Technical Support Document:
EPA's Redesignation
of the Canton, Ohio Area for the
2008 Lead National Ambient Air Quality Standard
February 2023
U.S. Environmental Protection Agency
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Table of Contents
Section 1:
Overview
Section 2:
Definitions
S ecti on 3: B ackground
3.1 History of 2008 Pb NAAQS
3.2 History of 2008 Pb NAAQS Area Designations
3.3 History of 2008 Pb NAAQS Violations in Stark County
Section 4: Technical Analysis
4.1 General Approach
4.2 Ambient Air Quality Monitors
4.3 Ambient Air Quality Monitoring Data
4.4 Violations based on Ambient Air Quality Monitoring Data in Stark
County
4.5 Nonattainment Designation Boundary Determination
4.5.1 Factor 1: Air Quality in Potentially Included Versus Excluded
Areas
4.5.2 Factor 2: Emissions in Areas Potentially Included Versus
Excluded from the Nonattainment Area
4.5.3 Factor 3: Level of Control of Emissions Sources
4.5.4 Factor 4: Population Density and Degree of Urbanization
including Commercial Development in Included Versus
Excluded Areas
4.5.5 Factor 5: Expected Growth
4.5.6 Factor 6: Meteorology
4.5.7 Factor 7: Geography/topography
4.5.8 Factor 8: Jurisdictional Boundaries
4.5.9 Additional Information provided by the State
4.6 Summary of EPA's Assessment and Redesignation for the Canton, Ohio
Area
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Tables
Table 1: Summary of Area Monitoring Information, Current Area Designation, and EPA's
Area Redesignation
Table 2: Ambient Air Quality Monitoring Data for Stark and Columbiana Counties
Table 3: Pb Design Values for Stark and Columbiana Counties
Table 4 Sources of Pb Air Emissions Greater than 5.0 Pounds/year in Stark County, Ohio
for 2016, 2017, 2018, and 2019
Table 5. Facilities Located in Counties Surrounding Stark County, Ohio with Pb Emissions
Greater than 0.1 tons/year (200 lb) in 2017
Table 6. Population and Population Density Data for Canton and Stark County, Ohio
Table 7. Change in Population and Population Density from 2010 to 2020 for Canton and
Stark County, Ohio
Figures
Figure 1. Canton, Ohio Area showing the Pb Ambient Air Monitoring Site (AQS Site No.
39-151-0024) and Pb Emissions Sources > 0.50 tons per year in Stark County
Figure 2: Republic Steel Pb Ambient Air Monitoring Site (AQS Site No. 39-151-0024),
Three-Month Rolling Averages (2017 - 2021)
Figure 3. Sources of Pb Emissions in Stark County, Ohio Area based on 2017 NEI
Figure 4. Locations of Sources of Pb Emissions Greater than 0.1 tons/year in 2017 in
Counties Surrounding Stark County, Ohio
Figure 5. Wind Rose for North Canton, Stark County, Ohio
Figure 6: Pollution Rose for Pb Concentrations from Republic Steel Ambient Air
Monitoring Site (AQS Site No. 39-151-0024), Canton, Stark County, Ohio
Figure 7. Polar Plot Map of Mean Pb Ambient Air Concentrations (October 2018 -
December 2020)
Figure 8. Boundaries of the Canton, Ohio Nonattainment Area for the 2008 Pb NAAQS
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Technical Support Document
OHIO
EPA's Redesignation
of the Canton, Ohio Area for the
2008 Lead National Ambient Air Quality Standard
1. Overview
On November 12, 2008, the EPA revised the National Ambient Air Quality Standard (NAAQS)
for lead (Pb) (73 FR 66964). The EPA set the level for the primary (health-based) standard at
0.15 micrograms per cubic meter ((j,g/m3) and set the secondary (welfare-based) standard to be
identical in all respects to the primary standard. 73 FR 66964 (November 12, 2008).
Pursuant to section 107(d) of the Clean Air Act (CAA), EPA must designate as "nonattainment"
those areas that violate the NAAQS and those nearby areas that contribute to violations. Once an
area has been designated, the EPA Administrator, under CAA section 107(d)(3), "may at any
time" notify a state that a designation should be revised. 42 U.S.C. § 7407(d).
EPA designated all areas of the United States as "unclassifiable," "unclassifiable/attainment," or
"nonattainment" for the 2008 Pb NAAQS in two rounds. The first round published in the
Federal Register on November 16, 2010 (75 FR 71033), and the second round published on
November 8, 2011 (76 FR 72097). In the November 8, 2011 action, Stark County, along with the
remaining unmonitored areas of Ohio, was designated as unclassifiable/attainment because
available information did not indicate that the air quality in this area exceeded the 2008 Pb
NAAQS.
Based on recent data from an ambient air quality monitoring site and EPA's technical analysis
described below, Table 1 identifies portions of one county in Ohio that EPA is redesignating
from "unclassifiable/attainment" to "nonattainment" for the 2008 Pb NAAQS. As explained in
the technical analysis below, the nonattainment area addresses violations at the Republic Steel
plant in Canton, Ohio and is smaller than the presumptive county-wide boundary in the 2008 Pb
NAAQS final rule.
Table 1. Summary of Area Monitoring Information, Current Area Designation, and
EPA's Area Redesignation
Area
Con illy
AQS II)
2019-2021
Design
Value
(Mg/iii')
Current
Designation
Uedesignalion
Canion, Ohio
Slark
(partial)
39-151-0024
0.40
Lnclassi liable.
Attainment
Nonallainmenl
Figure 1 contains maps of Stark County and the Canton, Ohio area showing the location of the
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ambient air quality monitoring site with violations of the 2008 Pb NAAQS based on the 2019-
2021 design value and sources of Pb emissions greater than 0.50 tons per year (1,000 pounds per
year) in Stark County.
Figure 1. Canton, Ohio Area showing the Pb Ambient Air Monitoring Site (AQS Site No.
39-151-0024) and Pb Emissions Sources > 0.50 tons per year in Stark County
Legend
Violating Pb
Monitor
39-151-0024
(2019-2021
Design Value)
Perimeter of Pb
Sources > 0.5
tons/year
(2017 NEI),
Republic Steel
©
Fulton Heights ¦
VASSAM PARK
WESTBI
^
—
-
STARK COUNTY Tff
Plain Twp
..t *
J
....
PLAIN A CITY
FAIRMOUNT
'EST NEW HOPE
Lynn Center Park
"HincolnSti
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Section 107(d)(3) of the CAA identifies the schedule for the redesignation process. On April 26,
2022, EPA notified the Governor of the State of Ohio regarding our intended redesignation and
established a 120-day period for the state to respond according to the provisions found in CAA
section 107(d)(3)(B). On May 3, 2022, the EPA notified the public of the intended redesignation
decision along with supporting documentation for Stark County, OH (87 FR 26147). At that
time, the EPA also announced a 30-day public comment period that closed on June 2, 2022.
