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Technical Support Document

Definition of important terms used in this document:

1) Designated “unclassifiable” – an area where EPA could not determine if there was a 

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

violation in a nearby area, because there was insufficient air quality data for both 2006-2008 and

2007-2009 and where additional monitoring data for 2010 could not result in a different 

designation.

2) Designated “attainment” – an area which EPA has determined, based on the most recent 3 

years of certified air quality data from 2006-2008 or 2007-2009, has no violations of the 2008 

Lead NAAQS during 36 consecutive valid 3-month site means; and which EPA has further 

determined does not contribute to a violation of the 2008 Lead NAAQS in a nearby area and that 

additional monitoring data from 2010 could not result in a different designation.

3) Designated nonattainment area – an area which EPA has determined, based on a State 

recommendation and/or on the technical analysis included in this document, has a violation of 

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

certified air quality data. 

4) Prior nonattainment area – an area that is currently designated as nonattainment or 

maintenance for the 1978 Lead NAAQS (including both current nonattainment areas and 

maintenance areas).

5) Recommended nonattainment area – an area a State or Tribe has recommended to EPA be 

designated as nonattainment.

6) Violating monitor – an ambient air monitor whose design value exceeds 0.15 micrograms per 

cubic meter (μg/m3). As described in Appendix R of part 50, a violation can be based on either 

lead-total suspended particles (Pb-TSP) or Pb-PM10 data and only three months of data are 

necessary to produce a valid violating design value. 

7) 1978 Lead NAAQS – 1.5 μg/m3, National Ambient Air Quality Standard for Lead

promulgated in 1978. Based on Pb-TSP indicator and averaged over a calendar quarter.

8) 2008 Lead NAAQS - 0.15 μg/m3, National Ambient Air Quality Standard for Lead

promulgated in 2008. Based on Pb-TSP indicator and a three-month rolling average. Pb-PM10

data may be used in limited instances, including to show nonattainment.
2

Florida

Area Designations For the 

2008 Lead National Ambient Air Quality Standards

EPA has revised the level of the primary (health-based) standard from 1.5 micrograms per cubic 

meter (μg/m3) to 0.15 μg/m3 measured as total suspended particles (TSP). EPA has revised the 

secondary (welfare-based) standard to be identical in all respects to the primary standard.

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

those areas that violate the national ambient air quality standard (NAAQS) and those 

nearby areas that contribute to violations. The table below identifies the counties or portions 

of counties (or tribal areas) in Florida that EPA is designating “nonattainment” for the 2008 lead

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 1978 Lead

NAAQS

Tampa, Florida None1 Hillsborough (partial) No

(Unclassifiable)

Technical analysis for Tampa, Florida

Introduction 

This technical analysis for the Tampa Area identifies the partial county with two monitors that 

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

lead 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 patterns);

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

Jurisdictional boundaries (e.g., counties, air districts, reservations, etc.); and

Any other relevant information submitted to or collected by EPA (e.g., modeling where 

done appropriately).

 

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 (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 

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 Surrounding Counties

Figures 1 and 2 are maps of the area analyzed showing the location and design value of the air 

quality monitors in the area, the counties surrounding the violating air quality monitors, and 
4

Florida’s recommended boundary for an “unclassifiable” designation. The violating monitors 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 lead unclassifiable boundaries for the 1978 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.

On October 15, 2009, Florida recommended that the previous five kilometer (km) area in 

Hillsborough County that was designated “unclassifiable” remain designated as “unclassifiable,” 

and the remainder of the State be designated as “attainment,” for the 2008 Lead NAAQS based 

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. Their recommendation was based on data from Federal 

Reference Method monitors located in the State, as well as the previous “unclassifiable” 

designation. Subsequently, on May 4, 2010, Florida reiterated their recommendation for 

Hillsborough County to be designated as unclassifiable 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 described below, EPA is designating the entire portion of 

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

364104 meters East, 3093830 meters North, Zone 17, fully including the EnviroFocus 

Technologies facility, as 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 Quality Data 

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

County in the Tampa Area, and the surrounding area based on data for the 2007-2009 period. A 

monitor’s design value indicates whether that monitor attains a specified air quality standard. 

