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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. 

Alabama

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 Alabama that EPA is designating
“nonattainment” for the 2008 lead national ambient air quality
standard (2008 Lead NAAQS).  

Table 1:  Area Designation

Area (listed alphabetically)	Alabama Recommended Nonattainment Counties
EPA’s Designated Nonattainment Counties	Nonattainment area for 1978
Lead NAAQS

Troy, Alabama	None	Pike (partial)

	No



Technical analysis for Troy

Introduction  

This technical analysis for the Troy Area identifies the partial county
with a monitor that violates the 2008 Lead NAAQS for contributions to
lead concentrations in the area.  EPA has evaluated Troy, Alabama 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).

Figure 1:  Pike County Area of Troy, Alabama

 

Figure 2:  Troy, Alabama Area and Surrounding Counties

Figures 1 and 2 are maps of the area analyzed showing the location and
design value of the air quality monitor in the area, the counties
surrounding the violating air quality monitor, and the state’s
recommended area to be designated.  The violating monitor in the Troy
Area is located in Pike County, in close proximity to Sanders Lead
Company, shown in Figure 1.

The Troy Area was not designated nonattainment for the 1978 Lead NAAQS. 
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 1, 2009, Alabama recommended that a portion of Pike County be
designated as “nonattainment” for the 2008 Lead NAAQS based on air
quality data from 2006-2008.  Their recommendation was based on data
from Federal Reference Method monitors located in the state, as well as
their own analyses of the recommended factors and air quality modeling. 
Subsequently, on October 26, 2009, EPA received a revised letter of
recommendation from Alabama with a request to designate a portion of
Pike County as “unclassifiable.”  

Based on EPA's technical analysis described below, EPA is designating
the entire portion of Pike County, Alabama, within a 0.8 mile (1.3 km)
radius from a center point at latitude 31.78627106 and longitude
85.97862228, which fully includes the Sanders Lead Facility, as
nonattainment for the 2008 Lead NAAQS as the Troy 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 the air
quality monitor in Pike County in the Troy 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.

The 2008 Lead NAAQS design values for Pike County in the Troy 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)

Pike County, AL	No

011090003	Henderson Road	1.35	1.35



	011090006	Henderson Road	0.50	0.31

Monitors in Bold have the highest design value in the respective county.

Pike 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 Pike County are in close proximity to
Sanders Lead Company, Sanders Road, Troy, Alabama.  The monitoring
objective, according to the EPA monitor locator, is to determine the
highest concentration of lead.  The emissions from Sanders Lead Company
and other area lead emitters will be discussed in the corresponding
section. 

 

The State of Alabama provided similar information from these monitors in
their October 2009 letter.  The State information is consistent with the
data provided by EPA, although the reported results are slightly
different because of different reporting periods used.  In addition,
Alabama provided data from monitors owned by Sanders Lead Company sited
near this facility.  These monitors (Anderson and Murphree) are at a
slightly greater distance from the facility and located to the southwest
and northwest of the facility.  The reported maximum rolling three month
average lead concentrations from these sites are 0.31µg/m3 and 0.19
µg/m3 for the period from November 2005 to August 2009.  These values
are also in excess of the new lead NAAQS of 0.15 µg/m3.

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 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   HYPERLINK
"http://www.epa.gov/ttnchie1/net/2005inventory.html" 
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.  Some States provided updated information on
emissions and emission controls in their comments to EPA.  Alabama
provided emissions information for the Troy Area from the 2005 NEI,
therefore EPA relied on the 2005 NEI emissions data.  These data are
provided in Table 3.

Table 3 shows total emissions of lead (given in tons per year (tpy)) for
violating and potentially contributing counties in the Troy Area with
sources emitting (or anticipate to contribute) greater than 0.1 tpy of
lead according to the 2005 NEI.  

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.  

Table 3.  Lead Emissions

County	Facility in State

Recommended Nonattainment Area?	Facility Name	Facility Location	Total
Lead Emissions

(tpy)

Pike County	No*	Sanders  Lead Company	100 Sanders Road, Troy	4.44

* In Alabama’s October 26, 2009, revised letter of recommendation, the
State requested a portion of Pike County, within a 0.8 mile (or 1.3 km)
radius from a center point at latitude 31.78627106 and longitude
85.97862228, which fully includes the Sanders Lead Facility, be
designated as “unclassifiable.”  However, Alabama mentioned in their
letter that if EPA determines this request to be unfeasible, Alabama
requests for the portion of Pike County within a 0.8 mile (or 1.3 km)
radius from a center point at latitude 31.78627106 and longitude
85.97862228, which fully includes the Sanders Lead Facility, be
designated as “nonattainment.”  The facility is within the state’s
recommended boundary.