Three public comments supporting EPA's intended redesignation were submitted to EPA's
public docket for this redesignation action, Docket No. EPA-HQ-OAR-2022-0195, located at
www.regulations.gov. On August 22, 2022, the Ohio Environmental Protection Agency (Ohio
EPA) submitted a response to EPA's April 26, 2022 notification concurring with EPA's intended
boundaries for the proposed nonattainment area. The EPA is therefore finalizing the
redesignation without modification.
The redesignation of the Canton, Ohio area to nonattainment for the 2008 Pb NAAQS imposes
certain planning requirements on the State of Ohio to reduce Pb concentrations within this area.
These include, but are not limited to, the requirement per CAA section 191(a) to submit, within
18 months of redesignation, a revision to the Ohio state implementation plan (SIP) that provides
for attainment of the 2008 Pb NAAQS as expeditiously as practicable, but no later than 5 years
after the date of redesignation to nonattainment, consistent with CAA section 192(a).
2. Definitions
The following are definitions of important terms used in this document.
1) Designated "nonattainment" area - an area which EPA has determined, based on a
state recommendation and/or technical analysis, does not meet the 2008 Pb NAAQS
based on the most recent 3 years of quality-assured air quality monitoring data including
at least one valid 3-month site mean above the level of the 2008 Pb NAAQS, or that
contributes to a violation in a nearby area.
2) Designated "unclassifiable/attainment" area - an area which EPA has determined does
not contribute to a violation of the 2008 Pb NAAQS in a nearby area and either: (1) meets
the 2008 Pb NAAQS, based on the most recent 3 years of quality-assured air quality
monitoring data including 36 consecutive valid 3-month site means, or (2) has no
monitors or has incomplete air quality monitoring data but has no violations of the 2008
Pb NAAQS.
3) Designated "unclassifiable" area - an area which EPA has determined cannot be
classified on the basis of available information as meeting or violating the 2008 Pb
NAAQS, based on the most recent 3 years of quality-assured air quality monitoring data,
but for which available monitoring data from the same or a recent period indicate a
significant likelihood that the area may be violating the 2008 Pb NAAQS.
4) Violating monitor - an ambient air monitor whose valid design value exceeds 0.15
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[j,g/m3. As described in Appendix R of part 50 of Title 40 of the Code of Federal
Regulations (CFR), a violation can be based on either Pb-TSP or Pb-PMio data, and only
3 months of data are necessary to produce a valid violating design value, where PMio is
particulate matter less than 10 microns in diameter.
5) 1978 Pb NAAQS - 1.5 (J,g/m3, National Ambient Air Quality Standard for Pb
promulgated in 1978. Based on Pb-TSP indicator and averaged over a calendar quarter.
6) 2008 Pb NAAQS - 0.15 (J,g/m3, National Ambient Air Quality Standard for Pb
promulgated in 2008. Based on Pb-TSP indicator and a 3-month rolling average. Pb-PMio
data may be used in limited instances, including to show nonattainment.
7) Design value - the site-level metric (i.e., statistic) that is compared to the NAAQS level
to determine compliance; the design value for the Pb NAAQS is selected according to the
procedures in 40 CFR part 50, Appendix R from among the valid 3-month Pb-TSP and
Surrogate Pb-TSP (Pb-PMio) arithmetic mean concentration for the 38-month period
consisting of the most recent 3-year calendar period plus two previous months (i.e., 36 3-
month periods) using the last month of each 3-month period as the period of report.
3. Background
3.1. History of 2008 Pb NAAQS
On October 15, 2008, EPA strengthened the NAAQS for Pb. The revised standard was lowered
from the 1.5 [j,g/m3 set in 1978, to a level of 0.15 [j,g/m3 based on a 3-month averaging time. The
EPA also established minimum ambient air monitoring requirements for source-oriented and
population-oriented sampling for sources with Pb emissions greater than a 1.0 ton per year
threshold. 43 FR 46246 (October 5, 1978); 73 FR 66964 (November 12, 2008). On December
14, 2010, EPA revised the Pb emissions threshold for source-oriented monitoring to 0.50 tons
per year except for airports. 75 FR 81126 (December 27, 2010).
On September 16, 2016, EPA announced its decision to retain, without revision, the 2008 Pb
NAAQS, finding that the existing primary (health-based) standard provided health protection for
at-risk groups, especially children, and the existing secondary (welfare-based) standard provides
protection against adverse effects to public welfare, including harm to aquatic and terrestrial
ecosystems. 81 FR 71906 (October 18, 2016).
3.2. History of 2008 Pb NAAQS Area Designations
In November 2010, EPA completed an initial round of nonattainment designations for the 2008
Pb NAAQS. 75 FR 71033 (November 22, 2010). On November 8, 2011, EPA designated all
remaining areas of the United States as meeting or not meeting the 2008 Pb NAAQS based on
data from 2008-2010. In the November 8, 2011 action, Stark County, along with the remaining
unmonitored areas of Ohio, was initially designated as unclassifiable/attainment because
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available information did not indicate that the air quality in this area exceeded the 2008 Pb
NAAQS. 76 FR 72097 (November 22, 2011).
3.3 History of 2008 Pb NAAQS Violations in Stark County
On June 6, 2017, an ambient air quality monitoring site began operating in Stark County to
measure concentrations of Pb. The site is known as the Republic Steel ambient air monitoring
site (AQS Site No. 39-151-0024) and is located at 3150 Georgetown Road NE, Canton, Ohio.
The most recent certified, quality-assured air quality monitoring data collected at the Republic
Steel ambient air monitoring site indicate that the 2019-2021 design value is 0.40 (J,g/m3, which
exceeds and violates the 0.15 [j,g/m3 level of the 2008 Pb NAAQS.
Ohio EPA's response to EPA's intended redesignation to nonattainment noted ongoing efforts to
address violations of the 2008 Pb NAAQS, including pending enforcement actions and a July 2,
2021, Consent Order for Preliminary Injunction in the Stark County Court of Common Pleas,
which mandated that Republic Steel facility undertake certain actions to reduce lead emissions.
4. Technical Analysis
4.1 General Approach
This technical analysis for the Canton, Ohio area identifies a monitor in Stark County that
violates the 2008 Pb NAAQS, evaluates sources and nearby counties contributing to Pb
concentrations in the area, and determines the area boundaries for redesignation.
To determine whether areas are in violation, the 2008 final rule for the Pb NAAQS adopted
guidance (2008 EPA Pb Guidance) for using monitoring data from the 3 most recent calendar
years to identify a violation. 73 FR 67033 (November 12, 2008).
To determine the boundaries of an area where violations support a nonattainment designation,
the 2008 EPA Pb Guidance states that the perimeter of a county containing the violating monitor
is the initial presumptive boundary for nonattainment areas. If the boundaries are smaller than
the full county, as here, that smaller boundary should be accompanied by a demonstration to
show that violations are not occurring in the excluded portions of the county and that the
excluded portions are not source areas that contribute to the observed violations. To justify
establishing either a larger or smaller area than the presumptive boundary, the 2008 EPA Pb
Guidance indicated the following eight factors should be considered (73 FR 67033 (November
12, 2008)):
1) Air quality in potentially included versus excluded areas;
2) Emissions in areas potentially included versus excluded from the nonattainment area;
3) Level of control of emissions sources;
4) Population density and degree of urbanization including commercial development in
included versus excluded areas;
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5) Expected growth of the population (including extent, pattern, and rate of growth);
6) Meteorology (weather/transport patterns);
7) Geography/topography (mountain ranges or other air basin boundaries); and
8) Jurisdictional boundaries (e.g., counties, air districts, reservations, etc.).