The 2008 Lead NAAQS are met at a monitoring site when the identified design value is valid 

and less than or equal to 0.15 μg/m3. A design value is only valid if minimum data completeness 

criteria are met. A lead design value that meets the NAAQS is generally considered valid if it 

encompasses 36 consecutive valid 3-month site means (specifically for a 3-year calendar period 

and the 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 monitoring days in the 3-month period. A lead 

design value that does not meet the NAAQS is considered valid if at least one 3-month mean that 

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

monitor for three full calendar 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.
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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 

Name

Monitor Air Quality 

System ID

Monitor 

Location

Lead Design 

Value, 

2006 - 2008

(μg/m3)

Lead Design 

Value, 

2007-2009

(μg/m3)

Hillsborough 

County, 

Florida

No2120571073 6811 E. 14

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 monitors violating the 2008 Lead NAAQS. Therefore some 

area in this county and possibly additional areas in 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. Each area has been evaluated 

based on the weight of evidence of the eight factors and other relevant information.

The violating monitors located in Hillsborough County are both located within 480 meters of the 

largest lead emissions source in the county, EnviroFocus Technologies, 1901 North 66th Street, 

in Tampa, Florida. The monitoring objective, according to the EPA monitor locator, is sourceoriented. The emissions from EnviroFocus Technologies will be discussed in the corresponding 

section below.

Emissions and Emissions-Related Data

Evidence of lead emissions sources surrounding a violating monitor are an important factor for 

determining whether a nearby area is contributing to a monitored violation. For this factor, EPA 

evaluated county level emission data for lead and population data.

Emissions

Emissions data were 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 recognizes that for certain counties, 

emissions may have changed since 2005. For example, certain large sources of emissions in or 

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

since 2005.

 

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 “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 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 included some emission estimates; however, the source of these 

estimates was not documented or referenced by Florida. As discussed below, emissions levels at 

the EnviroFocus Technologies facility are currently in flux as major construction projects are 

underway. Florida also provided updated emissions information via email for the City of Tampa 

Wastewater Treatment Plant, noting that actual lead emissions from that site were less than 100 

pounds in 2005.

Table 3 shows total emissions of lead (given in tons per year (tpy)) for violating counties and 

potentially contributing facilities in and around the Tampa Area including sources emitting (or 

anticipate to contribute) greater than 0.1 tpy of lead according 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 that 

states use the draft 2008 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 

Nonattainment

Area?

Facility Name Facility Location 2005 NEI (tpy)

Hillsborough 

County, FL

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

No Tampa Electric Company 3602 Port Sutton Road, 

Tampa

0.1

No Tampa Electric Company 13031 Wyandotte 

Road, Apollo Beach

0.1

No Coronet Industries Inc 4082 Coronet Road, 

Plant City

0.3

* Originally 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 “unclassifiable” for the 2008 Lead 

NAAQS. This facility falls within that state-recommended boundary.

According to the available data, Hillsborough County has four sources emitting at or above 0.1 

tpy. The greatest emitter of lead in the County is EnviroFocus Technologies. The other sources 

in the Tampa Area are not expected to contribute to the violations recorded at the air quality 

monitors, and will be discussed further in the discussion 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 includes 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 

facility. 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 and/or removal of 
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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 from 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 battery 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 started 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 12/13/2010

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 8/29/2011
8

Phase 1C

This phase will include the final 2 refining kettles, lead lab and control 

rooms.

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

Roofing 11/16/2011 1/19/2012

Refining 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 11/10/2011 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 schedule is not approved in any enforceable permit or rule, it is instructive in 

helping to define the appropriate boundary for the Tampa Area. All of the activities included in 

this schedule will take place on EnviroFocus Technologies facility.

Table 4: Airport Facilities Using Leaded Aviation Gas in Hillsborough County

City Facility Name Type 2008 draft 

NEI (tpy)

Distance to Violating 

Monitor (kilometers)

Tampa Vandenburg Airport 0.27 6.69

Tampa Peter O’Knight Airport 0.14 8.52

Tampa Tampa 

International

Airport

Airport 0.22 15.02

Plant City Plant City Airport Airport 0.12 21.69
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There are four airport facilities 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 airports are located beyond 

the 5 km boundary that Florida recommended 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 monitor. 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 2008 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-oriented 

commercial development may indicate emissions-based activity contributing to elevated ambient 

lead levels. This may include ambient lead contributions from activities that would disturb lead 

that has been deposited on the ground or on other surfaces. Reentrainment of historically 

deposited lead 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

No31,180,784 1,058 177,518 18

[Source of data: U.S. Census Bureau estimates for 2008 

(http://www.census.gov/popest/datasets.html) and estimation of the area of U.S. Counties]

