5455 905R78104
&ER&
Federal Register Preamble
and Regulations for
State Implementation
and
Advance Notice of
Proposed Rulemaking -
Ambient Monitoring
Requirements for
Significant Lead
Point Sources
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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Title 40--Protection of Environment
CHAPTER I—ENVIPONMENTAL PROTECTION AGENCY
PART 51—PREPARATION, ADOPTION, AND SUBMITTAL
OF IMPLEMENTATION PLANS
Implementation Plans for Lead National
Ambient Air Quality Standard
AGENCY: Environmental Protection Agency.
ACTION: Final Rulemaking.
SUMMARY: The regulations promulgated below, together with the current
requirements of 40 CFR Part 51, set forth the requirements for States to
follow in developing, adopting, and submitting acceptable implementation
plans for the lead national ambient air quality standards (NAAQSs),
promulgated elsewhere in this FEDERAL REGISTER. The implementation
plans are required under section 110 of the Clean Air Act.
Amendments to the existing regulations for implementation plans are
necessary because lead differs from other pollutants for which the
existing regulations were designed.
The amendments address the following topics:
--Definitions of point source and control strategy.
--Control strategy requirements.
—Air quality surveillance.
EFFECTIVE DATE: This rulemaking is effective upon publication; State
implementation plans for lead are due by [the date nine months from
publication].
ADDRESSES: U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Control Programs Development Division (MD 15),
Research Triangle Park, NC 27711.
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FOR FURTHER INFORMATION CONTACT: Joseph Sableski, Chief, Plans Guide-
lines Section, at the above address or at 919-541-5437 (Commercial) or
629-5437 (FTS).
SUPPLEMENTARY INFORMATION
1. BACKGROUND
On December 14, 1977, EPA proposed regulations for the preparation,
adoption, and submission of implementation plans to achieve the national
ambient air quality standards for lead, which were also proposed on that
same date (42 FR 63087). EPA invited comments from interested persons
and held a hearing on the proposed NAAQS and State implementation plan
(SIP) regulations on February 15 and 16, 1978. EPA received comments on
the proposed lead implementation plan requirements from 25 commenters.
Of these, there were ten representatives from industry, nine from State
and local governmental agencies, four from citizen's organizations and
private citizens, and two from other federal agencies.
2. SUMMARY OF COWENTS AND RESPONSES
The following discussion summarizes most of the comments received
on the proposal. There were a few other comments that EPA felt were not
significant to warrant discussion in the FEDERAL REGISTER and that did
not affect the final regulation. A summary of all the comments received
and EPA's response is available for public inspection during normal
business hours in EPA's Public Information Reference Unit (PM 215), 401
M Street, S.W., Washington, D.C. 20460, telephone: 202-755-0707.
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2.1 POINT SOURCE DEFINITION
There were several comments concerning the definition of a point
source. One commenter indicated that the definition of a point source
is confusing and differs from that used in the provisions in the Clean
Air Act concerning prevention of significant deterioration (PSD). Parts
of that comment were directed toward the existing definition of point
source in S 51.1(k), which, as the commenter acknowledged, is not the
subject of the proposal and will not be discussed here.
Currently, S 51.1(k) defines point sources in terms of emisssions
per year and location of the source, as well as a listing of individual
source categories. Currently, point sources of other pollutants for
which NAAQSs exist that are located in urban areas are defined as those
that emit pollutants in excess of 100 tons per year; point sources in
less urbanized areas are defined as those that emit pollutants in excess
of 25 tons per year. In light of the low level of the lead standard in
relation to the other standards (e.g., for particulate matter), good
reason exists to define point sources for lead at a lower level of emis-
sions than that for the current set of pollutants for which EPA has
established NAAQSs. Based on an analysis contained in EPA's "Supplemen-
tary Guidelines for Lead Implementation Plans,' EPA is defining a point
source of lead as "any stationary source causing emissions in excess of
4.54 metric tons (5 tons) per year of lead or lead compounds measured as
elemental lead." This represents a slight change from the proposal,
which failed to account for lead compounds.
The significance of the definition of S 51.1(k) is that the emis-
sion inventory, which is used to determine the extent of possible
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violations of the air quality standard and determine the effectiveness
of control strategies, must include a determination of emissions from
each point source. All emissions from sources other than point sources
may be grouped together as area (or line) sources.
The definition of point source, which was intended to be based on
actual emissions, differs from the definition in section 169 of the
Clean Air Act (which pertains to prevention of significant deterioration),
which is based on potential emissions. The reason for the difference is
that for planning purposes, the inventory of existing sources must be
based on an actual situation to be used as a baseline upon which one
develops a plan. For new source review (including review for prevention
of significant deterioration), one must be aware of the emissions that
could be emitted from the proposed source as well as actual emissions;
hence, the source size criteria for selection of new sources to be
reviewed under the recently-promulgated PSD regulations incorporate
potential, as well as actual, emissions. The definitions of point
source in 5 51.1(k) for all pollutants have been revised from the proposal
to clarify that the size criteria are based upon actual emissions. This
implies the emissions that are emitted after any control is applied.
2.2 CONTROL STRATEGY
A number of persons provided comments concerning the control
strategy aspects of the proposed regulations.
One commenter correctly noted a discrepancy between the list of
source categories in SS 51.80 ("Demonstration of attainment") and
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51.84 ("Areas around significant point sources"), for which the State
must perform an analysis. The lists should have been identical —
§ 51.84(a) should have also inc".jded lead-acid storage battery manufacturing
plants that produce 1200 or more batteries per day. The rulemaking
promulgated below incorporates this change. The criterion for production
of batteries, which was based on a monthly standard, has been raised to
2000 batteries per day, however, to account for the slightly less stringent
quarterly lead ambient standard.
Several commenters indicated that the requirements in SS 51.83
("Certain urbanized areas") and 51.85 ("Other areas") appeared identical
and therefore one of the sections was redundant. The difference between
the two sections lies in the required geographical scope of the analysis.
Section 51.83 requires that the plan contain an analysis of each urbanized
area that has a measured lead air concentration that is in excess of 4.0
O
ug/m quarterly mean (monthly mean in the proposal). The distinguishing
provision is that the analysis must cover at least the entire urbanized
area. Section 51.85, on the other hand, requires that for any area
(urbanized or not) with a recorded lead concentration that does not meet
the national standard of 1.5 ug/m quarterly mean (monthly mean in the
proposal), the plan must contain an analysis of at least the area in the
vicinity of the monitor that has recorded the concentration. Therefore,
the analysis may be restricted to an evaluation of only those sources
within a relatively small radius from the monitor.