In addition to an analysis of the eight factors above, states can choose to recommend Pb
nonattainment boundaries by using any one, or a combination of, the following techniques (id.):
• Qualitative analysis;
• Spatial interpolation of air quality monitoring data; or
• Air quality simulation by dispersion modeling.
The EPA has looked to the 8 factors provided in the 2008 EPA Pb Guidance in this redesignation
to nonattainment. In the technical analysis below, EPA evaluated the violating monitoring site,
contributing sources, and area boundaries based on the weight of evidence of the factors listed
above. The boundaries of the nonattainment area are smaller than the county boundary, as
explained below.
4.2 Ambient Air Quality Monitors
On June 6, 2017, an ambient air quality monitoring site was installed and began operating in
Stark County to measure concentrations of Pb and other toxic metals. Ohio EPA, through its
partnership with the Canton City Board of Health's Air Pollution Control Division,1 installed this
special purpose monitor (SPM) to meet the requirements of a state permit2 issued on December
12, 2016, to Republic Steel as part of operational changes made to its plant at 2633 Eighth Street
NE, Canton, Ohio 44704-2311 (Republic Steel). Republic Steel manufactures leaded steel and
other steel products. The Republic Steel ambient air monitoring site (AQS Site No. 39-151-0024)
is located at 3150 Georgetown Road NE, Canton, Ohio, which is near a residential area across
the street from and south of the Republic Steel plant.
In April 2019, Ohio EPA converted the designated primary Pb sampler at the Republic Steel
ambient air monitoring site from an SPM to a State or Local Air Monitoring Station (SLAMS)
monitor. The conversion was made as a result of Ohio EPA's 2017 emissions inventory, which
indicated that Republic Steel's Pb emissions were at 0.81 tons per year. 40 CFR Part 58
Appendix D, Section 4.5(a) requires ambient air monitoring of Pb emissions around any non-
airport facility that reports actual Pb emissions greater than 0.50 tons per year. The EPA requires
SLAMS monitors to collect Pb samples at a minimum frequency of l-in-6 days and those data be
reported to EPA's Air Quality System (AQS).
On March 1, 2021, Ohio EPA began operating a second monitor at the Republic Steel ambient
air monitoring site to collect additional Pb samples on a random day sampling schedule.3 Pb data
1 Canton City Board of Health, Air Pollution Control Division. https.V/www. cantonhealth. org/apc/
2 Ohio EPA Air Pollution Permit-to-Install (PTI), Permit Number: P0121793, Facility ID: 1576050694, Republic
Steel, http://wwwapp.epa.ohio.gov/dapc/permits_issued/1499790.pdf
3 2021-2022 Ohio EPA Air Monitoring Network Plan.
https://epa. ohio.gov/static/Portals/27/ams/sites/2021-2022_AMNPMain Report_Final.pdf
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from both of these monitors are combined to calculate the monitoring site level design value for
comparison to the NAAQS. Ohio EPA continued to also collect air samples to evaluate air
quality specifically during leaded production at the Republic Steel plant. Because these air
samplers were operated only during leaded production time periods, typically less than the
routine 24-hour air samples required for air monitoring data used for NAAQS comparisons, the
data are not reported to EPA's AQS. Ohio EPA posts data from all the Pb monitors on its
website.4
The two ambient air quality monitors (Parameter Occurrence Code - POC 1, POC 4) at the
Republic Steel monitoring site measure ambient concentrations on a microscale level of 0 to 100
meters with a staggered schedule. POC 1 operates on the EPA sampling schedule of l-in-6 days,
and POC 4 operates on a randomized schedule. The POC is used to distinguish different
instruments that measure the same parameter at the same monitoring site. The collection method
uses Manual Equivalent Method EQL-0170-192: Heated Nitric Acid Block Digestion and
Inductively Coupled Plasma / Mass Spectrometry (ICP/MS) Analysis for Lead (Pb) on total
suspended particulate matter (TSP) High-Volume Filters. In this method, total suspended
particulate matter is collected on glass fiber filters according to 40 CFR Appendix B to part 50,
EPA Reference Method for the Determination of Suspended Particulate Matter in the
Atmosphere (High-Volume Method), extracted with a solution of nitric acid, heated on a hot
block to 95°C for one hour, and brought to a final volume of 50 milliliters (mL). The Pb content
of the sample extract is analyzed by Inductively Coupled Plasma / Mass Spectrometry (ICP-MS)
based on EPA Method 200.8 and SW-846 Method 6020A. Both POC 1 and POC 4 met quality
assurance criteria to be deemed as valid and the requirements of 40 CFR Part 58 Appendix A5
and the Quality Assurance Handbook Volume II, Appendix D, Measurement Quality Objectives
and Validation Templates.6
In April 2022, another ambient air quality monitoring site was installed at 719 Marietta Avenue
NE, Canton, Ohio, and the Canton City Board of Health's Air Pollution Control Division began
collecting data. This new "Republic Community" monitoring SLAMS site (AQS Site No. 39-
151-0025) operates two monitors denoted as POC 1 and 4 on the same schedule and days as the
Republic Steel monitoring site (AQS Site No. 39-151-0024). Data are reported to EPA's AQS
and are also available on Ohio EPA's website.7
4 Ohio EPA, Air Pollution Control, Reports & Data, Special Sampling Projects.
https://epa.ohio.gov/wps/portal/gov/epa/divisions-and-offices/air-pollution-control/reports-and-data/special-
sampling-projects
5 40 CFR Part 58, Appendix A, Quality Assurance Requirements for Monitors used in Evaluations of National
Ambient Air Quality Standards
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-58/appendix-
Appendix%20A%2 Oto % 2 0Part%2058
6 Quality Assurance Handbook Volume II, Appendix D, Measurement Quality Objectives and Validation
Templates
https://www.epa.gov/sites/default/files/2020-
10/documents/app_d_validation_template_version_03_2017_for_amtic_rev_l.pdf
7 Ohio EPA Special Sampling Projects, Republic Steel, Canton, Stark County.
https://epa.ohio.gov/divisions-and-offices/air-pollution-control/reports-and-data/special-sampling-projects
7
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4.3 Ambient Air Quality Monitoring Data
Ambient air quality monitoring data for the Republic Steel ambient air monitoring site (AQS Site
No. 39-151-0024) are reported in EPA's AQS. Both monitors POC 1 and POC 4 at the site were
used in summary statistics of annual max 3-month rolling averages and design value
calculations. Figure 2 shows the plot of AQS reported Pb concentrations as 3-month rolling
averages at the Republic Steel ambient air monitoring site for 2017-2021 with violations above
the 0.15 [j,g/m3 2008 Pb NAAQS noted in red.
