20363 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DATE: July 27, 1978
SUBJECT: National Ambient Air Quality Standards
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PROM: (J. Edward Rcush, Director
Office of Regional & Intergovernmental Operations
T0: All Regional Administrators
Attached for your raview is the National Ambient Air Quality
Standard (Red Border Clearance). Please raview this package and
provide me with your comments by C.O.B. August 11, 1978. If you
have any questions concerning the attached package, please contact
Marvin Fast on 755-0444.
Attachment
EPA FORM 1320-6 IREV. 3-76>
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D C. 20460
OFFICE OF
AIR AND WASTE MANAGEMENT
SUBJECT: National Ambient Air Quality Standard and State Implementation
Plan Regulations for Lead—ACTION MEMORANDUM
FROM : David G. Hawkins, Assistant Administrator
for Air, Noise, and Radiation
MEMO TO: Administrator (A-100)
THRU : AX (A101)
I. PURPOSE
This memorandum forwards for the approval of the Administrator the
final National Ambient Air Quality Standard and State Implementation
Plan Regulations for lead. Signature of these materials will promulgate
the standard and begin the schedule for attainment set by the Clean Air
Act. States will have nine months to submit implementation plans demon-
strating attainment of the standard. EPA will then have four months to
approve or reject the State Implementation Plans. The standard must be
attained as soon as practicable, and no later than three years after
plan approval unless a two year extension is granted. Included with the
standard and regulations are the final Federal Reference Method for
lead, proposed regulations for establishing equivalent lead monitoring
methods, and an advance notice of proposed rulemakircg for ambient moni-
toring near lead point sources.
II. BACKGROUND
As a result of litigation, NRDC. Inc.. et al_. y. Train. 411FSupp.
864 (S.D. N.Y., 1976), aff'd 545 F7Zd~ 3ZOT2nHl:ir. T976), lead was
listed as a criteria pollutant under Section 108 of the Clean Air Act on
March 31, 1976. Section 109 of the Act instructs EPA to set an ambient
air quality standard for each criteria pollutant:
"The attainment and maintenance of which in the judgment
of the Administrator based on such criteria and allowing for
adequate margin of safety are requisite to protect the public
health."
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The air quality criteria for lead, the control techniques document, the
proposed standard, and the proposed regulations for State Implementation
Plans were issued on December 14, 1977.
The proposed standard was 1.5 nricrograms lead per cubic meter
(1.5 u9 Pb/m3), monthly average. This was based on the view that young
children are particularly sensitive to lead, and that the lead induced
impairment of the biosynthesis of heme in cells—indicated by elevation
of erythrocyte protoporphyrin (EP) —is adverse to health.
For the final standard, OANR is recommending a level of 1.5 yg Pb/m3,
calendar quarter average. The final preamble and standard are attached
under Tab A, and the final preamble and regulations for State Implementa-
tion Plans are attached under Tab B. The final page of this memo provides
a full listing of the attached tabs.
III. SUMMARY OF SIGNIFICANT COMMENTS
A. Proposed Standard
OANR received comments on the proposed standard and regulations
from 81 individuals and organizations. All comments opposing the proposed
level of the standard (25) as excessively stringent came from industry
representatives. Extensive comments came from: the Lead Industries
Association; ASARCO, DuPont, Ethyl, and St. Joe Minerals. Sixteen of the
comments received from industry representatives counterproposed a 5 ng/m3
90-day standard.
Comments supporting the proposal or advocating a lower level (20)
came from the medical community, Federal agencies, state agencies, and
public interest groups. Endorsement of the proposed standard came from
the Center for Disease Control/Public Health Service, the Occupational
Health and Safety Administration, the Food and Drug Administration, the
American Academy of Pediatrics, and state health or environmental agencies
in California, Massachusetts, New York, Tennessee, and Wisconsin. A
summary of comments received opposing and supporting the proposal are
attached under Tab C.
No comments were received on three elements of the proposed
rationale:
1. The structure of the rationale used to derive the proposed
standard.
2. The selection of children as the sensitive population.
3. The adoption of a blood lead level of 12 ug Pb/dl as an
estimate of non-air contribution of blood lead levels.
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Comments received did address:
1. The health significance of EP elevation.
2. The blood lead threshold level for adverse effects.
3. The relationship between air lead and blood lead.
4. The contribution of air emissions to blood lead, EP elevation,
and health effects in the vicinity of smelters.
5. The need for a respirable particulate standard.
A summary of the significant comments received is attached under
Tab D, and a summary and comparison of the rationales for the proposed
and final standards is presented under Tab E.
B. Proposed State Implementation Plan Requirements
Tab B contains the Federal Register preamble and final rulemaking
that revises the implementation plan requirements of 40 CFR Part 51 to
account for the national ambient air quality standard for lead. The
requirements differ only slightly from those proposed; changes were made
either for clarification or to reflect the change in the averaging time
of the standard. The preamble contains a discussion of the significant
comments received on the proposed SIP regulations.
OANR intends to propose a requirement that the State implementation
plans for lead contain provisions for owners and operators of primary and
seconday lead smelters to monitor air quality in the vicinity of their
plants. This requirement was not proposed previously, and OANR has not
yet developed criteria for placement of air quality monitors in the
vicinity of point sources. Because this requirement will result in expen-
ditures by the owners and operations of point sources of lead particulate
emissions, OANR is giving advance notice of the proposal of this require-
ment.
C. Economic Impact Assessment
Comments on the EPA draft Economic Impact Assessment forecast more
severe impacts on the industries affected, but. did not include data which
would allow OANR to confirm the more severe estimate. The EIA has been
revised to take into account a quarterly averaging period.
IV. ISSUES
OANR sees a number of issues associated with the decision on the final
standard and SIP regulations. These can be divided into three areas:
estimating the safe level for children's blood lead; estimating the
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relative contribution to blood lead from air and non-air sources of lead;
and, assessing the economic impacts of the standard and the attainment
program. The principal issues in these areas are discussed below.