Several commenters suggested that the control strategy requirements
ensure that the burden for solving the lead air problem be equitably
distributed between mobile and stationary sources. The commenters
realized that either kind of control is expensive and difficult to
implement. In response, EPA maintains that the allocation of the
burden of control in the SIP is the primary responsibility of the States,
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arid therefore EPA will avoid setting criteria in 40 CFR 51 that favor
control of one source category over another. EPA acknowledges that
measures that are expensive and difficult to implement may have to be
adopted in order to demonstrate attainment of the lead standard.
Two commenters indicated that the regulations did not provide a
satisfactory treatment to problems related to background concentration.
They claimed that a facility in an area of high background concentrations
may be unduly penalized in efforts to attain the standard. EPA acknow-
ledges that this problem may exist. In most cases, however, the high
background air concentrations are generally due to other sources in the
vicinity. It is the primary responsibility of the State to allocate the
burden of emission control to the various sources causing the problem.
Sources will have an opportunity to comment on the plan at the public
hearing that is required before the plan is submitted to EPA.
One cownenter suggested that EPA recofimend analysis of fugitive
dust and on-premise soil before a State initiates a program of prolonged
monitoring in the vicinity of gray iron foundries. As mentioned in the
preamble to the proposed regulations, EPA identified gray iron foundries
as having the potential for causing violations of the national standard
for lead, but this identification was based on limited data concerning
the amount of fugitive emissions from the facilities. Although EPA does
not feel that the degree of confidence in this identification justifies
a requirement for States to analyze all gray iron foundries (of which
approximately 1500 exist), EPA encourages States to consider analysis of
these sources to the extent that time and resources permit.
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The commenter's suggestion concerning the analysis of fugitive dust and
on-premise soil before undertaking extensive monitoring and analysis
appears to offer the potential for conserving scarce resources in that
States may want to restrict their monitoring and analysis efforts to
those plants with relatively high lead levels in dust and soil.
The same commenter also indicated that secondary lead smelters and
similar sources probably cannot be modeled because of fugitive dust and
low stacks. EPA recognizes the difficulty in quantifying fugitive dust
and fugitive emissions and recognizes that low stacks will generally
cause higher concentrations closer to the stack than will higher stacks.
The Clean Air Act requires that an approved plan must demonstrate attain-
ment of the standard, however. EPA has, based upon preliminary analyses,
determined that secondary lead smelters and other sources listed in
S 51.84 have the potential for causing violations of the lead standard.
EPA also believes that attainment of the lead standard around such
sources can best be demonstrated by the use of an atmospheric dispersion
model. In many cases, States will not have the time or resources to
perform detailed studies to quantify the fugitive dust and fugitive
emissions from individual facilities and may have to rely on factors
that were based on limited studies of other facilities or best estimates.
In complying with S 51.84, for cases where no ambient lead data were
collected in the vicinity of the source and where a State must thus
estimate the air quality impact of the sources, the State will have to
decide for itself what level of control is warranted by the confidence
in the data upon which the analysis is based.
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In another comment concerning modeling, one commenter from a State
agency claimed that the models used for assessing the monthly impact of
point sources are not accessible to most air pollution control agencies.
In the initial analysis of the impact of the proposed standard on point
sources, it is true that EPA used the Oak Ridge National Laboratory
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Model, "Atmospheric Transport and Dispersion Model" (ATM), which is
probably not available to most agencies. That analysis was revised
subsequently, and another model was used, however. Also, EPA is recom-
mending the use of other models, specifically those models for particulate
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matter described in EPA's "Guideline on Air Quality Models, for modeling
point sources for SIP development. These models are generally available.
The same commenter indicated that only ambient monitoring or
upwind-downwind sampling can give a reliable assessment of the impact of
sources with a large fugitive emission component. EPA acknowledges that
monitoring studies generally give a more reliable estimate of the air
quality impact of sources that emit fugitive emissions because no estimate
need be made of the fugitive emissions, which are difficult to measure
directly. Such studies cannot be done for many areas within the time
and resource constraints facing the States, however, and therefore EPA's
regulations require the use of modeling around such point sources.
States will have to make estimates of the fugitive emissions based on
whatever information may exist. EPA is, however, in another part of
this FEDERAL REGISTER giving advance notice of proposed rulemaking to
require the installation of ambient monitors in the vicinity of three
categories of point sources that have major fugitive emissions—primary
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and secondary lead smelters and primary copper smelters. Presumably,
after these monitors have been in place for a few years, the data yielded
will provide more accurate information concerning the nature and magnitude
of the lead problem from these sources. After those data become available,
EPA may require States to revise their implementation plans. Furthermore,
EPA intends to develop fugitive lead emission factors that are more
accurate than those that currently exist.
One commenter recommended that the regulations place the proof of
compliance with emission regulations on the stationary source. The
commenter claimed that local enforcement agencies do not have the funds
for continuous monitoring. In response, EPA has found that there are no
techniques for continuous monitoring of lead emissions. The State will
be required under existing regulations (40 CFR 51.19) to carry out a
source surveillance program, which generally consists of visual inspec-
tion of the installation of control equipment and testing of stack emis-
sions.
Several comments addressed issues concerning control of lead in
gasoline. One commenter indicated that any reduction of the lead content
of gasoline or any other similar kinds of programs (presumably meaning
control of fuels or the control of lead emissions from individual vehicles)
that may be needed in the SIP over and above the current Federal program
should be done through Federal rather than local regulation. EPA has
already taken steps to control the amount of lead in gasoline through
the phasedown of lead in leaded gasoline and the requirement that cars
equipped with catalyst mufflers must burn unleaded gasoline. The level
of control of lead in leaded gasoline was based on average conditions
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concerning lead air quality concentrations. Areas that have unique
problems and that will find it impossible to demonstrate attainment of
the lead standard through stationary source control or through trans-
portation control measures may have to adopt measures such as requirements
for further reduction of lead in gasoline or control of lead emissions
from the tailpipe of vehicles,, Currently, EPA does not foresee the
need for additional mobile source control strategies and does not Intend
to require further nationally-applicable lead-in-gasoline reductions.
Other comments concerning further reductions of the lead content of
gasoline suggested that such reductions be undertaken only after sufficient
data 1s available to indicate that the lead air quality problem is
geographically broad enough and only after a finding that such a limitation
is necessary to achieve a national ambient air quality standard. The
coomenters enumerated the problems with instituting further control of
the lead content of gasoline. The coirsnenters contended that application
of more stringent local limitations of lead in gasoline could seriously
disrupt the nation's gasoline distribution system, resulting in severe
spot shortages, especially during the summer months when gasoline demand
is at its highest.
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EPA recognizes this problem and advises the States to consider the
comment. Also, under S 211 (c)( .-)(C) of the Clean Air Act, EPA will not
approve State or regional programs for further reductions of lead content
of gasoline unless the State demonstrates that no other reasonable
measures are available.
