5431                                   905R78103
C
                      Environmental
                      Impact Statement
                      U.S. ENVIRONMENTAL PROTECTION AGENCY
                      Office of Air, Noise, and Radiation
                      Office of Air Quality Planning and Standards
                      Research Triangle Park, North Carolina 27711

                      September 1978

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                              ABSTRACT
      Under Section 109 of the Clean Air Act,  the U.S.  Environmental
Protection Agency intends to promulgate a National Ambient Air Quality
Standard for lead.   In this report,  the  sources  and 1975  ambient air
concentrations of lead, trends in growth, and  the existence  and
potential for lead  emissions control are summarized.   Emission control
strategies have been developed and,  under one, the nationwide environ-
mental impacts are  assessed for three alternative standards  (1.0
1.5 yg/nr and 2.0 yg/m3) and a quarterly averaging period.

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                          TABLE OF CONTENTS

                                                              Page

LIST OF TABLES                                                  vii

LIST OF FIGURES                                                  ix

1.0  INTRODUCTION AND BACKGROUND                                1-1

2.0  AIRBORNE LEAD IN THE ENVIRONMENT: SOURCES AND              2-1
     AMBIENT LEVELS

2.1  Sources of Lead in Ambient Air                             2-1

     2.1.1  Mobile Sources                                      2-1
            2.1.1.1  Source Types and Significance              2-1
            2.1.1.2  Current and Potential Control            2-11
                     Technology
            2.1.1.3  Emission Trends                          2-15
     2.1.2  Stationary Sources                                2-21
            2.1.2.1  Source Types and Significance            2-21
            2.1.2.2  Current Control Technology for           2-33
                     Stationary Sources
            2.1.2.3  Emission Trends                          2-34

2.2  Ambient Lead Concentrations                              2-40

     2.2.1  Network Monitoring Data                           2-41
     2.2.2  Specific Source Data                              2-53
            2.2.2.1  Specific Source Analysis                 2-54
            2.2.2.2  General Considerations                   2-61
     2.2.3  Estimated Ambient Lead Levels for AQCR's          2-65
            Without Monitoring Data
            2.2.3.1  Introduction                             2-65
            2.2.3.2  Concentration Estimates from             2-66
                     Mobile Sources
            2.2.3.3  Concentration Estimates from             2-68
                     Stationary Sources

3.0  ENVIRONMENTAL IMPACTS OF THE PROPOSED STANDARDS            3-1

3.1  Development of Control Strategies                          3-1

     3.1.1  Control Philosophy                                  3-4
     3.1.2  Overall Control Strategies                          3-6

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                   TABLE OF CONTENTS (Concluded)

                                                              Page

     3.1.3  Stationary Source Control  Strategies               3-9
     3.1.4  Combined Stationary and Mobile Source             3-11
            Control Strategies
     3.1.5  Mobile Source Control  Strategies                  3-12

3.2  Primary Impacts                                          3-14

     3.2.1  A1r Quality                                       3-14
            3.2.1.1  Lead Emissions                           3-15
            3.2.1.2  Ambient Concentrations                   3-13
     3.2.2  Human Health and Welfare                          3-19

3.3  Other Environmental Impacts                              3-19

     3.3.1  Energy Consumption                                3-21
            3.3.1.1  Capital Energy                           3-21
            3.3.1.2  Operating Energy                         3-24
     3.3.2  Noise Levels                                      3-25
     3.3.3  Land Use Parameters                               3-27
            3.3.3.1  Space Requirements for BEFF              3-27
                     Facilities
            3.3.3.2  Landfill Considerations                  3-29
            3.3.3.3  Mobile Strategy Considerations           3-29
     3.3.4  Other Air Pollutants                              3-30
     3.3.5  Hydrology                                         3-31
     3.3.6  Topographic, Geologic and Soil Characteristics    3-34
     3.3.7  Historical and Archaeological Sites               3-36
     3.3.8  Aesthetics                                        3-36
     3.3.9  Ecological Impacts                                3-37
            3.3.9.1  Terrestrial Environments                 3-38
            3.3.9.2  Aquatic Environments                     3-39
     3.3.10 Demography                                        3-40

3.4  Relationship  Between Local Short-Term Uses of Man's      3-41
     Environment and the Maintenance and Enhancement of long-
     Terra Productivity

3.5  Mitigating Measures and Unavoidable Adverse Impacts      3-44
     3.5.1  Mitigating Measures                               3-44
     3.5.2  Unavoidable Adverse Impacts                       3-45

3.6  Irreversible  Impacts                                     3-46
                                 v1

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                           LIST OF TABLES
Table Number                                                  Page

   2-1      Age Distribution of Passenger Cars in the          2-4
            United States, 1964 through 1975

   2-2      Retail Passenger Car Sales in the United           2-5
            States, 1964 through 1975

   2-3      Fuel Consumption Characteristics, by Vehicle,       2-7
            1950 through 1975

   2-4      Percentage of Gasoline Sales by Grade,            2-12
            1970 through 1976

   2-5      Summary of Automotive Factors                     2-18

   2-6      Lead Emissions Inventory, 1975                    2-22
            Nationwide Values

   2-7      Factors for Projecting Future Lead Emissions      2-37

   2-8      Maximum Monthly Lead Concentrations for Selected  2-44
            AQCR's

   2-9      Probability of Exceeding Lead Concentration       2-64
            Levels Near Selected Industries

   2-10     Estimated Air Quality in AQCR's Without           2-69
            Monitoring Data

   3-1      Number of AQCR's Projected to Require Control       3-7
            of Lead Emissions to Comply with Proposed Lead
            NAAQS

   3-2      Number of Vehicles Which May Require Lead         3-13
            Particulate Traps as a Function of Alternative
            Standards and Time

   3-3      Nationwide Estimate of Reduction in Tons of       3-16
            Lead Emitted to the Atmosphere to Meet Proposed
            Standards

   3-4      Nationwide Energy Costs Associated with Fugitive  3-23
            Lead Emissions Control at Primary Copper and
            Lead Smelters, 1982.

                                  vii

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                      LIST OF  TABLES  (Concluded)
Table Number                                                  Page

   3-5      Nationwide Land Use Parameters  Associated          3-28
            with Fugitive Lead Emissions  Control  at
            Primary Copper and Lead Smelters,  1982

   3-6      Trace Metals~Estimated Fugitive Emissions         3-32
            and their Reductions

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                         LIST OF FIGURES

Figure Number                                                  Page

   2-1      Motor Fuel Consumption in the United States,        2-8
            1950 through 1975

   2-2      Lead Content of Gasoline - National Averages,      2-10
            1970 through 1976

   2-3      Number of AQCR's with Maximum Monthly Concen-      2-52
            tratlons Above Indicated Values

   2-4      Lead Concentrations Versus Distance from           2-63
            Primary and Secondary Lead Smelters

   2-5      Lead Concentrations Versus Distance from           2-63
            Primary Copper Smelters and Gray Iron
            Foundries

   2-6      Lead Concentrations Versus Distance from           2-63
            Battery Plants

   2-7      Number of AQCR's with Maximum Estimated Lead       2-73
     -      Concentrations Above Indicated Values

   3-1      Number of A1r Quality Control Regions (AQCR's)      3-2
            with 1975 Ambient Lead Concentrations Exceeding
            Various Proposed Standards

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1.0  INTRODUCTION AND BACKGROUND
     On May 7, 1974, the Administrator of EPA announced in the Federal
Register that the Agency, although not required to do so by law, would
prepare environmental impact statements on significant regulatory
actions.  Because the National  Ambient Air Quality Standard (NAAQS) for
lead, proposed under Section 109 of the Clean Air Act, meets the criteria
for a significant action, the following impact analysis of standard
implementation has been prepared.
     The EIS employs actual  and estimated air quality data, adjusted
for growth, to predict areas of the country which may exceed a par-
ticular standard level by the date for attainment.  Under the assumption
that emissions of lead are proportional to lead air quality, the
percentage reduction in emissions necessary to attain the standard
in such areas is calculated.  The extent of the required rollback is
heavily influenced by the large emission reductions expected with the imple-
mentation of lead phasedown regulations for gasoline and the anticipated
compliance of sources with state implementation plans for control of
particulate matter.  As a result, two categories  of stationary sources
of lead emissions, primary lead  and copper smelters, are identified by
the  EIS as requiring  additional  lead emission control by the attainment
date of 1982.
     The Economic  Impact  Assessment  (EIA), published separate from  the
EIS  but incorporated  by  reference, utilizes  a somewhat different
methodology  to  estimate  the  economic consequences of standard implemen-
tation.   Dispersion-models are employed  to estimate air quality
resulting  from  lead  emissions of plants  representative of each source
                                  1-1

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category.  Because this technique is more.sensitive to point source impacts
than the linear rollback model  applied in the EIS to determine Air Quality
Control Regions (AQCR's) with potential for violating alternative standard
levels, the EIA identifies potential problems for the additional source
categories of:  Secondary lead smelters, lead-acid battery manufacturers,
grey iron foundries, and lead additive manufacturers.

BACKGROUND:  EVENTS LEADING TO THE LISTING OF LEAD UNDER SECTION 108

      CLEAN AIR ACT AMENDMENTS  OF 1970
      In 1970,  Congress adopted Amendments  to the Clean Air Act.  The
 Senate Committee on Public Works, in recoranending the changes to the
 Act, made specific reference to lead as a  contaminant of broad national
 impact, suggesting that air quality criteria for this pollutant be
 issued within 13 months of enactment of the amendments.
      REGULATION OF LEAD AS A FUEL ADDITIVE UNDER SECTION 211
      EPA analysis of the available data on atmospheric lead singled out
 mobile source anissions as the largest contributor to ambient lead
 levels.  The use of lead additives to increase the octane rating of
 gasoline fuels was estimated by the Agency to account for approximately
 90* of the air lead observed nationwide.  In early 1971 , EPA determined
 that the most effective means of reducing  atmospheric lead concentrations
                               1-2

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would be to remove or reduce the le;d in gasoline and issued an Advanced
Notice of Proposed Rulemaking on January 30, 1971.
     Under Section 211 of the Clean Air Act, the Administrator of EPA
is authorized to regulate any motor vehicle fuel additive which "causes,
or contributes to, air pollution which may reasonably be anticipated
to endanger the public health or welfare" or which  "will impair to
a significant degree the performance of any emission control device."
[Section 211(C)(1)].  The January, 1971,notice outlined regulation of
additive lead under both criteria; first, to gradually phase down
the  lead content of gasoline and, second, to establish and provide for
the  availability of a lead-free fuel which would not poison the catalytic
converters scheduled for installation in new model  cars to reduce emis-
sions of hydrocarbons and carbon monoxide.
     In February, 1972, EPA proposed regulations requiring the availa-
bility of a grade of lead-free gasoline and a phased reduction of lead
in gasoline over a four-year period (37 FR 3882).   Following an extended
comment period the Agency determined that the two regulations should
be dealt with separately.  On January 10,1973, regulations requiring
the  availability of lead-free fuel by July 1, 1974  were promulgated
(38  FR 1255).
     Re-evaluation of the health effects analysis by EPA, based on
comments received, led to reproposal of the phase-down regulations on
January 10, 1973 (38 FR 1258) and promulgation on December 6 of the
same year (38 FR 33734).  These regulations provided for a phase-down
                                  1-3

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in the average lead content of gasoline to 0.5 grains per gallon over
a period of four years, beginning January 1, 1975.  The schedule was
designed to ahcieve a 60-65 percent decrease in lead usage in gasoline.
EPA determined that the phase-down schedule was reasonable with regard
to protection of health and economically and technically feasible.
     On December 20, 1974, thesU. S. Court of Appeals for the District
of Columbia Circuit set aside the phase-down regulations, following
a petition by taembers of the additives Industry.  At that time, EPA
suspended enforcement.  On March 17, 1975, however, the Court vacated
the prior judgment which served to reinstate the regulations.  EPA
continued to suspend enforcement until the June 14, 1976, decision by
the U. S. Supreme Court upholding the regulations.  A revised phase-
down schedule was promulgated on September 28, 1976, which required
that the pooled average of lead in gasoline be reduced to 0.5 grams/
gallon by October 1, 1979.
     LITIGATION TO REQUIRE NAAQS FOR LEAD UNDER SECTION 109
     During 1976, the Natural Resources Defense Council (NRDC) and
others, brought suit against EPA for failing to list lead as a pollutant
under Section 108 of the Clean Air Act and subsequently establish ambient
air quality standards.  NRDC argued that the statutory language, legi-
slative history and purpose, and administrative interpretation of the
Clean Air Act required that the EPA Administrator list pollutants
under Section 108 if the pollutant is ubiquitous and "may cause or
contribute to air pollution which may reasonably be anticipated to
endanger public health or welfare."  EPA argued that the listing of
pollutants under Section 108 is at the discretion of the Administrator.

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The Agency had determined that the most effective means of reducing
ambinet lead levels was through  -eduction of the lead content of gaso-
line.  Therefore, the pollutant need not be listed even though it met
the criteria of Section 108.
     In NRDC et.  al.  vs. Train,the U. S. District Court of the Southern
District of New York ruled against EPA stating:
          "There is no language anywhere in the statute which
     indicates that the Administrator has discretion to choose
     among the remedies which the Act provides.  Rather, the
     language of Section 108 indicates that upon certain enum-
     erated conditions, one factual and one judgmental, the
     Administrator "shall" list a pollutant which triggers the
     remedial provisions of Sections 108-110.   The statute does
     not provide, as defendants (EPA) would have it, that the
     Administrator has authority to determine  whether the
     statutory remedies which follow a Section 108 listing
     are appropriate for a given pollutant."
     As of March 1, 1976, EPA was given thirty days to list lead under
Section 108.  The listing was signed on March  31, 1976, and announced
in the Federal Register on April 8, 1976, pursuant to the Court's
decision.
     In July, 1976, EPA appealed the lower court's decision.  Pending
the decision of  the appellate court, the one-year time-table for issuance
of the air quality criteria and proposal of national ambient air quality
standards for lead was stayed.  On November 10, 1976, the U. S. Court
of Appeals upheld  the original decision.  A period of nine months was
                              1-5

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allowed for the issuance of criteria and proposal of the standard.  The
August 10, 1977, deadline was not met due to dejays in finalizing the
air quality criteria document for lead which, under the Section 109,
must be issued at proposal.  EPA reached agreement with the litigants
to reschedule the standard proposal date to December 2, 1977.
    On December 14» 1977, EPA proposed a level of 1.5 ug/u ( calendar
month average, as an ambient lead standard protective of public health
with an adequate margin of safety.  Following receipt and consideration
of comments by the Agency, the averaging period  for the final standard
has been  lengthened to a calendar quarter.  This change is not anticipated
to significantly reduce the protectiveness of the standard but wilTi
improve the validity of air quality data gathered and avoid placing
an undue  burden on state and local air pollution agency monitoring
programs.
    On the date of proposal a draft Environmental Impact Statement was
issued.   No significant comments were recieved on this draft.
 ALTERNATIVES TO THE PROPOSED ACTION
      As a result of the litigation previously described, there are no
 regulatory alternatives to establishing the lead NAAQS.  The Agency is
 further limited by the language of the authorizing legislation which
 identifies the health and welfare implications of lead air pollution
 described in the Criteria Document as the only basis for the NAAQS.
 Costs of control and availability of control technology may not be
 taken into account in the decision-making process.
                             1-6

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    Both the EIS and the EIA evaluate the impacts  of three possible
standard levels, as required by Agency guidelines.   Because under
Section 109 of the Clean Air Act the standard  must be based on health
considerations.   The analysis of alternative levels were not a factor
in the decision  on the level of the standard.
                                1-7

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2.0  AIRBORNE LEAD IN THE ENVIRONMENT:  SOURCES AND AMBIENT LEVELS
2.1  Sources of Lead In Ambient Air
     Almost all airborne lead can be traced to man-made sources.
That which is derived from natural origins (e.g., wind erosion of
naturally lead-bearing soils or the stable end-product of radioactive
radon gas releases) is believed to be negligible.  Of the man-made
sources, automotive emissions comprise the largest single source type
(approximately 90 percent of all emissions, by weight).  With regard
to stationary sources, primary nonferrous smelters appear to be the
most significant contributors.
     2.1.1  Mobile Sources
     For several decades, compounds containing lead have been added
to automobile fuels to inhibit auto-ignition (engine knocking) (Lewis
and Von Elbe, 1961).  As automobile engine manufacturers sought to
increase the compression ratio of gasoline engines (to maximize power
and minimize fuel consumption), the tendency toward auto-ignition
increased, requiring a higher concentration of antl-knock compounds
in the fuel.
     2.1.1.1  Source Types and Significance.  Estimation of automotive
lead emissions requires the evaluation of several factors regarding
automotive vehicles and the fuels they use.  These factors include
(1) the distribution of the several  types of vehicles—buses,  trucks,
cars, (2) the age distribution of automobiles, (3) the extent of
which catalytic converters are in use, (4) vehicle miles traveled,
                                 2-1

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(5) fuel  economy (miles per gallon),  (6)  gasoline sales, and (7) the
lead content of gasoline.
     Distribution by Type of Vehicle*   The Motor Vehicle Manufacturers
Association reports three broad categories of motor vehicles registered
in the United States:  passenger cars, buses, and trucks.  In 1975,
passenger cars represented 80.3 percent of all motor vehicles regis-
tered in the United States, trucks represented 19.4 percent, and
buses represented only 0.4 percent.  Motorcycles are not considered
as a major source of mobile lead emissions because of their relatively
low gasoline consumption, wide spatial distribution, and substantial
off-highway use.
     Most passenger cars bum gasoline and of gasoline-burning
cars, a substantial proportion consume leaded gasoline.  However,
most gasoline-burning  cars manufactured in the United States in 1975
or later years  are  equipped with  catalytic converters,  designed to
reduce carbon monoxiue and hydrocarbon emissions,  which preclude  the
use of leaded gasoline.   Unleaded gasoline is  also required  for some
non-catalyst vehicles.  The age distribution of  the automobile  popula-
tion is described  in more detail  below.
     Buses  are  conveniently grouped into  two categories:   commercial
buses and  school buses.   In 1975, approximately  80 percent of the
buses were  school  buses and 20 percent were  commercial  buses.   Of the
total buses, 83.2  percent, including  essentially all of the  school
buses, consumed gasoline, while the remaining  16.8  percent consumed
diesel fuel  (Motor  Vehicle Manufacturers  Association, 1976).

