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 b y: Ohio Environmental Protection Agency Division of Air Pollution Control
September 2013Th is page left intentionally blankTABLE 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 assu red

................................ ................................ ................................ .......... 8 Three complete years of data

................................ ................................ ................................ ......... 9 Commitment to continue monitoring

................................ ................................ ............................. 1 0 Chapter Four Emission i nventory

................................ ................................ ................................ ........................ 1 1 Base y ear i nventory

................................ ................................ ................................ ...................... 1 1 Emission p rojections

................................ ................................ ................................ ..................... 1 1 Demonstration of maintenance

................................ ................................ ................................ ..... 12 Permanent and en forceable emissions reductions

................................ ................................ ...... 12 Provisions for fu ture update

................................ ................................ ................................ .......... 13 Chapter Five Con trol measures and regulations

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

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

................................ ................................ .................. 1 4 Emission inventories

................................ ................................ ................................ ..................... 15 Implementation of p ast SIP r evisions

................................ ................................ ........................... 15 New source review provisio ns
................................ ................................ ................................ ..... 15 As surance of continued controls

................................ ................................ ................................ .. 16 Chapter Six Contingency measures

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

................................ ................................ ................................ ........... 17 Commitm ent for contingency measures

................................ ................................ ....................... 17 P otential contingency measures

................................ ................................ ................................ ... 18 List of LEAD , SO 2 , and NO x sourc es
................................ ................................ ............................ 19 Chapter Seven Public participation

................................ ................................ ................................ ........................ 2 0 Chapter Eight Conclusions

................................ ................................ ................................ ................................ ... 21FIGURES

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 DocumentationThis page left intentionally blank

### REDESIGNATION REQUEST AND MAI NTENANCE PLAN FOR

THE PARTIAL LOGAN COUNTY , OH ANNUAL LEAD

NONATTAINMENT AREA
CHAPTER ONE I ntroduction The Clean Air Act (CAA) , as amended, requires each State with areas failing to meet the annual l ead National Ambient Air Quality Standard s (NAAQS) to develop State Implementation Plans (SIPs) to expeditiously attain and maintain the standard s
. T he United States Enviro nmental Protection Agency (U.S. EPA ) revised the NAAQS for l ead on November 12, 2008 (73 FR 66964)

. It replaced the existing annual l ead s tandard of 1.5 micrograms per cubic meter (μg/m 3 ) with a lower annual standard set at 0.15 μg/m 3

. The new lead standard is measured as a rolling three
- month average (not to be exceeded) of the monthly mean concentrations , which i s evaluated over a three
- ye ar period

. On November 22, 2010, U.S. EPA promulgated the initial lead nonattainment areas designations for the l ead standard , which became effective on December 31, 2010

. Section 191 of the CAA Amendments require states with l ead nonattainment areas to s ubmit a plan within eighteen months of the effective date of the designations ( November 2 2, 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 de monstration 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 formal ly 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 sat isfies that requirement. Section 107(d)(3)(E) of the CAA allows states to request nonattainment areas to be redesignated to attainment provid ed certain criteria are met. The following are the criteria that must be met in order for an area to be redesignat ed from nonattainment to attainment: i) A determination that the area has attained the l ead standard. ii) An approved State Implementation Plan (SIP) for the area under Sectio n 110(k ). iii) A determination that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting2 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 p o rtion of the city of Bellefontaine and an area surrounding the violating monitor located near the facility Daido 1

. This area is shown in Figure 1 under Chapter Three. Daido was a producer of bearing sleeves for the automo tive industry

. In June of 2009, the Daido facility permanently shut down all lead operations

. T his document is intended to support Ohio’s request that the partial Loga n County nonattainment area be redesignated from nona ttainment to attainment for the an nual lead s tandard

. Status of Air Quality Lead complete quality
- assured ambient air quality monitoring data for the m ost recent three (3) years, 20 10 through 2012 , demonstrate that the air quality has m et the NAAQS for the annual lead standard in this no nattainment area. The NAAQS attainment, accompanied by decreases in emission lev els discussed in Chapter Four, supports a redesignation to attainment for the partial Loga n 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 Township3



### C HAPTER 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 g uidance ), issued September 4, 1992 , to Regional Air Director s. The redesignation request and maintenance plan are based on the redesignation g uidance, supplemented with additional guidance re ceived from staff of U.S. EPA Region 5

