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Technical Support Do cument

Definition of important t erms used in this document:

1) Designated “unclassifiable”

– an area where EPA could not determine if there was a

violation of the 2008 Lead national ambient air quality standard ( NAAQS ) or a contribution to a

violation in a nearby area, because t here was insufficient air quality data for both 2006

- 2008 and

2007

- 2009 and where additional monitoring data for 2010 could not result in a different designation

.

2) Designated “attainment”

– an area which EPA has determined

, base d on the most recent 3

years of certified air quality data from 2006

- 2008 or 2007

- 2009

, has no violations of the 2008 Lead NAAQS during 36 consecutive valid 3

- month site means ; and which EPA has further

determine d does not contribute to a violation of the 2008 Lead NAAQS in a nearby area and that additional monitoring data from 2010 could not result in a different designation

.

3 ) Designated nonattainment area

– an area which EPA has determined

, based on a State

recommendation and/ or on the technical analys is included in this document

, has a violation of

the 2008 Lead NAAQS during the most recent three consecutive years of quality

- assured, certified air quality data.

4 ) Prior nonattainment area

– an area that is currently designated as nonattainment or

ma intenance for the 1978 Lead NAAQS (including both current nonattainment areas and maintenance areas).

5 ) Recommended nonattainment area

– an area a State or Tribe has recommended to EPA be designated as nonattainment

.

6 ) Violating monitor

– an ambient ai r monitor whose design value exceed s 0.15 micrograms per cubic meter ( μ g/m 3 )

. As described in Appendix R of part 50, a violation can be based on either

lead

- total suspended particles ( Pb

- TSP ) or Pb

- PM 10 data and only three months of data are

necessary to produce a valid violating design value.

7 ) 19 78 Lead NAAQS

– 1

. 5 μg/m 3

, N ational Ambient Air Quality Standard for Lead promulgated in 1978. Based on Pb

- TSP indicator and averaged over a calendar quarter.

8 ) 2008 Lead NAAQS

- 0. 1 5 μg/m 3

, National Ambien t Air Quality Standard for Lead promulgated in 2008

. Based on Pb

- TSP indicator and a three

- month rolling average. Pb

- PM 10 data may be used in limited instances

, including to show nonattainment.2 Florida Area Designations For the

2008 Lead National Ambient Air Quality Standard s EPA has revised the level of the primary (health

- based) standard from 1.5 micrograms per cubic meter (μg/m3) to 0.15 μg/m3 measured as total suspended particles (TSP). EPA has revised the secondary (welfare

- based) standard t o be identical in all respects to the primary standard

.

Pursuant to section 107(d) of the Clean Air Act, EPA must designate as “ nonattainment ”

those areas that violate the national ambient air quality standard ( NAAQS ) and those nearby areas that contribut e to violations. The table below identifies the counties or portions

of counties (or tribal areas) in Florida that EPA i s designat ing “nonattainment” for the 200 8 l ead national ambient air quality standard (2008 Lead NAAQS)

.

Table 1 : Area Designation

Area Florida Recommended

Nonattainment

Counties EPA’s Designated

Nonattainment

Counties Nonattainment

area for 19 78 Lead NAAQS Tampa, Florida None 1 Hillsborough (partial) No (Unclassifiable)

Technical analysis for Tampa, Florida

Introduction

Th is t echnical analysis for the Tampa Area identifies the partial county with two monitor s that

violate the 2008 Lead NAAQS and evaluates nearby counties (if appropriate) for contributions to

l ead concentrations in the area. EPA has evaluated these areas based on the weight of evidence of the following factors recommended in previous EPA guidance :

Air quality in potentially included versus excluded areas ; Emissions and emissions

- related data in areas potentially included versus excluded from

the nonattainment area , including population data

, growth rates and patterns and emissions controls; Meteorology (weather/transport patter n s) ; Geography/topography (mountain ranges or other air basin boundaries) ; Jurisdictional boundaries (e.g., counties, air districts, re servations, etc.) ; and Any other relevant information submitted to or collected by EPA (e.g., modeling where done appropriately)

.