Also, two of the commenters recommended that the 40 CFR 51 regula-
tions be modified to reflect the restrictions in S 211(c)(4)(C) of the
Act regarding State limitation of the lead content of gasoline. In
response, EPA has incorporated the intent of the Act into the definition
of "control strategy" as it pertains to restrictions on fuel additives.
Two commenters representing primary lead smelting companies recommended
an alternative approach to protecting the health of persons from the
ambient lead levels in the vicinity of primary lead smelters. They
recommended that sources that cannot control emissions so that the lead
standard will be met be allowed to conduct a public health screening and
hygiene program aimed at reducing the amount of lead that children in
the vicinity of the source take in and ensuring that safe blood lead
levels are satisfactorily maintained.
EPA believes that there are legal, technical, and equity problems
with the program that render it unacceptable as the sole means of imple-
mentation of the national standard for lead.
Concerning the legal problem, such a program assumes that the air
quality standard will be violated, and presumably, the plan will not
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contain a demonstration that the air quality standard will be attained.
Under the Clean Air Act, EPA must disapprove a plan that does not contain
a demonstration that the air quality standard will be attained by the
mandatory attainment date. The Act provides for the protection of health
through the standard setting, planning, and implementation processes; it
does not allow for a surrogate procedure whereby public health may be
protected even though the ambient standards are not met.
Concerning technical problems, the relationship between emissions from
a source and blood lead levels is not quantitatively certain. Even assuming
a biological monitoring system were to be established, it is unclear
what the source would have to do concerning its operation or emissions
if the monitoring program revealed unacceptable blood lead levels. Even
if a course of action were clear, the damage would have already been done,
while the basic purpose of the standard setting and implementation pro-
cess envisioned by S 110 of the Act is prevention of public health prob-
lems.
Concerning equity, the biological monitoring program would incon-
venience the very people that are supposed to benefit from the Act. The
Act invisioned that all people have an equal right to healthy air. The
commenters who recommended the biological monitoring approach apparently
believe that people who happen to live in areas with elevated lead levels
should not be accorded equal protection, but should be made to pay extra
for their health through presumably continuous participation in a blood
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sampling program. If a person did not want to participate, it is doubtful
whether he could be forced to, so therefore his health could be placed
in jeopardy.
One co/rmenter representing a primary lead smelter warned that enclo-
sure of smelter operations to control fugitive lead emissions may present
a severe occupational health hazard to employees who must work within
the enclosed space. EPA realizes these potential problems. If a source
installs such enclosures, it must of course also meet any applicable regu-
lations set forth by the Occupational Safety and Health Administration as
well as control emissions to the extent specified in the applicable
implementation plan.
One other conmenter expressed concern that there appears to be
nothing that can be done in areas where a source is employing best
available control technology, yet the standard is still not being met.
The Act requires that for approval, an implementation plan must demonstrate
that the control strategy contained in the plan is adequate to attain and
maintain the NAAQS. EPA realizes, however, that a plan which meets this
criterion may, even after full implementation, not actually result in
attainment by the attainment date. This would generally indicate that
assumptions concerning the amount of emissions and the relationship
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between emissions reductions and air concentrations that were made when
the plan was developed eventually were proven erroneous. If an approved
plan is later found to be inadequate to attain the standard, EPA will
require the State to revise the plan. If that plan has already required
all measures short of those that would force significant source closures,
EPA will at that time decide whether the closure must be effected or
whether there are alternatives to this in the discretion given to EPA
under the Act in Sections 110 or 113. States should make every effort
to develop and submit plans that demonstrate attainment of the standard
using the best data available.
Several commenters from State air pollution control agencies indi-
cated that the development of lead SIPs will be difficult within the
time frai.ie provided. EPA realizes that the development of the lead
plans will be competing in priorities and resources with the development
of plan revisions required by Title I, Part D, of the Clean Air Act for
nonattainment areas. Where a State needs additional assistance in the
development of its lead plan, or where it is unsure as to the priority
of development of its lead plan, the State should consult with the
appropriate EPA Regional Office.
2.3 AIR QUALITY MONITORING
Several commenters recommended that a minimum number of samples be
taken to determine whether the standard is being attained. Also, several
persons commented that the sampling should be performed more frequently,
such as daily. One person indicated that determination of the attainment
status should be done by annual rather than monthly averaging. At least
a three month average would be more desirable. Another person indicated
that the shorter the averaging period, the more the number of samples
should be.
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Concerning the minimum number of valid samples needed to determine
an average, it is general practice to require at least 75 percent of the
scheduled samples to be valid. EPA will prepare a guideline on this and
other issues concerning the determination of attainment of the standard.
Concerning the frequency of sampling, EPA is promulgating a national
ambient air quality standard for lead in this FEDERAL REGISTER that is
based on a calendar quarter, rather than calendar month as had been pro-
posed. EPA has determined that a sampling schedule of once every six
days is adequate to give a representative sample for a quarter.
One commenter indicated that monitoring the inner city area should
be given top priority because the vehicle mix in these areas favors
older cars that bum leaded gasoline. EPA's response is that if maximum
exposures occur in these areas, then monitoring these areas should in
fact receive first priority. The determination of acceptability of the
sites will be the joint responsibility of the States and the cognizant
EPA Regional Office.
One commenter recommended that EPA change the recommendation in the
draft "Supplementary Guidelines for Lead Implementation Plans' for
locating lead monitors near roadways that are at or below grade level
rather than near elevated roadways. The commenter suggested that the
guideline require measurements to be representative of emissions and
environmental exposure. The commenter indicated that the proposed
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guidance would exclude monitoring play areas that are located beneath
elevated roadways. EPA agrees with this comment. The purpose
behind excluding below grade level monitoring and monitoring near ele-
vated roadways was to ensure adequate exposure at the monitoring site.
If significant population exposures consistent with the averaging time
of the NAAQS were encountered in these situations, then monitoring in
these locations would meet the intent of the guidance. EPA has revised
the siting guidance to account for these considerations.
Several comments were directed toward the recommended location of
a monitor at a given location. Two persons indicated that the allowance
of 5 meters in elevation of lead air monitors is too high and that it
should be changed or should allow for numerical adjustment of the data.
One person suggested that the monitors be required to be placed closer
to roadways because he felt that would be more representative of
exposure; another suggested that the monitors are required to be placed
too close to the street already in some cases and that the data from the
monitors would be unrepresentative. EPA proposed a range of heights
for lead monitors from 0 to 5 meters above ground level. The proposed
required distance from major roadways for the peak concentration site
was 5 to 15 meters. The intent was to sample ambient air to which
significant portions of the population are being exposed over the
averaging time of the standard. During a typical day, even the most
susceptible population group does not spend more than one half of their
time in the ambient air below the 2 meter level or within 15 meters of
a major roadway. They are indoors or at considerable distances from
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roadways for the remainder of their time. Consequently, requiring
samplers to be placed below two meters above the ground or closer than
5 meters to a roadway would lead to concentration measurements that
would be unrepresentative of lead exposures. Further, some range of
heights and distances is necessary due to practicalities involved in
finding suitable sites, power availability, protection against vanda-
lism, allowing free pedestrian movement along sidewalks, etc.