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     In 1975, approximately 92 percent of the trucks registered
in the United States used gasoline, while the remaining eight percent
used diesel fuel  (Motor Vehicle Manufacturers Association, 1976).
This corresponds closely with the 92.2 percent of all registered
trucks which were under 26,000 pounds in weight.  Therefore, it is not
unreasonable to assume for computational purposes that all trucks
under 26,000 pounds burn gasoline while all  trucks over 26,000 pounds
burn di esel fuel.
     Age Distribution of Automobile Population.  The age distribution
of passenger cars registered in the United States 1s presented in
Table 2-1 for five model years between 1964 and 1975.  The pattern
of age distribution of all cars registered during any of those five
model years was quite similar, with over 90 percent of the cars being
between 1 and 16 years of age and with approximately ten percent being
older than 10 years of age (Motor Vehicle Manufacturers Association,
1976).
     The Use of Catalytic Converters and Unleaded Gasoline.  Most new
cars manufactured in the United States subsequent to model year 1974
utilize a catalytic converter that is intended to reduce carbon
monoxide and hydrocarbon emissions.  Because these converters are
susceptible to lead contamination, cars so equipped must use unleaded
gasoline.  Using retail passenger car sales data (see Table 2-2), it
is estimated that approximately 3.3 percent of the 1975 car population
                                 2-3

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                            TABLE 2-1

              AGE DISTRIBUTION OF PASSENGER CARS IN
               THE UNITED STATES, 1964 THROUGH 1975
CAR AGE
(YEARS)
0-16+
0-16
1-16
2-16
3-16
4-16
5-16
6-16
7-16
8-16
9-16
10-16
11-16
12-16
13-16
14-16
15--16
>16
PERCENT OF ALL CARS IN USE DURING MODEL YEAR:
1964
100.0%
98.4
91.1
80.0
70,0
61.7
52.4
43.9
37.9
30.2
23.1
16.0
12.0
8.3
6.5
4.5
2.6
1.6
1969
100.0%
98.0
91.8
80.4
70.1
58.9
47.6
38.0
29.3
21.9
16.7
12.0
8.9
7.4
5.6
4.1
2.7
2.0
1973
100.0%
98.0
91.1
79.8
70.1
60.5
50.6
41.3
33.4
25.3
17.8
12.2
8.1
5.4
4.0
2.9
2.3
2.0
1974
100.0%
98.2
93.3
81.1
70.0
60.8
51.6
42.3
33.7
26.5
19.4
13.2
8.9
5.9
3.9
2.9
2.2
1.8
1975
100.0%
99.0
95.1
84.8
72.9
62.3
53.3
44.5
35.7
27.8
21.4
15.3
10.2
6.8
4.5
3.0
2.3
1.0
Source:   Motor Vehicle Manufacturers Association,  1976.
         Vehicle Facts and Figures,  1976.
Motor
                                2-4

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                             TABLE 2-2

          RETAIL  PASSENGER  CAR  SALES  IN THE  UNITED  STATES,
                         1964 THROUGH 1975
YEAR
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
DOMESTIC
NUMBER
(thousands)
7,617
8 ,763
8,377
7,568
8,625
8,464
7,120
8,681
9,327
9,676
7,454
7,053
PERCENT
OF TOTAL
94.0 -
93.9
92.8
90.8
39.3
88.3
84.8
84.7
85.2
84.5
84.0
81.6
IMPORT
NUMBER
(thousands)
484
569
651
769
1,031
1,118
1,280
1,568
1,622
1,781
1,417
1,590
PERCENT
OF TOTAL
6.0
6.1
7.2
9.2
10.7
11.7
15.2
15.3
14.8
15.5
16.0
18.4
TOTAL
(thousands)
8,101
9,332
9,028
8,337
9,656
9,582
8,400
10,250
10,949
11,457
8,871
8,643
Source:  Motor Vehicle Manufacturers Association.   1976.   Motor
         Vehicle Facts and Figures, 1976.   Statistics Department,
         Detroit, Michigan.
                                2-5

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were so equipped and 1t follows that in subsequent years an Increasing
proportion of the passenger car population will use unleaded gasoline.
     In addition to new cars requiring unleaded fuel, there has been
United voluntary use of unleaded gasoline for pre-1975 cars.  In
1974, this use amounted to slightly aore than one percent of total
gasoline consumption (Federal Energy Admi n1strati on, 1976a).
     Vehicle Miles Traveled.  Total vehicle miles traveled increased
from 458.2 billion in 1950 to 1,307.7 billion in 1975.  Of the total
vehicle miles traveled in 1975, 78.6 percent were passenger car
niles, 21.0 percent were truck miles, and only 0.4 percent were bus
miles (Svercl, 1977).
     Fael Econoay dalles per gallon).  In general, average motor fuel
mileage per gallon declined during the period from 1950 to 1973, and
then laproved in 1974 and 1975 as shown in Table 2-3.  The recent
improvement is due to several factors including lower speed limits, a
growing population of smaller vehicles, and engineering design
emphasis on fuel economy.  This improvement is expected to continue.
One study has indicated that the sales weighted average fuel economy
in 1977 should be 18.6 mpg for all model year cars and vary from 31.8
rapg for cars in the 2,250 pound weight class to 12.7 mpg for cars  1n
the 5,500 pound weight class (Murrell et al., 1976).
     Gasoline Sales.  With the exception of 1974, annual motor fuel
consumption has risen steadily since 1950  (see Figure 2-1).  In
                                 2-0

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1973, total highway fuel consumption was 113 billion gallons, exclu-
ding fuel for military purposes.  This included 104.5 billion gallons
of gasoline of which 96.3 percent was used for highway transport
while 3.7 percent was used for non-highway purposes.  In 1974, there
was a real drop in motor fuel consumption to 106.3 billion gallons
(Bureau of the Census, 1976b).
     Gasoline sales exhibit both a temporal and spatial distribution.
During 1975, 57 percent of the gasoline sales took place in the six
months from April through September.  In the same year, the state
with the highest gasoline consumption was California, where 10.22
billion gallons were consumed.  California and nine other states
(Texas, Mew York, Ohio, Illinois, Michigan, Pennsylvania, Florida,
New Jersey and North Carolina) accounted for 51 percent of the total
U.S. gasoline sales (National Petroleum News, 1975).
     Lead Content of Gasoline.  The average lead content of gasoline
has declined since 1969 (see Figure 2-2).  The summertime peaking
trend is due to the additional tetraethyl lead (TEL) or tetramethyl
lead (Tffi.) added to increase the octane rating and compensate for the
shorter distillation time required by increased product demand.
     A decreasing trend in lead content combined with an increasing
gasoline consumption resulted in an overall decrease of 25 percent
in the amount of lead going into gasoline between 1972 and 1975.
In addition to the manufacture of lower compression engines in the
United States which would require less lead, many overseas outlets

                                 2-9

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                   2-10

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for TEL and THL are dwindling because of low-lead legislation in
foreign countries (Edwards, 1973).  The average lead content of all
gasoline in 1970 was 
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                             TABLE 2-4

     PERCENTAGE OF GASOLINE SALES BY  GRADE, 1970 THROUGH  1976
YEAR
1970
1971
1972
1973
1974
1975
1976
PREMIUM ._
SALES (7)
(percent)
42.6
41.1
38.1
32.4
24.5
19.2
15.2
REGULAR _
SALES ©
(percent)
55.8
57.3
60.4
66.2
74.3
72.9
62.8
UNLEADED^-
SALES @
(percent)
1.6
1.6
1.5
1.4
1.2
7.9 (?)
22.0 ®
1.  Source:  National Petroleum News.  Mid-May 1976.  Factbook
             Issue.  National Petroleum News.

2.  Calculated by difference,

3.  Calculated using data in:  Federal Energy Administration.
    November 16, 1976b.  Preliminary Findings and Views Concerning
    the Exemption of Motor Gasoline from the Mandatory Allocation
    and Price Regulations..  Washington, D.C.

4.  Numbers directly cited from:  Federal  Energy Administration.
    November 16, 1976b.  Preliminary Findings and Views Concerning
    the Exemption of Motpf Gasoline from the Mandatory Allocation
    Price Regulations.Washington, D.C.
                               2-12

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The advent of a lead-tolerant catalyst could substantially increase
this population, however, and the potential need for traps.
     Transportation Control Plans.  A well conceived and comprehensive
transportation control plan may help to reduce lead emissions, parti-
cularly in urban areas, through the application of:
     (a)  Controls on traffice movements and routing;
     (b)  Incentives for car-pools and demand-responsive
          transit; and
     (c)  Improvements in mass transit systems.
     Fuel Modification.  Lead emissions from mobile sources may
be reduced by restricting the lead content of gasoline by replacing
lead additives with non-leaded substitutes, and through the use of
substitute fuels.  A program of lead phase-down has been initiated by
EPA with the required availability of an unleaded gasoline grade as
of July 1, 1974 and a stepped phase-down of the pooled average of lead
in gasoline to 0.5 g/gallon by October 1, 1979.
     High effectiveness and low production costs have favored the
development of lead aklyl additives over unleaded substitutes.  Other
compounds with antiknock characteristics include ethers, alcohols,
amines, and most metal alkyls.  As commercial  availability has been
limited by a lack of cost-effectiveness versus the lead alkyls, they
have not been commercially used as antiknock additives.
     Recent interest in eliminating lead additives from gasoline
has spurred the development of unleaded antiknock compounds,  and
                                2-13

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there are presently at least two metal -based additives which have been
considered.  A recently developed compound is Cerium (2,2,6,6-tetramethyl-
3,5-heptanedionate)4, or Ce(thd)4.  Preliminary tests, at a recom-
mended concentration in gasoline of 0.5 g.Ce/gal have shown no health
problems associated with Its use.
     Another potential substitute compound commercially available
at this time 1s methyl cyclopentadlenyl manganese tricarbonyl (WIT),
used in conjunction with moderately leaded gasoline to provide
blending flexibility.  MMT appears to be compatible with some cata-
lysts (Bailie, 1976) but may contaminate others necessitating
replacement (Consumers Union, 1977a, b).  Because of the low toxlcity
of manganese* and the TOM concentrations that would be used in
gasoline (Faggan et al., 1976; Ter Haar, 1975), the use of WT is not
expected to present a direct public health hazard.  However, use of
the additive has been associated with Increased hydrocarbon emissions
(Consumers Union, 1976b).  As a result, the State of California has
decided to ban MMT, effective September 7, 1977 (Sessa, 1977).  Congress,
thru the Clean Air Act has imposed a maximum concentration of IW in
gasoline cf 0.0625 g/gal., effective November 30, 1977, and a total
removal of MMT unless manufacturers can document that the operation
of catalytic converters is not impaired.
 ^Manganese  has  a workroom threshold limit value, TLV, of 5,000
  compared to  200 ng/m3  for lead (Occupational Safety and Health
  Administration, 1976).
                                2-14

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      --".  -.:   .      "  .   .v;  ,u-.i3   i.-_-  included  trie  use  of  natural
gas  -nd  hydroqen  ro»-  more  conventional vehicles and so-called  fuel
cells  for  electric vehicles.  Ethanol, and possibly methanol,  hold
promise  for near-term use  in  automobiles as substitute  fuels.   Though
the  combustion of pure  alcohol requires major engine  modifications, a
blend  of about 10 to  20 percent alcohol in gasoline could be utilized
with only minor engine modifications  and a slight mileage penalty.
     2.1.1.3  Emission Trends.  Legislation.  There are two Federal
regulations promulgated by the U.S. Environmental Protection Agency
and one public law that have  direct bearing on lead emissions  from
mobile sources.  The  regulations are:  "EPA Regulations on Control
of Air Pollutants from Motor Vehicles and New Motor Vehicle Engines"
(40 CFR 85) and "EPA Regulations on Fuels and Fuel Additives"  (40 CFR
80).  The public law is the "Energy Policy and Conservation Act"
(PL 94-163).
     The first regulation (40 CFR 85) establishes hydrocarbon, carbon
monoxide, and nitrogen oxide emissions standards for all new light-
duty vehicles (e.g., cars, station wagons, small passenger vans).  To
achieve the standards with respect to hydrocarbons and carbon monoxide,
United States automobile manufacturers, beginning in 1975, have
installed catalytic converters on all gasoline-powered cars with
engine designs which would not otherwise meet emission limits.  The
sensitivity of the catalysts  employed requires the use of unleaded
gasoline.  An upward  trend in the proportion of sales represented by
                                2-15

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unleaded fuel, with gradual  turnover of the vehicle population, is
expected to continue unless  lead-tolerant catalytic converters are
developed as an alternative  emission control device.
     The second regulation (40 CFR 30), promulgated in two parts,
requires the availability of unleaded gasoline at all retail outlets,
effective July 1, 1974, and provides for the phase down of the
average lead content of gasoline to no more than 0.5 gram of lead per
gallon by October 1, 1979.
     In addition to these two Federal regulations, the "Energy Policy
and Conservation Act" (PL 94-163) requires each manufacturer to
obtain a progressively higher average fuel economy for all new car
models to begin in 1978.  The objective is to achieve an average of
18.0 mpg by 1978, 19.0 mpg by 1979, and 37.5 mpg by 1985.  It should
be noted that the average fuel economy of all 1977 model years cars
is estimated to be 18.6 mpg (Murrell et al., 1976), placing the fuel
economy performance at least one year ahead of the required schedule.
     Average Emission'Rate.  One study of mixed urban and suburban
driving has shown that 75 percent of the lead in gasoline is exhausted
to the atmosphere.  The remaining 25 percent is retained in either
the crankcase oil or the engine and exhaust system, in approximately
equal amounts (Hum, 1968).  In addition to the lead emitted from
combustion, a small amount  is lost through evaporative emissions
from the fuel tank and carburetor.
                                 2-16

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     During 1975, the average me tor vehicle consumed 790 gallons
of gasoline with an average lead content of 1.69 grams per gallon,
emitting to the air approximately 1.0 kilogram (2.2 pounds) of lead.
Estimated on-highway mobile source emission of lead from the combus-
tion of gasoline can be calculated in three ways based on:
     (a)  Gasoline sales;
     (b)  Vehicles miles traveled; and
     (c)  Lead consumption at TEL plants.
     Based on gasoline sales, the on-highway mobile source emissions
for 1975 amounted to 140,200 tons.  Using data on vehicles miles
traveled, 136,200 torrs of lead were emitted, while lead emissions
based upon lead consumption at TEL plants amounted to 141,300 tons.
     Projected Lead Emissions.  The legislation cited in the previous
section will serve to reduce mobile source lead emissions.  Estimates
of the resulting decrease of emissions have been calculated using the
following assumptions:
     (a)  75 percent of the lead in gasoline is emitted from
          the tailpipe over the lifetime of the vehicle
          (Hum, 1968);
     (b)  Medium-duty trucks consume three percent of the total
          gasoline and they average ten miles/gall on (Motor
          Vehicle Manufacturers Association, 1977a; Commercial
          Car Journal, 1974);
     (c)  Leaded gasoline contains 2.0 g Pb/gallon and unleaded
          contains 0.05 g Pb/gallon (actual value for unleaded
          gasoline presently lower than this); the pooled
          average for future years is shown in Table 2-5;
     (d)  The percentage of pre-1975 automobiles will vary
          in future years as shown in Table 2-5;
                                2-17

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     (e)  The average fuel economy for vehicles weighing less
          than 10,000 pounds will vary in future years as shown
          in Table 2-5;
     (f)  The total number of vehicles miles traveled annually is
          assumed to follow recent trends and increase each year
          by 31 billion miles (Motor Vehicle Manufacturers
          Association, 1975a); and
     (g)  Small refineries (<50,000 barrels per day), which are
          exempt, are assumed to constitute a negligible portion
          of the market.
     Based on the automobile replacement rate reported by the Motor
Vehicle Manufacturers Association, essentially all automobiles using
leaded gasoline would be retired by 1990.  Medium-duty trucks (greater
than 10,000 pounds gross vehicle weight and less than 26,000 pounds*)
and off-highway users may still require leaded fuel.  These trucks
consume three percent of total  gasoline, while off-highway uses
(gasoline powered tools, agricultural equipment, and snowmobiles)
account for approximately four percent of the gasoline consumed.
The off-highway sources have different emission characteristics
than mobile sources, generally are not affected by mobile source
control strategies, and are widely dispersed; therefore, they are not
included in this discussion.
     Based on the factors enumerated above, and the expected increase
in fuel economy as specified in PL 94-163 (Energy Policy and Conser-
vation Act), lead emissions from mobile sources in 1985 would be
*Nearly all trucks with gross vehicle weights greater than 26,000
 pounds use diesel fuel (which does not contain lead) and, there-
 fore, would not affect the analysis and have been disregarded in
 this study.
                                2-19

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approximately 11 percent of the 1975 estimated mobile lead emissions
(or an 89 percent reduction) and in 1995 would be about 8 percent of
the 1975 values (or a 92 percent reduction).  Most of the emission
reduction would occur in the ten years between 1975 and 1985 because
during those years the majority of the cars using leaded gasoline
would be replaced by models requiring unleaded fuel.  Thereafter, the
annual reduction would be smaller as the percentage of pre-1975
models shrink to five percent or less of the total vehicle population.
     After 1990 (when essentially all replacement of pre-1975 cars
is expected to be accomplished) no additional reduction of lead
emissions by retirement of vehicles using leaded gasoline is antici-
pated.  Moreover, the improvement 1n average fuel economy resulting
from the Energy Policy and Conservation Act will taper off after
1985, reaching a plateau by 1997.  At the sane time, however, the
number of vehicle miles traveled should increase each year.  The net
effect of these conditions would be an incremental reduction in lead
emissions between 1985 and  1995 of only three percent.  Under the
present regulation, no reduction in emissions from medium-duty trucks
occurs and small quantities of lead are still expected to be emitted
from vehicles using unleaded gasoline assumed to contain 0.05 g
Pb/gallon.  Thus, the reduction relative to 1975 lead mobile emissions
can never reach 100 percent.  The lead emissions for 1979, 1980, and
1981 would be fairly constant because the pooled averages for these
years do not vary appreciably (as shown in Table 2-1).

                                2-20

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     2.1.2  Stationary Sources.
     The annual supply of lead to U.S. industry is furnished by
primary smelters, secondary smelters, ore and metal imports, industry,
stocks; and government stockpile releases.  In addition to these
sources, lead is emitted to the air from a variety of industrial
applications and uses.
     Stationary source emissions of lead are classified as stack
emissions and fugitive emissions.  The former are released from
on-site stacks ranging from tens to hundreds of feet in height and
the subsequent behavior of the emitted material has been reasonably
well studied and documented.  Fugitive emissions, as the name implies,
may occur throughout the facility and are more difficult to define,
measure and control.  Sources of fugitive emissions Include leakages
from process buildings, wind erosion of slag piles, and dust stirred
up by automotive traffic, particularly on unsurfaced roads near major
point sources.
     2.1.2.1  Source Types and Significance.  Twenty-three industries
have been identified as being important emitters of airborne lead
(U.S. Environmental Protection Agency, 1977a).  Table 2-6 lists these
industries along with their uncontrolled emission factors and 1975
emissions (after control).  The industries listed contributed almost
90 percent of the 1975 nationwide stationary source lead emissions.
For the purpose of analysis, 1975 has been adopted as the baseline
                                 2-21

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                   TABLE 2-6
LEAD EMISSIONS INVENTORY, 1975 NATIONWIDE VALUES
INDUSTRY
FERROALLOY
BATTERY
PRIMARY LEAD
SECONDARY LEAD
PRIMARY COPPER
GASOLINE ADDITIVES
CAST IRON FOUNDRIES
COAL-FIRED
UTILITIES
OIL-FIRED
UTILITIES
MUNICIPAL
INCINERATORS
IRON AND STEEL
ORE CRUSHING
AND GRINDING
PRIMARY ZINC
BRASS AND BRONZE
1975
PRODUCTION
2,215 x 106 tons
48.3 x 106
batteries
642,000 tons
604,600 tons
1.38 x TO6 tons
326,000 tons
27.8 x 106
tons of lead
processed
182,200 MUe
78,420 MUe
11.57 x 106 tons
©
352 x 106 tons
4.5,000 tons
232,000 tons
EMISSION FACTOR
STACK
©
27.69 Ibs per
1 ,000 batteries
68.5 Ibs/ ton
56 Ibs/ton
20.9 Ibs/ton
5.2 Ibs/ton
(sludge pit,
process vents);
41.3 Ibs/ton
(lead recovery)
0.44 Ib/ton
55.3 Ibs/TMe
56.1 Ibs/MHe
0.6 lb/ ton
©
a.012-0.3
Ib/ton
20.85 Ibs/ton
22.75 Ibs/ton
FUGITIVE
—
—
7.3 Ibs/ton
0.4 Ib/ton
3.6 Ibs/ton

—
—
—
—
—
—
—
—
COMPLIANCE
CONTROL
FACTOR
(percent)
89
85
98.2 0
95 0
92.6 0
92
70
92
0
64
©
25 to 27
97.3
98
CONTROLLED (?)
34
TOO
2,734
954
3,461
1,333
1,841
403 ©
2,200 ©
1 ,254 @
1,227
544
124
52
                      2-22

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                                    TABLE 2-6 (concluded)
                       LEAD EMISSIONS INVENTORY, 1975 NATIONWIDE VALUES
INDUSTRY
LEAD OXIDE
PRODUCTION
PIGMENT PRODUCTION
CABLE COVERING
CAN SOLDERING
TYPE METAL CASTING
METALLIC LEAD
PRODUCTION
CEMENT PRODUCTION
Wet
Dry
LEADED GLASS
AUTOMOBILE
EMISSIONS
1975
PRODUCTION
500,000 tons
73,000 tons
500,000 tons of
lead processed
134 x TO6
base boxes
6.3 x 106 tons
113,503 tons
32.5 x TO6 tons
39.5 x 105 tons
492,000 tons
—
EMISSION FACTOR
STACK
0.44 Ib/ton
—
0.5 Ib/ton
0.5 ton/106
base boxes
0.25 Ib/ton
1.5 Ibs/ton
0.10 Ib/ton
0.11 Ib/ton
5 Ibs/ton
—
FUGITIVE
—
—
—
—
•~
—
—
—
—
COMPLIANCE
CONTROL
FACTOR
(percent)
0
—
0
0
50% of
industry
at 80*;
50% at 02
0
93
95
—
CONTROLLED 0
no
*
13
125
67
480
85
137
207
62
140,200
1.   See Appendix V for discussion of 1975 emission calculation.
2.   Includes crankcase oil  combustion.
3.   To the extent that the industry was controlled.
4.   For stack emissions only, zero percent for fugitive emissions.
                                            2-23

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year as more recent information is not available on a consistent
basis for all the industries listed.
      Ferroalloy Producers.  There are 48 ferroalloy plants in the
United States which produced a total of 2.22 x 106 tons (2.01 x ID6
metric tons) of ferroalloys in 1975.  The majority of the plants are
concentrated in Alabama, Pennsylvania, and Ohio with the remainder
scattered in 13 other states.  Most ferroalloy plants have capacities
below 25,000 kilowatts electric (kWe) while ten plants have a capacity
in the 25,000 to 75,000 kWe range, and ten have capacities over
75,000 kWe.  Lead emissions in 1975 from this industry were 84.3 TPY,
assuming a compliance control factor* of 89 percent.
      Lead-Acid Battery Plants.  There are 280 battery plants** in
the United States, producing approximately 48,325,000 batteries
in 1975.  The plants are scattered fairly uniformly throughout the
country, with some concentration occurring in New York, New Jersey,
Pennsylvania, and California.  Plant sizes range widely.  Plants
with a lead  oxide (PbO) mill have a slightly larger emission factor
 *The  degree of  compliance  for a  given  industry, expressed as a
  percentage,  is a  measure  of the number of plants operating with the
  required  SIP control  devices.   Numerically,  this compliance factor
  is the ratio of the  tons  of airborne  particulate matter controlled
  by the industry relative  to the tons  which would be  emitted by the
  industry.  Consider,  for  example, an  industry where  80 percent of
  the  plants have SIP  control devices collecting 90  percent of the
  airborne  particulate matter.  The degree of  compliance would
  theoretically  be  72  percent.  In actuality,  the reported compliance
  factors,  based on emissions,  may be slightly different sines not
  all plants may  have achieved the identical level of control.
 **With more than ten  employees;  producing lead-acid storage batteries
                                  2-24