1 In a letter dated October 15, 2009, the State of Florida recommended an area that is encompassed within a radius of five kilometers (km) centered at the Universal Transverse Mercator (U TM) coordinates 364.0 East and 3093.5 North, Zone 17, in Hillsborough County, be designated “unclassifiable” for the 2008 Lead NAAQS. Florida reiterated this recommendation in a letter to EPA dated May 4, 2010. In a letter dated August 16, 2010, Florida

s tated, “ While we still feel that a designation of nonattainment is not necessary, we appreciate EPA upholding our request to shrink the boundary of the affected area from a 5 kilometer (km) radius to a 1.5 km radius surrounding the EnviroFocus Technologies facility. ”3

Figure 1 : Hillsborough County Area of Tampa, Florida

Figure 2: Tampa, Florida Area and Sur rounding Counties

Figure s 1 and 2 are map s of the area analyzed showing the location and design value of the air quality monitor s in the area, the counties surrounding the violating air quality monitor s , and4

Florida’s recommended boundary for an “unc lassifiable” designation

. The violating monitor s in

the Tampa Area are located in Hillsborough County in close proximity to EnviroFocus Technologies (formerly Gulf Coast Recycling) , shown in Figure 1

.

For this area, EPA previously established l ead unclas sifiable boundaries for the 19 78 Lead NAAQS that included Hillsborough County located in Florida. For each revision to a NAAQS EPA is required to conduct a separate designation action, which may result in the same or a different nonattainment boundary.

O n October 15, 2009

, Florida recommended that the previous five kilometer (km) area in Hillsborough County that was designated “unclassifiable” remain designated as “ un classifiable,”

and the remain der of the State be designated as “attainment,” for the 2008 Lead NAAQS b ased on air quality data from 2006

- 2008

. This area is located within a radius of five km centered at

the Universal Transverse Mercator (UTM) coordinates 364.0 East (E) and 3093.5 North (N)

, Zone 17, in Hillsborough County. The ir recommendati on was based on data from Federal

Reference Method monitors located in the S tate

, as well as the previous “unclassifiable” designation. Subsequently, on May 4, 2010 , Florida rei t e rated their recommendation for Hillsborough County to be designated as uncla ssifiable within a radius of five km centered at the UTM coordinates 364.0 East and 3093.5 North, Zone 17, fully including the EnviroFocus Technologies facility. In a letter dated August 16, 2010, Florida stated, “ While we still feel that a designation of nonattainment is not necessary, we appreciate EPA upholding our request to shrink the boundary of the affected area from a 5 kilometer (km) radius to a 1.5 km radius surrounding the EnviroFocus Technologies facility. ”

Based on EPA's technical analysis de scribed below, EPA is designat ing the entire portion of Hillsborough County

, Florida , located within a radius of 1.5 km centered at the UTM coordinates

364104 meters East

, 3093 830 meters North, Zone 17, fully including the EnviroFocus Technologies facility

, a s nonattainment for the 2008 Lead NAAQS as the Tampa nonattainment

area
, based upon currently available information

. This county is listed above in Table 1

.

Detailed Assessment

Air Q uality D ata

This factor considers the l ead design values (in μg/m 3 ) for air quality monitors in Hillsborough County in the Tampa Area, and the surrounding area based on data for the 200 7

- 200 9 period. A monitor’s design value indicates whether that monitor attains a specified air quality standard.

The 2008 Lead NAAQS are met at a monitoring site when the identified design value is valid and less than or equal to 0.15 μg/m 3

. A design value is only valid if minimum data completeness

criteria are met. A l ead design value that meets the NAAQS is generally considered valid i f it encompasses 36 consecutive valid 3

- month site means (specifically for a 3

- year calendar period and the two previous months)

. For this purpose, a 3

- month site mean is valid if valid data were obtained for at least 75 percent of the scheduled monitorin g days in the 3

- month period. A l ead design value that does not meet the NAAQS is considered valid if at least one 3

- month mean that

meets the same 75 percent requirement is above the NAAQS. That is , a site does not have to

monitor for three full calenda r years in order to have a valid violating design value; a site could monitor just three months and still produce a valid (violating) design value

.5

The 2008 Lead NAAQS design values for Hillsborough County in the Tampa Area are shown in

Table 2

.

Table 2 : Air Quality Data
County State

Recommended

Nonattainment Monitor

Na me Monitor Air Quality

System ID Monitor

Location Lead Design

Value,

2006

- 2008 (μg/m 3 ) Lead Design

Value,

2007

- 2009 (μg/m 3 ) Hillsborough County,

Florida No 2 120571073 6811 E. 1 4 th

Avenue 0.74 0.74

120571066 1700 North

66th Street 1.77 1.77

Monitors in bold have the highest design value.