Figure 2. Republic Steel Pb Ambient Air Monitoring Site (AQS Site No. 39-151-0024),
Three-Month Rolling Averages (2017 - 2021)
Stark Lead Monitor Three-Month Rolling Averages (2017-2021)
0.45
0.40 a—
0.35
m 0.30
E
Until April 2022 when the new Republic Community ambient air monitoring site (AQS Site No.
39-151-0025) was installed, the Republic Steel monitoring site (AQS Site No. 39-151-0024) was
the only ambient air monitoring site for Pb in Stark County. The nearest downwind monitors for
Pb are approximately 69 kilometers (km) east southeast of the Republic Steel ambient air
monitoring site and located in Liverpool, Ohio in adjacent Columbiana County. No other air
monitors for Pb are located in the counties adjacent to Stark County besides Columbiana County.
Table 2 contains the annual maximum Pb 3-month rolling averages for the ambient air monitors
in Stark and Columbiana Counties for 2016-2022.
Table 2. Ambient Air Quality Monitoring Data for Stark and Columbiana Counties
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Con illy
Monitor
N si mc
Monitor
AQS II)
Monitor
l.ocsition
Msixiimim PhS-Monlh Rolling Avi'rsigi'"
(UU ill')
(Number of Complete Months
in Parentheses)
2016
2017
20 IS
2019
2020
2021
2022
Stark
Republic
Steel
39-151-
0024
3150
George-
town
Road
NE,
Canton,
Ohio
N/A
0.11
(5)
0.20
(12)
0.21
(12)
0.13
(12)
0.40
(11)
0.07
(6)
Stark
Republic
Community
39-151-
0025
719
Marietta
NE,
Canton,
Ohio
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Columbiana
Columbiana
Port
Authority
39-029-
0019
1250
George
Street,
East
Liverpoo
1, Ohio
0.02
(12)
0.02
(12)
0.02
(12)
0.01
(12)
0.01
(8)
0.01
(12)
0.01
(3)
Columbiana
Eastside
Elementary
39-029-
0023
500
Mary lan
d
Avenue,
East
Liverpoo
1, Ohio
0.01
(9)
0.01
(12)
0.03
(12)
0.01
(12)
0.01
(8)
0.01
(12)
0.01
(6)
Columbiana
East
Liverpool
WTP
39-029-
0020
2220
Michigan
Avenue,
East
Liverpoo
1, Ohio
0.01
(12)
0.01
(12)
0.01
(12)
0.01
(12)
0.01
(8)
0.01
(12)
0.00
(6)
* Information on the am
)ient air quality monitors and c
ata used to calculate t
le Pb rolling
averages is publicly available at: https://www.epa.gov/aqs
The Pb design values for Stark County and surrounding area were calculated based on the most
recent quality-assured and certified AQS ambient air quality monitoring data for 2016-2018,
2017-2019, 2018-2020, and 2019-2021 as shown in Table 3. The design values were calculated
according to the data handling procedures in 40 CFR part 50, Appendix R, and are valid for
comparison to the NAAQS.
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Table 3. Pb Design Values for Stark and Columbiana Counties
Con illy
Monitor
Name
Monitor
AQS II)
Monitor
Location
Pb Design \ aliie-
(iig/m')
2016-
20 IS
2017-
2019
2018-
2020
2019-
2021
Stark
Republic
Steel
39-151-0024
3150 Georgetown
Road NE,
Canton, Ohio
0.20
0.21
0.21
0.40
Stark
Republic
Community
39-151-0025
719 Marietta NE,
Canton, Ohio
N/A
N/A
N/A
N/A
Columbiana
Columbiana
Port
Authority**
39-029-0019
1250 George
Street, East
Liverpool, Ohio
0.02
0.02
0.02
0.01
Columbiana
Eastside
Elementary
**
39-029-0023
500 Maryland
Avenue, East
Liverpool, Ohio
0.03
0.03
0.03
0.01
Columbiana
East
Liverpool
WTP**
39-029-0020
2220 Michigan
Avenue, East
Liverpool, Ohio
0.01
0.01
0.01
0.01
Information on the ambient air quality monitors and data used to calculate the Pb design
values is publicly available at https://www.epa.gov/aqs.
Some Columbiana County design values are incomplete due to site establishment dates
and COVID-19 restrictions.
4.4 Violations based on Ambient Air Quality Monitoring Data in Stark County
A monitor's design value indicates whether that monitor attains a specified air quality standard.
Procedures for using monitored air quality data to determine whether the monitor attains or
violates the 2008 Pb NAAQS are given in 40 CFR part 50, Appendix R. The 2008 Pb NAAQS
are met at a monitoring site when the identified design value is valid and less than or equal to
0.15 [j,g/m3. A Pb 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 Pb
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 3 full calendar years to have a valid violating design value; a site could monitor just
3 months and still produce a valid (violating) design value.
EPA considered the Pb NAAQS design value for the Republic Steel ambient air monitoring site
in Stark County (AQS Site No. 39-151-0024) by assessing the most recent 3 consecutive years
(i.e., 2019-2021) and two previous months of quality-assured, certified ambient air quality data
in EPA's AQS using data from Federal Reference Method and/or Federal Equivalent Method
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monitors that are sited and operated in accordance with 40 CFR parts 50 and 58.
Data collected at the Republic Steel monitoring site (AQS Site No. 39-151-0024) indicate that
the 2019-2021 design value representative of the Stark County area is 0.40 [j,g/m3. With a design
value of 0.40 (J,g/m3, the Republic Steel ambient air monitoring site shows a violation for 2019-
2021 of the 2008 Pb NAAQS of 0.15 ^g/m3.
4.5 Nonattainment Redesignation Boundary Determination
Under CAA section 107(d)(3), the EPA Administrator may at any time notify the Governor of
any State that available information—including air quality data, planning and control
considerations, and any other air quality-related considerations the Administrator deems
appropriate—indicates that the designation of any area or portion of an area within the State
should be revised. Air quality data from 2019-2021 indicate that ambient lead concentrations in
Stark County do not meet the NAAQS, and, therefore, it is appropriate to redesignate to
nonattainment some area in Stark County and possibly additional areas in surrounding counties.
The absence of monitors indicating violations in nearby counties is not a sufficient reason to
eliminate nearby counties as candidates for nonattainment status.
A nonattainment area should contain the area violating the NAAQS (e.g., the area around a
violating monitor or encompassing modeled violations), as well as any nearby areas (e.g.,
counties or portions thereof) that contain emissions sources contributing to the violation. See
CAA section 107(d)(1). EPA has also looked to the guidance used in the initial area designations
process to inform the boundaries of the new nonattainment area. Accordingly, EPA conducted an
evaluation of the eight factors listed above to determine the geographic scope of the
nonattainment boundary. In the sections below, we consider the appropriate geographical extent
of the nonattainment area.
4.5.1 Factor 1: Air Quality in Potentially Included Versus Excluded Areas
This factor considers the Pb design values (in (J,g/m3) for the ambient air quality monitors in
Stark County and the surrounding area based on data for the 2019-2021 period. Ambient air
quality data are discussed above in section 4.3.