According to the 2005 NEI data, Pike County has one source (Sanders Lead
Company) emitting at or above 0.1 ton per year.  There are no other
stationary sources emitting greater than 0.1 tpy located within Pike
County, nor any major sources of lead in the counties surrounding Pike
County.

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

City	Facility Name	Type	2008 draft NEI (tpy)	Distance to Violating
Monitor (km)

Pike County	Troy Municipal

	Airport	0.1	8.83



There is one airport facility with aircraft using leaded aviation gas in
Pike County that emits at or above 0.1 ton per year.  Troy Municipal
Airport is located approximately 8.83 km from Sanders Lead Company.    

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

Pike County	No	30.381	45	647	2

[Source of data: U.S. Census Bureau estimates for 2008 (  HYPERLINK
"http://www.census.gov/popest/datasets.html" 
http://www.census.gov/popest/datasets.html ) and estimation of the area
of U.S. Counties]

Growth rates and patterns  

Pike County shows a population change of two percent between 2000 and
2008.  EPA has considered the population growth rate for this area and
does not believe that it affects the boundary recommendation.

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 Troy area
before 2005 on stationary sources.  As mentioned above, on October 26,
2009, EPA received a revised letter of recommendation from Alabama with
a request to designate a portion of Pike County as “unclassifiable.”
 This letter stated that the Alabama Department of Environmental
Management (ADEM) has met with the source in Pike County to discuss
potential mitigation measures for achieving compliance with the new lead
standard.  According to Alabama’s letter, the source has shown
willingness to enclose the processes at the facility in order to abate
lead emissions.  This method has proven successful when used at other
similar facilities, and should greatly reduce ambient lead
concentrations if implemented at Sanders Lead in Pike County, Alabama.  

Meteorology (weather/transport patterns)

For this factor, EPA considered data from National Weather Service (NWS)
instruments and other meteorological monitoring sites in the area,
usually associated with major airport operation.  A three-dimensional
bar chart shows the wind frequencies in eight directions, for the four
seasons, based on thirty two years of historical data for the Troy 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:  Pike County Historical Wind Direction Frequency

 

As seen in Figure 3 above, the predominant wind direction in the Winter
season is originating from the West/Northwest (WNW), while in the Spring
season it is from the South/Southwest (SSW), in the Summer it is from
the East/Southeast (ESE), and in the Autumn it is from the
East/Northeast (ENE), indicating that lead sources located in any
direction from the monitoring site in Troy could influence the monitored
ambient air concentrations during different time periods.  

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 three percent of the time the wind speeds are between 2.1
– 3.6 meters/second (m/s)).  

Figure 4:  Troy Wind Rose; Montgomery Airport

Annual Wind Rose – 30 years (1961-1990)

Figure 4 provides an annual wind rose diagram for the Troy 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 Montgomery Airport (NWS Station No. 13895).  This station
has the most representative long-term record of wind data for area near
Montgomery, including the lead monitoring site located in the Troy Area.

The Troy Area wind rose is consistent with the wind direction bar chart
in Figure 3 above and indicates that the wind does not blow from a
strongly predominant wind direction.  The winds blow from each direction
at least three percent of the time, and from most directions more than
five percent of the time.  The highest frequencies of winds are from due
East (approx eight percent), due North (approx seven percent), and due
South (approximately seven percent).  The wind speeds also vary with no
strongly predominate speed category either.  However, more than 50
percent of the time, the wind speeds are less than 3.6 m/s.  It is also
important to note that winds are classified as calm (less than 0.5 m/s)
approximately 15 percent of the time.  The wind rose indicates that lead
sources located in any direction from the monitoring site in the Troy
Area could influence the monitored ambient air concentrations during
different time periods.  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.

Additionally, in evaluating the Alabama climatological data for 2007,
the statewide temperatures for the year were above normal and the
statewide precipitation for the year was much below normal (see attached
charts).  In fact, Alabama was ranked as the 3rd driest state for 2007
according to the rankings from the National Oceanic and Atmospheric
Administration.  See the following figures for more detail.  Alabama
attributes the prolonged warm and dry weather that lasted throughout the
year as a factor in elevating emissions from soils in 2007 and resulting
in monitored lead concentrations for that time period that were higher
than other years.  