Hillsborough County shows two monitor s violating the 2008 Lead NAAQS

. Therefore some area in this county and possibly additional areas i n surrounding counties must be designated

nonattainment

. However, the absence of a violating monitor alone is not a sufficient reason to
eliminate nearby counties as candidates for nonattainment status. E ach area has been evaluated based on the weight of evidence of the eight factors and other relevant information.

The violating monitor s located in Hillsborough County are both located within 480 m eters of the large s t l ead emissions source in the county, EnviroFocus Technologies, 1901 North 66 th Street,

i n Tampa, Florida. The monitoring objective, according to the EPA monitor locator, is source

oriented. The emissions from Enviro Focus Technologies will be discussed in the corresponding

section below.

Emissions and Emissions

- Related Data

Evidence of l ea d emissions sources surrounding a violating monitor are an important factor for determining whether a nearby area is contributing to a monitored violation. For this factor, EPA evaluated county level emission data for l ead and population data

.

Emissions

Emissions data were generally derived from the 2005 National Emissions Inventory (NEI),

version 2 , which is the most up

- to

- date version of the national inventory available when these data were compiled for the designations process in 2009. See http://www.epa.gov/ttnchie1/net/2005inventory.html

. EPA recognize s that for certain counties, emissions may have changed since 2005. For example, certain large sources of emissions in or

near this area may have installed emission controls or otherwise significantly reduced emissions

since 2005.

2 In a letter dated October 15, 2009, the State of Florida recommended an area that is encompassed within a radius of five km centered at the UTM coordinates 364.0 East and 3093.5 North, Zone 17, in Hillsborough County, be designated “unclassi fiable” for the 2008 Lead NAAQS. Florida reiterated this recommendation in a letter to EPA dated May 4, 2010. In a letter dated August 16, 2010, Florida stated, “ While we still feel that a designation of nonattainment is not necessary, we appreciate EPA upholding our request to shrink the boundary of the affected area from a 5 kilometer (km) radius to a 1.5 km radius surrounding the EnviroFocus Technologies facility. ”6

Some States provided updated information on emissions and emission controls in their comments

to EPA

. Florida provided a preliminary determination prepared for EnviroFocus Technologies dated August 2009

, which i ncluded some emission estimates; however, the source of these

estimates w as not documented or referenced by Florida

. As discussed below, emissions levels at the EnviroFocus Technologies facility are c urrently in flux as major construction projects are underway. Florida also provided updated emissions information via email for the City of Tampa

W astewater T reatment P lant , noting that actual l ead emissions from that site were less than 100 pounds in 200 5

.

Table 3 shows total emissions of l ead (given in tons per year (tpy) ) for violating counties and potentially contributing facilities in and around the Tampa Area i n clu d ing s ources emitting (or anticipate to contribute) greater than 0. 1 tpy of l ead accord ing to the 2005 NEI data. There are approximately 20,000 airport facilities in the U.S. at which leaded aviation gasoline is consumed. To evaluate the potential impact of emissions at and near these facilities, EPA recommends th at

s tates use the draft 20 08 NEI. Data for airport facilities in Hillsborough County which use leaded aviation gasoline are included in Table 4.

Table 3 : Lead Emissions for all Non

- Airport Lead Emitting Sources in Hillsborough County
County Facility in State

Recommended

Nonatta inment

Area? Facility Name Facility Location 2005 NEI (tpy)

Hillsborough County, FL No* EnviroFocus Technologies 1901 N 66 th St, Tampa 1.3

No Tampa Electric Company 3602 Port Sutton Road, Tampa 0.1

No Tampa Electric Company 13031 Wyandotte Road, Apo llo Beach 0.1

No Coronet Industries Inc 4082 Coronet Road, Plant City 0.3

* Originally i n a letter dated October 15, 2009, the State of Florida recommended an area that is encompassed within a radius of five km centered at the UTM coordinates 364.0 East and 3093.5 North, Zone 17, in Hillsborough County, be designated “unclassifiable” for the 2008 Lead NAAQS. This facility falls within that state

- recommended boundary.