The Republic Steel and Republic Community ambient air monitors (AQS Site Nos. 39-151-0024,
39-151-0025) are the only ambient air monitors for Pb in Stark County. The nearest downwind
ambient air monitors reporting Pb data to EPA's AQS are approximately 69 km east southeast of
the Republic Steel ambient air monitoring site in adjacent Columbiana County, Ohio. The three
Columbiana County ambient air monitors are all located in Liverpool, Ohio on the border of
West Virginia and Pennsylvania, and 11 km west and upwind of the Lower Beaver Valley,
Pennsylvania 2008 Pb Nonattainment Area, which was designated in 2010.8 As shown in Table
3, the 2019-2021 design values for the three Liverpool ambient air monitors meet the 2008 Pb
8 75 FR 71033 (November 22, 2010) https://www.govinfo.gov/content/pkg/FR-2010-ll-22/pdf/2010-
29405.pdfipage=1
11
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NAAQS.
There are no other ambient air monitors for Pb in the counties surrounding Stark County. The
absence of monitors is consistent with emissions reported in the 2017 National Emissions
Inventory (NEI) discussed under Section 4.5.2 below, which indicates there are no other sources
with actual Pb emissions greater than 0.50 tons per year that warranted a source-oriented monitor
under 40 CFR Part 58 Appendix D, Section 4.5(a). See Table 5 below.
4.5.2 Factor 2: Emissions in Areas Potentially Included Versus Excluded from the
Nonattainment Area
Evidence of Pb emissions sources in the vicinity of a violating monitor is an important factor
in determining whether a nearby area is contributing to a monitored violation. For this factor,
EPA evaluates county-level emissions data for Pb and growth in Pb emitting activities.
Figure 3 is a map of Stark County, Ohio and surrounding areas that shows all sources of Pb
emissions listed in the 2017 NEI (January 2021 version). The January 2021 version of the 2017
NEI was the most current version of the national inventory available in 2022 when these data
were compiled for the redesignation process. Sources with Pb emissions greater than 5 pounds
per year are labeled.
12
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Figure 3. Sources of Pb Emissions in Stark County, Ohio Area based on 2017 NEI9
Sources > 5 lb Pb/vear
Table 4 lists sources located in Stark County depicted in Figure 3 with emissions of Pb greater
than 5 pounds per year for 2016, 2017, 2018, and 2019. Emissions data were derived from the
2017 NEI and Ohio EPA's Emission Inventory System (EIS) for 2016, 2018, and 2019.
Table 4. Sources of Pb Air Emissions Greater than 5.0 Pounds/year in Stark County,
Ohio for 2016, 2017, 2018, and 2019
Facility
Address
Facility Type
Pb Emissions (pounds)
2016*
2017**
2018*
2019*
Republic Steel
Plant
2633 Eighth
Street ME,
Canton, OH
Steel Mill
722.4
1620.5
1324.6
1423.6
United Rolls,
Inc.
1400 Grace
Avenue, NE,
Canton, OH
90.0
122.1
123.2
123.8
Barber/Alliance
Alliance, OH
Airport***
52.6
Timkensteel
Corporation -
1835 Dueber
Avenue, SW,
Steel Mill
35.4
48.6
39.8
26.4
® Source:
https://enviro.epa.go\t/enviro/nei.htm?pType=FACILITY&pYear=2017&pN/ho=NEI&pState=&pState=39&pP
ollutant=&pPolIutant— 743992l&pReport=coimty&pCoimty=&pTier=&pSector=
13
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Harrison Steel
Canton, OH
Plant
Marathon
2408
Petroleum
27.0
37.7
33.8
31.2
Petroleum
Gambrinus
Refinery
Company LP -
Avenue SW,
Canton
Canton, OH
Refinery
Beach City
Beach City,
OH
Airport***
33.8
Tim ken steel
1835 Dueber
Steel Mill
18.4
32.6
36.4
26.4
Corporation -
Faircrest Steel
Avenue, SW,
Canton, OH
Plant
Minerva
Minerva, OH
Airport***
17.2
Sunset Strip
Marlboro, OH
Airport***
15.5
Yoder
Louisville, OH
Airport***
11.6
Ironrock
1201 Millerton
Brick,
7.0
6.6
6.6
7.4
Capital, Inc.
Road SE,
Canton, OH
Structural Clay,
or Clay
Ceramics Plant
**
***
Source: Ohio EPA, Emissions Inventory System, https://epa.ohio.gov/divisions-and-
offices air-pollution-control reports-and-data download-eis-data-and-reports
Source: 2017 NEI, https://www.epa.gov/air-emissions-inventories/2017-national-
emissions-inventory-nei-data
Emissions data for airport sources (there are approximately 20,000 airport facilities in the
U.S. at which leaded aviation gasoline is consumed) were derived from the 2017 NEI.
EPA recognizes that we have no information on emissions changes that may have
occurred at airport sources since 2017.
Of the sources listed in Table 4, the predominant source, and only source with Pb emissions
greater than 0.1 tons per year (i.e., greater than 200 pounds/year), is Republic Steel's plant at
2633 Eighth Street NE, Canton, Ohio 44704-2311. This plant accounted for 80% of the 2017
total Pb emissions from all the sources in Stark County that were reported in the 2017 NEI.
To evaluate growth in Pb emitting activities, EPA considered annual emissions from the sources
in Table 4 from 2016 to 2020. The Pb air emissions from the Republic Steel plant have increased
since 2016 from 722.4 lb to 1423.6 lb in 2019. As noted in Section 4.2 above, on December 12,
2016, Ohio EPA issued a Permit-to-Install to Republic Steel to make operational changes to its
plant at 2633 Eighth Street NE, Canton, Ohio.
In addition to sources in Stark County, EPA also evaluated potentially contributing sources in
counties around Stark County. Table 5 shows sources located in the counties surrounding Stark
County that emitted greater than 0.1 tons of Pb based on emissions data derived from the 2017
NEI. As described in EPA's 2008 "Proposed Lead NAAQS Regulatory Impact Analysis," Pb
particles in the air tend to deposit rapidly with distance from the source according to their
particle size and weight, and lead air concentrations in some cases can display significant
14
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gradients with distance from a source-oriented monitor.10 As discussed more fully below in
Section 4.5.6, a polar plot centered on the Republic Steel ambient air monitor shows the Pb
concentrations reach as low as nearly 0.0 [j,g/m3 within the windspeed variability a few blocks
from the Republic Steel parcel, indicating that the majority of Pb detected at the Republic Steel
ambient air monitoring site is coming only from the Republic Steel plant. Located several
kilometers outside the Republic Steel parcel, the sources in Table 5 are not anticipated to be
contributing to violations of the 2008 Pb NAAQS at the Republic Steel ambient air monitoring
site. Figure 4 is a map of counties surrounding Stark County and the locations of sources listed in
Table 5.