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than those without mills.  Total 1975 lead emissions are estimated
to be 100.4 tons based on a compliance control  factor of 85 percent.
      Primary Lead Smelter.  There are six primary lead smelters
in the United States, that is, smelters which use lead ore as the
primary feedstock.  These smelters accounted for the production of
642,000 tons (582,000 metric tons) of lead in 1975.   The six smelters
may be classified as relatively high emitters of lead (the older
smelters in the western part of the United States) and relatively
low emitters (the newer smelters located in Missouri).  Emissions
from each of these facilities were obtained from emission factors,
plant production statistics and compliance control factors of 98.2
percent for stack emissions and zero percent for fugitive emissions.
Total 1975 lead emissions from this industry are estimated to have
been 2,374 tons (16 percent of the total emissions from stationary
sources).
      Secondary Lead Smelters.  There are 93 secondary lead smelters
in the United States, that is, smelters for which the feedstock is
generally used lead products, primarily battery scrap and lead
residues.  These smelters produced 604,000 tons (548,000 metric tons)
of lead in 1975.  Plants are distributed more or less uniformly
throughout the country.  Total emissions of lead for this industry in
1975, including fugitive emissions, are estimated to be 973 tons
based on a compliance factor of 95 percent for stack emissions and
zero percent for fugitive emissions.
                                 2-25

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     Primary Copper Smelters.  There are 15 primary copper smelters
in operation in the United States.  They produced approximately
1.38 million tons (1.25 million metric tons) of copper in 1975.
Individual plant capacities range from 15,000 to 300,000 tons per
year (TPY).  All plants are located in the western region of the
United States near the ore deposits.  Lead is contained in the input
material to both the roasting and smelting processes and is emitted
as part of the flue dust produced.  Lead emissions from the copper
smelting Industry, including fugitive emissions, are estimated to be
3,460 TPY, based on a compliance control factor of 92.6 percent for
stack emissions and zero percent for fugitive emissions.
     Gasoline Additive Manufacturing (Lead Alky! Production).
There ire six gasoline additive manufacturing plants in the United
States, producing a total of 326,000 tons (296,000 metric tons) of
lead additive in 1975.  These plants are located in California, New
Jersey, Louisiana and Texas.  Based on emissions factors for the
various industrial processes employed, production data and estimated
compliance factors, lead emissions from this industry were estimated
to be 1,330 tons (1,210 metric tons) in 1975.  Particulate emissions
originate only from the lead smelting furnace, alloy reactor and the
lead recovery furnace.  All other emission points exhaust lead in
alky! vapor form.
     Gray Iron Foundries (Cast Iron).  In 1975 there were 1,519 gray
iron foundries in the United States, and together they produced 16.7
                                 z-es

-------
million tons (15.1 million metric tons) of castings.  The presence of
lead in the raw ores resulted in estimated emissions of 1,841 tons
based on a compliance control factor of 70 percent and internal
recycling due to a 40 percent rate of bad castings.
     Combustion of Crankcase Oil.  The quantity of waste automotive
lubricating oil that is generated annually has been estimated to be
between 400 and 730 million gallons (U.S. Environmental  Protection
Agency, 1974b; American Petroleum Institute, 1974; Weinstein, 1974a),
and the total  amount of waste crankcase oil burned as fuel in 1975
was 274 million gallons.  Values for the lead content of waste
crankcase oil  range from 800 ppm to 11,200 ppm (Chansky et al.,
1973); but a composite waste crankcase oil representing a nationwide,
all-season sample had a lead content of 8,400 ppm (American Petroleum
Institute, 1975).
     While there are studies to indicate which type of facilities
can burn waste crankcase oil (e.g., Chansky et al., 1974), there are
no data indicating the amounts used by different facilities.   It was
assumed in this report that one-half of the oil  would be used in
oil-fired power plants, one-third in coal-fired utilities, and
one-sixth in municipal  incinerators.  Although this breakdown is
somewhat arbitrary, it does allow for a reasonable geographical
distribution of lead emissions from crankcase oil  combustion.
Depending on the types of facilities assumed to burn waste crankcase
oil, different emissions may differ since 50 percent and 80 percent
                                2-27

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are used as emission factors when the crankcase oil is blended with
utility oil and solid fuels (coal and trash) respectively.  Assuming
that crankcase oil  is exclusively blended with utility oil, 4,300
tons of lead emissions would be expected from this industry in 1975.
Using the mix of facilities described above—oil-fired and coal-fired
power plants as well as municipal incinerators—would increase this
figure to 5,600 tons.
     Coal-Fired Power Plants.  In 1975, there were 380 coal-fired
power plants (above 25 megawatts electric equivalent) in the United
States, consuming approximately 4-12 million tons (374 million metric
tons) of coal as either a primary or auxiliary fuel.  Based on an
average lead content of coal of 8.3 ppn and assuming for the purpose
of analysis that about 91.3 million gallons of waste crankcase oil
were burnt at these power plants, emissions of lead from this industry
were estimated to be 403 tons.  This includes amounts contributed by
waste crankcase oil usage based on a compliance control factor of 92
percent.
     Oil-Fired Power Plants.  In 1975, there were 260 oil-fired
power plants (above 25 MWe equivalent) in the United States consuming
81.8 million bbl (13 x 106 m3) of distillate and 554 million bbl
(881. x 1Q6 m3) of residual oil as either a primary or auxiliary fuel.
     Since the lead emission factor for oil combustion is dependent
on the lead content in the oil and as an individual plant breakout
by type of oil used was not available, a weighted average of 0.9 ppm
                                2-28

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of lead in oil was used.  Assuming that 50 percent of  the  lead  in  oil
is emitted (U.S. Environmental Protection Agency, 1977a) and  that
approximately 137 million gallons of waste crankcase oil were burnt
in these power plants, lead emissions in 1975 were estimated  to be
2,200 tons, mostly due to crankcase oil usage.
     Municipal Incinerators.  In 1975, 143 municipal incinerators  in
the United States burned 11,669,000 tons of refuse and are assumed to
have used approximately 45.7 million gallons of waste crankcase oil
as fuel.  The vast majority of the installations are in the north-
eastern section of the country.  Based on an emissions factor of 0.4
pound of lead per ton of refuse,  the above assumed quantity of waste
crankcase oil burnt and a compliance factor of 64 percent, nationwide
lead emissions in 1975 from municipal  incinerators were estimated to
be 1,254 tons.
     Iron and Steel  Plants.  There are six processes at iron and
steel plants which are potential  lead emitters due to the presence of
lead as a trace metal in iron ore.  These processes include sintering,
coking, blast furnaces, basic oxygen furnaces, open hearth furnaces,
and electric arc furnaces.  In 1975, there were 160 iron and steel
plants throughout the United States, and the nationwide emissions of
lead from these plants were estimated to be 1,227 tons.
     Ore Crushing and Grinding.  Lead, zinc,  and copper ore mining,
crushing, and grinding operations, which are confined mostly to the
western states, together contributed about 544 tons (493 metric tons)

                                 2-29

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of lead to the nationwide total of lead emissions in 1975.  The
lead-containing ore mining operations are located almost exclusively
in Missouri, Colorado and Idaho.  Emissions are basically fugitive in
nature, and because of the large particle sizes and high specific
gravities of the dust, fallout occurs within a short distance from
the source.
     Primary Zinc Smelting.  Estimated zinc production in 1975 was
445,000 tons (404 thousand metric tons).  The zinc ore concentrates
contain lead, varying from less than 1 percent up to 5 percent.  The
amount of lead released to the atmosphere is dependent on initial ore
concentration.  Lead emissions in 1975 were estimated to be 124 tons
(112 metric tons) resulting from sintering and retorting operations.
     Brass and Bronze Production.  Production of brass and bronze
alloys was estimated to be 232,000 tons (210 x 103 metric tons) in
1975, produced in reverberatory, rotary, crucible, or electric
induction furnaces.  Sone of the alloys produced—leaded red brass,
semi-red brass, high-leaded tin bronze, aluminum bronze, and leaded
nickel bronze contain significant amounts of lead.  The particulate
emission factor is approximately 70 pounds/ton of charge with lead
contents ranging from 7 to 58 percent.  Estimated lead emissions
from this source were at 52 tons (47 metric tons in 1975).
     Lead Oxide Production.  Approximately 500,000 tons (454,000
metric tons) of litharge (lead oxide) and black oxide were produced
in the United States in 1975.  Based on an average lead emission
                                2-30

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rate of 0.44 pounds/ton of product, national lead emissions from this
industry were estimated to be 110 tons (100 metric tons) in 1975.
     Pigment Production.  Lead pigment production for 1975 was
estimated to be 73,000 tons (66.1 x 103 metric tons), the majority
of which was- red lead and lead chromate.  Lead emissions in 1975
after control were estimated to be 13 tons (11.8 metric tons).
     Cable Covering Manufacturing.  Consumption of lead by cable
covering facilities was 50,000 tons (45,500 metric tons) in 1975.
Based on a throughput to consumption ratio of ten to one, this
implies that about 500,000 tons of lead were processed through
internal recycling.  Using an emission factor of 0.5 pound of
lead/ton of lead processed, 1975 lead emissions were estimated to be
125 tons (113 metric tons).
     Can Soldering.  It has been estimated that metal can production
in 1975 included 134 million base-boxes* of soldered steel  cans.
Lead emissions in 1975 from the soldering operation are estimated to
be 67 tons (60 metric tons), based on an emission factor of 0.5 ton
of lead per million boxes.
     Type Metal  Casting.  Taking into account the metal  ore cycle-
to-replacement factor, it is estimated that of the 6.3 million tons
of lead recycled approximately 16,200 tons (14,740 metric tons) of
lead were consumed by type metal casting operations.  Based on a
* A base box is equivalent to 20.23 m2 (218 ft2)  of surface area.
                                2-31

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lead emission factor of 0.25 pound/ton recycled and a compliance of
40 percent, lead emissions in 1975 were estimated to be 480 tons
(436 metric tons).
     Metallic Lead Production.  Approximately 200,000 tons (180 x 10-3
metric tons) of lead were consumed in the manufacture of ammunition,
bearing metals, weights and ballasts, and other products in 1975.
Lead emissions from the 87,000 tons of lead processed for ammunition
                        /
and bearing metal are negligible and the lead emissions from other
processes are estimated to be 85 tons (77 metric tons) in 1975.
     Cement Production.  About 72 million tons (65 x 106 metric tons)
of cement were produced in 1975 by two methods described as dry and
wet process.  Production of cement by the dry process was estimated
to be 39.5 million tons (35.8 million metric tons).  Wet process
production in 1975 was estimated to be 32.5 million tons (29.5
million metric tons).  Lead is an incidental trace element in the raw
materials of both processes.  Emission factors for these processes
are estimated to be 0.11 pound/ton and 0.10 pound/ton, respectively.
Assuming an overall compliance factor of 93 percent, lead emissions
in 1975 were estimated to be 207 tons (188 metric tons) from the dry
process and 137 tons (124 metric tons) from the wet process.
     Leaded Glass Production.  Leaded glass production was estimated
to be 492,000  tons (446 x 103 metric tons) in 1975 and lead emissions
were estimated to be 62 tons (50 metric tons) using an emission factor
of 5.0 pounds/ton of glass and a compliance control factor of 95 percent.
                                 2-32

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     2.1.2.2  Current Control Techiology for Stationary Source
Emissions.  Except for some gaseous emissions from the lead alky]
Industry (I.e., gasoline additive manufacturing), lead is usually
emitted In the form of particulates from industrial sources.  Conse-
quently, control  devices for lead are usually the same as those used
for total particulates, namely, baghouses or fabric filter- (FF), wet
scrubbers or collectors (WC), and electrostatic precipitators (ESP).
     The collection efficiency of these three types of control devices
drops with decreasing particle size, while it is evident that smaller
diameter particulates have higher concentrations of lead (Natusch et
al., 1974; Greensburg, 1976).  Collection efficiency usually drops for
particles around 1 micron in diameter, and been some "high efficiency"
control devices (99.5 percent control) are only 90 percent effective
at removing these small particles.  On the other hand, many of the
major lead sources emit fumes rather than particulates, and any effect
due to surface area differential would be small.   Additionally, the
widespread use of baghouses, which are not as sensitive to differences
in particle sizes as the other control devices, serves to reduce any
control efficiency differences.
     Fabric Filtration.  Fabric filters, usually in the shape of a
bag, are used to trap particulates through the mechanics of inertia!
impaction, diffusion, and direct interception.  Collection efficien-
cies for well-designed baghouses exceed 99 percent, especially when
                                 2-33

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a cake builds up on the filter and sieving becomes an important
factor in collection.  The efficiency of fabric filters is, however,
more sensitive to flow fluctuations and temperature than scrubbers
or ESP's.
     Electrostatic Preciptators.  Electrostatic precipitation depends
upon the collection of previously charged particles from an oppositely-
charged collection plate.   ESP's are usually not sensitive to flow
fluctuations and they are capable of treating very large gas volumes
at various gas temperatures.
     Wet Scrubbers.  Venturi scrubbers, which are the most common
type of scrubbers used by those lead-emitting industries which use
scrubbers only, have snail space requirements and can accommodate
flow variations.  Water usage, water cleaning, and sludge generation
are inherent limitations to the use of scrubbers, but when there are
relatively low flow rates (<100,000 acftn) and high particulate con-
centrations, the venturf scrubber is often specified.
     2.1.2.3  Emission Trends.  In order to develop emission trends
for stationary sources, it is necessary to establish a baseline (in
this case, for 1975) inventory.  The tons of emissions are calculated
by multiplying together three factors—(1) an emission factor,
usually expressed as pound of lead emitted per ton of production and
as taken from Control Techniques for Lead Air Emissions (U.S. Environ-
mental Protection Agency, 1977a), (2) the production rate in tons per
                                 2-34

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year, and (3) a compliance control factor.  This last factor is used
to account for the amount of co itrol for total particulates (and,
hence, lead particulates) achieved by each industry by 1975 in
response to State Implementation Plans for control of total suspended
particulate matter (TSP).  The degree of compliance, based on work
performed for the D1v1son of Stationary Source Enforcement (Massoglia,
1976a), is a measure of the number of plants which had installed the
necessary SIP controls by 1975.  The compliance control factor,
presented in Table 2-6 is a combination of the degree of compliance
(i.e., number of plants) and the SIP control factor, and indicates
the percentage of tons of lead controlled in 1975 for an industry.
The 1975 lead emissions inventory can then be determined either as a
nationwide summation across individual industries or as a summation
of different industries within individual Air Quality Control Regions
(AQCR's).
     For the 11 major stationary source categories, emissions inven-
tories for subsequent years—1982, 1985, and 1995—can be extrapo-
lated from the 1975 inventory using industrial growth rates, present
industrial capacity factors, and the applicable emissions control
factors.  The growth rate is the percentage of annual production by
which an industry would be expected to grow for each subsequent year.
The capacity factor represents the 1975 production as a percentage of
the total-industry capacity.  These two factors are used to determine
the year of full capacity, i.e., when the growth rate indicates that

                                2-35

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present unused existing capacity would be filled.  These factors are
presented in Table 2-7.
     It is necessary to predict the year in which full capacity will
be achieved to assign the proper control factors to increased produc-
tion related to industrial growth.  For purposes of future lead
emissions inventory development, it has been assumed that existing
unused capacity would be utilized before any new production facilities
are built.  Thus, increased production until the estimated year of
full capacity would be controlled according to factors associated
with the State Implementation Plans (SIP) for total-particulate am-
bient air concentration standards, while production thereafter would
be controlled to the extent provided by the New Source Performance
Standards (MSPS) for particulate emissions at specific types of new
facilities.
     SIP Control.  On November 25, 1971, EPA established national
primary and secondary ambient air quality standards for particulate
matter (40 CFR 50.6-50.7).  The Clean air Act (Section 110) requires
that each state develop "a plan which provides for implementation,
maintenance and enforcement of such primary standards in each air
quality control region (or portion thereof) within such State."  The
resulting SIP's required  the control of particulates from a number of
stationary sources, many  of which have  lead as constituent of the
total particulate emission.  SIP control factors were computed based
on  the average control efficiencies required by the states in
                                 2-36

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                 TABLE  2-7



FACTORS FOR PROJECTING FUTURE LEAD EMISSIONS
INDUSTRY
FERROALLOY
STORAGE BATTERY
PRIMARY LEAD SMELTER
SECONDARY LEAD SMELTER
PRIMARY COPPER SMaTER
GAS ADDITIVE
CAST IRON
MUNICIPAL INCINERATOR
COAL-FIRED UTILITIES
OIL-FIRED UTILITIES
IRON AND STEEL
Sintering
Coking
Blast Furnace
Open Hearth
Basic Oxygen Furnace
Electric Furnace
GROWTH
RATE
2
5
1.5
3.2
3
-16
2
0
5
2.5
2.5
—
—
—
—
—
—
1975
CAPACITY
FACTOR
90
76
83
68
73
—
93
—
100
100
76.2
—
—
~
~
—
—
ESTIMATED
YEAR OF
FULL
CAPACITY
1981
1981
1988
1988
1986
—
1979
—
1975
1975
1987
—
—
--
—
—
—
SIP
CONTROL
FACTOR
99.5
85
98.9
97.5
96.2
—
88.9
—
98
0
—
99.4
72.3
99.6
90.2
99.7
84.3
NSPS
CONTROL
FACTOR
99.5
85
99.7
99.3
96.2
—
88.9
—
98.7
0
—
99.4
72.3
99.6
90.2
99.7
98.1
                    2-37

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their SIP's and Appendix B of the Requirement for Preparation,
Adoption, and Submlttal of Implementation Plans (40 CFR 52).  From
Table 2-3 it can be seen that SIP control factors are generally
>_ 80 percent and often ._> 90 percent.
     In 1975 most of the major stationary lead emitters were in a
fairly high degree of compliance (in terms of numbers of plants) as
inferred by comparing the compliance control factors in Table 2-2
with the SIP control factors in Table 2-3 and by recalling that the
compliance control factor is the product of the degree of compliance
and the value of SIP control.  Emission control techniques for total
partlculate (e.g., baghouse, scrubbers, and electrostatic preclpi-
tators) are the same as for control of lead emissions, and therefore
the MAAQS for partlculate natter has already and Mill continue to
result in sone control of lead.  It Is assumed that by 1982 all of
the Industries requiring SIP control would have a 100 percent degree
of compliance and the compliance control factors would be identical
to the SIP control factors.  The improvement in compliance, then,
would account for significant reductions in stadc emissions in 1982
relative to 1975.
     MSPS Control.  Section 111 of the Clean Air Act provides the
authority for the EPA Administrator to propose and promulgate regula-
tions for a category of new stationary sources wnich "causes or
contributes significantly to air pollution which may reasonably be
anticipated to endanger public health or welfare."  The first standards
                                 2-38

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of performance for new stationary sources (New Source Performance
Standars, or NSPS) were promulgited in December 1971.  By January 13,
1977, particulate standards had been promulgated for 13 source
categories and had been proposed for two additional source categories.
     No standards of performance have been promulgated or proposed
specifically to regulate lead emissions.  However, promulgation
of additional new source performance standards is being considered,
including promulgation of a lead regulation for process equipment
operated at lead-acid storage battery plants.  The scheduled date for
proposing such a regulation is December 1977.
     For 1982 and 1985, the effect of the NSPS control  factor,
with regard to lead emissions, is very small due to the fact that, in
these years, industrial growth could be mostly accommodated by
existing unused capacity.  By 1995 the NSPS control would begin to
have a slight effect, primarily due to the NSPS for electric furnaces
in the iron and steel industry.
     Fugitive Emissions.  It should be noted that neither the SIP
nor the NSPS control factors account for fugitive emissions.  As seen
in Table 2-6, fugitive emissions are only a fraction of the uncontrolled
stack emissions.  However, as SIP compliance on stack emissions
is effected, fugitive emissions gain relative importance and begin
to dominate.
                                 2-39

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     Other Control.   The phasedown of lead in gasoline not only
directly relates to  lead emissions from mobile sources, but also
affects lead emissions from point sources which burn waste crankcase
oil.  As the lead content of gasoline is reduced, the lead content
of waste crankcase oil will also decline and the resulting lead
emissions from the stationary combustion of waste crankcase oil (i.e.,
in coal-fired power plants, oil-fired power plants, and municipal
incinerators) would be expected to decrease proportionally.
2.2  Ambient Lead Concentrations
     Current levels of airborne lead concentrations in the United
States are important 1n determining the potential for air quality
improvement required to meet a proposed ambient lead standard.  The
feasiblity of attaining and maintaining a given standard, and the
impact of implementing that standard, depend on the required changes
in air quality relative to present levels.  Concentrations of
airborne lead have been routinely monitored by a variety of Federal,
state and local agencies in a number of Air Quality Control Regions
(AQCR's) throughout the United States in recent years, although the
reporting and monitoring procedures are not standardized and often
result in inconsistent data (e.g., data based on nonuniform averaging
times).  This type of monitoring information is discussed in Section
2.2.1.
     In addition to routine air quality monitoring conducted in an
AQCR, a number of special monitoring studies have been undertaken
                                2-40