One commenter recommended that the criteria for monitoring in the
vicinity of roadways not include specific distance restrictions, such as
the requirement for placement of monitors between 5 and 15 meters from
the traffic lane. The commenter indicated that many areas do not have
housing that close to major roadways and therefore the numerical restric-
tions would be counterproductive to ensuring accurate monitoring of
maximum population exposure. EPA's response is that even though housing
may not exist that close to roadways in all cases, the public has access
to many such areas.
One commenter recommended that the monitoring guidelines require
monitoring lead below ground level in public places such as subway
stations and underground shopping areas. In response, EPA's monitoring
guidance was written for purposes of determining attainment of a standard.
Locating monitors in subways to determine exposures would be considered
special purpose monitoring and thus could be performed if desired by the
State or local agency. EPA however, does not feel that monitors placed
in these situations would yield data suitable for developing implemen-
tation plans or determining national trends and strategies and thus will
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not require it. Furthermore, since no member of the public spends more
than perhaps eight hours out of twenty four in such locations, monitoring
there would not be representative of population exposure for a standard
based upon 24-hour sampling for an entire quarter.
One conunenter recommended that the regulations require ambient
monitoring in the vicinity of major point sources. Not doing so may
allow potentially significant public health impacts that result from
fugitive emissions at major point sources to be ignored. As mentioned
above, in another part of this FEDERAL REGISTER, EPA is giving advance
notice of proposed rulemaking to modify the regulations to require
source owners or operators to monitor in the vicinity of primary and
secondary lead smelters and primary copper smelters. EPA chose these
source categories because they are considered to have the potential for
causing the greatest concentrations of air lead in their vicinity and
because the nature and magnitude of their fugitive emissions are relatively
unknown compared to other source categories. The regulations will
continue to vest authority in the Regional Administrators to require
monitors in the vicinity of other sources. EPA will prepare guidance
concerning the recommended number and siting of monitors in the vicinity
of lead point sources.
Another commenter claimed that the regulations do not adequately
address the locations where air quality samples will be taken and at
what distance from a facility they will be taken. As mentioned above,
EPA will develop guidance on the placement of lead monitors in the
vicinity of point sources. The guidance for locating monitors elsewhere
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is highly specific in that the distances from obstructions and inter-
ferences are quantitatively described. It is not possible from a
national perspective, however, to develop general regulations that would
cover every conceivable situation that could occur without making the
regulations unduly complex.
One commenter suggested that the lead monitors should not be
required to be permanent until the State has more experience in sampling
and monitoring lead. Also, several commenters recommended that EPA
require initial monitoring by mobile vans or other procedures to locate
the most critical sites. EPA does not intend that the required monitoring
stations would remain at one place in perpetuity. EPA does, however,
need some stability in monitoring site locations to allow for trends
analysis. If a station once established is later found to be unrepresen-
tative, it should be moved to a new location. EPA agrees with the
intent of the comments and has always encouraged special purpose monitoring
prior to establishing a permanent monitoring station. EPA will not
require resource-intensive procedures to locate critical sites, however.
Several commenters recommended that the regulations require more
than a minimum of two monitors per area. EPA's response is that the
regulations do not preclude placing out more than two monitors. EPA is
interested nationally in obtaining only enough data to establish a data
trend, determine if the federal programs that result in the reduction of
automobile lead emission are causing decreases in lead air
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concentrations, and determine the approximate attainment status of
areas. Furthermore, the regulations would allow EPA to require additional
monitors on a case-by-case basis where EPA believes that two monitors
are insufficient to determine whether the national standard is being
attained and maintained.
One of the commenters who recommended that the regulations require
more than two monitors per area objected to placing responsibility on
the EPA Regional Offices to require additional monitors and determine
their location. The commenter claimed that this precludes both account-
ability of the State's actions and public participation. EPA's response
is that requiring a limited number of samplers specifically to meet data
needs at the national level and leaving the determination of the number
and location of the remaining stations in the State network to the State
and the Regional Office is consistent with the recommendations of EPA's
Standing Air Monitoring Work Group (SAMWG). In a recent action (43 FR
34892, published August 7, 1978), EPA proposed that the locations of
stations (for all pollutants) need not actually be included in the
implementation plan, but the plan must contain a monitoring program
which includes a monitoring network that is based upon negotiations
between the State and the EPA Regional Office. The plan would also have
to contain a commitment to annually review the adequacy of the network
and to establish new stations and relocate or terminate existing stations
as needed in order to keep the network responsive to data needs. EPA
feels that if the entire system were part of the SIP, the only way the
State could make modifications would be to propose the change, hold a
public hearing, and submit the change to EPA as a plan revision. EPA
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would then have to propose to approve the revision, entertain public
comment, and then finally promulgate its approval. EPA feels that this
process is too time-consuming and would defeat the purpose of the annual
review, which is to make timely adjustments to the network. Also, EPA
feels that the potential benefits from this process would be too few to
warrant its implementation. The proposed requirements concerning air
quality monitoring, however, would require that the locations of the
monitors be available at all times for public inspection. Therefore,
when the State revises its SIP in order to implement the forthcoming air
quality monitoring requirements, the public can at that time comment on
the State system. The public can also comment on changes to the net-
works at any time by submitting written comment on changes to the State
or EPA Regional Office.
One commenter indicated that the low-volume sampler compares
favorably in measurement with the high-volume sampler, which is the
reference method for collection of the sample, and excludes larger
particles that are not respirable and which the commenter feels are not
significant from a health standpoint. The commenter implies that EPA
should allow the use of the low-volume sampler. Low volume sampling
will be allowed if the agency that wishes to use it demonstrates that
the method is equivalent to the reference method, using the procedures
that EPA is proposing in another portion of this FEDERAL REGISTER.
3.0 OTHER CHANGES FROM PROPOSAL
3.1 AIR QUALITY SURVEILLANCE REQUIREMENTS
EPA has revised the air quality surveillance requirements for lead
slightly from the proposal to render them clearer and more consistent
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with the general air quality surveillance requirements currently under
revision that will apply to all pollutants. These revised general
requirements will closely follow and implement the recommendations of
EPA's Standing Air Monitoring Work Group. The significant revisions of
the lead requirements from the proposal include the following:
—A change of the date by which the entire monitoring system must
be established.