A. Estimating the Safe Blood Lead Level for Children
Because of the multiple routes and sources of environmental lead,
the air standard is derived in two stages. First, OANR has estimated the
blood lead level in children which can be regarded as the maximum safe
goal for total exposure to lead. Second, OANR has made judgments as to
the extent that sources of lead unrelated to air pollution should be taken
into account in calculating the maximum safe contribution from exposure
to air lead.
For the final standard OANR's judgment of the maximum safe blood
lead level from all sources is based on two factors:
1. Estimating the maximum safe blood lead level for an individual
child, and,
2. Determining where the blood lead level for a group of children
should be in order to maintain most children below the maximum
level for individuals.
ISSUE: In determining the maximum safe blood lead level, should the
standard'be based on a subclinical effect (elevated EP) rather than a
clinical effect (anemia)?
In the proposed standard, EPA took the position that the impariment
of heme synthesis indicated by elevated EP was an adverse health effect.
The criteria document reported the threshold for EP elevation in children
at 15-20 jig Pb/dl, and the proposed standard was developed from data
showing a correlation between EP elevation and blood lead as low as
15 ug Pb/dl. In the comments received, this position was challenged with
the following arguments: (1) there was no evidence linking the effect
with disease or impaired performance; (2) hemoglobin levels were not
affected; and (3) there was not evidence that the levels or functions of
other heme proteins were affected. Commentors supporting the proposed
standard argued that: (1) the impairment of heme synthesis due to lead
as indicated by elevated EP is adverse to health, in the same sense that
other indicators, such as blood pressure or changes in liver chemistry
indicate an abnormal state, (2) the vital nature of heme synthesis in the
function of hemoglobin and other herae proteins, (3) the apparent ability
of lead to alter the structure and processes of the intracellular
mitochondria; (4) the adverse effects of accumulating intermediate products
in the heme synthesis pathway; and (5) the need to manage subclinical
effects short of disease state as an established and prudent practice
of preventive medicine.
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From review of these points, OANR concludes that lead's interference
with heme synthesis to the extent that there is an accumulation of the
final substrate, protoporphyrin, is of sufficient medical concern that
public health measures should be designed to avoid this state as a chronic
condition in children. OANR also recognizes that the health significance
of the effect increases progressively from the point where it can just be
detected. OANR does not believe that there is sufficient information to
conclude that this effect is adverse to health at the threshold for
detection. In the preamble, OANR adopts 30 ug Pb/dl as the best available
estimate of the safe maximum blood lead level for individual children.
This is in accord with the guidelines established by the Center for Disease
Control of the Public Health Service in consultation with the American
Academy of Pediatrics.
The criteria document reports that clinically observable symptoms
of anemia can be detected above 40 u9 Pb/dl, and several commenters
advocated that this level be adopted as the maximum safe blood lead level
in an individual child. OANR cannot agree that the air standard should
be based on an individual maximum safe blood lead goal which is at the
threshold for clinical anemia.
ISSUE: What percentage of children should the standard protect?
From actual measured data, the air quality criteria report that
there is an individual variation of blood lead in a population with
uniform lead exposure. This variation is consistent for different
groups and different exposure levels. Because of this individual varia-
tion, a population whose average blood lead level is 30 ug Pb/dl will
have 50 percent of its members above the safe level. Because the
variation of individual blood lead levels within a group are log normally
distributed, the target geometric mean which will place a given percentage
of the population below a particular level can be calculated from the
standard, geometric deviation of that population. OANR has calculated
that a geometric mean blood lead of 15 ug Pb/dl would place 99.5-99.9
percent of children below the threshold of 30 »g Pb/dl. OAWM believes
that this percentage range is appropriate in view of the large size of
the sensitive population. In the United States in 1970 about 12 million
children under five years of age lived in urban areas. Approximately five
million of these lived in central city areas.
Alternative standards based on other judgments about the maximum
safe blood lead and percentages of children protected are presented
under Tab F.
B. Estimating Non-Air Contributions to Population Blood Lead
In the preamble to the proposed standard, EPA argued that an air
standard which did not consider the possible contribution to blood lead
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from other sources would not be protective of the population. This was
not challenged by the comments responding to the proposal. Based on
studies of blood lead levels where air lead levels were very low and
upon other clinical studies showing the rough proportion of blood lead
derived from air sources, OANR has estimated that 12 ug Pb/dl of the
allowable geometric mean population blood lead of 15 ug Pb/dl would be
derived from non-air sources.
ISSUE: Is 12 ug Pb/dl EPA's best estimate of non-air contribution to
blood lead?
While there is fairly good information linking the change in blood
lead level to air lead level, it is difficult to determine contribution
to blood lead from typical exposure to lead in water, lead in food, and
lead ingested in non-food items. The situation is further complicated
by the deposition of lead from the air which then moves through other
media to an exposure situation. NRDC has argued that almost all lead
in inner city children is ultimately derived from lead in gasoline and
that the ambient level of 1.5 yg/m3 will not protect young children. On
the other hand, in a study performed by EPA's Drinking Water Program,
MITRE Corporation has attempted to estimate the relative contribution
of various media to blood lead levels by calculating daily intake and
absorption factors. Their results predict that less than 1 percent of
lead in the blood derives from air lead. OANR believes that, on balance,
the weight of information available does not favor either of these
extreme views. Epidemiclogical and clinical studies reported in the
Criteria Document suggest that blood leads do change with air lead levels,
but that the lead content in food'and beverages can be significant.
Without new information, OANR has retained its belief that a 12 yg Pb/dl
level based both on scientific and policy considerations, is the best
available projection of non-air contribution to blood lead, and the
extent to which the air program can attempt to control total exposure.
C. Economic Impacts and Possible Non-Attainment of Point Sources
of Lead Emissions
In the Economic Impact Assessment, OANR estimates that attainment
of the national ambient air quality standard for lead may cause severe
localized economic impacts—including possible plant shutdown, for primary
and secondary lead smelters and primary copper smelters. The data upon
which this conclusion is based are of limited accuracy due to the diffi-
culties in estimating emission factors for fugitive lead particulate.