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in the immediate vicinity of particular stationary lead emission
sources.  This information, prfsented in Section 2.2.2, is useful
in analyzing the different types of point sources and determining
the important factors that contribute to high ambient lead levels.
     For those AQCR's in which there are not routine lead monitoring
data available, estimates of air quality can be made based on air-
borne lead emissions from existing typical point and mobile sources.
Section 2.2.2 presents the results of this estimation process, where
the highest expected lead concentrations are determined from maximum
point source emission rates and highest traffic counts in the
different AQCR's.
2.2.1  Network Monitoring Data
     Ambient air lead concentration data are collected by a number
of Federal, state, local and private agencies.  In 1974, the National
Air Surveillance Network (NASN) and the National Aerometrfc Data
Bank (NADB) included lead monitoring data from 127 of the 247 AQCR's,
and in 1975 there were 148 AQCR's represented in the data systems.
In August 1976 a telephone survey was made to air monitoring agencies
having responsibilities in the remaining AQCR's in the contiguous
United States which were not represented in the NASN and NADB files
(eight AQCR's in Alaska, Hawaii, Amen'can Samoa, Guam, and the
U.S. Virgin Islands were not contacted).  This survey found that lead
monitoring in 33 additional AQCR's has been accomplished to date.
                                2-41

-------
     The total number of AQCR's with 1974 data was 144, while a
total of 162 AQCR's had 1975 lead concentration data (including 2
with 1976 data).  For all years combined (effectively 1974 and 1975)
there were 170 AQCR's with reported monitoring data.  Many of the
monitoring agencies did not report their measured lead concentration
data to the NASN or NADB systems due to a failure to understand the
reporting procedures for lead, the relatively low values observed, or
other undisclosed reasons.
     The concentration data contained in the NASN and NAOB systems
were reported in terms of 24-hour measurements averaged over a calendar
quarter*, while other averaging times such as a year, were used as the
basis for data reported by some state and local monitoring agencies.
In order to compare concentration, all measurements were converted to
quarterly averaging times.  In some cases, quarterly averages were not
reported in the NASN or NAOB systems because the data were "insuf-
ficient"; that is, there were fewer than five 24-hour measurements
during a quarter, or there was no more than one measurement during any
two months of a quarter.
     Quarterly averages were determined for all 170 AQCR's with
reported lead concentrations, even those with "insufficient" data,
data reported in terms of different averaging times, or data from
years other than 1974 and 1975.  In order to compare Measured lead
concentrations with an ambient standard based on a quarterly averaging
                                2-42

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time, maximum concentrations for other averaging times were converted
to maximum quarterly concentrations.
     Table 2-8 indicates the maximum quarterly mean for all AQCR's with
at least one value exceeding 1.0 H-9/m-3.  In all, 103 AQCR's (42
percent of all regions) are presented in the table.  High ambient
lead concentrations usually are restricted to the vicinity of a lead
emitter; hence, an average concentration measurement for all monitors
in an AQCR is less indicative of potential  problems than maximum
concentration values.  However, the pervasiveness of high levels of
airborne lead may be impossible to determine because of the distribu-
tion of monitoring sites.  For example, there may be only one major
emitter in an AQCR, and all monitoring sites are clustered around it,
while the rest of the AQCR has very low levels of airborne lead.
Nevertheless, an analysis of the ambient lead concentration summary
given in Table 2-8 can give  an indication of wnich AQCR's have
potential problems due to high lead concentrations.
     Of the 103 AQCR's represented in Table 2-8, 54 had quarterly
mean lead concentrations of 1.5 ^9/m^ or above, 40 had concentra-
tions of 2 ug/n)3 or above, 18 had at least one quarterly mean of 3
^g/m^ or greater,  and 8 had concentrations above 4 ug/m2.  There
are a number of examples of the correlation between particular lead
emitters and nearby elevated concentrations of lead, but it is
extremely difficult to estimate the percent contributed from each
emitter to a particular receptor.  A review of the major sources of
                                2-43

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                         TABLE 2-8
MAXIMUM QUARTERLY LEAD CONCENTRATIONS  FOR SELECTED  AQCR'S  (1
AQCR NUMBER
2
3
4
5
7
8
9
13
14
15
16
18
24
28
29
30
31
36
42
43
45
47
49
50
52
54
55
56
58
62
65
67
69
70
73
76
78
79
LOCATION
AL/GA
E. AL
W. AL
FL/MS/AL
TN/AL
S. AK
N. AK
NV/AZ
AZ/CO/NM/UT
S. AZ
CENT. AR
AR/MS/TN
S.W. CA
N. CA
S. CA
W. CA
CENT. CA
CENT. CO
CT/MA
NJ/NY/CT
DE/NJ/PA
DC/MO/VA
FL/GA
S.E. FL
w. a
CENT. GA
GA/TN
W. GA
GA/SC
ID/WA
IL/IA
IL/IN
IL/IA
IL/MO
IL/WI
E. IN
KY/IN
KY/IN/OH
MAXIMUM QUARTERLY MEAN
VALUE
(jjLg/m3)
1.49
1.41
2.20
1.72
1.11
1.30
2.02
2.34
4.07
4.42
1.16
2.51
6.70
3.17
3.72
2.71
2.59
1.97
2.72
2.16
2.08
1.52
1.40
3.07
2.74
1.90
1.24
2.20
1.40
31.94
1.19
3.45
1.18
1.58
1.09
1.19
1.33
1.03
YEAR
1974
1975
1975
1974
1975
1974
1975
1974
1974
1974
1974
1975
1974
1974
1975
1975
1975
1975
1975
1974
1974
1975
1975
1974
1974
1974
1975
1975
1975
1974
1975
1975
1975
1975
1974
1975
1974
1975
                            2-44

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                    TABLE 2-8 (continued)
MAXIMUM QUARTERLY LEAD CONCENTRATIONS FOR  SELECTED AQCR'S  U.
AQCR NUMBER
30
32
83
35
88
92
94
101
102
103
104
106
115
116
119
120
122
123
128
129
131
136
139
142
148
151
152
153
158
159
160
161
162
166
167
174
176
178
LOCATION
CENT. IN
IN/MI
S. IN
IA/NE
N.E. IA
S. IA
MO/KS
S.E. KY
CENT. KY
KY/OH/WV
CENT. KY
LA/TX
N. MD
S. MD
E. MA
MA/RI
CENT. MI
E. MI
S.E. MN
MN/WI
car. MN
N. NC
S.W. MO
S.W. MT
W. HV
PA/NJ
CENT. MM
NM/TX
CENT. NY
NY/VT
CENT. NY
E. NY
W. NY
N. NC
NC/SC
N. OH
CENT. OH
OH/PA
MAXIMUM QUARTERLY MEAN
VALUE
(ng/m3)
1.21
1.39
5.33
1.08
1.03
1.34
1.46
2.17
1.27
2.08
3.07
1.71
3.58
2.07
1.18
1.38
1.27
1.87
1.46
1.08
3.53
1.27
3.16
4.02
1.59
2.89
1.46
2.65
1.38
1.22
3.27
2.70
1.07
1.44
1.28
1.33
1.19
1.63
YEAR
1974
1974
1974
1975
1975
1975
1974
1975
1975
1974
1975
1974
1975
1974
1975
1975
1975
1974
1975
1974
1975
1975
1974
1972
1975
1974
1974
1975
1974
1974
1975
1974
1975
1975
1975
1974
1975
1974
                             2-45

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                        TABLE  2-8  (concluded)

    MAXIMUM QUARTERLY  LEAD  CONCENTRATIONS  FOR  SELECTED  AQCR'S  0
AQCR NUMBER
184
193
195
196
197
200
202
LOCATION
CENT. OK
OR/WA
CENT. PA
S. PA
S.W. PA
CENT. SC
N.W. SC
207 TN/VA
208
209
211
214
215
216
217
218
220
221
222
223
225
226
229
234
239
240
244


CENT. TN
W. TN
N.W. TX
S.E. TX
N. TX
E. TX
S.W. TX
W, TX
W. UT
E. VT
S. VA
S.E. VA
CENT. VA
N.W. VA
CENT. WA
W. WV
S.E. WI
S. WI
PR
MAXIMUM QUARTERLY MEAN
VALUE VPaD
(ug/m3) YEAR
i
2.71
1.19
1.57
1.45
4.38
1.83
1.31
1.60
1.78
1.06
1.47
1.20
3.40
2.40
1.34
4.95
1.09
1.91
1.06
1.31
1.59
1.45
2.21
1.24
2.77
1.62
1974
1974
1974
1974
1974
1974-1975
1975
1975
1974
1975
1975
1975
1975
1975 i
1974 |
1974
1975 1
1974
1975 i
1975
1974 i
1974
1974
1975
1974
1974
2.31 1974
t i
1
i
Selected AQCR's are those with an estimated maximum quarterly
concentration exceeding 1.0
1.
Source:   See Appendices S,  T,  and U.
                                 2-46

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lead emissions in the  SAQCR's with maximum quarterly concentrations
above 4 ^g/m^ reveals specific types of situations which can lead
to relatively high ambient lead levels.  Most of the quarterly values
are estimates based on reported ambient concentrations for other
averaging times.
     The Eastern-Washington-Northern Idaho Interstate AQCR (No.  62)
has the highest proportion of ambient concentrations above 4 H-g/m^
of all AQCR's (U.S. Environmental Protection Agency, 1974h, i; U.S.
Environmental Protection Agency, 1975h, i).  Near the monitoring
sites is the Bunker Hill lead smelter in Kellogg, Idaho, which emits
up to 83 tons per day of lead into the atmosphere (U.S. Environmental
Protection Agency, 1974f: PEDCo-Environmental Specialists, Inc.,
1976).  The presence of this lead smelter, and possibly the presence
of three cast iron foundries, contribute to the relatively high
concentrations of airborne lead that were measured in AQCR 62.
     Other types of major lead emission sources can also be cited as
possible reasons for high values of airborne lead recorded in an AQCR.
For exmaple, the presence of five primary copper smelters in Southern
Arizona is probably a major cause of the elevated ambient lead
concentrations in AQCR 15 (viz., a maximum quarterly mean of
4.4 fig/m^K  in addition to the copper smelters, seven-oil fired
power plants, three cast iron foundries, and a battery plant represent
other stationary sources of lead in the AQCR.  The presence of
high traffic volumes and the resulting lead emissions from car exhausts
                                2-47

-------
is indicated by the fact that this area (Phoenix in particular) has
a transportation plan to control vehicular emissions.
     Primary lead and copper smelters also have contributed to
elevated lead levels in AQCR 142 in Southwestern Montana, where
maximum 24-hour measurements ranged up to 15 ;-ig/m^ (State Depart-
ment of Health and Envirotnental  Sciences, Montana, 1972).  Two cast
iron foundries and a ferroalloy producer also may have had some
impact on the observed values.
     Cast iron foundries are the major sources of lead emissions in
AQCR 218, Western Texas, where the maximum quarterly mean lead
concentration was 4.9ng/m3.  While vehicular emissions and small
stationary sources contribute to the overall ambient lead concentra-
tions, the four foundries are probably the major lead emitters
in this AQCR.
     In the Four Comers Region of Arizona, Mew Mexico, Utah, and
Colorado {AQCR 14), the maximum quarterly mean concentration
was over 4 ^g/rn^.  The major sources of lead emissions in this
area are six coal-fired power plants.  This is another example of an
AQCR where lead concentrations are primarily caused by one type of
source.
     In contrast, the Los Angeles region 1n Southwestern California
(AQCR 24) is an area where a number of different source types contri-
bute to the high lead concentrations, which range up to a maximum
                            •3
quarterly value of  6,7  ug/m   (Air Resources Board, California,

                                2-48

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1975).  Emissions from a number of battery plants, secondary lead
smelters, cast iron foundries, oil-fired power plants, in addition
to the large number of mobile sources, combined to produce the
measured airborne lead levels.
     All other AQCR's with maximum quarterly means above 4 ug/m
have various types of major lead emitters which contribute to the
potential airborne lead problem.  Cast iron foundries and a coal-
fired power plant are the major sources of airborne lead in
Southern Indiana (AQCR 83), where the maximum quarterly concentra-
tion is 5.3 ug/m .
     Cast iron foundries represent the largest number of stationary
lead emission sources in Pittsburgh and Southwestern Pennsylvania
(AQCR 197).  In addition, there are ferroalloy producers, battery
plants, coal-fired power plants, a secondary lead smelter, a munici-
pal incinerator, and an oil-fired power plant in the AQCR, plus a
relatively large number of mobile sources as evidenced by the fact
that Pittsburgh has a transportation plan to control vehicular
emissions.  The maximum quarterly mean lead concentration in AQCR
197 was 4.4 ug/m .
     Other ACQRs with maximum quarterly concentrations near 4 ug/m
include the following.  The San Diego region (AQCR 29) is similar to
the Los Angeles region, only on a smaller scale.  Two battery plants,
a similar number of cast iron foundries, and four oil-fired power
plants helped contribute to the estimated maximum quarterly lead

                                2-49
concentration of 3.7 ug/m .

-------
     The Chicago region (AQCR 57) includes a relatively large
number of different lead emission sources, such as battery plants,
secondary lead smelters, cast: iron foundries, municipal incinerators,
coal and oil-fired power plants, and mobile sources.  The resulting
estimated monthly level was 3.4  p-g/m^.
     The other two AQCR's with concentrations near  4 .ag/nr3 are
located in Northern Maryland (AQCR 115, 3.6 H-g/m^ maximum monthly
value), and in Central  Minnesota (AQCR 131, 3.5 ng/ra3 estimated
maximum quarterly concentrations).  Each AQCR has a few battery plants,
secondary lead smelters, and coal-fired power plants.  In addition,
A$CR 115 has six cast iron foundries, a municipal incinerator, and
five oil-fired power plants, while AQCR 131 has 14 cast iron foundries.
Each AQCR also has a mobile source plant to help control vehicular
emissions.
     Maximua quarterly lead concentrations in the 170 AQCR's
for which monitoring data have been received indicate  the extent
ol potential problems due to airborne lead, as defined by three
different levels cf airborne lead concentrations, 1.0, 1.5 and 2.0
       for maximum quarterly averages.
     Figure 2-3  shows  the number of AQCR's that have at least one
maximum quarterly concentration above each of the indicated levels in
1974 and 1975.   In a few instances, 1972 data were combined with 1974
results and 1976 data  augments  1975 information.  In all but one case
(viz., quarterly values above 1.0 ug/m ), the number of AQCR's with
                                2-50

-------
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                                     2-51

-------
concentrations greater than 1.0 ug/m , while only 14 percent would
have been out of compliance for a standard of 2.0 ug/m .   (Note that
Figure 3-1 includes estimated as well as reported data.)
 2.2.2  Source Specific  Data
      Empirical  studies  have been conducted in  order to investigate
 the ambient air concentrations  of airborne lead  in  the vicinity
 of various stationary lead emission  sources.   However, because of
 the number of different factors which  can influence ambient lead
 concentrations, the relationship between  a particular lead  emission
 source and the resultant ambient lead  levels can only be determined
 in a general  way.   Influencing  factors include meteorological  vari-
 ables such as wind speed and direction,  stability class, and ambient
 temperature;  source-related factors  such  as stack height, fugitive
 emissions, operating schedules  (e.g.,  plant shutdowns),  and source
 type; terrain factors such as topography, local  building sizes, and
 nearby vegetation  types, location factors such as downwind  distance,
 urban environmental, and other  proximate  emission source height,  and
 monitoring equipment condition.  Mo  single factor is responsible  for
 the concentrations observed at  various downwind  locations near an
 emission source; hence, it is difficult to extrapolate the  reported
 data to ambient lead concentrations  around other sources of airborne
 lead.  Nevertheless, empirical  studies of ambient lead concentrations
 near certain industries can provide  insight into the general  relation-
 ships between lead emissions and downwind concentrations.
                                  2-53

-------
in El  Paso.  The maximum 24-hour lead concentration between March
1973 and June 1974 at a monitoring site 2,500 feet (760 meters)
southeast of the mainstack was 45.5 n-g/tn^, while the average
24-hour value was 12.5 ^g/m^.  The distribution of daily concen-
trations at a receptor 0.4 mile from the Bunker Hill smelter shows a
larger percentage of values above 5 ng/rn^ when compared with the
concentration distribution at the closest receptor to the ASARCO-E1
Paso smelter (86 versus 61 percent, respectively), in spite of the
fact that the downwind distance to the El Paso receptor is smaller
(0.2 raile).  The annual mean concentration at the receptor near
the Bunker Hill smelter (12.5  fig/m3) is also larger than at the El
Paso receptor (10.2 ng/ra3).  This is probably because the Kellogg
plant emits more lead due to a number of factors, including a higher
rate of lead processing, a higher concentration of lead in the ore,
and slightly less efficient control devices.
     Ambient lead concentrations have been monitored near the ASARCO
lead smelter by the Environmental Protection Agency in 1975.  Only
maximum 24-hour values were reported, and these showed a general inverse
relationship between concentration and distance from the source.  The
three receptors within one mile of the smelter averaged 12.1 u.g/ra^
as a 24-hour maximum, while the two receptors 2.5 and 4.5 miles from
the smelter had 2.5 and 7.0 j^g/m^ maximums, respectively.
     Primary Copper Smelters.  Primary copper smelters also produce
lead as a byproduct, some of which is emitted to the effluent stream.
                                     2-55

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     2.2.2.1  Specific Source Analysis  -  Primary Lead Smelters.
Ambient air quality measurements conducted in the vicinity of three
primary lead smelters showed relatively high lead concentrations when
compared to other lead emission sources.  The American Smelting and
Refining company (ASARCO) smelter in East Helena, Montana is the
smallest of the three, producing an average of 170 tons of lead a
day.  The Bunker Hill smelter in Kellogg,  Idaho is the largest, with
a daily production of 350 tons of lead, while another ASARCO smelter
in El Paso, Texas produces 200 tons of lead as well  as 260 tons of
copper a day (U.S. Environmental Protection Agency,  1975g).
     The means of the monthly lead concentrations for ten receptors
in the vicinity of the El Paso smelter range from 10.2 ^9/m^
at the closest receptor (0.2 mile away) to 0.9 ng/ra^ at the most
distance receptor (3.7 miles away).  Receptors located more than
1.1 miles (1.8 kilometers) from the smelter had no monthly lead
concentrations greater than 5 &ig/ra3, while the average of the
monthly concentrations at any receptor was never more than 1.8
ng/m3.  Also, no monthly concentration exceeded 3 ug/m^, and no
average of the monthly concentrations exceeded 0.9 n-g/m^ for
receptor sites more  than three miles (4.8 kilometers) from the
smelter.
     The Bunker Hill  lead smelter in Kellogg, Idaho processes 75
percent more lead per day than  is processed by the ASARCO smelter
                               2-54

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maximum quarterly concentrations above a certain level decreased  from
1974 to 1975.  In all cases, however, the percentages of AQCR's with
data that had quarterly concentrations above a given level declined
from 1974 to 1975.  Thus, while nine more AQCR's reported quarterly
values above 1.0 ^g/w? in 1975 than in 1974, there was a 0.2
percent decrease from 1974 to 1975 in the percentage of AQCR's that
reported lead monitoring data and had monthly values above 1.0
y.g/m3.  These declines appear to signify a relative improvement in
air quality with respect to airborne lead from 1974 to 1975, due
possibly to the reduction of the lead content in gasoline as well
as the installation of particulate control devices on stationary
sources over the years.
     At a concentration of 1.0 ug/m  , 103 of the 170 AQCRs wTbh"~
available data (61 percent) had estimated quarterly lead concentra-
tions exceeding this value.  The number of AQCRs decreases to  56
(33 percent of those reporting data) with quarterly levels above
1.5 ug/m  , and to 38 (22 percent) that have at least one concentration
2  ug/m  .  Geographically, the  103 AQCRs which have maximum quarterly
lead concentrations above 1.0 M-9/ra^ comprise the majority of land
area of the country and include the heavily populated areas.
     Figure 3-1 shows the number of AQCR's which would have been out
of compliance relative to different proposed standards based on
reported ambient air concentrations for 1975 alone.  Out of the 162
AQCR's with reported data,  almost 80 percent reported ambient air
                                2-52

-------
In general, lead concentrations in the vicinity of primary copper
smelters are lower than those in the vicinity of lead smelters
because of the lower uncontrolled lead emissions per ton of product
from copper smelters.
     Ambient lead levels around the Anaconda copper smelter in Anaconda,
Montana were measured in 1973 and 1974.  This is the largest of the
copper smelters investigated, processing 500 tons of copper a day
(U.S. Environmental  Protection Agency, 1974f).   The mean of the
measured 24-hour lead concentration was 0.2 ^g/m^, with no values
exceeding 0.6 (j.g/m^.  These concentrations were much lower than the
ambient levels around the lead smelters described previously due to
the lower lead emissions, the generally greater distance to the
receptor, and the very tall stack (925 feet).
     The Kennecott copper smelter in McGill, Nevada is smaller than
the Anaconda plant,  processing only 190 tons of copper per day (U.S.
Environmental Protection Agency, 1974f).  The average 24-hour ambient
lead concentration 2.6 miles from the smelter was 0.3 ng/ro3,
which was much lower than similar measurements observed near the
three lead smelters described previously, even for receptors greater
than 2.6 miles from their respective smelters.
     The Magma copper smelter in San Manuel, Arizona processes 310
tons of copper per day.  The mean 24-hour lead concentration of only
0.07 ^g/m^ is far less than the average values around the primary
lead smelters described above,  and no concentration exceeded 0.7