Table 5. Facilities Located in Counties Surrounding Stark County, Ohio with Pb
Emissions Greater than 0.1 tons/year (200 lbs) in 2017
Cou illy
l-'acilitv
City
l-'acility
Type
Approximate
Distance from
Monitoring
Site (km)
2017 m:i
Pb
Kmissions
(lbs)
Wayne
Wayne County
Wooster
Airport
50
482.4
Mahoning
Vallourec Star, LP
Youngstown
Steel Mill
66
471.8
Medina
Weltzien Skypark
Wadsworth
Airport
42
437.9
Medina
Medina Municipal
Medina
Airport
51
436.6
Tuscarawas
Dover Municipal
Light Plant
Dover
Electricity
Generation
34
434.0
Summit
Kent State
University
Kent
Airport
39
393.7
Summit
City of Akron
Steam Generating
Akron
Steam /
Heating
Facility
35
380
Tuscarawas
Harry Clever Field
New
Philadelphia
Airport
37
301.5
Summit
Akron-Canton
Regional
Akron
Airport
16
271.5
Mahoning
Youngstown Elser
Metro
Youngstown
Airport
58
259.9
10 "Proposed Lead NAAQS Regulatory Impact Analysis" U.S. EPA Office of Air Quality Planning and Standards
(June 2008). Section 2.2 Air Quality Modeling on page 2-5 states, "This may be particularly true for Pb as
metals tend to deposit rapidly with distance from the source according to their particle size and weight." Section
5.5 Radius Method on page 5-18 states, "[L]ead air concentrations can in some cases display significant
gradients with distance from a source-oriented monitor."
https://www3.epa.gov/ttnecasl/regdata/RJAs/pb_ria_6-25-08_proposal.pdf
15
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Figure 4. Locations of Sources of Pb Emissions Greater than 0.1 tons/year in 2017 in
Counties Surrounding Stark County, Ohio
Star* County
Kent State University Airport
Vallourec Star, LP Steel Mill
Medina Municipal Airport
City of Akron Steam Generating
Youngstown Elser Metro Airport
Weltzien Skypark Airport
Akron-Canton Regional Airport
Republic Steel Ambient Air Monitor
Wayne County Airport
Dover Municipal Light
Harry Clever Field Airport
Medina County
4.5.3. Factor 3: Level of Control of Emissions Sources
Under this factor, EPA considers the existing level of control of emissions sources. The
emissions data used by EPA in this technical analysis and provided in Tables 4 and 5 above
represent emissions levels taking into account any control strategies implemented on stationary
sources in Stark County by 2020 and in the surrounding counties by 2017.
The predominant source of Pb emissions in Stark County, the Republic Steel plant (Facility ID
1576050694), operates under a Title V permit (P0101210) and a synthetic minor New Source
Review permit specifically for Pb. Emissions at the facility are subject to Ohio EPA rules,
regulations, and orders. Emissions controls for Pb include the Continuous Bloom Casting
Facility main Ladle Metallurgical Facility baghouse, FlexCast baghouse, and Meltshop
baghouse. Emissions include fugitive emissions from the Continuous Bloom Casting Facility,
FlexCast Building, and Meltshop Building.11
11 Ohio EPA Director's Final Findings and Orders, May 14, 2019.
http:ffedocpub.epa. ohio.gov/pu blicportaM'iewDocument. aspx?docid= 1063293
16
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4.5.4 Factor 4: Population Density and Degree of Urbanization including Commercial
Development in Included Versus Excluded Areas
The analysis for this factor considered population density for 2010-2020 in the area considered
for the redesignation to nonattainment. Table 6 shows the 2010 and 2020 population data for
Stark County and Canton, Ohio. 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 Pb levels. This may
include ambient Pb contributions from activities that would disturb Pb that has been deposited on
the ground or on other surfaces. Re-entrainment of historically deposited Pb typically is not
reflected in the emissions inventory. The EPA does not believe the population data provided in
the analysis of this factor affect the boundary recommendation.
Table 6. Population and Population Density Data for Canton and Stark County, Ohio
Area
2010
Population*
2020
Population*
2010
Population
Density
(population /
square
mile)--
2020
Population
Density
(population
square
mile)--
Stark County, Ohio
375,586
374,853
652.9
651.6
Canton, Ohio
73,007
70,872
2,867.3
2,805.7
Source: U.S. Census Bureau estimates for 2010 and 2020
(ihttps://www.census.gov/quickfacts/fact/table/US/PST045221)
Based on 25.26 square miles for Canton, Ohio and 575.27 square miles for Stark County,
Ohio.
4.5.5 Factor 5: Expected Growth
This factor considers population growth for 2010-2020 in the area evaluated for the
redesignation to nonattainment. Table 7 shows the population change for Canton and Stark
County, Ohio from 2010 to 2020.
Table 7. Change in Population and Population Density from 2010 to 2020 for Canton and
Stark County, Ohio
Area
Population
Population %
Population
Population
Change 2010 -
Change 2010 -
Density
Density %
2020
2020
Change
(pop/sq mi)-
2010 - 2020
Change 2010 -
2020
Stark County, Ohio
-733
-0.2
-1.3
-0.2
Canton, Ohio
-2135
-2.9
-61.6
-2.1
* Based on 25.26 square miles for Canton, Ohio and 575.27 square miles
br Stark County,
17
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Ohio.
** Source: U.S. Census Bureau estimates for 2010 and 2020
(ihttps://www.census.gov/quickfacts/fact/table/US/PST045221)
From 2010 to 2020, population in Stark County declined by 0.2%, while population in the City
of Canton declined by 2.9%. For the same time period, population density in Stark County
declined by 0.2%, while population density in the City of Canton declined by 2.1%. The EPA
has considered the growth rate for the population and population density for this area and does
not believe that it affects the boundary determination.
4.5.6. Factor 6: Meteorology
For this factor, EPA evaluates meteorological data to determine how weather conditions,
including wind speed and direction, affect the plumes from sources contributing to the ambient
Pb concentrations. Figure 5 below depicts a wind rose covering the 51-year period of
meteorological records from 1970 to 2021 from the National Weather Service meteorological
station at the Akron-Canton Airport in Akron, Stark County, Ohio near the Republic Steel
ambient air monitoring site, 16 kilometers away. These data help depict the potential for Pb
emissions sources located near a violating monitor to contribute to ambient Pb levels at the
violation location.
The wind rose depicts frequency and magnitude of wind speed and direction. The wind rose
shows the distribution of wind direction independently from wind speed by dividing the data into
36 wind directions and six wind speed classes in addition to calm conditions. As shown in Figure
5, winds blow predominantly from the southwest 5% of the time at speeds of 16 - 24 kilometers
per hour (10 - 15 miles per hour) 1.7% of the time.
18
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Figure 5. Wind Rose for North Canton, Stark County, Ohio
Wind Speed [mph]
¦¦ 2-5 ¦¦ 5-7 7-10 10-15 ¦ 15-20 ¦¦ 20 +
COM MEM'S
DATA PERIOD
IMAGE GENERATED BY
Wind Rose is centered
on Akron-Canton
Airport, North Canton,
Stark County. Ohio.
Start Date: 01/01/1970
End Date: 08/09/2021
Iowa State University's
Iowa Environmental Mesonet (IEM)
https://mesonet. agron. iastate. edu/sites/locate.php
Data provided by
National Weather
Service Data.