The severity of the actual impact may differ from that estimated. The
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final Economic Impact Assessment and an addendum addressing cost differ-
ences resulting from the change from a monthly to quarterly averaging
period are attached under Tab J.
ISSUE: How can EPA minimize the economic impact of the standard while
complying with Section 109 of the Act?
From the Act's requirement that the standard be based on health
criteria, OANR concludes that the level of the standard cannot be adjusted
to ease the economic impact on smelters.
OANR notes, however, that the forthcoming lead standard is only
one of a number of regulatory impacts on the non-ferrous smelters including
regulations from Water Programs and OSHA. Other EPA air regulatory
impacts include revisions of current State implementation plans for
fugitive particulate matter and sulfur oxide emissions, regulations for
designated pollutants under S lll(d) of the Act, and possible National
Emission Standards for Hazardous Air Pollutants under S 112 of the Act
for emissions of arsenic. Non-ferrous smelters face compliance difficulties
even without a lead standard.
OANR has looked at a number of ideas for lessening the economic
impact of the lead ambient air standard, and concludes that there are no
options under the Act for totally alleviating the impacts on stationary
sources of lead emissions. A discussion of the non-attainment problem
is attached under Tab G.
OANR envisions the following scenario for dealing with possible
point source non-attainment:
A. The States would be required to develop their SIPs under a
traditional approach. That is, they would have to
(1) analyze the air quality impact of all primary and secondary lead
smelters and primary copper smelters (among other source categories)
based upon available data and emission factors, (2) develop and evaluate
control strategies where needed, (3) select a control strategy that is
adequate on paper to attain and maintain the lead standard, and (4)
submit the plan to EPA. States will request two-year extensions of the
attainment dates under S 110(e) of the Act as needed.
B. In cooperation with EPA regions, State agencies, and affected
plants, OAQPS will act to improve data on critical point sources (non-
ferrous smelters) to the extent possible in the SIP development review.
C. Sources will request extensions of compliance dates under S
113(d) of the Act.
D. OAQPS will provide guidance to the States on the applicability
of land acquisitions as an acceptable control strategy.
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E. OAQPS will re-assess economic impacts of the attainment program
at the"time of SIP review, and inform all interested groups about the
results of this projection and what ameliorative steps EPA can take
under the Act. This will include discussions with members of Congress,
the executive branch, and affected industries.
F. OAQPS is issuing an advance notice of proposed rulemaking on a
requirement for air quality monitoring in the vicinity of primary and
secondary lead smelters, and primary copper smelters. This will initiate
a program for obtaining the air quality data that is essential to both a
better definition of the problem and the determination of the effect of
control measures.
G. OAQPS will request ORD to obtain more representative information
UN fugitive lead emissions and will also make available reports that
describe several techniques for estimating fugitive lead emissions.
H. OAQPS will request 0PM to undertake a study of the impact of
EPA regulations on the primary non-ferrous smelters. The study would
investigate which smelters will have difficulty meeting the various
environmental regulations, the magnitude of the nonattainment problem,
the area of impact around the sources, the cost of control, and the
various options available for alleviation of severe economic impacts.
V. AVERAGING PERIOD FOR THE STANDARD
OANR recommends that the averaging period for the standard be
lengthened from a calendar month to a calendar quarter (approximately 90
days). This change will improve the validity of the lead air quality
data gathered to monitor attainment without requiring additional monitoring
by state and local agencies, or significantly reducing the protectiveness
of the final standard.
With current practice of operating hi-vol TSP samplers on every
sixth day, the use of a monthly period to average lead values can result
in too few observations to be statistically valid. In most months, only
four or five samples would be taken, and it is possible that one or more
of these might be omitted as invalid. The resulting averages could vary
widely and the small number of observations would increase the error
introduced by a single uncharacteristic value. Increasing the frequency
of sampling would improve the quality of the average, but this alternative
is costly for state and local agencies charged with monitoring responsi-
bilities. The quarterly mean provides a larger number of values, and a
more accurate representation of average air quality.
The key criterion for the averaging period is the protection of
health of the sensitive population. In proposing the 1.5ug/m standard,
OANR concluded that this air level was safe for indefinite exposure of
young children. Critical to the determination of the averaging period
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is the health significance of possible evaluations of air lead above 1.5
ng/rn3 which could be encountered without violation of the standard. In the
proposed standard, OANR chose a monthly averaging period on the basis of
a study (Griffin 1975) showing an adjustment period of blood lead level
with a change of exposure. Because of the scientific and technical
difficulties of the monthly standard, QANR has re-examined this question
and concludes that there is little reason to expect that the slightly
greater possibility of elevated air lead levels sustainable by the
quarterly standard is significant for health.. This conclusion is based
on the following factors.
(1) from actual ambient measures there is evidence that the
distribution of air lead levels is such that there is little possibility
that there could be sustained periods greatly above the average value.
(2) while it is difficult to relate the extent to which a monitoring
network actually represents the exposure situation for young children,
it seems likely that where elevated air lead levels do occur, they will
be close to point or mobile sources. Typically, young children will not
encounter such levels for the full twenty-four hour period reported by
the monitor.
(3) there is medical evidence indicating that blood lead levels
re-equilibrate slowly to changes in air exposure which serves to dampen
the impact of a short-term period of exposure to elevated air lead.
(4) since direct exposure to air is only one of several routes of
total exposure, a change in air lead would not impact proportionately on
blood lead levels.
On balance, the Agency concludes that a requirement for the averaging
of air quality data over calendar quarter will improve the validity of
air quality data gathered without a significant reduction of the protectiveness
of the standard.
VI. IMPLICATIONS FOR OTHER CONTROL PROGRAMS
OANR has coordinated the development of the lead air standard
with other regulatory programs of EPA, and with FDA, OSHA, and CPSC.
This coordination has included discussion of the health basis for regulatory
standards, as well as the contribution of various media to total exposure.
EPA's drinking water program expressed concern about the adoption of a
population blood lead target of 15 Mg Pb/dl, and the basis for allocating
total population exposure to lead between air, water, and other media.
