed the value and does not concur with the qualifier.

Day JANUARY FEBRUARY MARCH APRIL MAY JUNE JULY AUGUST SEPTEMBER OCTOBER NOVEMBER DECEMBER

MONTH

STATE:
RAW DATA REPORT Aug. 20, 2013

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 9 of 10

(14129) Lead (TSP) LC

(39) Ohio

CAS NUMBER: 7439-92-1

SITE ID: 1 39-091-0006 POC:

AQCR: (177) NORTHWEST OHIO

COUNTY: (091) Logan

CITY: (05130) Bellefontaine

LONGITUDE: -83.7585

LATITUDE: 40.341467

LOCATION SETTING: URBAN AND CENTER CITY

SITE ADDRESS: 320 RICHARD

LAND USE: RESIDENTIAL

SITE COMMENTS: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES

MONITOR COMMENTS:

PROBE HEIGHT: 3

ELEVATION-MSL: 377

(0000) NOT IN AN URBAN AREA UTM NORTHING:

UTM EASTING:

URBANIZED AREA:

UTM ZONE:

SUPPORT AGENCY: (0810) Ohio EPA, Southwest District Office

MONITOR TYPE: SLAMS

COLLECTION AND ANALYSIS METHOD: (192) Hi-Vol Inductively Coupled PlasmaREPORT FOR: 2013 DURATION:

UNITS:

PQAO: (0810) Ohio EPA, Southwest District Office MIN DETECTABLE:

24 HOUR

Micrograms/cubic meter (LC)

.0075

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27

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31

 .00221 

 .00371 

 .00352 

 .00217 MD

 .00264 

NO.:

MAX:

MEAN:

5

.00371

.002850

 .00257 

 .00263 

 .00314 

 .00288 

 .00218 MD

 .00421 

 .00217 MD

 .00292 

 .00443 

 .00331 

 .00535 

 .00224 MD

 .00264 

 .00317 

 .00216 MD

 .00269 

 .00223 MD

 .00262 

 .00223 MD

 .00258 

 .00291 MD

 .00453 

 .00373 

 .0031 

 .00262 MD

5

.00314

.002680

5

.00443

.003408

5

.00535

.003112

5

.00269

.002470

5

 .0045

 .00338

0 0 0 0 0 0

ANNUAL OBSERVATIONS: 30 ANNUAL MEAN: .00298 ANNUAL MAX: .0054

Note: Qualifier codes with regional concurrence are shown in upper case, and those without

 regional review are shown in lower case. An asterisk ("*") indicates that the region

 has reviewed the value and does not concur with the qualifier.

Day JANUARY FEBRUARY MARCH APRIL MAY JUNE JULY AUGUST SEPTEMBER OCTOBER NOVEMBER DECEMBER

MONTH

STATE:
RAW DATA REPORT Aug. 20, 2013

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

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QUALIFIER CODES:

Qualifier Code Qualifier Description Qualifier Type

AG

AN

AQ

AV

BB

MD

Sample Time out of Limits

Machine Malfunction

Collection Error

Power Failure

Unable to Reach Site

Value less than MDL

NULL

NULL

NULL

NULL

NULL

QA

Note: Qualifier codes with regional concurrence are shown in upper case,

 and those without regional concurrence are shown in lower case.
Public Notice

Ohio Environmental Protection Agency

Redesignation and Maintenance Plan for the

Partial Logan County, OH Lead Nonattainment Area

Notice is hereby given that the Director of the Ohio Environmental Protection Agency, 

(Ohio EPA) is requesting that the United States Environmental Protection Agency (U.S. 

EPA) revise the current air quality designation for the Partial Logan County 

nonattainment area (Sections 27, 28, 33 and 34 of Lake Township), to attainment with 

respect to the 2008 lead national ambient air quality standard (NAAQS). Air quality 

monitoring data collected between 2010 and 2012 in the area demonstrate attainment 

of the NAAQS and there is evidence that the improved air quality is due to permanent, 

enforceable emission reductions. In addition, existing requirements are sufficient to 

maintain the 2008 lead standard in this area at least ten years into the future.

Ohio EPA’s analysis indicates there are no longer any lead sources within this 

nonattainment area and Ohio has attained and will be able to maintain the NAAQS in 

the future. Therefore, Ohio EPA proposes to utilize existing emission inventory 

information and projections of future emissions as the demonstration of the ability to 

maintain the NAAQS in the partial Logan County area in the future.

The partial Logan County area is currently designated as nonattainment for the 2008

lead standard. As part of an acceptable maintenance plan, Ohio EPA is required to 

develop a contingency plan to provide for additional emission reductions if a violation of 

the NAAQS is monitored after the area has been redesignated. The plan which Ohio 

EPA is proposing to USEPA as part of this redesignation contains reductions which will 

help alleviate the ambient problem until a revised SIP can be developed. 

The State of Ohio proposes to:

1. Request the U.S. EPA redesignate the partial Logan County area to attainment 

with respect to the 2008 lead NAAQS and revise the maintenance plan. This 

request will document that existing enforceable control measures are responsible 

for the observed improvement in air quality.