According to the available data, Hillsborough County has f our sources emitting at or a bove 0.1
tpy . The greatest emitter of l ead in the County is EnviroFocus Technologies. The other sources in the Tampa A

rea are not expected to contribute to the violations recorded at the air quality

monitors , and will be discussed further in the discussi on on air quality modeling

. The two Tampa Electric Company facilities are approximately 7 km and 18 km away, respectively. Coronet Industries formerly manufactured defluorinated phosphate, but ceased operation in

March 2004. Current work on site include s clean

- up activities associated with the decommission and shutdown of operations. The Coronet site is approximately 30 km away from the violating

monitors

.

EnviroFocus Technologies is the current owner and operator of the former Gulf Coast Recycling

f acility. EnviroFocus Technologies obtained a prevention of significant deterioration (PSD) permit from the State on September 22, 2009, to construct upgrades to the existing battery recycling facility, including enclosing the entire process area, paving a nd/or removal of7

contaminated soil, and increasing the production capacity of the facility. The battery recycling operation is continuing while construction activity is ongoing. The State of Florida provided the following detailed construction schedule f rom EnviroFocus Technologies. Full facility enclosure is on schedule to be completed by October 2010 , while all paving will be completed by March

2012

.

EnviroFocus Construction Milestones

Start Finish

Phase 1A This phase will replace the existing b attery breaking, water treatment plant, afterburner, containment room, baghouses, torit systems as well as add the new Reverb furnace, dryer, 2

- holding kettles and various site improvements. The two systems will run concurrently while the new

systems are s tarted up and tested.

Tilt up walls 7/6/2010 9/16/2010 Roofing 8/11/2010 10/15/2010

Acid mist scrubber 9/16/2010 12/20/2010 Baghouses 10/28/2010 12/13/2010

Torits 10/28/2010 12/17/2010 Hygiene Stack 10/28/2010 12/17/2010

SO2 Scrubber 10/28/2010 12/1 3/2010

Process Stack 10/28/2010 12/20/2010

Afterburner 8/31/2010 11/29/2010

Reverb Furnace 10/14/2010 11/29/2010 Dryer system 10/14/2010 12/15/2010 Holding Kettles 10/14/2010 12/30/2010

Launch Phase 1A 1/20/2011 2/16/2011

Phase 1B This phase will include the blast furnace improvements, installation of 4 refining kettles. The blast and kettles will be linked to the new baghouses and torit systems.

Tilt up walls 3/15/2011 4/25/2011 Roofing 4/13/2011 5/20/2011

Blast Furnace 5/5/2011 5/24/2011 Refining Kettles (4) 5/11/2011 5/26/2011

Launch Phase 1B 8/16/2011 8/29/20118

Phase 1C This phase will include the final 2 refining kettles, l ead lab and control

rooms. Tilt up walls 10/19/2011 10/25/2011

Roofing 11/16/2011 1/19/2012

Refinin g Kettles (2) 12/1/2011 12/20/2011

Launch Phase 1C 2/10/2012 3/23/2012

Phase 2 This phase will include the build out of the finished goods, spare parts, maintenance, mobile equipment and material transfer room structures.

Tilt up walls 11/10/201 1 12/15/2011 Roofing 12/16/2011 3/2/2012

Launch Phase 2 3/12/2012 3/23/2012

Additionally, Florida provided the following photographic documentation of the ongoing

construction activities at EnviroFocus:9

Although this schedul e is not approved in any enforceable permit or rule, it is instructive in helping to define the appropriate boundary for the Tampa A rea. All of the activities included in this schedule will take place on E n viroFocus Technologies facility

.

Table 4: Airp ort Facilities Using Leaded Aviation Gas in Hillsborough County

C ity Facility Name Type 2008 draft NEI (tpy) Distance to Violating

Monitor (k

ilo m eters ) Tampa Vandenburg Airport 0.2 7 6. 69 Tampa Peter O’Knight Airport 0.14 8.5 2 Tampa Tampa

International Airport Airport 0.22 15.02

Plant City Plant City Airport Airport 0.1 2 21.6910

T here are f

o ur airport facilit ies with emissions greater than 0.1 tpy . The nearest such airport is more than 6.5 km from the nearest violating monitor, and all of these airport s are located beyond

the 5 km boundary that Florida recommend ed for an “unclassifiable” designation

. The State has not provided analyses (such as air quality modeling) to examine the potential impact of lead emissions at these airports on the violating mo nitor. EPA's modeling suggests emissions from piston

- engine aircraft operating out of Vandenburg and Peter O'Knight airports contribute less

than 1 percent of lead concentrations measured at the violating monitor.