The water program agrees, however, that 30y g Pb/dl is an appropriate
goal for the maximum safe blood lead level of individual children, and
that the air program is within its discretion in calculating the percentage
of children to be protected by an air standard based on this goal.
Similarly, while the water program is uncertain as to the appropriate
allocation of lead exposure to non-air sources, it is recognized that
such an estimate must be made, and that OANR is making a policy judgment
as well as an estimate from the available scientific data.
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The promulgation of this standard will occur just before the OSHA's
final rulemaking for air lead in the workplace. Both standards will
impact non-ferrous smelters. Costs for these facilities estimated by
OSHA in its draft environmental impact statement were factored into the
EPA economic impact assessment. OANR is discussing with OSHA ways to
coordinate the compliance phase of these regulations, to the extent
possible under the Agency's separate legislative responsibilities.
Summaries of comments on the proposed standard from other Federal
programs are attached under Tab H.
VII. SECONDARY AMBIENT AIR QUALITY STANDARD
OANR has concluded that the secondary ambient air quality standard
for lead should be at the same level as the primary standard. This is
because (1) plants and animals do not appear to be more sensitive to
lead than man; (2) effects of airborne lead on visibility and climate
are minimal; and (3) significant damage of man-made materials resulting
from lead concentrations has not been documented. No comments were
received on the secondary standard.
VIII. ENVIRONMENTAL IMPACTS
The principal environmental impact of setting the lead standard
will be the reduction of airborne levels of lead and reversal over time
of the present trend of accumulation of lead in natural ecosystems,
principally soil and sediments. Reduction of lead emissions will also ,
result in reduction of emissions of particulate matter and other metals
at sources requiring control. The final environmental impact statement
for the standard is under Tab I.
IX. ECONOMIC AND ENERGY IMPACT
Economic impacts will -result primarily from control of lead emissions
from primary lead and copper smelters, secondary lead smelters, grey
iron foundries, gasoline lead additive manufacturers, and lead acid
storage battery manufacturers. Plant closures are possible in the
primary copper and lead industry and the secondary lead industry.
Comments on the Economic Impact Assessment forecast more severe
impacts within these industries than did the ETA. Because the comments
do not include data which would allow OANR to confirm the allegations of
more severe impact, the EIA has not been revised.
Changing the averaging time of the lead standard from a monthly
mean to a quarterly mean lowers estimated investment costs by 15 percent
and annualized costs by 14 percent. This is due primarily to lower
control requirements for the grey iron foundry casting, primary copper
smelting, and primary lead smelting industries. Although control requirements
are also reduced for the secondary lead smelting, gasoline lead additive
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manufacturing, and lead-acid battery manufactuing industries, control
costs are not noticeably reduced.
Estimated investment costs which may be incurred by affected 3
industries to attain the-recommended air lead standard of 1.5 yg Pb/m ,
quarterly averaging period are:
Table 1. NATIONAL CONTROL COST ESTIMATES FOR STATIONARY SOURCES
(1976 dollars, in millions)
1>5 uQ/m Quarterly Avg.
Industry Invest. Annual Cost **
Primary Lead Smelting 30* 7*
Secondary Lead
Smelting 99* 22*
Primary Copper
Smelting 235 51
Grey Iron Foundry
Casting 148 31
Gasoline Lead Additives 3 2
Lead Acid Batteris 13 6
TOTAL 530 120
*BACT is costed where necessary but may not be sufficient for this
standard to be met at, al 1 pi ants.
**Annualized investment plus operating and maintenance cost.
Besides lowering control costs, the quarterly averaging period
reduces the number of sources which have to install controls. This is
especially true for grey iron foundries.
The phased reduction of lead in gasoline and the continued increase
in the use of unleaded gasoline will result in sufficient reductions in
lead emissions from mobile sources for achievement of the standard in
most areas by the 1982 attainment data. For remaining problem areas,
little or no control of mobile source lead emissions may be needed if
EPA grants a two-year extension for attainment as provided for in the
Clean Air Act.
It is estimated that at least sixteen air quality control regions
will not attain the lead standard by 1982 without stationary source
emission controls for primary lead and copper smelters and gasoline lead
additive plants. Dependfng on the lead emissions from other stationary
sources and the extent to which individual plants are already controlled,
other air quality control regions may not attain the standard by 1982.
The final Economic Impact Assessment is attached under Tab J.
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X. STATE AND REGIONAL RESOURCE REQUIREMENTS
OANR estimates state and local control agencies' costs to be
$1.0 to $1.7 million for development and implementation of control
strategies during the first year, and ongoing costs of $1.4 to $2.8
million annually. The ongoing costs represent 1 to 2 percent of cur-
rent state and local air agency expenditures.
OANR estimates that EPA Regional Offices may incur costs of
$100,000 to $500,000 to aid states in developing state implementation
plans, to approve such plans, and provide technical assistance where
necessary. Yearly costs after development of implementation plans may
range from $100,000 to $300,000.
A more detailed table of the resources impact of the standard
on State programs, summarized by region, is attached under Tab J.
XI. PUBLIC PARTICIPATION
There has been extensive external review, comment, and participa-
tion in the development of this standard. In the development of the Air
Quality Criteria Document by ORD, three drafts of the criteria document
were circulated for external review, 165 written comments were received
on the final draft. The criteria document was written with extensive
input from experts and consultants from outside the Agency. The criteria
document was reviewed at three public meetings of the lead subcommittee
of the Science Adv,isory Board. OANR development of the proposed standard
involved external participation. In March, 1977, before initial drafting,
a workshop of industry representatives, environmentalists, state agency
officials and others was convened at Research Triangle Park, N.C. OANR
held a pre-proposal public meeting in Washington in April, 1977.
Following proposal of the standard in December, 1977, OANR held a public
hearing in February, 1978 to receive comments. Eighty-one written comments
have been received along with a number of Congressional and executive
branch correspondence referrals. A summary of comments received and
their disposition by the Agency is attached under Tab D. A review of
each significant comment has been placed in the rulemaking docket
(OAQPS 77-1).