—Deletion of the references to the terms, "National Air Quality
Trends Stations" (or "NAQTS") (which are now called "National Air Moni-
toring Stations") (or "NAMS") and "State and Local Air Monitoring Sta-
tions" (or "SLAMS"). These terms have not yet been defined by regula-
tion, so reference to them is meaningless.
--Modification to the requirement that the plan contain a des-
cription of the monitoring system.
--Revision of the "Supplementary Guidelines on Lead Implementation
Plans" to account for location of monitoring stations in urban street
canyons.
As mentioned in the preamble to the proposal, EPA will eventually
incorporate the lead monitoring requirements into the air quality moni-
toring requirements that apply to all pollutants for which NAAQSs exist.
3.2 REPORTING OF DATA BASE
Under the proposal in S 51.86(c), the State would have been required
to submit the air quality data collected since 1974 in the format of
EPA's Storage and Retrieval of Aerometric Data (SAROAD) system. The
final regulation below retains this requirement, but provides the Regional
Administrator with the authority to waive the requirement concerning the
format of the data.
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3.3 LISTS OF URBANIZED AREAS
There were several errors in the two tables of areas in the pre-
amble to the proposal. In Table 2, "Urbanized areas with lead air
concentrations exceeding or equal to 1.5 ug/m , maximum monthly mean
(1975)", the Norfolk, Va. AQCR number should have read 223 instead of
233. Table 3, "Urbanized areas with lead air concentrations equal to or
exceeding 4.0 ug/m , maximum monthly mean (1975)" should have read as
follows:
"AQCR URBANIZED AREA
15 Phoenix, Ariz.
24 Los Angeles--Long Beach, Cal.
29 San Diego, Cal.
30 San Francisco—Oakland, Cal.
30 San Jose, Cal.
67 Chicago, 111.—Northwestern Ind.
215 Dallas, Tex.
Source: Data from EPA's Environmental Monitoring Support Laboratory,
Statistical and Technical Analysis Branch."
These corrections, however, are now academic, since the averaging
time of the lead standard is now quarterly. Therefore, Tables 2 and 3
are revised to reflect the quarterly average. Table 2 (renumbered Table
1) appears at the end of the preamble. Table 3, revised to reflect the
quarterly average, now contains only one area, the Los Angeles—Long
Beach, California, urbanized area. The list reflects only the data
currently available to EPA, and generally the quarterly averages available
are not truly representative due to insufficient data. There are other
data available to State and local air pollution control agencies, however,
that may indicate that other areas have concentrations in excess of the
concentrations specified in the criteria for performing the analysis.
23
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3.4 EXAMPLE LEAD CONTROL STRATEGY
The preamble to the proposal indicated that EPA was developing an
example lead control strategy to assist the States in developing their
lead implementation plans. The preamble indicated that the example was
scheduled for completion by March 1978. Because EPA has received an
extension for promulgating the national ambient air quality standard for
lead, because the example control strategy would be based on the final
implementation plan regulations promulgated below, and because of other
delays, the example controls strategy will probably not be available
until November or December of 1978.
4.0 REFERENCES
1. Supplementary Guidelines for Lead Implementation Plans. U.S.
Environmental Protection Agency, Office of Air Quality Planning
and Standards, Research Triangle Park, N.C. 27711.
(OAQPS No. 1.2-104).
2. Culkowski, W.M. and M.R. Patterson, A Comprehensive Atmospheric
Transport and Diffusion Model. (ORNL/NSR/EATS-17. Oak Ridge
National Laboratory, Oak Ridge, Tenn., 1976.
3. Guideline on Air Quality Models. Monitoring and Data Analysis
Division, Office of Air Quality Planning and Standards, U.S.
Environmental Protection Agency, Research Triangle Park, N.C.
EPA-450/2-78-027 (OAQPS No. 1.2-080), April, 1978.
4. Air Monitoring Strategy for State Implementation Plans. Prepared
by the Standing Air Monitoring Work Group. U.S. Environmental
Protection Agency, Office of Air and Waste Management, Office of
Air Quality Planning and Standards, Research Triangle Park, N.C.
27711. EPA-450/2-77-010. June, 1977.
24
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TABLE 1
URBANIZED AREAS WITH LEAD-AIR CONCENTRATIONS
EXCEEDING OR EQUAL TO 1.5 ug/m , MAXIMUM QUARTERLY MEAN
(1975)
AQCR# AREA
004 Birmingham, Ala.
005 Jackson, Miss.
015 Phoenix, Ariz.
031 Fresno, Calif.
024 Los Angeles—Long Beach, Calif.
028 Sacramento, Calif.
024 San Bernardino—Riverside, Calif.
029 San Diego, Calif.
030 San Francisco—Oakland, Calif.
030 San Jose, Calif.
036 Denver, Colo.
043 New York, N.Y.—Northeastern N.J.
042 Waterbury, Conn.
042 Springfield, Chicopee-Holyoke, Mass.—Conn.
045 Wilmington, Del.—N.J.
045 Philadelphia, Pa.—N.J.
047 Washington, D.C.— Md.~Va.
067 Chicago, 111.—Northwestern Ind.
131 Minneapolis—St. Paul, Minn.
070 St. Louis, Mo. —111.
013 Las Vegas, Nev.
148 Reno, Nev.
184 Oklahoma City, Okla.
151 Scranton, Pa.
244 San Juan, P.R.
200 Columbia, S.C.
202 Greenville, S.C.
055 Chattanooga, Tenn.—Ga.
207 Knoxville, Tenn.
018 Memphis, Tenn.--Miss.
215 Dallas, Tex.
153 El Paso, Tex.
216 Houston, Tex.
Source: Data from EPA's Environmental Monitoring Support Laboratory,
Statistical and Technical Analysis Branch.
Date Administrator
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The Code of Federal Regulations, Title 40, Chapter I, Part 51, is
amended as follows:
1. In section 51.1, paragraph (k) is revised and paragraph (n) is
amended by adding subdivision (11) as follows:
S 51.1 Definitions.
* * * * *
(k) "Point source" means the following:
(1) For particulate matter, sulfur oxides, carbon monoxide, hydro-
carbons, and nitrogen dioxide—
(i) Any stationary source the actual emissions of which are in excess
of 90.7 metric tons (100 tons) per year of the pollutant in a region con-
taining an area whose 1970 "urban place" population, as defined by the
U.S. Bureau of the Census, was equal to or greater than one million;
(ii) Any stationary source the actual emissions of which are in
excess of 22.7 metric tons (25 tons) per year of the pollutant in a region
containing an area whose 1970 "urban place" population, as defined by the
U.S. Bureau of the Census was less than one million; or
(iii) Without regard to amount of emissions, stationary sources
such as those listed in Appendix C to this part.
(2) For lead, any stationary source the actual emissions of which
are in excess of 4.54 metric tons (five tons) per year of lead or lead -
compounds measured as elemental lead.