Population Data

Table 5 shows the 200 8 population for each county in the area that was evaluated, as well as the population density for each county in that area. These data help assess the extent to which the concentration of human activities in the area and concentration of population

- orient ed commercial development may indicate emissions

- based activity contributing to elevated ambient

l ead lev els. This may include ambient l ead contributions from activities that would disturb l ead that has been deposited on the ground or on other surfaces. Re entrainment of historically deposited l ead is not reflected in the emissions inventory

.

Table 5: Population Data
County State

Recommended

Nonattainment 2008

Population 2008

Population Density (pop/sq mi) Population

Change

2000

- 2008 Population

% Change

2000

- 2008

Hillsborough County, FL No 3 1,180,784 1,058 177,518 18

[Source of data: U.S. Census Bureau estimates for 200 8 ( http://www.census.gov/popest/datasets.html ) and estimation of the ar ea of U.S. Counties]

Growth rates and patterns

This factor considers population growth from 2000 to 2008. A county with rapid population growth is generally an integral part of an urban area that may have the potential to be contributing to l ead conce ntrations in the area. Hillsborough County had an 18 percent population change during the eight year time period, which h as be en considered when determining the nonattainment status of the County. The emissions from EnviroFocus Technologies are not impa c ted by local population growth. EPA has considered the population growth rate for this area and does not believe that it affects the boundary recommendation.

3 In a letter dated October 15, 2009, the State of Florida recommended an area that is e ncompassed within a radius of five km centered at the UTM coordinates 364.0 East and 3093.5 North, Zone 17, in Hillsborough County, be designated “unclassifiable” for the 2008 Lead NAAQS. Florida reiterated this recommendation in a letter to EPA dated May 4, 2010. In a letter dated August 16, 2010, Florida stated, “ While we still feel that a designation of nonattainment is not necessary, we appreciate EPA upholding our reque st to shrink the boundary of the affected area from a 5 kilometer (km) radius to a 1.5 km radius surrounding the EnviroFocus Technologies facility. ”11

Emissions Controls

Under this factor, the existing level of control of emission sources is tak en into consideration. The emissions data used by EPA in this technical analysis and provided in Table 3 represent
emissi ons levels taking into account any control strategies implemented in the Tampa Area before 2005 on stationary sources. EPA has receiv ed additional information on current emission conditions in Hillsborough County from Florida Department of Environmental Protection (DEP)

. Based on Florida’s Octo ber 15, 2009, letter, the high l ead concentrations in the area are localized

and attributable to one single facility, a secondary l ead smelter ( formerly Gulf Coast Recycling Co., now EnviroFocus Technologies .)

Since 1990, a monitor located near the property has occasionally violated the former NAAQS for

l ead (4 th quarter 1991). Evidence sugges ts fugitive l ead emissions from the facility were the source of the violations. Based on this assessment, EPA approved a revision to Florida’s state implementation plan (SIP) on September 18, 1996, that included stack emissions standards for

various l ead sources in Florida, and also required the State to submit an additional SIP revision providing a source

- specific fugitive emissions control plan for the Gulf Coast facility. A plan was developed, and submitted to EPA for approval on December 9, 1999. Fol lowing another

violation in 2000 (also attributable to fugitive l ead emissions)

, the Florida DEP committed to EPA that it would require the facility to implement a more stringent fugitive emissions control plan, and submit the revised plan to EPA as a repl acement to the 1999 SIP submittal.

T he process emissions from the facility were relatively consistent , around 1.0 to 1.3 tpy, while operated by Gulf Coast . The 2005 NEI l ead emissions reported for the former Gulf Coast Recycling facility are consistent with historical emissions from that facility

. In 2007, EnviroFocus Technologies purchased the facility, and submitted a new permit application to expand production capacity and completely enclose the facility, while continuing operation. The

emissions f

rom EnviroFocus have remained at a similar level during the permitting process and while undergoing the modifications since EnviroFocus purchased the facility, and are also consistent with the expected actual emissions once construction is complete. Envir oFocus listed the expected actual emissions at 1.12 tpy in their permit application, although the allowable

emissions will be 0.96 tpy once construction is completed

. The expected actual plantwide

emissions will drop to approximately 0.82 tpy.