. Below is a summary of each redesignation criterion as it applies to the partial Loga n 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 b e 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 t he public for review. The second component relies upon supplemental U.S. EPA

approved air quality modeling. While no modeling is required for redesignating nonattainment areas, the redesignation guidance states it is “generally necessary” for lead redesi gnations 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 enforce able 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 ar e 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 measur es 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 purpos es 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 designa ted 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 T itle 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 prog ram to regulate the modification and construction of any stationary source within the areas covered by the plan; include provisions for the implementation of P art C, p revention of s ignificant d eterioration (PSD) and P art D, NSR permit programs; include cri teria for stationary source emission control measures, mon itoring, 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, 20 11 infrastructure SIP submission, Ohio verified that the S tate 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 nonattai nment 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 major5 programs related to the interstate transport of pollution. OAC Chapters 374 5
- 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 re gulated 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) f or 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 decr ease with the distance from a l ead 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 t o 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 wit h 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

i i i.) 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 redesigna tion 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 c onformity 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]. i v.) Main tenance 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 revi sion and must provide for maintenance of the relevant NAAQS in the area for at least 10 years a fter 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) verifi ca tion 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 measuri ng lead concentrations in this no nattainm ent area. The monitor is operated by Ohio EPA Division of Air Pollution Control, Northwest District Offic e
. A listing of the design value s f rom 20 10 through 201 2 are shown in Table 1. The location of the monitoring site for this nonattainment area is shown on Figure 1

.8

D emonstration 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) data base, 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. R equirement 3 of 4 I n accordance with 40 CFR Part 50, Appendix R, the lead NAAQS is met at a mo nitoring site when the identified design value is valid and less than or equal to 0.15 μg/m 3 . A lead design value that meets the NAAQS ( i.e. , 0.15 μg/m 3 or less), is considered valid if it encompasses 3 6 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 effect ive but before January 15, 2010, lead design value s that meets the NAAQS will be considered valid if it encompasses at least 34 cons ecutive 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 mo nitoring 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. D emonstration Table 1 - Monitoring d ata for the partial Logan County , OH A rea

for 2010
– 2012

Site Location City 3 - month period (unless noted) Three - month rolling average

(ug/m 3 )

2010 2011 201 2 2013 39 - 091 - 0006 Richard Ave.
– Daido Facility Bellefontaine Jan Only 0.005 0.004 0.00 4 0.00 3 Feb Only 0.00 4 0.003 0.00 3 0.002 Jan
- Mar 0.006 0.00 3 0.00 3 0.00 2 Feb
- Apr 0.006 0.003 0.00 3 0.002 Mar
- May 0.005 0.003 0.00 3 0.002 Apr
- Jun 0.004 0.003 0.00 3 May
- July 0.00 3 0.003 0.00 4 Jun
- Aug 0.00 3 0.003 0.003 July
- Sept 0.00 4 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 data
completeness requirements are met. There is incomplete data for the 3

- month means for January to March 2012 and February to April 2012 p eriods. 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 missed10

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

- month mean pe riods 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 ana lysis was detailed in Ohio EPA’s April 19, 2013 clean data request. The design values calculated for the partial Loga n County area demonstrate that the annual lead NAAQS has been attained. The area's design values have remained consistently low since th e permanent shutdown of the Daido facility

. Requirement 4 of 4 A commitmen t that once redesignated, the s tate will continue to operate an appropriate monitoring network to verify the maintenance of the attainment status. Demonstration Ohio EPA commit s to continue moni toring 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 conti nue to quality assure the monitoring data to meet the requirements of 40 CF R 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 S ection 107(d)(3)(E)(iii) U.S. EPA’s redesignation g uidance 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 demonstr ate 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 invent ory 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 trackin g of emis sion 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 nonattainmen t. 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 Nationa l Emissions Inventory (NE I) reporting program. The period coincides with nonattainment air quality in the partial Loga n 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 Loga n 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 prepare d a comprehensive future year inventory for the partial Logan County area. See Requirement 3 of 5 under Requirement Three of th is 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 re quest. 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. Demonstra tion Table 2
– Partial Logan County , O H Lead Emission Inventory Totals for Base Year 2005 , Attainment Year 20 10 , and Projected 2015 and 202 5 (tpy) Source 200 5

Base 20 10

Attainment 2015

Interim 202 5

Maintenance Safety

Margin Daido 0.0035 0 0 0 0 TOTAL 0.0035 0 0 0 0

As shown in the table above (T able 2 ), lead emissions in the nonattainment a rea are projected to decrease to zero tpy by 2025 due to the permanent shutdown of Daido in June 2009

. Furthermore, the 2008 NEI 2 shows 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=113

conditions or unusually favorable meteorology. Background Ambient air quality data from all monitoring sites indicate that air quality met the NA AQS for lead in 20 10
- 201 2