Summary
obs count: 508657
Missing: 5725
Avg Speed: 9.4 mph
[CAK] Akron / Canton
Windrose Plot
Time Bounds: 01 Jan 1970 02:00 AM
- 09 Aug 2021 01:51 AM America/New York
Calm values are < 2,0 mph
Arrows indicate wind direction.
Generated: 09 Aug 2021
Evidence of source-receptor relationships between specific emissions sources and high Pb
concentrations at violating monitors is another important factor in determining the appropriate
contributing areas and the appropriate extent of EPA's nonattainment area.
19
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Figures 6 and 7 below, generated by EPA, depict a pollution rose and polar plot centered at the
Republic Steel ambient air monitoring site (AQS Site No. 39-151-0024) covering the 3-year
design value period from 2018-2020. The pollution rose and polar plot were developed using
open-source software in the coding language, R. The graphical user interface, RStudio, was used
along with the open-source R packages, openair and openairmaps.12 Figures 6 and 7 are based
on data from a local meteorology site, which was only available from October 2018 through
December 2020.
As shown in Figure 6, the pollution rose illustrates the frequency distribution of wind direction
correlated with Pb concentrations. The pollution rose is divided into 24 wind directions and five
concentration ranges. Pb concentrations are based on the mean daily readings from the Republic
Steel ambient air monitoring site corresponding with the available meteorology data during
October 2018-December 2020.13 Of the winds from the east that reach the Republic Steel
ambient air monitoring site, Figure 6 shows that approximately 1% of the winds range in Pb
concentration from 0.075 to 0.30 (J,g/m3, and 1% of the winds range from 0.15 to 0.30 [j,g/m3. Of
the winds from the west northwest, Figure 6 shows that approximately 8% of the winds range in
Pb concentration from 0.075 to 0.15 (J,g/m3, 1% of the winds range from 0.15 to 0.30 (J,g/m3, 1%
of the winds range from 0.30 to 1.00 (J,g/m3, and 1% of the winds range from 1.00 to 1.87 [j,g/m3.
12 Carslaw DC, Ropkins K (2012). "openair - An R Package for air quality data analysis." Environmental
Modeling & Software, 27-28(0), 52-61. ISSN 1364-8152, doi: 10.1016/j.envsoft.2011.09.008.
13 EPA AirData Air Quality Monitors, Daily Data for 2018 - 2020
https://epa.maps. arcgis.com/apps/webappviewer/index. html?id=5f239fd3e72f424J98eJ3 d5deJ547eb5&extent=-
146.2334,13.1913,-46.3896,56.5319
20
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Figure 6: Pollution Rose for Pb Concentrations from Republic Steel Ambient Air
Monitoring Site (AQS Site No. 39-151-0024), Canton, Stark County, Ohio
t
I
moan - Q.OaeeM
odm = 0%
Concentration by Frequency
1 to 1.87
0.3 to 1
0.075 to 0.15
Pb {Lig m )
Frequency of counts by wind direction (%)
COMMENTS
Pollution Rose is centered on the Republic
Steel Pb Ambient Air Monitoring Site (AQS
Site No. 39-151-0024), 3150 Georgetown
Road NE, Canton, Stark County, Ohio.
Local meteorological data was obtained
from a local meteorology site and was only
available from October 2018 through
December 2020. This figure only shows
concentration data when winds were above
calm (>0.45 m s"1) and during the
timeframe when meteorology data was
available (October 2018 - December 2020).
DATA PERIOD
Start Date:
End Date:
01/01/2018
12/31/2020
CALM WINDS
0%
IMAGE GENERATED
BY
U.S. EPA, Region 5
SOFTWARE
R coding language
21
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Figure 7 is a polar plot centered around the Republic Steel ambient air monitoring site (AQS Site
No. 39-151-0024) and superimposed on a map of the local area. The map also shows an outline
of the Republic Steel parcel across the street at 2633 Eighth Street NE in Canton, Ohio. Polar
plots are used to visualize mean pollutant concentrations across an area that vary by wind speed
and wind direction. The concentric circles in the polar plot show wind speed in 0.5
meters/second (m/s) intervals. Superimposing a polar plot on a map is useful in exploring source
directions of atmospheric pollutants. As shown in Figure 7, the polar plot demonstrates that a
majority of Pb detected at the Republic Steel ambient air monitoring site is coming from the
northwest and is distributed according to the concentration color palette. The highest Pb levels of
0.25 pg/m3 and greater are observed when wind is blowing from the northwest at speeds of 1.25
- 2.5 m/s. Pb concentrations are lower and less than 0.05 ug/nr' when wind is blowing from the
south and east.
Figure 7. Polar Plot Map of Mean Pb Ambient Air Concentrations (October 2018 -
December 2020)
N
A
1.2 Miles
I
A *
% PRO^
Service Layer Credits: Stark County
GIS, Esri, HERE, Garmin, SafeGraph,
INCREMENT P, MET1/NASA, USGS, EPA,
NPS, US Census Bureau, USDA
Pb (na m"1)
22
-------
For this area, winds can be from any direction. Therefore, sources in all directions can have some
potential contribution. However, as noted in Section 4.5.2., Pb particles in the air tend to deposit
rapidly with distance from the source according to their particle size and weight. The Republic
Steel plant is the closest NEI source to the Republic Steel ambient air monitoring site and is the
only source in Stark County with Pb emissions greater than 0.1 tons per year, and accounts for
80% of the Pb emissions from all the sources in Stark County that were reported in the 2017
NEI. Based on the Pb concentration frequencies in the pollution rose and polar plot in Figures 6
and 7, the majority of Pb detected at the Republic Steel ambient air monitoring site is coming
from the northwest, where the Republic Steel plant is located; this analysis indicates that the
Republic Steel plant is the primary contributor to the violations at the monitoring site. With wind
directionality potentially affected by building downwash and vehicular traffic, elevated Pb levels
at the Republic Steel ambient air monitoring site might also be coming from the north
corresponding to the location of the larger emission sources at Republic Steel.
4.5.7 Factor 7: Geography/topography
The geography/topography analysis evaluates the physical features of the land that may have an
effect on the airshed and, therefore, on the distribution of Pb over the nonattainment area in Stark
County.
Stark County does not have any geographical or topographical barriers significantly limiting air
pollution transport within its airshed. The terrain in Stark County is generally flat, rising in
elevation from approximately 1,000 feet above mean sea level in the western portion of the
county to 1,200 feet above mean sea level in the eastern portion of the county.14 There are no
mountain ranges, basins, or other physical features that may affect distribution of emissions that
would define area boundaries.
4.5.8 Factor 8: Jurisdictional Boundaries
Existing jurisdictional boundaries may be helpful in determining a boundary for purposes of the
redesignation to nonattainment, and for purposes of carrying out the governmental
responsibilities of planning for attainment of the Pb 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. We typically base designations on clearly defined legal boundaries that
align with existing administrative boundaries, when reasonable.