In Septemb er 2009, Florida DEP issued the permit to EnviroFocus . The project is ex pected to significantly reduce the impact of l ead emissions from the facility, and Florida’s analysis indicates that the facility will not cause or contribute to violations of the rev ised l ead NAAQS once the modifications to the facility are completed , even though plant production will increase

. The modeling conducted for the new facility reflects the future allowable emissions, at the 0.96 tpy level, rather than the current allowable emissions of 2.0 tpy . T he permit includes a fugitive emissions control plan , including removal of contaminated soil and additional paving to reduce

reentrainment. It also contains a requirement that the company conduct post

- construction monitoring at tw o additional sites near the facility. While not totally representative of the current operating conditions at EnviroFocus, the modeling is useful for this analysis . The modeling is

based on future allowable emissions

, but the current actual emissions are similar to future

allowable emissions (current actual of ~1.0 to 1.3 tpy vs. future allowable 0.96 tpy) . As a result,12

the modeling is instructive as a factor to help in defining the appropriate boundary for the Hillsborough County area.

Florida DEP has previously indicated its intentions to submit an additional SIP revision to EPA to incorporate the air quality benefits obtained through the project. The SIP revision will fulfill Florida DEP’s commitment to EPA to replace the 1999 submitt al with a more e ffective plan.

Meteorology (weather/transport patterns)

For this factor, EPA considered data from National Weather Service (NWS) instruments and other meteorological monitoring sites in the area , usually associated with major airport operation

. A three

- dimensional bar chart shows the wind frequencies in eight directions, for the four seasons, based on thirty

- two years of historical data 4 for the Tampa Area . These historical data may provide evidence of the potential for l ead emissions sources located up wind of a violating

monitor to contribute to ambient l ead levels at the violating monitor location, in the season of the

violation.

Figure 3: Hillsborough County Historical Wind Direction Frequency

As seen in Figure 3 above, the predominant wind dir ection in the Autumn/Winter seasons is originating from the North/Northeast (NNE) and East/Northeast ( ENE ) , while in the Spring/Summer seasons it is from the East/Southeast ( ESE )

.

4 This data was taken from 1960

- 1992 Solar and Meteorological Surface Observation Network information issue d jointly by the U.S. Department of Commerce: National Climatic Data Center and the U.S. Department of Energy: National Renewable Energy Laboratory.13

For each air quality monitoring site, EPA also developed a “ wind rose,” w hich provides information about how wind speed and direction are distributed at the NWS monitoring station during the 30

- year time period. The “spokes” on the diagram indicate the frequency of winds blowing FROM a particular direction. The length of a sp oke shows the amount of time (in percentage) that the wind blows from that direction. Each concentric doted

- line circle on the diagram represents increasing frequencies as you move out from the center. The spokes also provide information about the speed of the winds blowing from that direction. Each spoke is broken into discrete frequency categories that are color

- coded to indicate the percentage of time that wind speeds are within that category (e.g., for winds blowing from the East, approximately

five percent of the time the wind speeds are between 2.1

– 3.6 meters/second (m/s) ).

Figure 4: Tampa Wind Rose; Tampa International Airport

Annual Wind Rose

– 30 years (1961

- 1990)

Figure 4 provides an annual wind rose diagram for the Tampa Area

. The win d rose was generated from 30 years (1961

- 1990) of wind speed and wind direction data collected at the NWS meteorological monitoring station located at the Tampa International Airport (NWS Station # 12842) , approximately 15 km from the nearest violating mon itor

. This station h as the most representative long

- term record of wind data for the Tampa A rea, including Tampa’s l ead monitoring site.14

The Tampa A

rea wind rose is consistent with the wind direction bar chart in Figure 3 above and

indicates that wind bl ows predominantly from due East, approximately 13 percent of the time; however wind is also blowing from the East/Northeast approximately ten percent of the time. The winds blow from each direction at least three percent of the time. The wind speeds also vary with no strongly predominate speed category either. However, the majority of the time, the wind speeds are less than 5.7 m/s. The wind rose indicates that l ead sources located in any direction from the monitoring site in the Tampa Area could influe nce the monitored ambient air concentrations during different time periods; however sources located to the East/Northeast may have a greater influence . Also, the higher frequency of low to moderate wind speeds would

indicate that air emissions sources loc ated closer to the monitor have a larger influence than

those located more distant from the monitor.