. U.S. EPA’s redesignation g uidance (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 inv entory, 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 attain ment 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.
Requ irement 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 a ir 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. Th is lead inventories will be prepared for future years as n ecessary to comply with the inventory reporting req uirements established in the CFR

. Emissions information will be compared to the 2005 base year and the 202 5 projected maintenance year inventor y to assess emission trends, as necessary, and to assure cont inued 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 appropria te 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 bee n 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 nonattainm ent 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 2 009, 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, inc luding 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 u sed 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 upda tes 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 (Requiremen t 4), Ohio EPA submits, and commits to submit, emission inventories (statements) every three years. Requirement 4 of 6 Evidence that control measures required in pas t lead SIP revisions have been fully implemented. D emonstration There are no past contro l 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. Thi s is addressed in OAC Chapter 3745

- 31 3 . 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 conditi onally approved on October 10, 2001 (66 FR 51570 ) and received final

3 http://www.epa.ohio.gov/dapc/regs/3745_31.aspx16

approv al on January 22, 2003 (68FR 2909 ) by U.S. EPA as part of the SIP

. Demonstration Any facility that is not listed in the 200 5 emission inventory, or for the closing of which credit was taken in demonstrating attainment, will not be allowed to construct, r eopen, modify, or reconstruct without meeting all applicable NSR requirement s . 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 r edesignation unless the State demonstrates through modeling that the standard can be maintained without one or more control measure s. Demonstration O hio commits to maintaining the existing control measures after redesignation. Ohio, through Ohio EPA’s L egal 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 Coun ty 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 p lan eight years after redesi gnation, 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 vio lations 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 r esponse shall be prompted whenever a l ead 3
- month rolling average concentration of 0.1 3 5 μg/m 3 occurs within the maintenance area. A warning level r esponse will consist of a study to determine whether the lead value indicates a trend toward higher lead values. The study will evaluate whether t he 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 neces sary controls in resp onse to a warning level r esponse 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. Shoul d it be determined through the warning l evel study that action is nec essary to reverse the noted trend, the procedures for control selection and implementation outlined under “action l evel response” shall be followed. Action Level Response : An action level response shall be prompted whenever a two
- year average of the 3
- mon th rolling average concentration of 0.1 43 μg/m 3 or greater occurs within the maintenance area. A violation of the standard ( any 3
- month rolling average over a 36
- month18

rolling average period (3

- calend a r years plus the preceding 2 months) exceeds 0.15 μg/m 3 ) 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 o f 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. T his 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 S t ate 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 ade quate 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 th e 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 ot her 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 requirement s. Demonstration Ohio EPA does not expect any future lead sources in this area. As discussed elsewhere in this document, any new source plan ning 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 publi c comment concerning the draft redes ignation 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 an d complied with the applicable provisions of the 1990 Amendments to the CAA regarding redesignations of lead nonattainment areas. Documentation to that effect is contained herein. Ohio EPA has prepa red a redesignation request and maintenance p lan that me et the requirement s of Section 110 (a)(1) of the 1990 CAA

. Based on this presentation, the partial Logan County annual lead nonattainment area meets the requirements for redesignation under the CAA and U.S. EPA guidance. Ohio has performed an analysis t hat 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 a n increasing margin of safety. The State of O hio hereby requests that the partial Logan County annual lead nonattainment area be redesignated to attainment simultaneously with U.S. EPA approval of the maintenance p lan provisions contained herein.Th is page left intentionally blankUNITED STATES ENVIRONMENTAL PROTECTION AGENCY

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

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 2013 01 01 06 30 Tribal Code

APPLICABLE STANDARDS Standard DescriptionAug. 20, 2013 RAW DATA REPORT UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 1 of 10 (14128) Lead (TSP) LC Non-FRM/FEM
(39) Ohio 7439-92-1 CAS NUMBER: 39-091-0006 SITE ID: 1 POC: (177) NORTHWEST OHIO AQCR: (091) Logan COUNTY: (05130) Bellefontaine CITY: -83.7585 LONGITUDE: 40.341467 LATITUDE:

URBAN AND CENTER CITY LOCATION SETTING: 320 RICHARD SITE ADDRESS: RESIDENTIAL LAND USE: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES SITE COMMENTS: MONITOR COMMENTS: 3 PROBE HEIGHT: 377 ELEVATION-MSL: UTM NORTHING: (0000) NOT IN AN URBAN AREA 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 COMPOSITE OF 24-HOUR SAMPLES MONTHLY 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:Aug. 20, 2013 RAW DATA REPORT UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 2 of 10 (14128) Lead (TSP) LC Non-FRM/FEM
(39) Ohio 7439-92-1 CAS NUMBER: 39-091-0006 SITE ID: 3 POC: (177) NORTHWEST OHIO AQCR: (091) Logan COUNTY: (05130) Bellefontaine CITY: -83.7585 LONGITUDE: 40.341467 LATITUDE:

URBAN AND CENTER CITY LOCATION SETTING: 320 RICHARD SITE ADDRESS: RESIDENTIAL LAND USE: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES SITE COMMENTS: MONITOR COMMENTS: 3 PROBE HEIGHT: 377 ELEVATION-MSL: UTM NORTHING: (0000) NOT IN AN URBAN AREA 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 COMPOSITE OF 24-HOUR SAMPLES MONTHLY 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:Aug. 20, 2013 RAW DATA REPORT UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 3 of 10 (14128) Lead (TSP) LC Non-FRM/FEM
(39) Ohio 7439-92-1 CAS NUMBER: 39-091-0006 SITE ID: 3 POC: (177) NORTHWEST OHIO AQCR: (091) Logan COUNTY: (05130) Bellefontaine CITY: -83.7585 LONGITUDE: 40.341467 LATITUDE:

URBAN AND CENTER CITY LOCATION SETTING: 320 RICHARD SITE ADDRESS: RESIDENTIAL LAND USE: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES SITE COMMENTS: MONITOR COMMENTS: 3 PROBE HEIGHT: 377 ELEVATION-MSL: UTM NORTHING: (0000) NOT IN AN URBAN AREA 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 COMPOSITE OF 24-HOUR SAMPLES MONTHLY 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:Aug. 20, 2013 RAW DATA REPORT UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 4 of 10 (14128) Lead (TSP) LC Non-FRM/FEM
(39) Ohio 7439-92-1 CAS NUMBER: 39-091-0006 SITE ID: 3 POC: (177) NORTHWEST OHIO AQCR: (091) Logan COUNTY: (05130) Bellefontaine CITY: -83.7585 LONGITUDE: 40.341467 LATITUDE:

URBAN AND CENTER CITY LOCATION SETTING: 320 RICHARD SITE ADDRESS: RESIDENTIAL LAND USE: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES SITE COMMENTS: MONITOR COMMENTS: 3 PROBE HEIGHT: 377 ELEVATION-MSL: UTM NORTHING: (0000) NOT IN AN URBAN AREA 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 COMPOSITE OF 24-HOUR SAMPLES MONTHLY 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:Aug. 20, 2013 RAW DATA REPORT UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 5 of 10 (14129) Lead (TSP) LC
(39) Ohio 7439-92-1 CAS NUMBER: 39-091-0006 SITE ID: 1 POC: (177) NORTHWEST OHIO AQCR: (091) Logan COUNTY: (05130) Bellefontaine CITY: -83.7585 LONGITUDE: 40.341467 LATITUDE:

URBAN AND CENTER CITY LOCATION SETTING: 320 RICHARD SITE ADDRESS: RESIDENTIAL LAND USE: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES SITE COMMENTS: MONITOR COMMENTS: 3 PROBE HEIGHT: 377 ELEVATION-MSL: UTM NORTHING: (0000) NOT IN AN URBAN AREA 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 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:Aug. 20, 2013 RAW DATA REPORT UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 6 of 10 (14129) Lead (TSP) LC
(39) Ohio 7439-92-1 CAS NUMBER: 39-091-0006 SITE ID: 1 POC: (177) NORTHWEST OHIO AQCR: (091) Logan COUNTY: (05130) Bellefontaine CITY: -83.7585 LONGITUDE: 40.341467 LATITUDE:

URBAN AND CENTER CITY LOCATION SETTING: 320 RICHARD SITE ADDRESS: RESIDENTIAL LAND USE: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES SITE COMMENTS: MONITOR COMMENTS: 3 PROBE HEIGHT: 377 ELEVATION-MSL: UTM NORTHING: (0000) NOT IN AN URBAN AREA UTM EASTING: URBANIZED AREA: UTM ZONE:

SUPPORT AGENCY: (0810) Ohio EPA, Southwest District Office MONITOR TYPE: SLAMSCOLLECTION AND ANALYSIS METHOD: (192) Hi-Vol Inductively Coupled PlasmaREPORT FOR: 2010 DURATION: UNITS: MIN DETECTABLE: PQAO: (0810) Ohio EPA, Southwest District Office 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:Aug. 20, 2013 RAW DATA REPORT UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 7 of 10 (14129) Lead (TSP) LC
(39) Ohio 7439-92-1 CAS NUMBER: 39-091-0006 SITE ID: 1 POC: (177) NORTHWEST OHIO AQCR: (091) Logan COUNTY: (05130) Bellefontaine CITY: -83.7585 LONGITUDE: 40.341467 LATITUDE:

URBAN AND CENTER CITY LOCATION SETTING: 320 RICHARD SITE ADDRESS: RESIDENTIAL LAND USE: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES SITE COMMENTS: MONITOR COMMENTS: 3 PROBE HEIGHT: 377 ELEVATION-MSL: UTM NORTHING: (0000) NOT IN AN URBAN AREA UTM EASTING: URBANIZED AREA: UTM ZONE:

SUPPORT AGENCY: (0810) Ohio EPA, Southwest District Office MONITOR TYPE: SLAMSCOLLECTION AND ANALYSIS METHOD: (192) Hi-Vol Inductively Coupled PlasmaREPORT FOR: 2011 DURATION: UNITS: MIN DETECTABLE: PQAO: (0810) Ohio EPA, Southwest District Office 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:Aug. 20, 2013 RAW DATA REPORT UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 8 of 10 (14129) Lead (TSP) LC
(39) Ohio 7439-92-1 CAS NUMBER: 39-091-0006 SITE ID: 1 POC: (177) NORTHWEST OHIO AQCR: (091) Logan COUNTY: (05130) Bellefontaine CITY: -83.7585 LONGITUDE: 40.341467 LATITUDE:

URBAN AND CENTER CITY LOCATION SETTING: 320 RICHARD SITE ADDRESS: RESIDENTIAL LAND USE: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES SITE COMMENTS: MONITOR COMMENTS: 3 PROBE HEIGHT: 377 ELEVATION-MSL: UTM NORTHING: (0000) NOT IN AN URBAN AREA UTM EASTING: URBANIZED AREA: UTM ZONE:

SUPPORT AGENCY: (0810) Ohio EPA, Southwest District Office MONITOR TYPE: SLAMSCOLLECTION AND ANALYSIS METHOD: (192) Hi-Vol Inductively Coupled PlasmaREPORT FOR: 2012 DURATION: UNITS: MIN DETECTABLE: PQAO: (0810) Ohio EPA, Southwest District Office 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:Aug. 20, 2013 RAW DATA REPORT UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 9 of 10 (14129) Lead (TSP) LC
(39) Ohio 7439-92-1 CAS NUMBER: 39-091-0006 SITE ID: 1 POC: (177) NORTHWEST OHIO AQCR: (091) Logan COUNTY: (05130) Bellefontaine CITY: -83.7585 LONGITUDE: 40.341467 LATITUDE:

URBAN AND CENTER CITY LOCATION SETTING: 320 RICHARD SITE ADDRESS: RESIDENTIAL LAND USE: MONITORS LEAD EMISSIONS FROM FORMER GLACIER DAIDO INDUSTRIES SITE COMMENTS: MONITOR COMMENTS: 3 PROBE HEIGHT: 377 ELEVATION-MSL: UTM NORTHING: (0000) NOT IN AN URBAN AREA UTM EASTING: URBANIZED AREA: UTM ZONE:

SUPPORT AGENCY: (0810) Ohio EPA, Southwest District Office MONITOR TYPE: SLAMSCOLLECTION AND ANALYSIS METHOD: (192) Hi-Vol Inductively Coupled PlasmaREPORT FOR: 2013 DURATION: UNITS: MIN DETECTABLE: PQAO: (0810) Ohio EPA, Southwest District Office 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 .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:Aug. 20, 2013 RAW DATA REPORT UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

Page 10 of 10 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 Enviro nmental Protection Agency Redesignati on and Maintenance Plan for the Partial Logan County , OH Lead Nona ttainment Area
Notice is hereby given that the Director of the Ohio Environmental Protection Agency, (Oh io 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 20 10 and 201 2 in the area demonstrate attainment of the NAAQS and there is evidence that the improved air quality is due to permanent, e nforceable em ission 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 par tial 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 additiona l 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 revis ed 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 an d revise the maintenance plan. This request will document that existing enforceabl e 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 comme nt and to satisfy USEPA requirements for public involvem ent in SIP related activities. This notice addresses Ohio EPA’s reliance on the emission project ion s as evidence of attainment and maintenance and the commitment to institute contingency measures if a mbient exceedances or violations trigger the contingency plan requirements. Written comments will be receivedon or before September 25, 2013 at the following address:

E
- mail: jennifer.dines@epa.state.o h.us Mailing address: Jennifer Dines

Ohio Environmental Protection Agency, DAPC Lazarus Government Center P.O. Box 1049 Columbu s, 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 state ments 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 dow nloading 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 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24jennifer.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 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24clarifying 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.)

- - - 4

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24**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. 5

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