                                 2-56

-------
     .  in spite of the fact that the quantity of copper  processed
at the San Manuel smelter is greater than the amount at the McGill
smelter, and the receptor was closer (0.9 mile versus 2.6 miles), the
airborne lead levels were lower.  This was probably due in part  to
the taller stack and the high efficiency of the parti oil ate control
methods used at the San Manuel smelter.
     The Phelps Dodge copper smelter in Ajo, Arizona processes
200 tons per day of copper (U.S. Environmental Protection Agency,
1974f), while the average 24-hour measured lead concentration near
the smelter was 0.06 pg/wP.  Another Phelps Dodge copper smelter,
in Douglas, Arizona, processes 370 tons of copper per day (U.S.
Environmental Protection Agency, 1974f) with an average 24-hour
concentration of 0.2 tJ-g/ra^, and maximum concentration of 1.3
fig/ra3 at the receptors 3.1 miles from the smelter.
     All receptors greater than 0.4 nrile from the lead and copper
smelters had 58 percent or more of their monthly lead concentrations
below the level of 2 M-g/m^.  If receptors near the El Paso and
Kellogg smelters are excluded from the analysis, then over 94 percent
of the 24-nour concentrations at all  other receptors were less than 1
     Lead Storage Battery Plants.  Ambient lead monitoring has been
conducted in the vicinity of five battery plants by Pennsylvania's
Department of Environmental Resources.  Four of the plants investi-
gated combine grid manufacturing with secondary smelting of reclaimed
                                2-57

-------
lead from used batteries.  The secondary lead smelting facilities of
the General  Battery plant in Hamburg, Pennsylvania were removed
in April 1971; ambient lead concentrations were monitored both before
and after the operational change.
     The Marjol Battery Company plant in Throop, Pennsylvania pro-
cesses an average of 3.7 and a maximum of 3.8 tons of lead per hour.
Measured ambient concentrations ranged up to 4.9 ^.g/wP for an average
of all 24-hour values at one receptor, while at another receptor over
35 percent of the observations were above 5 H-g/ro^, both receptors
being 330 yards from the plant.  This fact probably results from the
relatively small stack height of the battery plant (20 feet) and the
proximity of the receptors (0.19 mile).
     Lead emissions from the General Battery Company in Hamburg,
Pennsylvania are reported to average 1.1 pounds/hour with a maximum
of 1.6 pounds/hour for the grid casting operations without a rever-
beratory furnace.  Existing control equipment includes a baghouse
with a 98 percent designed particulate removal efficiency and a
scrubber with a 96 percent design efficiency (Department of Environ-
mental Resources, Pennsylvania, 1976b).  Prior to April 23, 1971,
when the reverberatory furnace at the plant was removed, ambient lead
concentrations  near the  plant were extremely high, with average
24-hour values  up to 56.5 u-g/m^ at a  distance of 50 yards (46
meters), and  a  maximum 24-hour value  of 160 ^g/m^ at a receptor 275
yards  (251 meters) away.  Current lead concentrations at these same

                                  2-58

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two receptors are 2.5 ^g/m  (averaqe 24-hour value) and 2.9
(maximum 24-hour value), respectively.
     The General Battery Company plant in Laurel dale, Pennsylvania,
employs a total of eight smelting and casting operations, and emits
an average of 4.9 pounds of lead per hour and up to a maximum of
7.3 pounds per hour.  Average 24-hour lead concentrations measured in
1971 at three monitors within 250 yards (230 meters) of the plant
were no greater than 1.5 ug/m3, with no single 24-hour value
exceeding 3.2 jig/ra3.  However, in 1970 the average 24-hour lead
concentrations at two monitors 150 yards from the plant were 15.2 and
33.2 M-g/m3  with maximum 24-hour values of 72 H-g/m3 and 140 i^g/m3,
respectively (these higher values probably reflect increased lead
emissions which were reduced by 1971).  The reported concentra-
tions at the Laurel dale plant were measured prior to the addition of
a lead reverberatory furnace that was moved from the Hamburg plant of
the General Battery Corporation.
     The Prestoli:.e Battery Division of the Eltra Company in Temple,
Pennsylvania emits a total of 9.7 pounds of lead per hour from
13 different processing operations.  Average 24-hour ambient concen-
trations near the plant generally decline with increasing distance,
from 8.2 to 1.3 ^g/m3 for receptors from 25 to 250 yards (23 to 230
meters) from the plant.  However, the two closest monitoring sites
are near a heavily traveled road where lead emissions from traffic
nay be important contributors to overall concentration levels.
                                  2-59

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Another receptor 1,330 yards (1,210 meters) away recorded an average
concentration of 2.7 ^g/m^ in 1970, but this level was influenced
by the lead emissions from the nearby General Battery plant in
Laurel dale.
     The East Penn Battery Plant incorporates a blast furnace with
potential lead emissions of 237 pounds/hour.  The average 24-hour
ambient lead concentrations, measured from 250 to 300 yards (230
to 270 meters) away, ranged from 3.1 to 3.9 ^g/m3.
     Secondary Lead Smelters. Ferroalloy Producers, and Gray Iron
Foundries.  Ambient lead concentrations near the property line of
secondary lead smelters, ferroalloy manufacturers, and gray iron
foundries have been measured by the Texas Air Control Board.  Sample
24-hour lead concentrations ranged from 3.3 to 111.6 ug/m3 near two
secondary lead smelters, from 2.5 to 4.2 H-g/nfr3 near a ferroalloy
producer, and from zero to 50.9 tig/m^ near seven gray iron foundries.
Unfortunately, the relatively small number of reported samples and
the lack of precise information concerning source emissions tend to
reduce the significance of the data when compared to the ambient data
presented for other source types.
     A study was conducted between May and December 1973 by the
Toronto Board of Health of lead concentrations near two secondary
lead smelters (Roberts et al., 1974).  It was found that fugitive
emissions were more important than stack emissions in contributing
to the nearby ambient lead levels, primarily because of the lower
                                2-60

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emissions heights of fugitive sources.   A comparison was made of
ambient lead concentrations near the smelters with concentrations in
an urban control  area away from the smelters to see if there were any
significant differences that could be attributed to lead emissions
from the smelters.  It was found that the geometric mean lead concen-
tration in the smelter area was 3.0 H-g/nr3 compared to a similar
mean of 0.8 M^/m^ in the urban control  area (Roberts et al., 1974).
     2.2.2.2  General Considerations.  Ambient lead concentrations in
the vicinity of certain industrial plants are the result of a number
of variables.  In general, the data demonstrate some important
relationships such as the direct relationship between concentrations
and the lead emission rate, and the inverse relationship between
downwind distance and ambient levels of lead.  Figures 2-4, 2-5, and
2-6 depict maximum 24-hour ambient lead concentrations as a function
of distance from primary and secondary lead smelters (Figure 2-4),
primary copper smelters and gray iron foundries (Figure 2-5), and
battery plants (Figure 2-6).  Lead concentrations near primary lead
smelters (Figure 2-4) show most clearly the general decline of lead
levels at increasing downwind distances from an emission source.
     Table 2-9 indicates the percentage of monthly concentrations
which exceeded five different concentration levels in the vicinity
of the industrial plants investigated.   In some cases, general con-
clusions concerning ambient lead concentrations near certain types of
stationary emission sources may be drawn based on previous discussions.
                                2-61

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LEAD CONCENTRATIONS NEAR:
• Primary Lead Smelters
A Secondary Lead Smelters
11 11 1
33 50 m 100 m 500 m 1 km 5 km 10










km
          RECEPTOR DISTANCE  (meters)
                    FIGURE 2-4
    LEAD  CONCENTRATIONS  VERSUS  DISTANCE FPOM
      PRIMARY AND SECONDARY LEAD SMELTERS
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w
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II 1 I 1






















10 a 50 a 100 a 5CO a 1 km 5 ka 10 ka
RECEPTOR DISTANCE ^.aeters)
                    FIGURE 2-5
   LEAD COKCENTRATIONS VERSUS :ISTANCE
PRIMARY COPPER SMELTERS AND GRAY IRON FOUNDRIES
                       2-62

-------
 1,000



   500
00

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 10


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2  1.0
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-LEAD  CONCENTRATIONS NEAR:



   •  Battery Plants


 	I	I
                                             I
                                                                 I
      10  a
                  50  m   100  m          500  m   1 km


                        RECEPTOR DISTANCE (meters)
                                                            5  km  10 km
                                FIGURE 2-6

         LEAD CONCENTRATIONS VERSUS DISTANCE FROM BATTERY  =>LANTS
                                     2-63

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    PROBABILITY  OF  EXCEEDING  LEAD  CONCENTRATION  LEVELS  NEAR SELECTED INDUSTRIES
INDUSTRY AND PLANT
PRIMARY LEAD SMELTER
ASARCO— El Paso, TX
Bunker Hill— Kellogg, ID
ASARCO— East Helena, MT
PRIMARY COPPER SMELTER
ASARCO— El Paso, TX
Anaconda — Anaconda, MT
Kennecott— McGill, NV
Magma--San Manual , AZ
Phelps Dodge— Ajo, AZ
Phelps Dodge— Douglas, AZ
LEAD BATTERY MANUFACTURER
Marjol Battery— Throop , PA
j General Battery—Hamburg, PA
j General Battery— Laurel dale, PA
Presto! ite Battery— Tempi e , PA
East Penn— Richmond Township, PA
SECONDARY LEAD SMELTER (a)
Dixie Lead— Dallas, TX
NL Industries— Dallas, TX
FERROALLOY PRODUCER (a)
Tenn-Tex Alloy— Houston, TX
GRAY IRON FOUNDRY (a)
Oil City Iron Works— Corsicana, TX
Lufkin Industries— Luf kin, TX
Tyler Pipe— Tyler, TX
PERCENTAGE OF MONTHLY AVERAGES
EXCEEDING GIVEN LEVELS ( g/m3)
0.5

96
100
27

96
0
7
0
0
0

93
100
100
100
100

100
100

100

0
100
100
1.5

49
100
0

49
0
0
0
0
0

60
100
79
92
100

100
100

100

0
100
0
Trinity Valley Iron and Steel— 100 j 100
Fort Worth, TX
Green's Bayou Foundry— Houston, T« TOO
McKinley Iron Works— Fort Worth, TX 100
2.0

35
100
0

35
0
0
0
0
0

47
100
79
67
100

100
100

100

0
100
0
3.0

20
100
0

20
0
0
0
0
0

30
57
64
67
100

100
100

100

0
100
0
100 0

1 00 1 00 1 00
100 | TOO j ',00
American Darling Foundry— Beaumont, TX 100 100 TOO
5.0

13
87
0

13
0
0
0
0
0

17
0
57
33
0

100
100

0

0
100
0
0

NUMBER
OF
MONTHLY
AVERAGES

379
16
15

379
9
14
11
10
12

101
7
14
12
3

1
1

1

1
1
1
1

100 1 i
100
100 100
1
T
1
Mote:  (a) Percentages are based on the one monthly average ambient air lead concen-
           tration value available for each plant listed.

Sources:   U.S. Environmental Protection Agency.   19/4g.  Smelter Study, 1973-1974.

          Deoartment of Environmental Resources, Pennsylvania.  1976a.  Hi-Vol
          Sampling Data.
          Texas Air Control Beard.  April 197^a.
          Emissions from Texas Smelters.  Austin
A Deport of Typical  Element
"exas.
          Texas Air Com il Board,  ^oril 197^b.  A ".sport of Typical Element
          Emissions from Texas Foundries.  Austin, Texas.

-------
High ambient lead levels were observed in the vicinity of primary lead
smelters and battery plants, particularly those which include secondary
lead smelting facilities, and may be expected in the vicinity of other,
similar plants.  These results are mainly due to the relatively large
lead emissions from the primary lead smelters, and the apparent lack
of atmospheric dispersion at the battery plants/secondary smelters
due to relatively small source-recej. or distances and stack heights.
Concentrations in the vicinity of primary copper smelters were not as
high because of their comparatively large stack heights.  However, in
some cases ambient lead concentrations could show elevated values
because of downwash or fumigation conditions from the stack, and the
anount of fugitive lead emissions from this type of facility.  A
large percentage of the lead emissions from copper smelters is due to
fugitive emissions, which produce maximum downwind concentrations
relatively near the plant site and much closer than the monitoring
sites used for the reported air quality studies.  If all monitoring
sites were located at the point of maximum, downwind concentration
from each emission source, primary lead and copper smelters would
probably produce higher ambient lead concentrations than oattery
plants or other types of sources.
     2.2.3  Estimated Ambient Lead Levels for AQCR's Without Monitoring
            Data
     2.2.3.1   Introduction.  For 73 of the 77 AQCR's where concen-
trations were  not measured in 1975, estimates of the maximum
Quarterly lead levels have been determined through mathematical
                                  2-55

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modeling of lead emissions arid subsequent atmospheric diffu-
sion patterns (the four AQCR's omitted from the analysis were outside
the continental  United States).  Maximum lead emissions were estimated
from mobile sources at the location of the highest recorded daily
traffic volume within each AQCR.  A line source diffusion model was
then applied to estimate the resulting ambient lead concentration ten
meters downwind from the road or street, given the observed traffic
speeds and road conditions.  Emissions from stationary sources were
estimate.! by applying appropriate emission factors and control
efficiencies to each size and type of major lead source known to
exist in an AQCR.  Maximum downwind concentrations were then esti-
mated for each source from diffusion equations, given appropriate
stack and fugitive emission parameters.  The highest monthly lead
concentration from a stationary source was then superimposed on the
maximum concentration from mobile sources in each AQCR to derive the
expected upper limit for ambient lead levels.  Because of the uncer-
tainties involved  in estimating lead concentrations, the use of the
expected upper limit as a design value for determining emission
rollback requirements tends to cnin-'-nize the probability of under-
estimating  the impact of alternative lead standards.
      2.2.3.2  Concentration Estimates from Mobile Sources.  Each
AQCR  within  the  continental United States which did not have reported
lead  concentrations was contacted  in order to  determine the maximum
average  daily traffic count (ACT)  in that AQCR and  the  location of

                                 2-66

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-------
converted to a downwind concentration by use of a line source diffu-
sion model.   Table 2-10 shows the resulting maximum monthly ambient
lead concentration for mobile sources in each of the indicated AQCR's.
     2.2.3.3  Concentration Estimates from Stationary Sources.  An
inventory of the size and type of nine stationary sources of airborne
lead was used to estimate lead emissions in those AQCR's without
monitoring data.  Appropriate emission factors and control requirements*
were applied to the output levels of typical plants representing
the different major industries with lead emissions.  Each resulting
lead emission rate, Q in (tons/year), was then related to a maximum
quarterly lead concentration, x(in-ug/ra ), by use of an atmospheric
diffusion model (Scruggs, 1977).  The model was run for different
industry types, and in some cases for different sizes, because of the
varying stack parameters and other variables which affect pollutant
diffusion.  A separate factor, X/Q, was developed for each typical
plant type and then multiplied by Q for the largest plant of each
category in each of the pertinent AQCR's.  The resulting monthly
downwind concentrations, repre«^nting the maximum ambient lead levels
in  the vicinity of the different industry categories in each AQCR,
are shown in Table 2-10.
     The sum of the maximum expected concentration from the largest
stationary contributor and the concentration near the roadway with
the highest traffic count  is used as an upper limit of the expected
 'Due to SIP regulations for particulates.
                               2-68

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ambient lead level  in an AQCR, as given in Table 2-10.   While it is
not expected that the location of the two maximum concentrations
would necessarily coincide, the analysis was designed to reduce
greatly the probability of underestimating ambient lead concentra-
tions in an AQCR.
     Figure 2-7 shows the number of AQCR's which would have been
out of compliance relative to different proposed standards based on
estimated ambient air concentrations for 1975.   Out of the 73 AQCR's
with estimated data, almost 48 percent had estimated ambient concen-
trations greater than 1.0 ng/m^ while only 11  percent would have
be«ffc out of compliance for a standard of 2.0 ^g/m^.
     The estimated maximum lead concentrations  from 73 AQCR's without
monitoring data are to be combined with the maximum observed concen-
trations from the 162 AQCR's with 1975 data (see Section 2.2.1) and
eight AQCRs with only 1974 data.  These data are to be used in
determining required emissions rollbacks in order to meet possible
ambient lead standards.  The four AQCR's not included in the analy-
sis  (located in Guam, American Samoa and two in Alaska) were not
considered to have major sources of lead emissions.
                                 2-72

-------
            74 AQCR'S WITH ESTIMATED DATA
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19

13

          1.0             1.5            2.0

      MAXIMUM  MONTHLY  LEAD CONCENTRATION
                 FIGURE 2-7
  NUMBER OF AQCR'S WITH MAXIMUM ESTIMATED
 LEAD CONCENTRATIONS  ABOVE INDICATED VALUES

                   2-73

-------
                              REFERENCES
AIRBORNE LEAD IN THE ENVIRONMENT:  SOURCES AND AMBIENT LEVELS

Air Resources Board, California.   November 1975.   Reconstruction of
     the California Ambient Air Quality Standard  for Lead, Staff
     Report 75-21-1.

American Petroleum Institute.  September 1974. Waste Oil  Roundup...
     No. 3.  Publication No. 1587.  Washington, D.C.

American Petroleum Institute.  October 1975.  Energy from Used
     Lubricating Oils.  Publication No. 1588.  Washington, D.C.

Bailie, J.D.  March 1976.  Economics of Manganese as an Antiknock
     in Unleaded Gasoline.  Ethyl Corporation, Houston, Texas.
     Presented at the 1976 Annual Meeting, March  30, 1976, San
     Antonio, Texas.

Bureau of the Census.  1976b.  Statistical Abstract of the United
     States:  1976.  U.S. Department of Commerce.

Chansky, Steven, James Carroll, Benjamin Kincannon, James Sahagian,
     and Norman Surprenant.  September 1974.  Waste Automotive
     Lubricating Oil Reuse as a Fuel.  Prepared for U.S. Environ-
     mental Protecti on Agency, Washington, D.C.

Commercial Car Journal.  July 1974.  "Industry Trends and Statistics,"
     Commercial Car Journal.

Consumers Union.  April 1977a.  "Emissions Control:  The Impossible
     Standards That Could Have Been Met," Consumer Reports.
     Consumers Union.

Consumers Union.  August 1977b.   "MMT:  A Gasoline Additive That
     Should Be Subtracted," Consumer Reports.

Department of Environmental Resources, Pennsylvania.  1976a.  Hi-Vol
     Sampling Data.  Harrisburg,  Pennsylvania.

Department of Environmental Resources, Pennsylvania.  1976b.  Emissions
     Inventory.  Harrisburg, Pennsylvania.

Edwards,  H.W.   December 31,  1973.   "Colorado  State University Research
     Program,"  Impact  on Man of  Environmental Contamination Caused  Dy
     Lead,  Interim  Report  prepared  for the  National Science Foundation.
     Colorado State University,  Fort Collins, Colorado.
                                 2-74

-------
                        REFERENCES (Continued)
AIRBORNE LEAD IN THE ENVIRONMENT:   SOURCES AND AMBIENT LEVELS

Faggan, J.E., J.D.  Bailie,  E.A. Desmond, and D.L. Lenane.   October
     1975.  An Evaluation of Manganese as an Antiknock in  Unleaded
     Gasoline.  Ethyl  Corporation,  Detroit, Michigan,  and  Houston,
     Texas.For presentation at the SAE Automobile Engineering
     Meeting, Detroit, Michigan, October 13-17, 1975.

Federal Energy Administration.  November 16, 1976a.  Preliminary
     Findings and Views Concerning the Exemption of Motor  Gasoline
     from the Mandatory Allocation and Price Regulations.Washington,
     _s_                      ,       ,


Greenberg, Robert Russ.  1976.  A Study of Trace Elements  Emitted
     on Particles from Municipal Incinerators.University of
     Maryland.

Hum, R.W.  1968.  "Mobile Combustion Sources," Air Pollution,
     Vol. 3, edited by Arthur C. Stern.  Academic Press, New York.

Lewis, Bernard and Guenther von Elbe.  1961.  Combustion,  Flames.
     and Explosions of Gases.  Combustion and Explosives Research,
     Inc., Pittsburgh, Pennsylvania.

Massoglia, Martin F.  August 1976a.  Summary of Particulate and
     Sulfur Oxide Emission Reductions Achieved Nationwide  for
     Selected Industrial Source Categories, 1970-1975: Volume  I.
     Center for Technology Applications, Research Triangle
     Institute.  Prepared for Environmental Protection Agency.

Motor Vehicle Manufacturers Association of the United  States,  Inc.
     1975a.  1975 Automobile Facts and Figures.  Statistics
     Department, Detroit, Michigan.