* *" * * *
(n) *** *
(11) Control or prohibition of a fuel or fuel additive used in
motor vehicles, if such control or prohibition is necessary to achieve
26
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a national primary or secondary air quality standard and is approved
by the Administrator under S 211(c)(4)(C) of the Act.
* * * * *
2. Section 51.12, paragraph (e) is amended by adding subdivision (3)
as follows:
S 51.12 Control Strategy: General.
* * * * *
(e) * * *
(3) This paragraph covers only plans to attain and maintain the
national standards for particulate matter, sulfur oxides, carbon monoxide,
photochemical oxidants, hydrocarbons, and nitrogen dioxide.
* * * * *
3. Section 51.17 is amended by (1) revising the heading to read "Air
quality surveillance: Particulate matter, sulfur oxides, carbon monoxide,
photochemical oxidants, hydrocarbons, and nitrogen dioxide," and (2)
adding paragraph (d) as follows:
S 51.17 Air quality surveillance: Particulate matter, sulfur oxides,
carbon monoxide, photochemical oxidants, hydrocarbons, and nitrogen
dioxide.
* * * * *
(d) This section covers only plans to attain and maintain the national
standards for particulate matter, sulfur oxides, carbon monoxide, photo-
chemical oxidants, hydrocarbons, and nitrogen dioxide.
27
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4. A new section 51.17b is added as follows:
S 51.17b Air quality surveillance: Lead.
(a) This section covers only plans to attain and maintain the national
standards for lead.
MONITORING IN CERTAIN AREAS
(b) The plan must provide for the establishment of a monitoring
system that contains at least two permanent lead ambient air quality
monitoring stations in each urbanized area (as defined by the U.S. Bureau
of the Census)--
(1) That has a 1970 population greater than 500,000; or
(2) Where lead air quality concentrations currently exceed or
have exceeded 1.5 ug/m quarterly arithmetic mean measured since January 1,
1974.
(c) The EPA Regional Administrator may specify more than two moni-
toring stations if he finds that two stations are insufficient to adequately
determine if the lead standard is being attained and maintained. He may
also specify stations in areas outside the areas covered in paragraph (b)
of this section.
(d) The monitoring system must contain at least one roadway type
monitoring site and at least one neighborhood site and be sited in
accordance with the procedures specified in EPA's "Supplementary Guidelines
for Lead Implementation Plans."
28
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(e) The monitors must be operated on a minimum sampling frequency
of one 24-hour sample every six days.
(f) Existing sampling sites being used for sampling particulate
matter may be designated as sites for sampling lead if they meet the
siting criteria of "Supplementary Guidelines for Lead Implementation
Plans."
(g) The plan must provide that all lead air quality monitoring
stations will be established and operational as expeditiously as prac-
ticable but no later than two years after the date of the Administrator's
approval of the plan for the stations specified under paragraph (b) of
this section.
(h) The analysis of the 24-hour samples may be performed for
either individual samples or composites of the samples collected over
a calendar month or quarter.
(i) [Reserved].
REQUIREMENTS APPLICABLE TO ALL MONITORS
(j) The plan must provide for having a description of the system
available for public inspection and submission to the Administrator at
his request. The description must be available at all times after the
date the plan is made available for public inspection. The description
must include the following information:
(1) The SAROAD site identification form.
(2) The sampling and analysis method.
(3) The sampling schedule.
(k) The monitoring method used in any station in the monitoring
systems required in this section must be a reference or equivalent method
for lead as defined in 5 50.1 of this chapter.
29
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5. A new subpart E is added as follows:
Subpart E~Control Strategy: Lead
§ 51.80 Demonstration of attainment.
§ 51.81 Emissions data.
§ 51.82 Air quality data.
§ 51.83 Certain urbanized areas.
S 51.84 Areas around significant point sources.
S 51.85 Other areas.
S 51.86 Data bases.
S 51.87 Measures.
S 51.88 Data availability.
S 51.80 Demonstration of attainment.
(a) Each plan must contain a demonstration that the standard will
be attained and maintained in the following areas:
(1) Areas in the vicinity of the following point sources of lead:
—Primary lead smelters.
—Secondary lead smelters.
—Primary copper smelters.
—Lead gasoline additive plants.
—Lead-acid storage battery manufacturing plants that produce 2000
or more batteries per day.
—Any other stationary source that actually emits 25 or more tons
per year of lead or lead compounds measured as elemental lead.
(2) Any other area that has lead air concentrations in excess of
the national standard concentration for lead, measured since January 1,
1974.
30
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(b) The plan must demonstrate that the measures, rules, and regula-
tions contained in the plan are adequate to provide for the attainment of
the national standard for lead within the time prescribed by the Act and
for the maintenance of that standard for a reasonable period thereafter.
(c) The plan must include the following:
(1) A summary of the computations, assumptions, and judgments used
to determine the reduction of emissions or reduction of the growth in
emissions that will result from the application of the control strategy.
(2) A presentation of emission levels expected to result from
application of each measure of the control strategy.
(3) A presentation of the air quality levels expected to result
from application of the overall control strategy presented either in
tabular form or as an isopleth map showing expected maximum concentrations.
S 51.81 Emissions data.
(a) The plan must contain a summary of the baseline lead emission
inventory based upon measured emissions or, where measured emissions are
not available, documented emission factors. The point source inventory
on which the summary is based must contain all sources that emit five or
more tons of lead per year. The inventory must be summarized in a form
similar to that shown in Appendix D.
(b) The plan must contain a summary of projected lead emissions for—
(1) at least three years from the date by which EPA must approve or
disapprove the plan if no extension under section 110(e) of the Clean Air
Act is granted;
(2) at least five years from the date by which EPA must approve or
disapprove the plan if an extension is requested under section 110(e)
of the Clean Air Act; or
31
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(3) any other longer period if required by the appropriate EPA
Regional Administrator.
(c) The plan must contain a description of the method used to
project emissions.
(d) The plan must contain an identification of the sources of the
data used in the projection of emissions.
S 51.82 Air quality data.
(a) The plan must contain a summary of all lead air quality data
measured since January 1974. The plan must include an evaluation of the
data for reliability, suitability for calibrating dispersion models
(when such models will be used), and representativeness. When possible,
the air quality data used must be for the same baseline year as for the
emission inventory.
(b) If additional laad air quality data are desired to determine
lead air concentrations in areas suspected of exceeding the lead national
ambient air quality standard, the plan may include data from any previously
collected filters from particulate matter high volume samplers. In
determining the lead content of the filters for control strategy demon-
stration purposes, a State may use, in addition to the reference method,
x-ray fluorescence or any other method approved by the Regional Adminis-
trator.
(c) The plan must also contain a tabulation of, or isopleth map
showing, maximum air quality concentrations based upon projected emissions.
S 51.83 Certain urbanized areas.