XII. ANTICIPATED REACTIONS
Based on the comments received, OANR anticipates the following
reactions:
A. Industry representatives will continue to hold that the standard
is excessively stringent, questioning the health significance of a
subclinical effect, the relative importance of air pollution to blood
lead levels, and the importance of considering economic consequences
when making judgments about the standard. Those most seriously affected,
lead primary and secondary smelters, battery plants, and copper smelters
may initiate litigation, individually or through representative insti-
tutions such as the Lead Industries Association.
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B. Most Federal and State public health agencies, much of the
medical community, and environmental groups will support the standard,
particularly in light of recent media attention to possible neurological/
behavioral implications of low level chronic lead exposure and environ-
mental contamination of soil with lead.
C. NRDC and others in the New York area will respond that the
standard is not sufficiently stringent because New York children have
blood leads above safe levels even though measured air quality has been
near the standard. They may point out that the standard will not accelerate
lead phasedown in gasoline, and so will have little effect in urban areas
away from point sources. NRDC disagress with EPA's monitoring guidelines,
and may sue for more protective monitoring.
RECOMMENDATIONS
OANR recommends that you approve and sign the Federal Register
Rulemaking which amends 40 CFR Part 50 by adding an NAAQS for lead of
1.5 ug/m3, quarterly average (Signature Tab 1). OANR recommends that
you similarly approve and sign the Federal Register Rulemaking which
amends 40 CFR Part 51 by adding specific requirements for State Implemen-
tation Plans for lead (Signature Tab 2), the Notice of Proposed Rulemaking
under 40 CFR Parts 51 and 53 establishing equivalent monitoring methods
for lead (Signature Tab 3), and the Advance Notice of Proposed Rule-
making under 40 CFR Part 51 for the requirement of ambient monitoring
in the vicinity of certain lead point sources (Signature Tab 4).
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LIST OF TABS
A - Federal Register Preamble, Standard and Federal Reference Method
(Signature item)
B - Federal Register Preamble and Regulations for State Implementation
Plans (Signature item)
C - List of External Comments Opposing or Endorsing the Proposed Standard
0 - Summary of Significant Comments and Agency Disposition
E - Summary and Comparison of Rationales Underlying the Proposed and
Final Standard
F - Table of Alternative Standards
G - Options for Dealing with Point Source Economic Impacts and Attainment
Difficulties
H - Comments from Other Federal Regulatory Programs for Lead
I - Final Draft Environmental Impact Statement
,J - Final Draft Economic Impact Assessment
K - Equivalency Regulation (Signature item)
L - Advance Notice of Proposed Rulemaking—requirements for ambient
monitoring in the vicinity of certain lead point sources (Signature
item)
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TAB A- Federal Regester Preamble, Standard and Federal Reference
Method (Signature item)
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From promulgation, States will have nine months to prepare and submit
to EPA plans demonstrating attainment of the standard by no later than
September of 1982. Final regulations for the development of the State
Implementation Plans appear elsewhere in this Federal Register.
FOR FURTHER INFORMATION CONTACT:
Mr. Joseph Padgett, Director
Strategies and Air Standards Division
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency, RTP, N.C. 27711
Telephone: 919-541-5204
AVAILABILITY OF RELATED INFORMATION: A docket (Number OAQPS-77-1) containing
the information used by EPA in the development of the proposed standard is
available for public inspection and copying between 8:00 a.m. and 4:30 p.m.
Monday through Friday, at EPA's Public Information and Reference Unit, Room 2922,
Waterside Mall, 401 M Street SW, Washington, D. C. 20460.
The Federal Reference Method for collecting and measuring lead and its
compounds in the ambient air is published in Appendix G to this promulgation.
This Federal Register also contains proposed regulations under 40 CFR Parts 51
and 53 for equivalent lead air monitoring methods, final rules for the develop-
ment of State Implementation Plans promulgated under 40 CFR Part 51, and an ad-
vance- notice of proposed rulemaking under 40 CFR Part 51 for ambient monitoring
in the vicinity of certain lead point sources. Additional information on the
development of the plans is contained in the document Supplementary Guidelines
for Lead Implementation Plans. The environmental and economic impact of
implementing this standard are described in an Environmental Impact Statement
and an Economic Impact Assessment. These documents are available for public
inspection and copying at the Public Information and Reference Unit (address
above). Copies may be obtained upon request from Mr. Joseph Padgett at the
above address.
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TITLE 40 - PROTECTION OF ENVIRONMENT
CHAPTER 1 - ENVIRONMENTAL PROTECTION AGENCY
SUBCHAPTER C - AIR PROGRAMS
PART 50 - NATIONAL PRIMARY AND SECONDARY AMBIENT AIR QUALITY STANDARDS
NATIONAL PRIMARY AND SECONDARY AMBIENT AIR QUALITY STANDARDS FOR LEAD
AGENCY: Environmental Protection Agency
ACTION: Final Rulemaking.
SUMMARY: EPA is setting a National Ambient Air Quality Standard for lead
at a level of 1.5 ug Pb/m3, averaged over a calendar quarter. This final
rulemaking follows a 1976 court order to list lead as a criteria pollutant
for the development of an ambient standard, and the Agency's issuance of a pro-
posed standard on December 14, 1977. In response to comments received on
the proposed standard, EPA has changed the averaging period for the standard
from a calendar month to a calendar quarter, and has clarified the health
basis used in selecting the standard level.
In establishing the level of the final standard, EPA has determined
that young children (age 1-5 years) should be regarded as a group within
the general population that is particularly sensitive to lead exposure,
The final standard for lead in air is based on a goal of preventing most
children in the United States from exceeding a blood lead level of 30 ug Pb/dl
Blood lead levels above 30 ug Pb/dl are associated with the alteration of
certain biochemical processes within the cell, including the impairment of
heme synthesis indicated by elevated erythrocyte protoporphyrin, which EPA
regards as adverse to the health of chronically exposed children. There
are a number of other adverse health effects in children and the general
population associated with blood lead levels above 30 yg Pb/dl, including the
possibility that some type of neural damage may exist in children without
overt symptoms of lead poisoning.