 

 

Alabama attributes the prolonged warm and dry weather that lasted
throughout the year to exacerbate lead concentrations in the soil.  As a
result, monitored lead concentrations for that time period were higher
than previous years.  EPA’s evaluation of the monitoring data during
and just after this period of time, revealed the highest level of
monitored values.  The highest value of all of the 3-month rolling
average for the 2007-2009 period occurs in December of 2007 at a level
of 1.35 µg/m3.  Other monitoring values in that time period include
1.07 µg/m3 for the November 2007 3-month rolling average; 1.18 µg/m3
for January 2008; 1.15 µg/m3 for February 2008; 1.02 µg/m3 for March
2008; and 1.05 µg/m3 for April 2008.  The 3-month rolling averages,
excluding the period of November 2007 through April 2008, range from
0.10 µg/m3 to 0.78 µg/m3.  

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 Troy Area.

The Troy 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.

The Troy Area does not have any jurisdictional boundaries that affect
this analysis.  Therefore, this factor did not play a significant role
in determining the nonattainment boundary.

Other Relevant Information

EPA received additional information relevant to designating this area
pertaining to modeling that was performed by the State of Alabama.  The
American Meteorological Society/Environmental Protection Agency
Regulatory Model (AERMOD) modeling system was used in the lead
designation boundary modeling.  The AERSURFACE tool was also used to
generate the surface characteristics.  Only emission sources from
Sanders Lead were modeled using Title V permit and facility data. 
However, other sources that may locally impact the state monitors were
not modeled.  These less than 0.1 tpy sources, which are all well within
the State’s recommended boundary, include K W Plastics (a recycling
facility), and reentrained lead emissions from a railroad and major
roadway that borders the Sanders Lead facility.

Downwash was considered for all Sanders Lead stacks in the modeling. 
The AERMOD system was simulated twice, using both Montgomery NWS Airport
site and the Sanders Lead facility surface characteristics, since site
specific meteorological data at Sanders Lead was unavailable. The model
was simulated twice in this manner because the State conservatively
decided to utilize the surface characteristics around both sites in all
modeling and reported the highest concentrations between the two.  

As required by EPA modeling guidance in 40 CFR Part 51 Appendix W: 
Guideline on Air Quality Models, the State included five years (i.e.,
2001-2005) of meteorological data.  The AMS/EPA Regulatory Model Terrain
Pre-processor program inputs were developed with National Elevation
Data.  AERMOD was simulated using default modeling inputs.  A 10 km by
10 km discrete Cartesian receptor grid was used in the modeling analysis
with grid spacings of 100 meters.  The maximum 3-month rolling
concentration of 0.779 µg/m3 was modeled near the location of the
Sanders Lead stacks.  As mentioned above, excluding the November 2007
through April 2008 time period, the monitored 3-month rolling
concentrations ranged from from 0.10 µg/m3 to 0.78 µg/m3, which is in
line with the modeled values.  As noted above, Alabama attributes the
highest design values to a period of time where there was unusually dry
weather and many areas in the state were under drought conditions. 
Despite the fact that these sources were not modeled from the facility,
the southwest yellow contours shown in the following plots from the
State modeling agree with design value of 0.19 µg/m3 from the Sanders
Lead-owned Murphee monitor.  The modeling contours and the data from the
second state monitor indicate that the lead concentrations rapidly
decrease with distance from the industrial area, railroad and roadway
such that predicted quarterly lead concentrations would be below the
NAAQS (i.e., >0.15 µg/m3) well within the recommended boundary of 0.8
mile (or 1.3 km) radius from a center point at latitude 31.78627106 and
longitude 85.97862228, which fully includes the Sanders Lead Facility. 
The maximum predicted concentration at the outer edge of the State’s
recommended nonattainment boundary is less than 50 percent of the NAAQS
(0.072 µg/m3.

EPA reviewed the modeling analysis included in Alabama’s
demonstration.  The results of that review are summarized below:

Sanders Lead, Troy, Alabama – Pike County

AERMOD Modeling

Source characterization

If any fugitives, how were they characterized?    No

Did stacks use defaults or actual parameters?   Used data from Sanders
Lead and considered downwash

What is the emissions year?  There is no emissions year.  The emissions
used in the Sanders Lead Designation modeling performed by ADEM
represent the allowable emissions for the units, not the actuals.  This
allows for additional conservatism in the modeling.