For urbanized areas with measured lead concentrations in excess of
3
4.0 ug/m , quarterly mean measured since January 1, 1974, the plan must
employ the modified rollback model for the demonstration of attainment
as a minimum, but may use an atmospheric dispersion model if desired.
32
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S 51.84 Areas around significant point sources.
(a) The plan must contain a calculation of the maximum lead air
quality concentrations and the location of those concentrations resulting
from the following point sources for the demonstration of attainment:
--Primary lead smelters.
--Secondary lead smelters.
—Primary copper smelters.
--Lead gasoline additive plans.
--Lead-acid storage battery manufacturing plants that produce 2000
or more batteries per day.
—Any other stationary source that actually emits 25 or more tons
per year of lead or lead compounds measured as elemental lead.
(b) In performing this analysis, the State shall use an atmospheric
dispersion model.
§ 51.85 Other areas.
For each area in the vicinity of an air quality monitor that has
recorded lead concentrations in excess of the lead national standard
concentration, the plan must employ the modified rollback model as a
minimum, but may use an atmospheric dispersion model if desired for the
demonstration of attainment.
S 51.86 Data bases.
(a) For interstate regions, the analysis from each constituent
State must, where practicable, be based upon the same regional emission
inventory and air quality baseline.
33
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(b) Each State shall submit to the appropriate EPA Regional Office
with the plan, but not as part of the plan, emissions data and informa-
tion related to point and area source emissions as identified in the
"Supplementary Guidelines for Lead Implementation Plans."
(c) Air quality data.
(1) Each State shall submit to the appropriate EPA Regional Office
with the plan, but not as part of the plan, all lead air quality data
measured since January 1, 1974. This requirement does not apply if the
data has already been submitted.
(2) The data must be submitted in accordance with the procedures
and data forms specified in chapter 3.4.0 of the "AEROS User's Manual"
concerning Storage and Retrieval of Aerometric Data (SAROAD) except
where the Regional Administrator waives this requirement.
5 51.87 Measures.
The lead control strategy must include the following:
(1) A description of each control measure that is incorporated
into the lead plan.
(2) Copies of or citations to the enforceable laws and regulations
to implement the measures adopted in the lead plan.
(3) A description of the administrative procedures to be used in
implementing each selected control measure.
(4) A description of enforcement methods including, but not limited
to, procedures for monitoring compliance with each of the selected
control measures, procedures for handling violations, and a designation
of agency responsibility for enforcement or implementation.
34
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§ 51.88 Data availability.
(a) The State shall retain all detailed data and calculations used
in the preparation of the lead analyses and plan, make them available
for public inspection, and submit them to the Administrator at his
request.
(b) The detailed data and calculations used in the preparation of
the lead analyses and control strategies are not considered a part of
the lead plan.
(Sections 110 and 301(a) of the Clean Air Act as amended (42 USC 7410,
7601))
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ENVIRONMENTAL PROTECTION AGENCY
[40 CFR Part 51]
IMPLEMENTATION PLANS FOR LEAD NATIONAL
AMBIENT AIR QUALITY STANDARD
Proposed Requirements for Ambient Air Quality
Monitoring in the Vicinity of Certain Lead Point Sources
Advance Notice of Proposed Rulemaking
AGENCY: Environmental Protection Agency.
ACTION: Advance notice of proposed rulemaking.
SUMMARY: This is an advance notice of EPA's intent to propose regulations
that would require the State implementation plans (SIPs) for attainment
and maintenance of the national ambient air quality standard (NAAQS) for
lead to provide for the owner or operator of each primary or secondary
lead smelter or primary copper smelter to establish a lead air quality
monitoring system in the vicinity of the source and report the data to
the State. EPA intends to propose this requirement partly in response
to a comment received on the proposed lead implementation plan requirements
of December 14, 1977 (42 FR 62087), but mainly as the initiation of a
procedure for obtaining information concerning the nature, extent, and
impact of fugitive lead emissions from the smelters, since very little
accurate information is currently available. The intended effect of
this requirement would be to obtain sufficient air quality data around
the subject sources to determine if they are causing violations of the
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lead NAAQS. If violations are recorded, the States and EPA will determine
whether additional or alternative control strategies would be adequate
to attain and maintain the NAAQS for lead.
DATES: Comments on this advance notice must be received on or before:
[the date sixty days after publication]. Comments submitted in duplicate
will facilitate internal distribution and public availability.
ADDRESSES: Persons may submit written comments on this advance notice
to: U.S. Environmental Protection Agency, Office of Air Quality Planning
and Standards, Control Programs Development Division (MD 15), Research
Triangle Park, N.C. 27711, Attention: Mr. Joseph Sableski.
EPA will make all comments received on or before [the date sixty
days after publication] available for public inspection during normal
business hours at: EPA Public Information Reference Unit, 401 M Street,
S.W., Room 2922, Washington, D.C. 20460.
FOR FURTHER INFORMATION CONTACT: Mr. John Silvasi, U.S. Environmental
Protection Agency, Office of Air Quality Planning and Standards, Control
Programs Development Division (MD 15), Research Triangle Park, N.C. 27711,
telephone: Commercial—919-541-5437; RS—629-5437.
SUPPLEMENTARY INFORMATION:
BACKGROUND
In another part of this FEDERAL REGISTER, EPA promulgated the
national ambient air quality standards (NAAQSs) for lead and requirements
for the preparation, adoption, and submission of State implementation
plans (SIPs) for the attainment and maintenance of those standards.
Further information about the standards and the SIPs appears in those
notices.
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States must now prepare and submit to EPA within nine months SIPs
that demonstrate that the NAAQSs will be attained. In doing so, the
States will have to quantify the lead emissions from sources and determine
the effect of those emissions on the ambient air concentrations. For
emissions that originate from stacks or tailpipes, the quantification
can be done with a fair degree of accuracy. For emissions that originate
from other than a primary exhaust system, such as through a plant's
doors, windows, leaks in equipment, and so forth, the quantification is
far more difficult. Such emissions are commonly called fugitive emissions.
Fugitive emissions are difficult to quantify accurately since they are
dependent on a wide range of site-specific parameters, such as the lead
content of the raw materials used in the process; number and size of
open windows, doors and vents; wind speed and direction; rainfall; and
so on—factors other than process throughput or production rates.
Furthermore, there has not been much lead air quality data gathered
around sources of these fugitive emissions. Also, there have never been
any specific requirements in the regulations that apply to SIPs for
requiring such data to be collected around individual sources. Conse-
quently, there is little accurate information concerning the amounts of
fugitive emissions and the ambient air lead levels in the vicinity of
sources of large amounts of lead emissions. EPA's assessments of the
1 p
environmental and economic impacts of the lead NAAQSs ' indicate that
several categories of sources that emit predominantly fugitive lead
emissions have the potential for the greatest air quality impacts. The
categories of concern are primary and secondary lead smelters and primary
copper smelters.