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The documents Air Quality Criteria for Lead and Control Techniques for
Lead Air Emissions were issued at the time of proposal. Both documents
are available upon request from Mr. Joseph Padgett at the above address.
SUPPLEMENTARY INFORMATION:
BACKGROUND
Lead is emitted to the atmosphere by vehicles burning leaded fuel and by
certain stationary sources. Lead enters the human body through ingestion
and inhalation with consequent absorption into the blood stream and distri-
bution to all body tissues. Clinical, epidemiological, and toxicological
studies have demonstrated that exposure to lead adversely affects human health.
EPA's initial approach to controlling lead in the air was to limit the
lead emissions from automobiles, the principal source of lead air emissions.
Regulations for the phasedown of lead in the total gasoline pool were
promulgated in 1973, and, following litigation, modified and put into effect
in 1976. EPA has also established regulations requiring the availability of
no-lead gasoline for catalyst-equipped cars. EPA also intended to control "
emissions from certain categories of industrial point sources under Section 111
of the Clean Air Act.
In 1975, the Natural Resources Defense Council (NRDC) and others
brought suit against EPA to list lead under Section 108 of the Clean Air
Act as a pollutant for which air quality criteria would be developed and
a National Ambient Air Quality Standard established under Section 109 of
the Act. The Court ruled in favor of NRDC. NRDC, Inc. et al. v_. Train,
411 F.Supp. 864 (S.D.N.Y., 1976) aff'd 545 F.2d 320 (2nd Cir. 1976). EPA
listed lead on March 31, 1976, and proceeded to develop air quality criteria
and the standard.
On December 14, 1977, EPA proposed a standard of 1.5 ug Pb/m , calendar
month average .proposed the Federal Reference Method, issued the documents
Air Quality Criteria for Lead and Control Techniques for Lead Air Emissions
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and proposed regulations for State Implementation Plans. EPA invited
public comments during the period from December 14, 1977 to March 17, 1978
on the standard, reference method, and the SIP regulations. Additional
comments on these matters were provided to EPA at a public hearing held on
February 15-16, 1978.
LEGISLATIVE REQUIREMENTS FOR NATIONAL
AMBIENT AIR QUALITY STANDARDS
Sections 108 and 109 of the Clean Air Act govern the development of
National Ambient Air Quality Standards. Section 108 instructs EPA to
document the scientific basis for the standard:
"Sec. 108(a)(2)" The Administrator shall issue air quality criteria
for an air pollutant within 12 months after he has included such pollutant
in a list under paragraph (1). Air quality criteria for an air pollutant
shall accurately reflect the latest scientific knowledge useful in indicating
the kind and extent of all identifiable effects on public health or welfare
which may be expected from the presence of such pollutant in the ambient air,
in varying quantities. The criteria for an air pollutant, to the extent
practicable, shall include information on —
(A) those variable factors (including atmospheric conditions) which
of themselves or in combination with other factors may alter the effects
on public health or welfare of such air pollutant;
(B) the types of air pollutants which, when present in the
atmosphere, may interact with such pollutant to produce an adverse effect
on public health or welfare; and
(C) any known or anticipated adverse effects on welfare."
Section 109 addresses the actual setting of the standard:
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"Section 109(b)(l) National primary ambient air quality standards,
prescribed under subsection (a) shall be ambient air quality standards
the attainment and maintenance of which in the judgment of the Administrator,
based on such criteria and allowing an adequate margin of safety, are
requisite to protect the public health. Such primary standards may be revised
in the same manner as promulgated.
(2) Any national secondary ambient air quality standard prescribed,
under subsection (a) shall specify a level of air quality the attainment
and maintenance of which in the judgment of the Administrator, based on such
criteria, is requisite to protect the public welfare from any known or
anticipated adverse effects associated with the presence of such air pollutant
in the ambient air. Such secondary standards may be revised in the same
manner as promulgated."
In order to conform to the requirements of Section 109, EPA is required to
base the level of the lead air quality standard on information presented in the
criteria document pertaining to the health and welfare implications of lead
air pollution. This is in contrast, to other sections of the Act under which
EPA considers economic costs and technical availability of air pollution control
systems in determining the standard. The Act also requires that the Agency
should not attempt to place the standard at a level estimated to be at the
threshold for adverse effects, but should set the standard at a lower level
in order to provide a margin of safety. EPA believes that the extent of the
margin of safety represents a judgment in which the Agency considers the severity
of reported effects, the probability that such effects may occur, and un-
certainties as to the full biological significance of exposure to lead.
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Comments resulting from external review of the air quality criteria and
the proposed standard highlight disagreements on a number of areas critical
to EPA's judgments underlying the level of the standard. However, the
scientific data base provided in the document Air Quality Criteria for Lead
is as extensive as that for any other regulated air pollutant. Also, at
every stage of development of the air quality criteria and the standard, EPA
has facilitated and received broad external participation. EPA regards as
inevitable the presence of scientific disagreement and uncertainty about key
factors relevant to environmental standards. Provisions of the Act requiring
timely promulgation of the standard, and requirements for periodic future review
of air quality criteria and standards, however, indicate Congressional intent
that the Agency proceed even where scientific knowledge is not complete or where
there is an absence of full scientific consensus.
SUMMARY OF GENERAL FINDINGS FROM AIR QUALITY CRITERIA FOR LEAD
Following the listing of lead as a criteria pollutant, EPA developed
the document, Air Quality Criteria for Lead. In the preparation of this
document, EPA provided opportunities for external review and comment on three
successive drafts. The document was reviewed at three meetings of the Sub-
committee on Scientific Criteria for Environmental Lead of EPA's Science
Advisory Board. Each of these meetings was open to the public and a number
of individuals presented both critical review and new information for EPA's
consideration. The final criteria document was issued on December 14, 1977.
From the scientific information summarized in the criteria document,
conclusions in several key areas have particular relevance for the ambient
air quality standard for lead.
1. There are multiple sources of lead exposure. In addition to
air lead, these sources include: lead in paint and ink, lead in
drinking water, lead in pesticides, and lead in fresh and processed
food.