Motor Vehicle Manufacturers Association of the United  States,  Inc.
     1976.  Motor Vehicle Facts and Figures 1976.  Statistics
     Department, Detroit, Michigan.

Murrell, J.D., R.G. Pace, G.R. Service,  and D.M. Yaeger.   October
     18-22, 1976.  "Light Duty Automotive Fuel Economy Trends
     Through 1977," Paper No. 760795 presented at the  Automotive
     Engineering Meeting.  Society of Automotive Engineers,
     Dearborn, Michigan.
                                2-75

-------
                        REFERENCES (Continued)
AIRBORNE LEAD IN THE ENVIRONMENT:   SOURCES AND AMBIENT LEVELS

National Petroleum News.  Mid-May  1976.  Factbook Issue,  National
     Petroleum News.

Natusch, D.F.S., J.R. Wallace,  and C.A. Evans.  January 18, 1974.
     "Toxic Trace Elements:  Preferential  Concentrations  in
     Respirable Particles," Science, Vol.  183.

PEDCo-Environmental  Specialists,  Inc.  June 1976.  Interim
     Report on Control  Techniques  for Lead Ennssion~Factors and
     1975 National Lead Emission  Inventory.Cincinnati,  Ohio.
     Prepared for U.S.  Environmental Protection Agency.

Roberts, T.M., T.C.  Hutchinson, J. Paciga, A. Chattopadhyay, R.E.
     Jervis, and J.  VanLoon.  December 20, 1974.  "Lead Contamination
     around Secondary Smelters:  Estimation of Dispersal  and Accu-
     mulation by Humans," Science, Vol. 186 (4169), pp. 1120-1123.

Sessa, Bill.  September 1, 1977.   Public Information Officer,
     California Air Resources Board.  Telephone conversation.

Shelton, Ella Mae.  January 1972a»  Motor Gasolines, Summer 1971.
     Bart!esvilie Energy Research  Center,  Bureau of Mines, U.S.
     Department of the Interior,  Bartlesville, Oklahoma.

Shelton, Ella Mae.  June 1972b.  Motor Gasolines, Winter  1971-1972.
     Bartlesvilie Energy Research  Center.Bureau of Mines, U.S.
     Department of the Interior,  Bartlesvilie, Oklahoma.

Shelton, Ella Mae.  January 1973a.  Motor Gasolines. Summer 1972.
     Bartlesville Energy Research  Center,  Bureau of Mines, U.S.
     Department of the Interior,  Bartlesville, Oklahoma.

Shelton, Ella Mae.  June 1973b.  Motor Gasolines. Winter 1972-1973.
     Bartlesville Energy Research  Center,  Bureau of Mines, U.S.
     Department of the Interior,  Bartlesville, Oklahoma.

Shelton, Ella Mae.  January 1974a.  Motor Gasolines, Summer 1973.
     Bartlesville Energy Research Center,  Bureau of Mines, U.S.
     Department of the Interior,  Bartlesville, Oklahoma.
                                 2-76

-------
                        REFERENCES (Continued)
AIRBORNE LEAD IN THE ENVIRONMENT:   SOURCES AND AMBIENT LEVELS

Shelton, Ella Mae.  June 1974b.  Motor Gasolines,  Winter 1973-1974.
     Bartlesville Energy Research  Center,  Bureau of Mines,  U.S.
     Department of the Interior, Bartlesvilie, Oklahoma.

Shelton, Ella Mae.  January 1975a.  Motor  Gasolines, Summer 1974.
     Bartlesville Energy Research  Center,  Bureau of Mines,  U.S.
     Department of the Interior, Bartlesville, Oklahoma.

Shelton, Ella Mae.  June 1975b.  Motor Gasolines,  Winter 1974-75.
     Bart!esvilie Energy Research  Center,  Energy Research and
     Development Administration, Bartlesville, Oklahoma.

Shelton, Ella Mae.  January 1976a.  Motor  Gasolines, Summer 1975.
     Bartlesville Energy Research  Center,  Energy Research and
     Development Administration, Bartlesville, Oklahoma.

Shelton, Ella Mae.  June 1976b.  Motor Gasolines.  Winter 1975-76.
     Bartlesvilie Energy Research  Center,  Energy Research and
     Development Administration, Bartlesvilie, Oklahoma.

Shelton, Ella Mae.  January 1977.   Motor Gasolines, Summer 1976.
     Bartlesvilie Energy Research  Center,  Energy Research and
     Development Administration, Bartlesville, Oklahoma.

State Department of Health and Environmental  Sciences, Montana.
     1972.   Lead Concentration from High Volume Filters, Jan. 1972-
     Dec. 197T.

Svercl,  Paul.  March 8, 1977.  Highway Engineer, Federal  Highway
     Administration.  Telephone conversation.

Ter Haar, G.L., M.E. Griffing, M.  Brandt,  D.G. Oberding, and
     M.  Kapron.  August 1975.  "Methylcyclopentadienyl Manganese
     Tricarbonyl as an Antiknock:   Composition and Fate of
     Manganese Exhaust Products,"  Journal  of  the Air Pollution
     Control Association, Vol. 25(8):858-860.

Texas Air Control Board.  April 1974a.  A  Report of Typical  Element
     Emissions from Texas Smelters.  Austin,  Texas.

Texas Air Control Board.  April 1974b.  A  Report of Typical  Element
     Emissions from Texas Foundries.   Austin,  Texas.

-------
                        REFERENCES (Concluded)
AIRBORNE LEAD IN THE ENVIRONMENT:   SOURCES AND AMBIENT LEVELS

U.S. Environmental  Protection Agency.   April  1974b.   Report to
     Congress. Waste Oil  Study.   Washington,  O.C.

U.S. Environmental  Protection Agency.   October 1974f.  Background
     Information for New Source  Performance Standards:  Primary
     Copper. Zinc,  and Lead Smelters;   Volume 1:   Proposed Standards.
     Office of Air Quality Planning and Standards,  Research Triangle
     Park, North Carolina.  NTIS No. PB-237 832.

U.S. Environmental  Protection Agency.   1974g.  Smelter Study, 1973-
     1974.

U.S. Environmental  Protection Agency.   1974h.  National  Air Surveil-
     lance Network—Ambient Air  Quality Data, 1974.   Computer
     Printouts.

U.S. Environmental  Protection Agency,  1974i.   National Aerometric
     Data Bank—Quarterly Frequency Distributions,  1974.  Computer
     Printouts.

U.S. Environmental  Protection Agency,  1975g.   Scientific and Technical
     Assessment Report on Lead from Stationary~Sources.EPA-60016-
     75-OOX.August 1975.~

U.S. Environmental  Protection Agency.   1975n.  National  Aerometic
     Data Bank—Quarterly Frequency Distributions,  1975.  Computer
     Printouts.

U.S. Environmental  Protection Agency.   1975i.  National  Air Surveil-
     lance Network—Ambient Air Quality Data, 1975.   Computer
     Printouts.

U.S. Environmental  Protection Agency.   January 1977a.  Draft Document:
     Control Techniques for Lead Air Emissions.  Office of Air Quality
     Planning and Standards, North Carolina.

Weinstein, J.  August 1974a.  Waste Oil Recycling and Disposal.
     Recon Systems. Inc., Princeton, New Jersey.   Prepared for
     Environmental  Protection Agency.   NTIS No. PB-236 148.

Wilson, James.  July 14,  1976a.   U.S.  Environmental  Protection Agency.
     Personal communication.
                                 2-78

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         3.  ENVIRONMENTAL IMPACTS OF THE PROPOSED STANDARDS
3.1  DEVELOPMENT OF CONTROL STRATEGIES
     The environmental impacts of a lead NAAQS are contingent upon
the emission control philosophy and specific control strategies
adopted by the states with the ultimate authority over those AQCR's
whose ambient quality is projected to exceed the standard by the
attainment date.  In this section, sample control strategies are
developed for the purpose of assessing the national impacts of the
three possible standards (1.0, 1.5 and 2.0 ug/m  , with attainment
required by 1982.  The probability of these sample control
strategies being sufficient to bring the nation  into compliance
with the proposed standards is closely correlated with the
accuracy of the ambient concentrations (both measured and predicted)
on which the impact analysis is based.  It is not to be inferred, how-
ever, that the control strategies developed are those which would
necessarily be used by any given state.
     Figure 3-1 shows the number of AQCR's with ambient air lead con-
centrations in the baseline year, 1975, in excess of alternative
levels of the proposed standard.  A large number of AQCR's (113 out
of 243) would require additional control of lead emissions to meet
an ambient lead standard of 1.0/ig/m  (quarterly average).  To meet the
                                            •3             o
less stringent candidate standards (1.5/ug/m  and 2.0^g/m ), 53 and
31 AQCR's respectively would require control.  However, by 1982, the
year in which the AQCR's must be in compliance with the lead NAAQS,
                                 3-1

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the niv.ber of AQCR's requiring control  should be substantially reduced
due to existing EPA regulations which affect lead emissions to the
atmosphere (SIP and "ISPS control for participates and no-lead/phase-
down of lead in gasoline--see Sections  2.1.1.3 and 2.1.2.3).
     To determine the amount of control which would be required in
198?. the rollback technique was used.   When the 1975 ambient concen-
tration was greater than the proposed level  of the standard,  the per-
centage reduction of lead concentration in ambient air (rollback)
required to attain the standard was computed.*  The rollback  tech-
nicue is based on the assumption that the percentage reduction in
the emissions of a pollutant is equal to the percentage reduction in
the ambient concentration of that pollutant.  Thus, a 1975 emissions
inventory is necessary to determine the initial  emissions rollback
required and a 1982 emissions inventory is needed for comparison to
determine how much additional control may be necessary relative to
the 1975 requirements.
     Using the latest available data, a 1975 lead emissions inventory
was prepared which includes lead emissions from mobile sources and
from the 11 types of major point sources identified in Section 2.1,
^Percentage rollback =
     maximum 1 gad concentration - proposed level of NAAQS
  maximum lead concentration - background lead concentration
    r* natural background lead concentration is ^stvated at 0.005
 wg/nv (National Academy of Sciences, '972).
                                 3-3

-------
namely:   ferroalloy production, lead acid battery production, primary
lead smelting, secondary lead smelting, primary copper smelting, lead
alkyl production, gray iron production, coal-fired power generation,
oil-fired power generation, solid waste incineration, and iron and
steel production.  The resulting 1975 emission inventory and projected
mobile and stationary source growth rates (see Sections 2.1.1.3 and
2.1.2.3) were the bases for estimating 1982 and later lead emissions
inventories for each AQCR.
     The percentage rollback of 1975 ambient lead concentrations
required to meet the proposed standard was applied to the estimated
tons of lead emitted in 1975.  The resulting number of tons was com-
pared to the estimated 1982 lead emissions to determine whether
additional control of lead emissions would be required to meet the
proposed level of the standard by 1982.  The same technique was used
to determine whether the standard would be maintained in 1982 and
1995, and was performed for the three different standards and 243
AQCR's involving approximately 2,900 plants in 11 industrial cate-
gories as well as mobile emissions for each AQCR  (based on gasoline
sales and lead content).
3.1.1  Control Philosophy
     There are three basic schemes for the control of lead emissions-
stationary source control, mobile source control, and combinations of
stationary and mobile  source control.  Several alternatives are avail-
able for  achieving  each control  scheme.  The way  in which these schemes
                                 3-4

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and options are applied depends on +** prevail ing levels o*: airborne
lead, the control  philosophy roll owed, and *he  control strategy devi:eu.
     One possible philosophy is to require uniform control, i.e.,
that all sources of lead emissions in an AQCR apply the same degree
of control.  By following such a philosophy, all  sources would share
the burden of meeting the proposed standard.  However, if ai AQCR
had one or two emitters of large quantities of  lead to the atmosphere,
the reduction in lead emissions which small sources could achieve
(even if they ceased operating) would be insignificant in terms of
bringing the AQCR into compliance  and in relation to the reductions
achievable by larger emitters.   The lead emissions inventory (pre-
sented in Chapter 2) shows that there is, in fact, a wide range in
the quantities of lead emitted by  various sources.  This large vari-
ation may, therefore, render such  a philosophy  impractical.
     Another alternative is to apply selective  control, i.e.,  to
require only the larger emitters to control their operations,  since
their emissions are rnqre likely to be the cause of the maximum lead
concentrations.  Under this philosophy,  the source of the largest
proportion of the total quantity would be controlled first, followed
*For purposes of analysis, control  options refer to the many indivi-
 dual measures available (e.g., baghouses, scrubbers,  and electro-
 static precipitators for point sources;  car pools, mass transit,
 bicycles, alternative engine designs, alcohol  blends, alternative
 octane boosters, and particulate traps for mobile sources).   Con-
 trol philosophy implies a broader  outlook—whether to apply controls
 uniformly on all emitters, large and small, or to select certain
 emitters preferentially.  If the latter course is foil owed, one
 develoos control strategies consisting of selected options.
                                 3-5

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by the next largest source and so on until the standard is achiev-
able.  This latter philosophy has, generally, been followed in the
development of the control strategies presented in this section.

3.1.2  Overall Control Strategies
     A sample control strategy has been developed for each AQCR
expected to be out of compliance under each of the three standards
under consideration.  Each strategy was developed by applying the
best available control technology (BACT) to the type of source from
which the largest proportion of the total quantity of lead is emitted.
If the resulting rollback was not sufficient, then BACT was applied
to the next higher class of emitters, with one exception.*  In this
instance, a smaller source of emissions was selected, as the residual
rollback required was relatively small.
     As a result of applying the selective control philosophy, two
candidates for additional control are primary lead and primary cop-
per  smelters and automotive vehicles.  The specific control strategies
developed are summarized in Table 3-1.   It should be noted that stack
and  fugitive emissions from the smelters were treated as separate
items for control strategy development.  It should also be noted that,
in one instance, pre-1975 automobiles and other automotive vehicles
(i.e., medium-size trucks) were treated  as separate source types.
*For one AQCR, the strategy included control of mobile sources rather
 than the second highest class of emitters as residual reduction  in
 emissions required  (after requiring control of the highest class of
 emitters) was of a  small magnitude.
                                3-6

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                      TABLE 3-1

    NUMBER OF AQCR'S PROJECTED TO REQUIRE CONTROL
OF LEAD EMISSIONS TO COMPLY WITH PROPOSED LEAD NAAQS
SUGGESTED AMBIENT AIR QUALITY STANDARD AND CONTROL STRATEGY

1 .0 ug/m3
Number of AQCR's Requiring Additional Control for
• Pre-1975 automobiles only
• Primary copper smelters - fugitive emissions only
• Primary lead smelters - fugitive emissions only
• Primary lead smelters - fugitive and stack emissions
plus mobile sources
Total AQCR's Requiring Control Measures
1.5 ug/m3
Number of AQCR's Requiring Additional Control for
• Primary copper smelters - fugitive emissions only
• Primary lead smelters - fugitive emissions only
• Primary lead smelters - fugitive emissions plus
mobile sources
• Primary lead smelters - fugitive and stack emissions
plus mobile sources
Total AQCR's Requiring Control Measures
_
2.0 ag/m3
Number of AQCR's Requiring Additional Control for
• Primary copper smelters - fugitive emissions only
• Primary lead smelters - fugitive emissions only
• Primary lead smelters - fugitive emissions only
plus mobile sources
• Primary lead smelters - fugitive and stack emissions
plus mobile sources
Total AQCR's Requiring Control Measures

1982


1
1
1
2

5


1
1
2

-

4



1
1
1

-

3
YEAR
1983 1


-
1
1
2

4


1
2
1

-

4



1
1
1

-

3

985


-
1
1
2

4


1
2
-

1

4



1
1
1

-

3

1995


-
1
1
2

4


1
1
-

2

4



1
1
- '

1 |

3
i
                          3-7

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      Control of combinations of sources other than those shown would
not, generally, result in the AQCR's achieving compliance.  This is
not the case in one AQCR; however, the application of the selective
control philosophy led to the control strategy developed.
      The control strategies indicated in Table 3-1 for 1982 are those
which are suggested for attaining the standards.  The strategies
specified for 1983, 1985 and 1995 are those which may serve to maintain
the proposed levels of the standard.  For each AQCR requiring control
of lead emitters in 1982, the control strategy in subsequent years is
the same or pertains to a subset of the controlled sources.*  This
implies that after the standards are attained in these AQCR's, the
maintenance of ambient standards would not require control of additional
source types or the introduction of new control strategies, although
a higher degree of control may be required within particular source
categories.
      As noted in Table 3-1, five AQCR's would require additional
control in 1982 for the most stringent standard proposed, 1.0 ug/m2.
Four AQCR's would require additional control in 1983.  For a standard
of 1.5 ug/m3, the number of AQCR's expected to be out of compliance
would be four by the years 1982 and 1983.  For a standard of 2.0 ug/nr3,
AQCR's out of compliance would be three for the years 1982 and 1983.
It should also be noted that mobile-only controls would be needed in
one AQCR in  1982 only  if the 1.5 ug/m3 standard were imposed; for
 *With  the exception of a primary copper smelter in one AQCR which
 may present a small problem in 1995, but not earlier.
                                 3-8

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any less stringent standard, mobile-only controls would be unnecas-
sary.   In subsequent years, for a given standard, there is a shi^t
from more complex strategies to simpler ones (e.g., fugitive-plus
stack-plus-mobile to fugitive-plus-stack to fugitive emissions alone).

3.1.3  Stationary Source Control Strategies
     Some AQCR's are expected to require control strategies only for
stationary sources.  The types of stationary sources requiring control
are projected to be primary lead and primary copper smelters.  These
smelters have already adopted measures or are in the process of adopt-
ing measures to control their stack emissions in order to comply with
total-particulate regulations.  These control measures have resulted
in some control of lead.  In most cases, further control of lead emis-
sions only from stacks could not provide the additional reduction in
lead emissions, according to the rollback technique, necessary to
bring the AQCR's into compliance with the proposed NAAQS for lead.
It should be noted that the analysis is sensitive to the amount of
total-particulate stack control in existence in 1975 (i.e., the com-
pliance control factor).  Since this value is not known for many
individual smelters, a nationwide average was employed and the amount
of further stack control is not precisely tailored to site-specific
conditions.
     The lead emissions inventory indicates that by 1982 an important
source of lead emissions is fugitive emissions from primary lead and
                                 3-9

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primary copper smelters.  In at least one case, the reduction of
these emissions would be sufficient to bring the AQCR into compliance.
     To control fugitive emissions at primary smelters, it is neces-
sary to provide a building evacuation system to a fabric filter
(BEFF).  Such a system consists of hoods, ducts, fans, and fabric
filters and is believed to be capable of achieving up to a 99 percent
collection efficiency.  It is projected that 10 to 22 such systems,
depending on the standard adopted, will be required.  For the purpose
of making this projection, it was assumed that each building requir-
ing control within the smelter would be provided with a separate con-
trol system.  However, this assumption does not significantly affect
the projected environmental impacts.
     For some AQCR's it would also be necessary to apply mobile source
controls, which are discussed later, or even stack emissions controls.
Typically, fabric filters and scrubbers are applied for control of
primary lead smelter stack emissions, while electrostatic precipita-
tors are employed for the control of primary copper smelter stack
emissions.
     Further stack control implies techniques above and beyond the
best available control technology already (by 1982) on the stacks in
response to requirements for the tota1-particulate NAAQS.  Such addi-
tional control would require the development of new technology (beyond
present 8ACT) and could prove to be highly unattractive economically
with the result  that  the smelter operators so affected may decide to
                                 3-10

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terminate operations.  Before such a drastic measure is taken, how-
ever, careful monitoring analyses near these smelters should be per-
formed.  Although the present study was based on the best available
monitoring data, the information was limited in many cases.  Further-
more, it is not the intent of this report to present detailed site-
specific information, rather a generalized nationwide overview.
     Thus, for purposes of developing strategies and their environ-
mental consequences, it is assumed that BEFF control of fugitive
emissions from primary lead and/or primary copper smelters would
clean up sufficient amounts of the anticipated point source emis-
sions.