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NATURE OF PROPOSAL
EPA intends to propose regulations to enable the States and EPA to
obtain an air quality data base needed to determine compliance with the
NAAQSs around sources in the above-mentioned categories. The regulation
would require the subject sources to establish and operate an air quality
monitoring system in the vicinity of the sources. If the ambient data
reveals that concentrations are not as high as had originally been
predicted when the State developed its initial lead SIP, and the source
has not yet implemented the control called for in that SIP, the State
may wish to revise its SIP to require less stringent control, thereby
requiring a lesser burden on the source. Conversely, if the ambient
data reveals that concentrations greater than the NAAQS occur after the
control strategy in the SIP has been implemented, EPA could require the
State to revise the SIP to require additional control of the sources.
The regulations would require that the method for sample collection
be the reference method as defined in 40 CFR Part 50; this method is the
high-volume sampler. No other collection methods would be allowed for
monitoring in the vicinity of point sources, since it appears that other
samplers would not sample the same quantity of larger particles that the
high-volume sampler would collect. The analysis method could be the
reference method or an equivalent method as defined in 40 CFR Part 50.
The sources would also have to obtain certain meteorological data to
properly locate the samplers.
EPA intends to restrict this requirement only to primary and second-
ary lead smelters and primary copper smelters because EPA modeling
2
studies of the six major lead point source categories (the other three
being gasoline additive plants, lead-acid battery manufacturing plants,
-------
and gray iron foundries) indicate that these three categories have a
potential for an air quality iupact that far exceeds that of the sources
in the other categories.
EPA would require the States to place the requirement for monitoring
directly on the source owners and operators, using the authority of
S 114(a)(l)(C) of the Clean Air Act. This section authorizes the Adminis-
trator to require any source subject to a requirement of the Act to ". . .
install, use, and maintain such monitoring equipment or methods. . ."
The implementation plan would have to require the source owners or
operators to periodically report a summary of the data to the States and
EPA. The data would then be used to determine whether a future plan
revision is indicated.
The amount of ambient point source monitoring needed would vary and
depend on the number of emission points at the source, the emission
patterns, the topography, and the meteorology. EPA will develop a
guidance manual on the number, siting, and operation of monitors around
point sources. EPA estimates that the guidance will recommend that a
network of about five samplers be placed in the vicinity of each source
to which the regulation applies. States would have nine months after
the promulgation of this requirement to revise their lead implementation
plans to require the monitoring around the selected point sources. The
sampling network would then have to be in place within one year after
the date required for submission of the plan revision to account for
this requirement if sufficient meteorological data were available for
use in siting the monitors. If the meteorological data were not available,
the source may have to collect a year's worth of data before siting the
air quality monitors.
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EPA solicits comments on any issues concerning the intended proposed
rulemaking and particularly solicits comments on the following topics:
--The need for the requirement for ambient monitoring in the vicinity
of the lead point sources mentioned above or alternatives to this require-
ment that will accomplish the objective of obtaining more accurate data
concerning these sources.
--Other sources around which EPA should require ambient monitoring.
--The criteria for the number, operation, and location of the
samplers.
--The criteria for the length of period of each sample, sampling
frequency, and duration of the existence of the sampling system.
--Procedures for accounting for other sources in the vicinity of
the source, including roadways.
—Procedures for accounting for complex topography.
—Procedures for accounting for meteorological conditions and
obtaining meteorological data.
—Procedures for accounting for the nature and magnitude of fugitive
emissions.
—Procedures for accounting for background concentrations.
—Procedures for accounting for source configuration.
—Procedures for reporting the collected data to the State and EPA.
--The time allowed for revision of the State implementation plan to
account for the requirement.
-------
--Time allowed for compliance with the requirement contained in the
implementation plan.
--Whether the burden of responsibility should lie with the State
agency or with the source.
--The cost to the States or the sources for compliance with these
requirements.
EPA intends to propose rulemaking on this matter by December, 1978,
and intends to make available for public review at the same time a draft
of the detailed guidance on ambient lead monitoring in the vicinity of
lead point sources.
FUGITIVE EMISSION FACTORS
Also, EPA intends to develop more accurate emission factors that
relate the operation of a source to the amount of fugitive emissions the
source generates. These factors will not be available, however, until
some time after the States must submit their implementation plans.
Therefore, the States will have to rely on available fugitive emission
factors to perform their air quality analyses in support of their imple-
mentation plans or develop their own factors based on any data that may
be available, such as emission factors for total particulate matter and
information concerning the lead content of that particulate matter.
Alternatively, States could develop their own emission factors
based on field studies. There are several methods for doing this. '
After EPA develops emission factors for fugitive lead emissions,
States could then determine whether their initially developed plans
require too much or too little control; they could then make any necessary
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adjustments to their implementation plans through revisions of those
plans. The initial plan could require that sources phase in their
control fairly slowly so that significant resources are not expended by
the sources before EPA develops its fugitive emission factors.
REFERENCES
1. National Ambient Air Quality Standard for Lead: Final Draft:
Environmental Impact Statement. U.S. Environmental Protection
Agency, Office of Air and Waste Management, Office of Air Quality
Planning and Standards, Research Triangle Park, N.C. July, 1978.
2. Economic Impact Assessment for the National Ambient Air Quality
Standard for Lead and the Economic Implications of a Quarterly
Mean Averaging Time for the Lead National Ambient Air Quality
Standard. U.S. Environmental Protection Agency, Office of Air
and Waste Management, Office of Air Quality Planning and
Standards, Research Triangle Park, N.C. June, 1978.
3. Technical Manual for the Measurement of Fugitive Emissions:
Upwind-Downwind Sampling Method for Industrial Fugitive Emissions.
U.S. Environmental Protection Agency, Industrial and Environmental
Research Laboratory, Research Triangle Park, N.C. April, 1976.
Publication No. EPA-600/2-76-H89a.
4. Technical Manual for the Measurement of Fugitive Emissions:
Roof Monitor Sampling Method for Industrial Fugitive Emissions.
U.S. Environmental Protection Agency, Industrial and Environmental
Research Laboratory, Research Triangle Park, N.C. May, 1976.
Publication No. EPA-600/2-76-089b.
5. Technical Manual for Measurement of Fugitive Emissions:
Quasi-Stack Sampling Method for Industrial Fugitive Emissions.
U.S. Environmental Protection Agency, Industrial and Environ-
mental Research Laboratory, Research Triangle Park, N.C.
May, 1976. Publication No. EPA-600/2-76-089c.
(Sections 110, 114(a)(l), and 301(a) of the Clean Air Act as
amended (42 USC 7410, 7417, and 7601)).
Date Administrator
8
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