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2. Exposure to air lead can occur directly by inhalation, or
indirectly by ingestion of lead contaminated food, water, or non-food
materials including dust and soil.
3. There is significant individual variability in response to lead
exposure. Even within a particular population, individual response
to lead exposure may vary widely from the average response for the
same group. Certain subgroups within the general population are
more susceptible to the effects of lead or have greater exposure
potential. Of these, young children represent a population of foremost
concern.
4. Three systems within the human body, appear to be most sensitive
to the effects of lead ~ the blood-forming or hematopoietic system,
the nervous system, and the renal system. In addition, lead has
been shown to affect the normal functions of the reproductive, endocrine,
hepatic, cardiovascular, immunologic, and gastrointestinal systems.
5. The blood lead level thresholds for various biologic effects
range from the risk of permanent, severe, neurological damage or death
as blood leads approach and exceed 80 to 100 ug Pb/dl in children down
to the inhibition of cellular enzyme systems at as low as 10 ug Pb/cil.
6. Lead is a stable compound, ubiquitously distributed, which
persists and accumulates both in the environment and in the human body.
In developing the proposed standard, EPA used these findings to arrive at a
standard level of 1.5 ug Pb/m calendar month average. This level was derived
from the Agency's judgment on two matters: first, that the maximum safe
population blood lead level for young children was 15 ug Pb/dl, and second, of
this amount, 12 ug Pb/dl should be attributed to non-air sources. The difference
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of 3.0 ug Pb/dl was then estimated to be the allowable safe contribution to mean
population blood lead from lead in the air. With epidemilogical data indicating
a 1:2 relationship between air lead (ug Pb/m ) and blood lead (ug Pb/dl),
EPA determined that the level for the proposed standard should be 1.5 ug/m .
SUMMARY OF COMMENTS RECEIVED
During the comment period from December 14, 1977 to March 17, 1978,
and at the public meeting on February 15-16, 1978, EPA received 95 written
and oral comments addressing the proposed standard or the requirements
for State Implementation Plans. All comments opposing the standard as
excessively stringent (25) came from representatives of affected industries,
and twenty of these counter-proposed 5.0 ug Pb/m3 calendar quarter average, as
the appropriate level for the standard.
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COMMENTS RECEIVED OPPOSING THE PROPOSED STANDARD
OF 1.5 ug/m3 AS EXCESSIVELY STRINGENT
COMPANY
OPPOSED 1.5 ug/nf
calendar month
Amax Lead and Zinc, Inc. X
American Mining Congress X
American Petroleum Institute X
ASARCO X
Associated Octal X
Battery Council International X
Bethlehem Steel X
Bunker Hill Company X
C & D Batteries X
DuPont X
ESA Laboratories X
Ethyl X
General Battery Corporation X
General Motors Corporation
Getty Refining and Marketing X
HECLA Mining Company X
Houston Chemical X
Hunt Oil X
Kerr-McGee
Lead Industries Association X
Nalco Chemical X
N L Industries X
Prestolite Battery X
Secondary Lead Smelters
Association X
Shell Oil X
St. Joe Minerals X
Texaco, Inc. X
United Machinery Group
Vulcan Materials Company
ENDORSED 5.0 ug/m,
calendar quarter (or
other averaging period)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Summary: 45 comments received from 29 corporations or their representatives
25 of the 29 firms opposed the proposed standard of 1.5 ug/m ,
calendar month average;
20 endorsed an alternative standard of 5.0 yg/m , calendar
quarter average (or other averaging period).
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Four comments opposed the proposed standard on the grounds that it
was not sufficiently protective of health.
COMMENTS RECEIVED OPPOSING PROPOSED LEAD AIR QUALITY
STANDARD OF 1.5 ug/m3, CALENDAR MONTH
IN FAVOR OF A MORE STRINGENT STANDARD
Natural Resources Defense Council
Sergio Piomelli, Pediatric Hematology, New York University Medical Center
Public Interest Campaign
University of Connecticut Health Center
Comments supporting the level of the proposed standard (17) came
from the medical community, Federal agencies, state and local
public health agencies, and public interest groups.
COMMENTS RECEIVED ENDORSING PROPOSED LEAD AIR QUALITY
STANDARD OF 1.5 uq/m3, CALENDAR MONTH AVERAGE
State and Local Agencies
California Department of Health
Massachusetts Department of Public Health
New York State Department of Environmental Conservation
New York City Department of Environmental Protection
Tennessee Department of Public Health
Texas Air Control Board
Wisconsin Department of Natural Resources
Federal Agencies
Center for Disease Control, Public Health Service
Department of Transportation
Food and Drug Administration
Occupational Safety and Health Administration
Public Interest Groups and the Medical Community
Committee on Environmental Hazards, American Academy of Pediatrics
D.C. Committee for Lead Elimination in the District
League of Women Voters of the U.S.
National Urban League
Herbert Needleman, Boston Children's Hospital Medical Center
University of North Carolina School of Public Health
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The comments received by EPA did not challenge three aspects of the
proposed standard:
1. the basic structure of the rationale used by the Agency in
deriving the level of the proposed standard.
2. the selection of young children as a population particularly
at risk to lead exposure.
3. the Agency's estimate of 12 ug Pb/dl as an appropriate target
for the mean population blood lead level attributable to non-air
sources of lead exposure.
Significant comments were received, however, on the following key areas
relating to the standard:
1. the validity of using a subclinical effect, EP elevation, as the
critical adverse health effect rather than clinically detectable
anemia.
2. the appropriate blood lead threshold for elevated EP.
3. the incidence of health effects in populations residing in the
vicinity of industrial sources of lead particulate emissions.
4. the appropriate relationship between micrograms of lead in the
air and micrograms of lead in the blood.
5. the statistical form and period of the standard.
6. the appropriate margin of safety.
7. the importance of the respirable fraction of total air lead level.
8. the economic impact of the standard.
9. the State Implementation Plan regulations.
10. the Federal Reference Method for monitoring lead air quality.
11. the administrative procedures employed by EPA in the development
of the standard and the provision for public participation.