2. Designate existing controls as sufficient to maintain the NAAQS into the future.

3. Commit to the proposed contingency plan.

These actions must be noticed to allow public comment and to satisfy USEPA 

requirements for public involvement in SIP related activities. This notice addresses Ohio 

EPA’s reliance on the emission projections as evidence of attainment and maintenance 

and the commitment to institute contingency measures if ambient exceedances or 

violations trigger the contingency plan requirements. Written comments will be received 
on or before September 25, 2013 at the following address:

E-mail: jennifer.dines@epa.state.oh.us

Mailing address: Jennifer Dines

Ohio Environmental Protection Agency, DAPC

Lazarus Government Center

P.O. Box 1049

Columbus, Ohio 43216-1049

Pursuant to Section 119.03 of the Ohio Revised Code, a public hearing on this 

redesignation request will be conducted as follows September 25, 2013 at 3:30

PM, at the Knowlton Library, 220 N. Main Street, Bellefontaine, OH 43311.

All interested persons are entitled to attend or be represented at the hearings and give 

written or oral comments on these changes. All oral comments presented at the 

hearing, and all written statements submitted at the hearing or to the above address by 

the close of business on September 25, 2013 will be considered by Ohio EPA prior to 

final action on this redesignation. Written statements submitted after September 25, 

2013 may be considered as time and circumstances permit, but will not be part of the 

official record of the hearing.

This redesignation and maintenance request is available on Ohio EPA DAPC’s Web 

page for electronic downloading at: http://www.epa.ohio.gov/dapc/SIP/annual.aspx.

Questions regarding accessing the web site should be directed to Arunee Niamlarb at 

614-728-1342; other questions or comments about this document should be directed to 

Jennifer Dines at (614) 644-3696, Jennifer.dines@epa.state.oh.us or mailed to Jennifer 

Dines at the above address.
BEFORE THE OHIO EPA

- - -

IN RE: :

:

Division of Air Pollution Control :

Redesignation and Maintenance Plan :

Lead Nonattainment Area - Logan County :

- - -

Audiotaped public hearing before 

Moderator Kristopher Weiss, taken at the Knowlton 

Library, 220 North Main Street, Bellefontaine, 

Ohio, 3:30 p.m. on Wednesday, September 25, 2013.

FRALEY, COOPER & ASSOCIATES

222 East Town Street, Second Floor

Columbus, Ohio 43215-4620

(614) 228-0018 - (614) 852-6163

Fax - (614) 224-5724

- - -
P-R-O-C-E-E-D-I-N-G-S

- - -

MODERATOR WHITE: My name is Kristopher 

Weiss. I'm a public information officer of Ohio 

EPA, and I will preside over today's public 

hearing.

Thank you for taking the time to attend 

this hearing before Ohio EPA. The purpose of the 

hearing is to obtain comments from any interested 

person regarding the Agency's proposed action.

The State of Ohio plans to submit to 

U.S. EPA the lead state implementation plan for 

the partial Logan County, Ohio, nonattainment 

area, Sections 27, 28, 33, and 34 of Lake 

Township. This submittal includes an attainment 

demonstration and identifies the strategies 

deemed necessary to obtain the air quality 

standard by December 31, 2015.

The current demonstration is based on 

air quality data collected in the area between 

2010 and 2012.

Comments can be submitted until the 

close of business today, September 25, 2013. You 

may email comments to 

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jennifer.dines@epa.ohio.gov. All interested 

persons are entitled to attend or be represented 

and to present oral and/or written comments 

concerning the proposed action. All written and 

oral comments received as part of the official 

record will be considered by Director of Ohio EPA 

before a final decision is made.

Written statements submitted after the 

public comment period closes may be considered as 

time and circumstances allow but will not be part 

of the official record of this hearing.

If you wish to present oral testimony at 

the hearing today and have not already signed the 

registration sheet, please do so at this time. 

The sheet is available at the registration table. 

People will be called to testify in the order in 

which they have registered.

There is no cross-examination of 

speakers or of representatives of Ohio EPA in 

public hearings of this type. Ohio EPA hearings 

afford citizens the opportunity to submit 

comments on the official record; therefore, we 

will not be able to answer questions during the 

hearing. However, Ohio EPA staff may ask 

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clarifying questions to ensure the record is as 

complete and accurate as possible

I will now read the names of those who 

have registered at the hearing and give each 

person an opportunity to testify.

And seeing as no one has signed in, we 

will go off the record.

(Break taken until 4:00 p.m.)

MODERATOR WEISS: Okay. We're back on 

the record. Would anybody like to testify at 

this time? (No audible response.)

Seeing no requests for testimony, I 

remind you that written comments can be submitted 

through 5 p.m. today.

The time is now 4:00 p.m., and this 

hearing is adjourned.

(Thereupon, the hearing was concluded at 

4:00 p.m., on September 25, 2013.)

- - -

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C E R T I F I C A T E

- - -

STATE OF OHIO :

 SS:

COUNTY OF FRANKLIN :

I, Jennifer L. Parish, Registered 

Professional Reporter, do hereby certify that the 

foregoing is a true, correct, and complete 

transcription of the above-mentioned audiotaped 

hearing before the Ohio EPA to the best of my 

ability.

DATED this 28th day of October, 2013.

_________________________

JENNIFER L. PARISH, RPR

NOTARY PUBLIC-STATE OF OHIO

My Commission Expires: November 23, 2014.

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