3.1.4  Combined Stationary and Mobile Source Control Strategies
     In some instances, the rollback analysis showed that control of
both stationary and mobile sources may be necessary to meet the pro-
posed levels of the lead NAAQS.  Review of the emission inventories
for these areas reveals that elimination of lead emissions from either
source category would not be sufficient to bring the AQCR into com-
liance.  Primary lead and/or primary copper semlters are operated
in all of the AQCR's requiring a combined point and mobile source
control strategy.  Quantities of lead emitted by other point sources
in these regions are estimated to be less than one ton per year or
three orders of magnitude less than the quantities of lead emitted
by the primary smelters.  The control strategy suggested for these
cases  is to apply the maximum amount of reasonably available control
                                3-11

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to the fugitive emissions at primary smelters, and to apply mobile
source controls (particulate traps) to achieve the remainder of the
reduction required.  Thus, some AQCR's would require installation of
particulate traps  as part of their control strategies.  The total
numbers of vehicles requiring particulate traps in order for alter-
native levels of the standard to be met are shown in Table 3-2.  Traps
on medium-size trucks and replacement traps have been accounted for
in these totals.  It should be noted that the installation of particu-
late traps in model-year medium-size trucks would be required in years
between those shown in the table to maintain compliance with the NAAQS
proposed.
3.1.5  Mobile Source Control Strategies
     In addition to the control of primary copper and lead smelters
alone or in combination with mobile source control, it is expected
that one AQCR would require some control of mobile sources in 1982
to achieve compliance with a standard of 1.0 ug/m .  It should be
noted, though, that these controls would not be needed by 1985 due
to the no-lead/phasedown of lead in gasoline already required under
current EPA regulations.  Nevertheless, the AQCR would be required
to undertake some  form of action to reduce mobile emissions, and,
since the elimination of the small quantities of lead emitted by point
sources would not  bring  the region into compliance with the standard,
a strategy of controlling only mobile sources is proposed for this
AQCR.  Naturally,  states may elect to propose a combination point
                                3-12

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                              TABLE 3-2

     NUMBER OF VEHICLES WHICH MAY REQUIRE LEAD PARTICULATE TRAPS
           AS A  FUNCTION OF  ALTERNATIVE  STANDARD AND  TIME
PROPOSED
STANDARD
(quarterly average, ug/nT)
1.0
1.5
2.0
YEAR
1982
1,265,300
106,500
58,000
1985 Q
49,100
26,900
26,900
1995 ©
8,800
4,900
0
1.   Pre-1975 autos and medium-size trucks obtaining their second
    participate trap plus model-year medium-size trucks.

2.   Medium-size trucks of various ages obtaining another particu-
    late trap plus model-year medium-size trucks.
                                3-13

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and mobile source strategy as they are in no way bound to apply the
mobile-only strategy used here.
     Only one option, the use of particulate lead traps on pre-1975
automobiles, appears capable of providing the necessary 25 to 30
percent reduction in emissions.  Although these traps are not expected
to be generally available until 1982, the inclusion of this option in
State Implementation Plans may provide an incentive to hasten the
development and marketing of traps, at least on a limited geographi-
cal basis.  For this reason, the installation of particulate lead
traps is considered a feasible control strategy, and is used in the
impact analysis for the AQCR discussed here.
3.2  PRIMARY IMPACTS
3.2.1  Air Quality
     Primary impacts are those which can be attributed directly to
the action being assessed— setting and enforcing the NAAQS for lead.
The two primary impacts which are expected to result from this action
are:  (a) a decrease in the quantity of lead emitted to the atmo-
sphere, and (b) a decrease in ambient air lead concentrations.  Of
the three levels of the standard considered (1.0, 1.5, and 2.0
monthly  average),  the most  stringent  level  (l.Q^g/m  ) applied  in
1982 would  result  in these  two primary  impacts occurring most often —
in  5 out of 243* AQCR's.  Thus,  the primary impacts  (i.e.,  changes
 *Four  AQCR's  (Guam,  American  Samoa,  and  two  in Alaska)  have  been
  excluded  from  the  analysis.
                                 3-14

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in lead emissions and air concentrations)  resulting from the setting
of the NAAQS for lead are seen to be limited to a few locations and
are discussed in the following sections.
      3.2.1.1  Lead Emissions
      A direct impact of setting and enforcing the NAAQS for lead is
a reduction in the numoer of tons of lead emitted annually to the
atmosphere.  Calculation of the reduction was based on the measured
and estimated ambient air quality concentrations presented in Section
2.2 and the rollback philosophy used in developing control strategies
in Section 3.1.  The reductions required in individual AQCR's were
summed to determine the total national  reduction which would be re-
quired to attain and maintain the proposed lead NAAQS in future years.
      Table 3-3 summarizes the nationwide reductions of lead emissions
which may result from the various proposed levels of the standard.
For the most stringent standard analyzed, 1.0 yg/rn^ quarterly average,
a 30 percent rollback of nationwide tonnage, relative to 1975 condi-
tions would be implied.  As the level of the standard becomes less
stringent, the percentage rollback required decreases.  For a stan-
dard of 1.5 ug/rn^, a 15 percent reduction would be implied, and for
a standard of 2.0 ug/rn^, a 10 percent reduction is indicated.  The
reduction required changes from year to year since the total number
of tons emitted varies due to (1) industry growth (or decline), (2)
elimination of lead in gasoline, and (3)  additional compliance with
total particulate regulations.
                                 3-15

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                              TABLE 3-3

         NATIONWIDE ESTIMATE OF REDUCTION IN TONS OF LEAD
       EMITTED TO THE ATMOSPHERE TO MEET PROPOSED STANDARDS
STANDARD
(ug/m3)
1.0
1.5
2.0

PERCENTAGE
ROLLBACK,
RELATIVE TO
1975
30
15
10
ADDITIONAL REDUCTIONS BY YEAR,
STATIONARY AND MOBILE SOURCES
(tons of lead)
1982
2,562
1,736
1,233
i
1983
2,274
1,658
1,170

1985
2,275
1,659
1,174

1995
2,901
2,286
1,710

Standards based on quarterly averaging time.
                                3-16

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     The trend in the reduction for any standard between 1982 and
1995 is a function of these factors and is independent or the level
of the standard.   In 1985, the rollback reouired is less than in
1982, primarily because the reduction in mobile emissions (due to
gasoline additive and fuel economy regulations) is greater than any
increases resulting from more vehicle miles traveled and/or  growth
in the industrial point source category.  But by 1995, the diminish-
ing effect of gasoline additive and fuel economy regulations is not
great enough to offset the increases in point source emissions.  More
specifically, anticipated increases in primary lead production would
yield increased lead emissions to the atmosphere, thereby resulting
in the need for additional reduction in lead emissions in 1995 rela-
tive to 1985.
     The reductions in Table 3-3 represent nationwide values for both
mobile and stationary sources.  The control of fugitive lead emis-
sions from primary lead and copper smelters as well as the control
of mobile sources is estimated to account for most of the required
reductions.  For example, for the most stringent standard, 1.0 ug/m
in 1982, the fugitive and mobile control strategies are designed to
effect approximately 98 percent of the total emissions reduction
required.*  The remainder is attributable to the stack emissions from
*In this case, fugitive control should eliminate 2,349 tons of lead
 emissions while mobile control measures should reduce 387 tons com-
 pared to a required reduction of 2,754 tons (see Table 3-3).
                                 3-T

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primary lead or primary copper smelters.  It should be noted, however,
that these stacks already have (by 1982) BACT* systems.  Thus, for
purposes of a nationwide assessment, it appears that the indicated
strategies—fugitive dust and mobile emissions control—represent a
reasonable and comprehensive approach.  Of course, the states have
the option and the responsibility to develop strategies to suit their
individual needs.

     3.2.1.2  Ambient Concentrations
     As presented earlier, Figure 3-1 shows how many AQCR's had
either reported or estimated 1975 ambient air lead concentrations
that would exceed the proposed levels of the standard.  The cumula-
tive influence of regulations (other than the lead NAAQS) which
directly control lead emissions to the atmosphere (SIP and NSPS con-
trol of parti dilates as well as no-lead in gasoline—see Sections
2.1.1.3 and 2.1.2.3) are themselves expected to reduce (1) lead emis-
sions by 1982, (2) ambient air lead concentrations, and (3) the num-
bers of AQCR's (relative to 1975) expected to exceed the proposed
levels or the standards.  For a standard of 1.0 ug/m  , quarterly aver-
rage, 113 AQCR's would have exceeded the standard in 1975, while in
1982 only five AQCR's are expected to exceed the same level.  It is
these five AQCR's whose ambient air lead concentrations would have
to be reduced further and thereby be affected by a lead NAAQS of 1.0
*8est available control technology.
                                 3-18

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ug/m^.   Other AQCR's may also experience reduced lead concentrations
because of other regulatory actions, but not as a direct result of
the lead NAAQS.  Any new facilities, constructed in areas where the
lead NAAQS is not exceeded, would have to be designed so their lead
emissions during operation would not result in ambient lead levels
exceeding the standard.
     For a standard of 1.5 ug/m , quarterly average, ambient lead con-
centrations would need to be reduced in four AQCR's in 1982, while
three AQCR's would require reductions in the same year if the 2.0
ug/m  standard were adopted.  It should also be noted, though, that
four AQCR's would need lead controls in 1995 using the 2.0 yg/m
standard, because of growth in the primary lead smelting industry.

3.2.2  Human Health and Welfare
     The protection of human health and welfare is the purpose of a
national ambient air quality standard for lead.  The effects of
lead on human health and welfare are addressed in the Air Quality
Criteria for Lead issued by EPA at proposal.   The level  of the
standard is based solely on health and welfare considerations.
The proposed rulemaking preamble contains a statement of basis
and purpose which explains the Agency's standard rationale.

3.3  OTHER ENVIRONMENTAL  IMPACTS
     Using the control strategies specified in the previous section,
the cumulative, nationwide secondary impacts likely to result from
promulgating a lead NAAQS can be determined.  The major secondary
impacts which may occur include changes in energy consumption, noise
levels, land acreage, other pollutant emissions, ecological implica-
tions and costs to  industries and state governments.

-------
     Assessment of these impacts with respect to stationary sources
has been based on the following assumptions:
     (a) Control  of fugitive emissions from primary lead and
         primary copper smelters would be achieved through the
         construction and operation of building evacuation sys-
         tem to fabric filter (BEFF) facilities;*
     (b) Such facilities would be located adjacent to the smelt-
         ing facilities on property already owned and developed
         by the smelting companies;
     (c) Lead emitted from fugitive sources and captured by the
         BEFF facilities would not be recovered, i.e., the
         worst case, and therefore landfill operations would
         be needed to dispose of the material collected; and
     (d) Landfills would be located a few miles from the smelt-
         ers in areas which are presently undeveloped.
     When the exact locations of all facilities being constructed as
a result of the lead NAAQS can be positively identified, site specific
impacts can be evaluated.
     The secondary impacts related to the mobile source strategy (the
application of lead particulate traps) are based on the assumption
that the particulate traps can be manufactured in existing muffler-
producing facilities.
     It is assumed that the operation of BEFF facilities at station-
ary sources would be ongoing actions for many years.  On the other
hand, with regard to the particulate traps, there would be a large
initial demand under conditions of the 1.0 yg/m  standard—approxi -
mately  1.3 million units, by 1982—with a  sharp fall off in production
 *!ncludes  hoods, ducts, fans, and baghouses,
                                3-20

-------
in subsequent years (see Table 3-2).  For years later than 1982 and/
or for standards greater than 1.0 ag/m  , the demand for participate
traps would be relatively small.
3.3.1  Energy Consumption
     Considerations of energy consumption involve the construction
and operation of the BEFF's at each of the primary lead and primary
copper smelters required to control fugitive emissions as well as
the fabrication and operation of particulate traps for reducing auto-
motive emissions.  Energy consumption is typically characterized by
capital and operating energy demands.  Capital energy is defined as
the energy required to produce various materials (e.g., structural
steel, sheet metal, raw chemicals) and assemble the materials into
finished products.  Operating energy consists of the energy to run
the BEFF fans, to dispose of the collected particulate matter, and
to operate automobiles with particulate traps.
     3.3.1.1  Capital Energy
     Based on (1) the amount of structural steel and other materials
used at the ASARCO smelter in El Paso, (2) the ratio of total parti-
culate to lead particulate, (3) the capacity of the BEFF at El Paso,
and (4) the tons of lead to be collected at the affected primary cop-
per and lead smelters, the nationwide capital energy costs in 1982
                          —                             IP
for a standard of 1.5 yg/m  are expected to be 3.12 x 10'   and 1.74
                                3-21

-------
    •j 2
x 10   BTU(th)* for primary copper and primary lead smelters, respec-
tively.  The capital energy costs in 1982 associated with the alter-
native standards are shown in Table 3-4.  The table also lists equi-
valent barrels of oil.  A comparison with either the nationwide
domestic demand of oil at 17.7 x 10  barrels per day in 1976 (Federal
Energy Administration, 1977) or the 1975 operating energy for the
primary lead and copper industries of 30 x 10  barrels of oil (based
on 1975 production rates and energy factors derived from Bureau of
the Census, 1967) indicates that the capital energy costs for retro-
fitting all the primary copper and lead smelters are relatively small.
     The capital energy for the automotive control strategy is con-
sidered to be the energy to manufacture the particulate traps.  Since
the particulate traps would likely be manufactured by muffler manu-
facturers at existing plants, no new major facilities would have to
be constructed and the capital energy is considered to be that which
would  be expended to provide and fabricate the necessary sheet metal.
Under  the most widespread application of the most stringent standard,
1.3 million particulate traps** would be required.  The capital energy
required to produce this number of mufflers is estimated to be the
equivalen* of 477,000 barrels of oil.  The corresponding energy to
produce the same number of particulate traps, containing slightly
 *BTU(th) = British thermal unit  (thermal)
 **Required for  the mobile  source  strategy relating to a  standard of
   1.0 ug/m3 in  1982.
                                3-22

-------
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                                             3-23

-------
more steel and/or aluminum, would be 542,000 barrels of oil.  In some
cases the parti oil ate traps would be Installed on vehicles requiring
new mufflers, so the capital energy would be expected to lie some-
where between the two energy values mentioned above.  It is important
to note that these capital energy requirements for the two devices,
mufflers and particulate traps, are fairly similar with the exception
of possible retooling, required for particulate trap production, which
is unknown but considered to be of a low order of magnitude.
     The need for particulate traps for less stringent alternative
standards or for later years is generally two orders of magnitude
less than for the 1982 case involving the 1.0 ug/m  standard presented
above.

     3.3.1.2  Operating Energy
     The operating energy for point source control is associatad with
the power to drive the fans in the BEFF and with, the fuel to trans-
port and bury the collected particulate matter.  Based on a study of
the BEFF facility for the ASARCO smelter at El Paso, Texas  (Nelson,
1977),  it is estimated that the nationwide energy consumption rates
                                  •j              i?              12
for 1982 at  a standard of 1.5 ug/m  are 0.63 x 10   and 0.43 x 10
BTU(th) for  the primary copper and lead smelter BEFF's, respectively.
     If it is assumed that  the collected material is transported to
landfills several miles away, the fuel energy requirements  for 1982
                          3                                    9
at a standard of  1.5 yg/m   are computed to be less than 1 x 10
                                 3-24

-------
BTU(th).   Even If the energy to operate the bulldozers at the land-
fill  sites were of the same magnitude, the energy for hauling and
burial  is negligible compared to that for the BEFF fans and is not
considered further in the analysis.  Thus, the operating energies
reported in Table 3-4 represent, for the different standards, the
energy to power the BEFF fans.  The energy values (for fans at the
required BEFF's) are small (less than one percent) in comparison to
the annual energy input to the primary copper and primary lead smelt-
ing industries.  Based on 1975 production values (see Appendices C
and E)  and energy-per-ton factors for both industries (Bureau of the
Census, 1967), the total energy input to both industries is estimated
to be 172 x 1012 BTU(th) for 1975.
     The operating energy associated with the use of particulate
traps refers to the power which is needed to force the spent gases
through the exhaust system.  With the present design of particulate
traps there is no appreciable difference in the pressure drop across
a standard acoustical muffler and a particulate trap and, therefore,
in operating energy required.
3.3.2  Noise Levels
     Most of the noise generated by the operation of BEFF's occurs
within the structure housing the system where Occupational Safety
and Health Administration (OSHA) standards specify that noise expo-
sure levels are not to exceed 90 dBA for an eight-hour workday.
Individual pieces of equipment, such as fans which typically generate
                                3-25

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noise levels ranging from 76 to 102 dBA at five feet (Goodfriend
and Kessler, 1973), may not meet these specifications.  Therefore,
the entire control system including fans, ductwork, and piping should
be designed using those acoustical measures necessary to insure that
the OSHA noise standards are met.  It should be noted that the expo-
sure levels can be increased by 5 dBA for each halving of the expo-
sure time.  The U.S. Environmental Pr^*°'-tion Agency (EPA) has pro-
posed to OSHA that a maximum eight-hc-ir occupational exposure level
of 85 dBA be established within three years of the OSHA regulation
and ultimately an eight-hour exposure level of 80 dBA (U.S. Environ-
mental Protection Agency, 1974).  Furthermore, EPA proposed that the
exposure level can be increased by only 3 dBA for each halving of the
exposure time.
     Assuming that the OSHA permissible noise exposure levels are
met, the exterior sound pressure levels would be less than 90 dBA
due to noise attenuation caused by the building walls, ambient air,
and nearby structures.  Maximum noise levels computed based only on
attenuation related to distance, are 70 dBA at 50 feet and 58 dBA at
200 feet.  Assuming that the SEFF's are to be at least 200 feet from
the property line, noise levels are not expected to exceed typical
local noise ordinances (e.g., New Jersey, 1974).
     The particulate traps are expected to have acoustical properties
similar to those of a standard muffler and any changes in noise lev-
els in the vicinity of roads and highways are not anticipated to be
perceivable.
                                 3-26

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3.3.3  Land Use Parameters
     The use of a BEFF system to control fugitive emissions requires
space not only to house the system but for the disposal of the parti-
culate matter collected in a landfill area.  It should be noted that
the space requirements for the BEFF housing represent a one-time allo-
cation, while the requirements for landfill are on an annual basis.
The manufacture of particulate traps is expected to occur at existing
facilities.

     3.3.3.1  Space Requirements for BEFF Facilities
     The area* occupied by the baghouse facility consists of the bag-
house proper, a transformer substation, ducting, a loading area, and
an approach road.  The baghouse itself is assumed to vary in size
according to the amount of lead particulate to be collected, but the
area for the other items is assumed to remain constant regardless of
output.  Based on the BEFF at the ASARCO smelter in El Paso, Texas
(Nelson, 1977), the BEFF area (for additional structures) for the
affected smelters (primary copper and primary lead) is estimated to
be 4.2 acres for a standard of 1.5 ug/mj.  This acreage and the acre-
ages according to the other levels of a lead standard are presented
in Table 3-5.  Relative to the area occupied by a single smelter
(e.g., the ASARCO smelter at El Paso itself occupies over 700 acres
of land), the space requirements for BEFF's are quite small.
"'External to the existing smelter.
                                3-27

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                           TABLE 3-5

    NATIONWIDE LAND USE PARAMETERS ASSOCIATED WITH FUGITIVE
LEAD EMISSIONS CONTROL AT  PRIMARY COPPER AND LEAD SMELTERS, 1982
LEVEL OF STANDARD
(//g/m3)
1.0
1.5
2.0
AREA FOR
ADDITIONAL STRUCTURES
(acres)
6.7
4.2
3.3
VOLUME FOR DISPOSAL
(acre-feet)
21.6
16.0
10.1
                               3-28

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     3.3.3.2  Landfill Considerations
     For a standard of 1.5 ug/m ,  the nationwide amounts of total
participate fugitive dust to be disposed of would be 9.5 acre-feet
and 6.5 acre-feet for primary copper and primary lead smelters, re-
spectively in 1982.  Landfill factors resulting from the promulgating
of the alternative standards are presented in Table 3-5.  Volumes (in
acre-feet) are listed instead of acreages since the number of acres
would vary from site to site according to the thickness of the land-
filling operations.  Even with a conservative estimate of two feet
for the proposed thickness of the  landfill layer of disposed dust,
the nationwide annual acreage requirements under the most stringent
of the standards proposed (1.0 ug/m ) would be very small—on the
order of ten acres.

     3.3.3.3  Mobile Strategy Considerations
     Not all of the 1.3 million particulate traps which would have
to be installed by 1982 represent  new production capacity.  In 1972
the annual muffler production in the United States was over 54 mil-
lion units of which 32.5 million units were replacement mufflers, up
from 26.5 million units in 1967 (Bureau of the Census, 1977).   Thus,
the annual production rate by 1982 may be extrapolated to at least
40 million units.  Since approximately one-third of the 1.3 million
pre-1975 cars would need a replacement muffler in the 1981 to 1982
time period, by virtue of normal wear, the production of 0.4 million
particulate traps would merely take the place of a similar number of
                                3-29

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mufflers.  Production of the other 0.9 million traps would be for
cars not needing replacement mufflers at the time and thus represents
an additional production capacity of one to two percent if all the
traps were produced in one year.  The percentage increase would be
even smaller if the particulate traps were also manufactured  in years
prior to 1982 in an effort to build up a stockpile.  Any plant expan-
sion of this magnitude could occur on property already owned by muf-
fler manufacturers.