In accordance with the 2008 Pb NAAQS final rule, the presumptive boundary of the
nonattainment area is the entire county with a violating monitor as described above under
Section 4.1. The State and/or EPA may conduct additional area-specific analyses that could lead
14 EPA AirData Air Quality Monitors, Topographic Basemap,
https://epa.maps. arcgis.com/apps/webappviewer/index. html?id=5f239fd3e72f424J98eJ3 d5deJ547eb5&extent=-
146.2334,13.1913,-46.3896,56.5319
23
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to a departure from the presumptive boundary.
The Republic Steel plant and violating ambient air Pb monitoring site (AQS Site No. 39-151-
0024) are located within a small portion of the jurisdictional boundary of Stark County, Ohio.
Based on the directionality of elevated Pb concentrations depicted in the pollution rose and polar
plot in Figures 6 and 7, the absence of other contributing sources, and the consideration of the
other seven factors above, EPA's nonattainment area is smaller than the entire county.
Rather than jurisdictional boundaries, EPA's nonattainment area is centered around the Republic
Steel plant and is bounded by the following major roadways within Canton, Ohio:
North: State Route OH-153 (12th Street NE; Mahoning Road)
East: Broadway Avenue
South: State Route OH-172 (Tuscarawas Street E; Lincoln Street E)
West: State Route OH-43 - Northbound (Cherry Avenue NE)
EPA's determined nonattainment area includes the area surrounding the violating monitor, the
source most likely contributing to the violating monitor, the area where Pb concentrations in the
ambient air violate the 2008 Pb NAAQS, and boundaries that are easily recognizable by the
public.
4.5.9 Additional Information provided by the State
In addition to an analysis of the eight factors above, states can choose to recommend Pb
nonattainment boundaries by using any one, or a combination, of the following techniques (73
FR 67033):
• Qualitative analysis;
• Spatial interpolation of air quality monitoring data; or
• Air quality simulation by dispersion modeling.
These techniques are more fully described in "Procedures for Estimating Probability of
Nonattainment of a PM-10 NAAQS Using Total Suspended Particulate of PM-10 Data,"
December 1986. See 57 FR 13549.
When EPA notified the State of Ohio regarding our intended redesignation on April 26, 2022,
EPA provided a 120-day period for the state to respond and encouraged the state to provide
additional information relevant to establishing a nonattainment area boundary for this area. On
August 22, 2022, Ohio responded by concurring with EPA's intended boundaries for the
proposed nonattainment area.
4.6 Summary of EPA's Assessment and Redesignation for the Canton, Ohio Area
The Republic Steel ambient air monitoring site in Stark County indicates violations of the 2008
Pb NAAQS based on the 2019-2021 design value. Under CAA section 107(d)(1), following
promulgation of a new or revised NAAQS, EPA must designate areas that violate the NAAQS
24
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and nearby areas that contribute to the violations as nonattainment areas. Although Stark County
was designated as unclassifiable/attainment in 2011, the EPA Administrator may notify the state
at any time that a designation should be revised. See CAA section 107(d)(3). After careful
evaluation of the information in this TSD, and considering the state's concurrence on EPA's
intended redesignation, EPA is redesignating a portion of Stark County, specifically around
Canton, Ohio, as nonattainment for the 2008 Pb NAAQS. To determine the geographic extent of
the nonattainment area in Stark County, EPA evaluated the eight factors in the 2008 EPA Pb
Guidance.
The Republic Steel and Republic Community ambient air monitoring sites (AQS Site Nos. 39-
151-0024, 39-151-0025) are the only Pb monitoring sites that report to EPA's AQS in Stark
County, and Columbiana County is the only surrounding county with such Pb monitoring sites.
Of these monitoring sites, only the Republic Steel monitoring site measured violations of the
2008 Pb NAAQS, with a 2019-2021 design value of 0.40 [j,g/m3. The remaining three
monitoring sites with design values, located approximately 69 kilometers southeast in
neighboring Columbiana County, are well below the 2008 Pb NAAQS with a 2019-2021 design
value of 0.01 [j,g/m3.
The Republic Steel plant, located at 2633 Eighth Street NE, Canton, Ohio, is the largest source of
Pb emissions located near the violating monitor (AQS Site No. 39-151-0024) and the only source
in Stark County with Pb emissions greater than 0.1 tons per year. Other sources of Pb emissions
greater than 0.1 tons per year in surrounding counties were more than 15 kilometers away and, as
noted in Section 4.5.2., are not anticipated to contribute to violations of the 2008 Pb NAAQS at
the Republic Steel ambient air monitoring site. The Pb concentration frequencies depicted in the
pollution rose and polar plot in Figures 6 and Figure 7 demonstrate the majority of Pb detected at
the Republic Steel ambient air monitoring site is coming from the west northwest, in the
direction of the Republic Steel plant. As such, the relevant information indicates the Republic
Steel plant is the primary contributor to the violations at the monitoring site for the 2019-2021
design value period.
Based on the directionality of elevated Pb concentrations, as depicted in the pollution rose and
polar plot in Figures 6 and 7, as well as the absence of other contributing sources and
consideration of the eight factors above, EPA's nonattainment area is centered around the
Republic Steel plant and is smaller than the presumptive county-wide boundary in the 2008 Pb
NAAQS final rule. The technical analysis shows that the excluded portions are not source areas
that contribute to the observed violations.
After considering the factors above, EPA's revision to the area's designation is to designate the
area to nonattainment, and to establish the boundaries of the nonattainment area to encompass
the area surrounding the violating monitor (AQS Site No. 39-151-0024), the source most likely
contributing to the violating monitor, and the area that does not meet the 2008 Pb NAAQS.
Population, expected growth, geography, and topography did not play a significant role in
determining the nonattainment boundary.
The nonattainment area, bounded by the following major roadways within Canton, Ohio, will
25
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have clearly defined boundaries, and we find these boundaries to be a suitable basis for defining
the nonattainment area.
North: State Route OH-153 (12th Street NE; Mahoning Road)
East: Broadway Avenue
South: State Route OH-172 (Tuscarawas Street E; Lincoln Street E)
West: State Route OH-43 - Northbound (Cherry Avenue NE)
Figure 8 shows the boundaries of this designated area.
26
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Figure 8. Boundaries of the Canton, Ohio Nonattainment Area for the 2008 Pb NAAQS
Center
PLAIN * CITY
Nimishillen
M alone Univerjiiy
COLONIAL
HEIGHTS
Heights
COLONIAL
HEIGHTS
HISTORIC
RIDGEWOOD
OAK PLACE
VASSAR PARK
GIBBS AREA
Lynn Center Park
DOWNTOWN
Canton
CONCER1
1TIZENS OF 4TH
EW HOPE
ESTATES
Clear View
Heights
Legend
Violating Pb Monitor 39-151-0024 (2019 - 2021 Design Value)
~
Perimeter of Pb Source > 0.5 tons/year (2017 NEI),
Republic Steel, 2633 Eighth Street NE, Canton, Ohio, Stark County
EPA's Nonattainment Boundary
North: State Route OH-153 (12th Street NE, Mahoning Road)
East: Broadway Avenue
South: State Route OH-172 (Tucarawas Street E, Lincoln Street E)
West: State Route OH-43 - Northbound (Cherry Avenue NE)
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