What is the source of the emissions (NEI or other)?  Title V permit
emissions

	Emission rate (g/s)	X (meters)	Y (meters)	Base elev (meters)	Stack
height (meters)	Stack Temp (K)	Stack exit vel (m/s)	Stack diameter (m)

STACK22	0.60000E-01  	596668.6	3517149.0	162.0	54.86	366	36.27	1.20

STACK22	0.60000E-01  	596701.9	3517158.2   	161.2	54.86	366	36.27	1.20

STACK24A	0.30000E-01  	596744.4	3517284.0   	161.7	27.43	339	32.31	0.90

Stack24B	0.30000E-01	596648.4	3517188.2   	161.2	27.43	339.	32.31	0.90

STACK27  	0.20000E-01  	596754.1	3517148.0   	156.4	9.14	294.	18.29	1.10



Were actual emissions used or potential emissions  -  assumed potential
emissions

Were multiple sources modeled or single source modeling done?  Only
emission sources from Sanders Lead were modeled.

 

Meterology

Years and stations used-  2001-2005 Montgomery (MGM) AL NWS (72226
)(sfc); Alabaster (53823) (upper air)

Was meteorological data representative of source(s), temporally and
spatially (surface characteristics) - The AERMOD system was simulated
twice using both Montgomery NWS Airport site and the Sanders Lead
facility surface characteristics since site specific meteorological data
at Sanders Lead was unavailable.

Receptor network

Adequate spatial coverage and adequate receptor spacing?   A 10 km by 10
km discrete Cartesian receptor grid was used in the modeling analysis
with grid spacing of 100 meters.  

Receptors placed in ambient air locations

Terrain included in modeling – Yes, terrain elevations generated using
National Elevation Data.

Output

3-month rolling average contours.  Highest concentration located at on
the facility property.

1st highest modeled concentrations (µg/m3)

Conclusion

After considering the factors described above, EPA has determined that
it is appropriate to include the portion of Pike County as the Troy
nonattainment area for the 2008 Lead NAAQS.  This area is located within
a 0.8 mile (or 1.3 km) radius from a center point at latitude
31.78627106 and longitude 85.97862228, which fully includes the Sanders
Lead Facility.

EPA is basing this nonattainment designation determination and boundary
on the fact that Pike County contains two air quality monitors that show
violations of the 2008 Lead NAAQS, based on 2007-2009 air quality data. 
Additionally, the Sanders Lead facility emits relatively large
quantities of lead that EPA believes caused the violations of the lead
NAAQS at those air quality monitor for this period.  Available modeling
and monitoring data indicates that a boundary within a 0.8 mile (or 1.3
km) radius from a center point at latitude 31.78627106 and longitude
85.97862228, which fully includes the Sanders Lead Facility, 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.

 In Alabama’s October 26, 2009, revised letter of recommendation, the
State requested a portion of Pike County, within a 0.8 mile (or 1.3
kilometers (km)) radius from a center point at latitude 31.78627106 and
longitude 85.97862228, which fully includes the Sanders Lead Facility,
be designated as “unclassifiable.”  However, if EPA determines this
request to be unfeasible, Alabama requests for the portion of Pike
County within a 0.8 mile (or 1.3 km) radius from a center point at
latitude 31.78627106 and longitude 85.97862228, which fully includes the
Sanders Lead Facility, be designated as “nonattainment.” 

 In Alabama’s October 26, 2009, revised letter of recommendation, the
State requested a portion of Pike County, within a 0.8 mile (or 1.3 km)
radius from a center point at latitude 31.78627106 and longitude
85.97862228, which fully includes the Sanders Lead Facility, be
designated as “unclassifiable.”  However, Alabama mentioned in their
letter that if EPA determines this request to be unfeasible, Alabama
requests for the portion of Pike County within a 0.8 mile (or 1.3 km)
radius from a center point at latitude 31.78627106 and longitude
85.97862228, which fully includes the Sanders Lead Facility, be
designated as “nonattainment.”  Both monitors are within the
state’s recommended boundaries.

 This monitor ceased operation in August of 2007.  The maximum 3-month
rolling average was calculated using data for the three month periods
ending from January 2006 through August 2007.

 In Alabama’s October 26, 2009, revised letter of recommendation, the
State requested a portion of Pike County, within a 0.8 mile (or 1.3 km)
radius from a center point at latitude 31.78627106 and longitude
85.97862228, which fully includes the Sanders Lead Facility, be
designated as “unclassifiable.”  However, Alabama mentioned in their
letter that if EPA determines this request to be unfeasible, Alabama
requests for the portion of Pike County within a 0.8 mile (or 1.3 km)
radius from a center point at latitude 31.78627106 and longitude
85.97862228, which fully includes the Sanders Lead Facility, be
designated as “nonattainment.” 

 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.

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