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 lead concentrations in the area. Hillsborough County had an 18 percent 

population change during the eight year time period, which has been considered when 

determining the nonattainment status of the County. The emissions from EnviroFocus 

Technologies are not impacted 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 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. 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.”
11

Emissions Controls

Under this factor, the existing level of control of emission sources is taken into consideration. 

The emissions data used by EPA in this technical analysis and provided in Table 3 represent 

emissions levels taking into account any control strategies implemented in the Tampa Area 

before 2005 on stationary sources. EPA has received additional information on current emission 

conditions in Hillsborough County from Florida Department of Environmental Protection (DEP). 

Based on Florida’s October 15, 2009, letter, the high lead concentrations in the area are localized 

and attributable to one single facility, a secondary lead smelter (formerly Gulf Coast Recycling 

Co., now EnviroFocus Technologies.) 

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

lead (4th quarter 1991). Evidence suggests fugitive lead 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 lead 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. Following another

violation in 2000 (also attributable to fugitive lead 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 replacement to the 1999 SIP submittal. 

The process emissions from the facility were relatively consistent, around 1.0 to 1.3 tpy, while 

operated by Gulf Coast. The 2005 NEI lead 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 from 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. EnviroFocus 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 September 2009, Florida DEP issued the permit to EnviroFocus. The project is expected to 

significantly reduce the impact of lead emissions from the facility, and Florida’s analysis 

indicates that the facility will not cause or contribute to violations of the revised lead 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. The 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 two 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 submittal with a more effective 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 data4for the Tampa Area. These historical data 

may provide evidence of the potential for lead emissions sources located upwind of a violating 

monitor to contribute to ambient lead levels at the 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 direction 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 issued 

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,” which 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 spoke 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 wind 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 monitor. This station has the 

most representative long-term record of wind data for the Tampa Area, including Tampa’s lead 

monitoring site.
14

The Tampa Area wind rose is consistent with the wind direction bar chart in Figure 3 above and 

indicates that wind blows 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 lead sources located in any direction 

from the monitoring site in the Tampa Area could influence 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 located 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 lead emissions sources located upwind and/or in close proximity 

to that of a violating monitor to contribute to ambient lead levels at the violating monitor. 

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

The geography/topography analysis evaluates the physical features of the land that might have an 

effect on the air shed and, therefore, on the distribution of lead over 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 designations, and for purposes of carrying out the governmental responsibilities of 

planning for attainment of the lead NAAQS and implementing control measures. These existing 

boundaries may include an existing nonattainment or maintenance area boundary, a county or 

township boundary, a metropolitan area boundary, an air management district, or an urban 

planning boundary established for coordinating business development or transportation activities.

A portion of the Tampa Area was designated as unclassifiable for 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 boundary was not based 

on the same factors as currently being analyzed 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, 2010, 

which included some modeling results based on the EnviroFocus Technologies permit 

application. The new facility, when completed later in 2010, will have multiple controls on its 
15

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

modeling 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 model output, which includes the impact of all point 

sources in the immediate area, when combined with an assumed background concentration of 

0.05 μg/m3, predicts a maximum concentration below 0.12 μg/m3. 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, higher 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 available 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 plant 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 something in 

between. However, the modeled emissions 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 are 

no permit limits or estimates on current and past emissions. Road fugitives are expected to drop 

to approximately 0.0355 tpy.
Copyrighted page(s) have been removed from 

this document. 

Please contact the EPA Docket Center, Public 

Reading Room to view this document. 

Address: 

1301 Constitution Ave, NW 

Room 3334 

Washington, DC 20004 

Telephone: 

202-566-1744 

Fax: 

202-566- 9744 

Email: 

docket-customerservice@epa.gov
17

EPA is basing this nonattainment designation 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 monitors emits relatively large quantities of lead that the EPA believes caused

the violations of the lead 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 

coordinates 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 lead 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 air quality in a nearby area that does not meet) the 2008 Lead 

NAAQS.