EPA considered this historical wind direction and wind speed data to show evidence of the potential transport patterns for l ead emissions sources located upwind and/or in close proximity

to that of a violating mo nitor to contribute to ambient l ead levels at the violating monitor.

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

The geography/topography analysis evaluates the physica l features of the land that might have an effect on the air shed and, therefore, on the distribution of l ead over the Tampa Area.

The Tampa Area does not have any geographical or topographical barriers significantly limiting

air

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

Jurisdictional boundaries

Existing jurisdictional boundaries may be helpful in articulating a boundary for purposes of nonattainment design ations, and for purposes of carrying out the governmental responsibilities of planning for attainment of the l ead NAAQS and implementing control measures. These existing boundaries may include an existing nonattainment or maintenance area boundary, a coun ty or township boundary, a metropolitan area boundary, an air management district, or an urban planning boundary established for coordinating business development or transportation activities.

A portion of t he Tampa Area was designated as unclassifiable f or the 1978 Lead standard on January 6, 1992. That portion of Hillsborough County contains what is now the EnviroFocus facility. However, EPA has concluded that this existing jurisdictional boundar y was not based

on the same factors as currently being an alyzed and does not affect this analysis . Therefore, this factor did not play a significant role in determining the nonattainment boundary.

Other Relevant Information

Florida submitted additional information in support of their recommendation on May 4, 201 0

, which included some modeling results based on the EnviroFocus Technologies permi t application. The new facility, when completed later in 2010 , will have multiple controls on its15

process operations, including operating within a total enclosure under negative pressure. The air

m odeling results referenced in that permit show that the maximum impact of the EnviroFocus Technologies facility is predicted to be approximately 50 percent of the NAAQS and would occur at the fence line of the facility. The mo del output, which includes the impact of all point

sources in the immediate area , when combined with an assumed background concentration of 0.05 μg/m 3

, predicts a maximum concentration below 0.12 μg/m 3

. Concentrations in excess of the new NAAQS do not extend beyond the fence line of the facility, and drop to approximately 5
percent of the NAAQS level well within a distance of 1.5 km from the facility (see the figure showing modeling results below)

. However, this modeling does not reflect permitted operating conditions during the monitoring period when violations were recorded . Permitted emissions levels during that period were 2.0 tpy, h igher than the future allowable emissions levels used in the modeling, and the modeling does not account for reentrained dust emissions that may have been present during the violation period . Nonetheless, the modeling represents the best

estimation availa ble to determine the facility impacts for purposes of establishing an appropriate

nonattainment boundary

.

Interpreting the modeling analysis for EnviroFocus Technologies is complicated by the unique

nature of the current circumstances and the ongoing pl ant modifications . Since the facility is being rebuilt, the current conditions represent neither the old Gulf Coast Recycling nor EnviroFocus Technologies facilities with all rebuilding complete, but rather some thing in

between. However, the modeled emis sions of 0.96 tpy are consistent with the past actual recent emissions in the 1.0 to 1.3 tpy range, as well as the expected actual future emissions of 0.82 tpy

. Additionally, the modeled emissions include on

- site road fugitive emissions, for which there a re no permit limits or estimates on current and past emissions. Road fugitives are expected to drop to approximately 0.0355 tpy.

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Address: 1301 Constitution Ave, NW

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Telephone:

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Fax:

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Email: docket-customerservice@epa.gov17

EPA is basing this nonattainment desig nation determination and boundary on the fact that Hillsborough County has two air quality monitors that show a violation of the 2008 Lead NAAQS, based on 2007

- 2009 air quality data. Additionally, the EnviroFocus facility located near the violating monito rs emits relatively large quantities of l ead that the EPA believes cause d

the violati ons of the l ead NAAQS at those air quality monitors for this period. Available modeling and monitoring data indicates that a boundary a 1.5 km radius centered at UTM

coor dinates 364104 meters E, 3093830 meters N, Zone 17, which surrounds the EnviroFocus Technologies facility, and includes a portion of Hillsborough County previously designated

unclassifiable for the 1978 Lead NAAQS, is a sufficient distance to encompass the area that

exceeds the l ead NAAQS.

Based on its consideration of all the relevant, available information, as described above, EPA believes that the boundaries described herein encompass the entire area that does not meet (or

that contributes to ambient ai r quality in a nearby area that does not meet) the 2008 Lead NAAQS.