3.3.4  Other Air Pollutants
     Control devices installed to reduce fugitive lead emissions
from primary lead and copper smelters are also expected to control
emissions of other trace contaminants.  In order to estimate  the
magnitude of this impact, the uncontrolled emissions were computed
for several pollutants.  Fugitive emission factors for trace metals
from primary lead and primary copper smelters have not yet been devel-
oped.  Estimates for the magnitude of trace element emissions were
derived from concentrations of the elements found in stack particu-
lates from one smelter  (Statnick, 1974) and from ^articulate  fugitive
emission factors (U.S.  Environmental Protection Agency, 1974a).  The
remaining estimates  (except mercury) were derived from typical con-
centrations of trace elements in the ores (U.S. Environmental Pro-
tection Agency, 1974f),  particulate fugitive emission factors, and
the assumption that  50  percent of the concentration of the elements
                                 3-30

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in the ores is found in the fugitive participates.  Mercury emissions
were computed from a materials balance (Van Horn, 1975).
     Table 3-6 represents the estimated fugitive emissions for seven
pollutants from both primary lead and primary copper smelters.  While
the estimates for some pollutants in the table may appear small when
considered on a nationwide basis, it must be remembered that there
were only a few primary copper and primary lead smelters operating
in the United States in 1975.  If, on the other hand, for a given
AQCR, the primary smelters constitute the major source of the trace
elements in question, particulate control at the smelters (fugitive
emissions control to provide compliance with the lead NAAQS) would
reduce the emissions of the trace elements as much as 99 percent in
the vicinity of the smelters.  The predicted reduction in arsenic
would be significant when compared to the estimated nationwide arse-
nic emissions of 4,890 tons/year from all types of sources.
     The use of lead particulate traps is not expected to alter the
exhaust emission characteristics except, of course, for lead (Summers,
1977).
3.3.5  Hydrology
     The impact on hydrology likely to result from the lead NAAQS is
a change in the lead concentrations of both ground waters and surface
waters.  The reduction of airborne lead concentrations expected from
the enforcement of the lead NAAQS would result in lower lead concen-
trations for bodies of water by limiting the amount of lead entering
                                3-31

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the surface water by direct deposition and/or runoff.  Lead concen-
trations of surface water as well as ground water may increase unless
the solid waste collected at the BEFF's is disposed of at carefully
sited and well designed landfills.  Leachate is a highly mineralized
fluid containing such constituents as chloride, iron, lead, copper,
sodium, nitrate, and a variety of organic chemicals (U.S. Environ-
mental Protection Agency, 1977c).  In confined, slow moving, or rela-
tively low-volume surface waters, leachate has killed vegetation and
fish, eliminated spawning areas, and precluded the use of existing
and planned recreational areas (U.S. Environmental Protection Agency,
1977c).
     Solid waste land disposal sites can be sources of groundwater
contamination because of the generation of leachate caused by water
percolating through the bodies of refuse and waste materials.  Dis-
posal sites located in areas where the water table is close to land
surface can produce leachate and subsequent groundwater contamination.
In some places, such as low lying coastal areas, the water table is
so high that all disposal sites constructed without sufficient natural
or artificial barriers would contaminate ground water.  Leachate
contamination of supply wells can result in adverse health effects
as a result of chronic exposure, and can cause severe economic hard-
ships, distresses, inconveniences, and inequities to owners of dam-
aged lands.
                                3-33

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     Because primary lead and primary copper smelters are located in
western states, their disposal sites would probably not be located
in areas highly susceptible to groundwater contamination (e.g., low
lying coastal areas, wetlands).  Under Section 1424(e) of the Safe
Drinking Water Act of 1974, only one aquifer, the Edwards Underground
Reservoir, San Antonio, Texas has been designated for special protec-
tion and there are no smelters in that area whose solid waste disposal
would have an impact on that aquifer.
     Although small quantities of water would be required for the
construction (e.g., in concrete) of the new control facilities, no
increase in water consumption is anticipated during the operation of
the BEFF's.  Moreover, there are no liquid effluents directly asso-
ciated with the operation of BEFF's.
     The use of particulate traps is not expected to have any adverse
impact on water use or water quality.  Fewer lead emissions onto and
near roads imply less lead in any runoff to streams.  The disposal
of the traps would be either as units removed from the auto or as
part of the auto when junked.  Some of this metal would be recycled
while the rest would be disposed of at landfill sites and junk yards.
It is not possible to quantify the impacts due to potential leaching
at these unspecified sites.

3.3.6  Topographic, Geologic, and Soil Characteristics
     Decreased quantities of lead in the air would cause less lead
to settle out onto all types of surfaces including soils.  Thus, the
                                3-34

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lead NAAQS would result in lead accumulation in the soil at a slower
rate than if the standard were not established.
     Slight changes in topographic, geologic, and soil characteris-
tics of the immediate construction areas may result from grading,
trenching, filling, and compacting operations occurring while build-
ing the BEFF's.  A nationwide total of less than seven acres was
estimated for construction of the BEFF's needed to meet the most
stringent of the proposed standards (see Section 3.3.3).  Because
the BEFF's would probably be located adjacent to the smelting facil-
ities on property already developed and owned by the smelting com-
panies and the construction would not involve major excavation for
these issentially above-ground facilities, occupying relatively small
acreages, no significant impacts on topographic, geologic, and soil
characteristics are anticipated.
     Even though the landfill operations would result in alterations
of topographic and soil characteristics during the excavation and
backfilling stages—some topsoil would be lost and/or replaced by
subsoil and the local topography would be slightly changed—the ex-
tent is anticipated to be small,  nn the basis of approximately 20
acre-feet of material to be buried (see Table 3-5), and assuming a
conservative layer thickness of two feet, the nationwide area involved
would be no more than ten acres annually for the affected primary cop-
per and lead smelters.  The depth of the landfills is not expected to
be great enough to affect geologic considerations.
                                3-35

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     The manufacture and installation of lead particulate traps should
not appreciably affect topographic, geologic, or soil characteristics
since existing facilities, with possible minor expansion, would be
used.

3.3.7  Historical and Archaeological Sites
     Those baghouses which are birlt as a result of the proposed lead
standard will probably be located adjacent to the smelting facilities
on property already developed and owned by the companies.  Therefore,
it is unlikely that any historical or archaeological sites would be
affected by the construction of additional baghouses.  On the other
hand, land used for landfill operations may be located at a distance
from the facilities and may be presently undeveloped.  When the spe-
cific locations of the new landfill sites are identified, it can be
determined whether they would involve historical and archaeological
sites by contacting local historical societies and references includ-
ing the National Register of Historic Places and the National Regis-
try of Natural Landmarks.
     Any plant expansions to produce lead particulate traps at exist-
ing muffler facilities are likely to occur adjacent to -the main com-
plex and no historical or archaeological site disturbances are anti-
cipated.

3.3.8  Aesthetics
     The addition of a 3EFF to an existing smelter would alter the
 appearance of the complex but the magnitude of this change in an
                                 3-36

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already industrial  area is expected to be small since the BEFF would
occupy only a small fraction of the area of the complex, would be
immediately adjacent to the smelter, and would have a lower profile
than the smelter itself.  Moreover, the design of a BEFF (general
industrial) would be in keeping with the rest of the complex.  How-
ever, locations designated for new landfills may be located in pres-
ently undeveloped areas and the changes in appearance, although tem-
porary and involving only small acreages, may be more obtrusive as
vegetation and topsoil are removed.
     For the manufacture of lead particulate traps, any plant expan-
sions, if necessary, would likely have the same general appearance
as the original building and no adverse impacts regarding aesthetics
are anticipated.

3.3.9  Ecological Impacts
     Ambient lead concentrations in natural environments should be
reduced in the future by the promulgation of the MAAQS for lead.
The major overall effect of this action, in conjunction with other
lead control programs would be ^o reverse the present trend of accumu-
lation of lead in natural ecosystems, principally in soils and sedi-
ments.  Other heavy metals would be controlled to some extent by
these programs, particularly at smelters, so that the overall effect
of an NAAQS for lead would be a reduction in the environmental burden
of several heavy metals.
                                 3-37

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     3.3.9.1  Terrestrial Environments
     The establishment of an NAAQS for lead is only one of several
factors that would be responsible for reducing -he input of lead to
terrestrial ecosystems.  Roadside areas would be affected primarily
by the gradual elimination of lead in gasoline.  By 1985 lead emis-
sions from vehicles to roadside environments should be about 11 per-
cent of 1975 levels (see Section 3.1).  Because medium-duty trucks
may continue to utilize leaded gasoline, lead emissions along high-
ways may never be completely eliminated but would be small in quantity.
     Reductions of lead inputs to terrestrial environments due to the
control of particulate emissions from stationary sources is expected
to be site specific.  Under the proposed strategy, fugitive sources
within some AQCR's may not be controlled (specifically for lead) if
the proposed ambient air standards for lead can be achieved by the
phasedown of lead in gasoline and/or ambient and emissions standards
for total particulate matter.  Since some fugitive emissions may not
be controlled, local areas affected primarily by a point source may
not experience a reduction in lead input.
     Where the lead input to a terrestrial system would be reduced,
the presently observed increase  in lead concentrations in soils is
expected to be retarded.  However, the fate of lead already stored in
soils  is not as straightforward.  Because of its relative immobility
in soils, existing  lead would probably be slowly (over geological
time)  covered by new soil or carried to streams through normal erosion
                                 3-38

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processes.  Lead still would be available to vegetation and the food
web as long as the present storage remained in the biologically active
surface layers.
     Surface deposition of lead on leaves would decline rapidly.
This deposition  is not believed to be a major source of lead to veg-
etation itself,  rather to those organisms feeding directly on the
leaves.  Thus, this route would be considerably reduced as a means
of transmitting  lead to higher species in the food web.

     3.3.9.2  Aquatic Environments
     Most of the actions that would reduce the input of lead to ter-
restrial environments would also reduce lead inputs both directly and
indirectly to aquatic environments.  In addition, effluent limitation
guidelines established under the Federal Water Pollution Control Act
Amendments of 1972 (PL 92-500) would be important in reducing lead
in various liquid point source discharges.
     As with terrestrial sites, actual reductions in lead in particu-
lar aquatic environments are expected to be site specific, depending
on the mix of lead sources.  For example, coastal ocean water would
experience a reduction in lead input from the phasedown of lead in
gasoline and the control of point source emissions to the air because
these are the dominant lead sources for that environment (see Appen-
dix X).  An aquatic environment dominated by the inflow of domestic
sewage wastes may experience no change in lead inputs because present
legislation sets no lead standards for this type of source.
                                3-39

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     Despite expected overall decreases in air and waterborne lead
concentrations, aquatic ecosystems would continue to receive some
lead from terrestrial ecosystems in normal erosion and runoff because
of the present large storage of lead that has accumulated in surficial
terrestrial soils.  Because of this, aquatic environments would not
exhibit as rapid a decline in overall lead concentrations as would
terrestrial environments.  Lead stored in sediments in eroding streams
would be transported slowly downstream.  High concentrations of lead
in sediments in depositional areas such as lakes would be covered by
sediments containing less lead as lead control measures become insti-
tuted and the storage of lead presently in terrestrial soils slowly
depletes by erosion.  Lead concentrations throughout the aquatic food
web would decline as lead in the water decreases and lead in sediments
becomes slowly buried beneath the biologically active surface layers.

3.3.10  Demography
     The total labor force required for construction of a BEFF is ex-
pected to be met by  using local construction workers.  The operation
of a BEFF would probably require a smelter company to hire two addi-
tional people, one for operation and one  for maintenance (Nelson,
1977).  Even under the most  stringent of  the standards proposed, only
20 to 22 BEFF's would be required.  Consequently no widespread popu-
lation shifts are anticipated—and none of the related imoacts are
likely to occur.  These would include such community services as
                                 3-40

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housing, medical facilities, educational institutions, public utili-
ties, and public safety organizations (fire and police).
     Since the exact nature of the particulate trap production pro-
cess has not yet been specified, the size and qualifications of the
labor force required to operate the facilities cannot be precisely
evaluated.  If the traps were simply to serve as replacements for
the usual attrition of mufflers, it might be possible for those work-
ers presently manufacturing mufflers to be reassigned the tasks nec-
essary for trap production.  A majority of the traps, however, would
likely be placed on cars not needing new mufflers at the time and an
additional work force would have to be hired for a one or two-year
period.   It does not appear that particularly skilled operators would
be needed and most industrial  areas have enough unemployment so that
unskilled workers could be found locally.

3.4  RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIRONMENT
     AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY
     The promulgation of an NAAQS for lead involves having to accept
some short-term environmental  concessions for anticipated long-term
benefits.  The latter are most importantly reflected in the expected
reduction of airborne lead and the subsequent improvement in public
health and welfare, while the former involve several short-term com-
mitments of and undesirable effects upon man's environment.
     Many of the short-term adverse impacts are expected to occur dur-
ing the construction stages of such projects as (1) the installation
                                3-41

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of BEFF systems to control fugitive emissions at smelters, and  (2)
the creation of landfill areas to accommodate solid wastes.  Other
short-term adverse impacts would occur if the additive effect of OSHA
standards and the lead emission control strategy should dictate the
extreme measure of plant closure of all or part of its operations.
In this case a notable short-term adverse impact would be the loss of
jobs.
     The taking of land for construction involves some long-term
loss of habitat but in the case of the land used for BEFF operations,
this area would be generally adjacent to the smelter within the prop-
erty lines and relatively uninhabitable.  Moreover, the acreage requir-
ments are small (on the order of a few acres total for all smelters).
The total acreage needed annually for landfill (to bury dust collected
during the 3EFF operations) is less than 25 acres and the land  is
expected to undergo only short-term disruption since the sites  can be
rehabilitated through revegetation.  It should be noted that this
short-term disruption will reoccur periodically as new waste is col-
lected for disposal.
     A major irony of the mobile portion of the control strategy is
that the need for particulate traps is short-lived.  Only for the
case of the most stringent standard (1.0 ug/m3) are these control
options needed to any large extent, and even then only for a
limited time period.  Due to the effectiveness of the Federal phase-
down program, the need for this control option is expected to drop
                                 3-42

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 dramatically  within  a  few  years.
     The short-term  implications of such a situation could involve
the drastic choice of decommissioning these facilities once phase-
down becomes effective enough.  Alternative actions include a gradual
production and stockpiling of traps before 1982 to minimize the size
of the additional production facilities needed.
     The use of energy represents both a short-term and a long-term
commitment of resources.  The former relates primarily to the capital
energy expended to construct the necessary BEFF systems, while the
latter derives from the operational stages, i.e., collecting fugitive
dust at smelters.  While the manufacturing of traps represents the
use of operating energy, whether this use would become long-term
depends upon how soon these facilities may be.decommissioned.   It is
not clear how useful  the further production of parti oil ate traps would
be.  Based on the reduction of lead in air, it would appear that the
parti oil ate trap program is a temporary option.
     While it is difficult to make direct comparisons between  the
adverse impacts of the proposed action and the benefits which  would
result, the improvement of human health constitutes the overriding
factor behind the promulgation of an NAAQS for lead.  The benefit
                                 3-43

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to be achieved is a Deduction of adverse health effects which might
otherwise occur as a result of prolonged community exposure to lead.

3.5  MITIGATING MEASURES AND UNAVOIDABLE ADVERSE IMPACTS
     Among the environmental impacts identified in this analysis are
several which can be classified as adverse impacts.  These include
the consumption of more energy, changes in land use patterns, water
pollution, and the production of a large number of particulate traps
in a short time.   In addition, certain economic impacts discussed in a
separate statement can be expected, such as increased costs to car
owners, to state and local governments, and to consumers of copper and
lead and their products.  Measures can be taken to reduce or eliminate
some of these impacts.  Those impacts which cannot be mitigated are con-
sidered to be unavoidable adverse impacts.
 3.5.1  Mitigating Measures
      Careful siting and design of the landfill sites which would be
 used for disposal of lead from BEFF's can eliminate or reduce the
 potential  for these sites to pollute surface and/or ground waters.
 To minimize the aesthetic impact of new landfill  sites on surround-
 ing areas, topsoil could be used to cover the disposal site and veg-
 etation reestablished.   It may also be possible to dispose of the
 solid waste from the SEFF's in abandoned mines which may be owned by
 the primary lead and primary copper smelting companies.  "To reduce
 ihe possibility of lead leaching from the disposal sites, new land-
 fills can be designed such that they would be lined with impermeable
                                  3-44

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membranes.  In addition, a monitoring system should be a part of a
design to identify failures or accidents at the landfill which result
in leaching.  Designing the BEFF's such that the lead dust collected
could be recycled in the smelting process or buried in the lead mines
would minimize the need for additional solid waste disposal sites and
their related impacts.  Acoustical devices can be incorporated in the
design of the BEFF's to minimize their operating noise levels.
     With stockpiling, the particulate traps could be manufactured
over several years to reduce the impacts of trying to quickly produce
large numbers of these essentially one-time-use devices.  Particulate
trap production facilities are expected to be located at existing
muffler plants and, therefore, should blend with the surroundings,
having no impact on aesthetics.

3.5.2  Unavoidable Adverse Impacts
     Of the impacts identified in Sections 3.2 and 3.3, measures  are
not available to mitigate some of the adverse impacts.   The expense
of adding control devices to automobiles and primary lead and primary
copper smelters cannot be avoided.  The additional energy consumed
to manufacture and operate these devices is another unavoidable
adverse impact which may be attributed to the setting and enforcing
of the NAAQS for lead.  Either the state, local, or Federal govern-
ment would have to pay for the implementation plan development, ambi-
ent air monitoring, and standard enforcement, as these  are unavoid-
able costs.  Measures to mitigate the increased costs of producing
                                3-45

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lead and copper and  their end products  are not available.   The magni-
tude of these impacts varies for alternative levels of the proposed
standard, but at none of the levels analyzed are these impacts-ex-
pected to be of major consequence.

3.6  IRREVERSIBLE IMPACTS
     This section identifies the resources which are irreversibly or
irretrievably committed as a result of the proposed action, i.e., the
establishment of an  NAAQS for lead.
     Resources are considered irreversibly committed if, as a result
of the proposed action, they
     (a) Are consumed,
     (b) Cannot be recovered and reused, or
     (c) Are permanently damaged.
     The proposed strategy for the implementation of the lead stan-
dard is the control  of both stationary and mobile sources of lead
emissions.  The control strategy (described in Section 3.1) involves
     (a) The use of labor and materials in the manufacturing of
         control systems (BEFF's and lead traps);
     (b) The use of labor, materials, and land for plant modi-
         fication (primary lead and copper smelters);
     (c) The use of labor for the installation of control  equip-
         ment;
     (d) The use of labor, equipment, and land for the disposal
         of dust collected by the BEFF's; and
     (e) The use of energy in connection with all the above
         activities.
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     From among the above resources, labor and energy should be
regarded as irreversibly committed.   On the other hand, materials
used in the above activities would be largely recoverable for reuse,
with the exception of reinforced concrete used in plant construction.
Similarly, any equipment would be reusable either as is or through
recovery in the form of scrap materials.
     It is not anticipated that there would be permanent impacts on
the land used; however, depending on use, as a result of the proposed
action, land would be temporarily unavailable, e.g., land used for
disposal sites.  No permanent hydrological or ecological impacts are
anticipated nor is there any anticipation of permanent effects on
topographical, geological, or soil characteristics.
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                              REFERENCES
ENVIRONMENTAL IMPACTS OF THE PROPOSED STANDARD

Bureau of the Census.  1967.  Census of Manufacturers,  1967:   Summary
     and Subject Statistics, Vol.  1, pp.  5-235  through  239.   U.S.
     Department of Commerce.

Bureau of the Census.  1977.  Information Officer,  Industry  Division,
     Department of Commerce.  Telephone conversation.

Federal  Energy Administration.  April 1977.   Monthly Energy  Review.
     National Energy Information Center,  Federal  Energy Administration.

Goodfriend, L.S. and F.M. Kessler.  1973.  "Industrial  Noise Pollution,"
     Pollution Engineering and Scientific Solution.   Proceedings of
     the First International Meeting of the Society  of  Engineering
     Science Held in Tel Aviv, Israel June 12-17,  1972.  Plenum Press,
     New York-London, 1973.

Nelson,  K.W.  January 11, 1972.  American Smelter and Refinery Company,
     Incorporated.  Written correspondence to John M. Pratapas, U.S.
     Environmental Protection Agency.

Statnick, Robert M.  October 1974.  Measurement of Sulfur Dioxide,
     Particulate, and Trace Elements in Copper  Smelter  Converter and
     Roaster/Reverberatory Gas Streams.  National  Environmental Research
     Center.  Research Triangle Park, North Carolina.

Summers, Joseph.  March 16, 1977.   U.S. Environmental Protection
     Agency, Michigan.  Telephone conversation.

U.S. Environmental Protection Agency.  January  1974. Lead and Air
     Pollution:  A Bibliography With Abstracts.  Air Pollution Technical
     Information Center, Office of Air and Water Programs, Office of
     Air Quality Planning and Standards,  Research Triangle Park,
     North Carolina.

U.S. Environmental Protection Agency.  December 18,  1974j.  "Occupa-
     tional Noise Exposure Regulation," Federal Register, Vol. 39,
     No. 244.

U.S. Environmental Protection Agency.  October  1974f.   Background
     Information for New Source Performance Standards:   Primary
     Copper, Zinc, and Lead Smelters; Volume 1:  Proposed Standards.
     Office of Air Quality Planning and Standards,  Research  Triangle
     Park, North Carolina.  NTIS No. PB-237 832.


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                        REFERENCES (Concluded)
ENVIRONMENTAL IMPACTS OF THE PROPOSED STANDARD
U.S. Environmental  Protection Agency.
     Assessment Report on Arsenic.
July 19761.  Air Pollutant
U.S. Environmental  Protection Agency.  January 1977c.  The Report
     to Congress on Waste Disposal  Practices and Their Effects on
     Ground Water:   Report January  197TIOffice of Water Supply.

Van Horn, William.   October 1975.  Materials Balance and Technology
     Assessment of  Mercury and Its  Compounds on National  and
     Regional  Bases.   Prepared for  U.S. Environmental Protection
     Agency by URS  Research Company.   NTIS P8-247 000.
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