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A review of the comments received and their disposition has been
placed in the rulemaking docket (OAQPS 77-1) for public inspection. The
following paragraphs summarize the significant comments and present the
Agency's findings.
The Health Significance of_ Erythrocyte Protoporphyrin Elevation
Ten commentors disagreed with EPA's conclusion that the impairment
of heme synthesis indicated by elevated erythrocyte protoporphyrin (EP)
constituted an adverse health effect. Reasons for this disagreement included:
1. An elevated level of EP is not itself toxic to the cells in
blood or other tissues.
2. EP elevation, while indicating a change in heme synthesis, does not
indicate an insufficient production of heme, or hemoglobin.
3. EP elevation and the alteration of heme synthesis does not cause
impairment of other mitochondrial functions.
4. EP elevation is not associated with impairment of other heme proteins,
particularly cytochrome P-450.
5. Elevated EP may be caused by conditions other than exposure to
lead, particularly iron deficiency.
Five other commentors agreed with EPA's conclusions about the health
significance of elevated EP citing the following arguments:
1. the interference of lead in a fundamental cellular metabolic function
to the extent that there is accumulation of a substrate is physiological
impairment even without the presence of clinical evidence of disease.
2. it is prudent medical practice to intervene where subclinical
indicators of physiological impairment are present.
3. the impairment of heme synthesis resulting from genetic or dietary
factors places a child at enhanced risk to lead exposure.
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4. there is evidence to suggest that impaired heme synthesis effects
the function of neural or hepatic tissue even at levels where heme
production is sufficient for hematopoiesis.
Agency Response
EPA agrees with the comments received that the onset of EP elevation
as a result of exposure to lead may not be a diseased state or be seen as
a clinically detectable decrement in performance. Also the extent of impairment
of the heme synthesis due to lead in an amount sufficient to move an individual
child beyond the threshold for EP elevation does not immediately lead to a
clinical disease. However, the Criteria Document points out that this impairment
does increase progressively with lead dose.
"The hematological effects described above are the earliest physiological
impairments encountered as a function of increasing lead exposures as
indexed by blood lead elevations; as such, those effects may be con-
sidered to represent critical effects of lead exposure. Although it may
be argued that certain of the initial hematological effects (such as
ALAD inhibition) constitute relatively mild, nondebilitating symptoms
at low blood lead levels, they nevertheless signal the onset of steadily
intensifying adverse effects as blood lead elevations increase. Eventually,
the hematological effects reach such magnitude that they are of clear-cut
medical significance as indicators of undue lead exposure."
The fact that other conditions, such as iron deficiency, may also produce
impairment of heme synthesis, does not obviate the concern that lead in these
circumstances is interfering with an essential biological function. The
possibility of a nutritional imbalance is an additional stress to this
system which may increase the sensitivity of a child to lead exposure.
EPA notes that there is general agreement that heme and heme-containing
proteins play important roles in the oxygen fixation pathways in all cells.
While the effects of low-level lead exposure on the heme synthetic pathway
in erythroid tissue have been extensively studied in part because of the ease
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with which this tissue may be obtained, other cellular metabolic systems
utilizing heme are less well understood. EPA does not have sufficient
information to conclude that impairment of heme synthesis in other tissue
is not of concern until blood lead levels greater than those associated with hema-
tological effects are reached. The air quality criteria does point out that this
effect has been established in other tissues and that other dose-response
factors may apply.
"The effect of lead on the formation of heme is not limited to the
hematopoietic system. Experimental animal studies have shown a
lead effect on the heme-requiring protein, cytochrome P-450, an
integral part of the hepatic mixed-function oxidase (Chapter 11),
the systemic function of which is detoxification of exogenous sub-
stances. Heme synthesis inhibition also takes place in neural
tissue."
In summary, the Criteria Document stated:
"Elevation in protoporphyrin is considered not only to be a biological
indicator of impaired mitochondria! function of erythroid tissue but
also an indicator of accumulation of substrate for the enzyme
ferrochelatase. It therefore has the same pathophysiological
meaning as increased urinary 6-ALA (vide supra). For these reasons
accumulation of protoporphyrin has been taken to indicate physiological
impairment in humans, and this clinical concensus is expressed in
the 1975 Statement of the Center for Disease Control (CDC), USPHS.
The criterion used by.CDC to indicate an effect of lead on heme
function is an FEP level of 60 ug/dl i-n the presence of a blood lead
level above 30 ug/dl whole blood.
More recent.information relating to threshold of lead effects indicates
that FEP levels begin to increase at a blood lead value of 15 to 20 ug Pb/dl
blood in children and women and, at a somewhat higher value, 20 to 25
ug Pb/dl blood, in adult men."
EPA concludes that the state of elevated EP must be regarded as potentially
adverse to the health of young children. While the onset or a mild experience
of this condition may be tolerated by an individual, as with other subclinical
manisfestations of impaired function, it is prudent to public health practice
to exercise corrective action prior to the appearance of clinical symptoms.
The criteria document reports that symptoms of anemia in children may occur
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at blood lead levels of 40 ug/dl. EPA has adopted 30 ug Pb/dl as the maximum
safe blood lead level for individual children.
The Blood Lead Threshold for Elevated Erythrocyte Protoporphyrin
Comments provided by ten organizations challenged EPA's conclusion
that the threshold for the elevation of EP occurs at a blood lead level
in children of 15 yg/dl. Evidence offered for a higher threshold included:
1. the threshold accepted by EPA is based on a study in which an
inappropriate statistical technique, probit analysis, was employed.
2. application of a more appropriate technique, segmented line
analysis, results in a higher threshold.
3. the study in question excluded data on children with blood lead
levels in excess of 30 ug/dl.
4. other investigators have reported higher thresholds.
Comments in support of the 15 ug/dl threshold maintained:
1. it is proper to exclude values considered abnormal if the intent
of the analysis is to determine an unbiased effect threshold.
2. other studies have reported thresholds with error bands which
include 15 ug/dl.
3. probit analysis is an appropriate technique and differs only
slightly from the results obtained from segmented line analysis.
Agency Response
EPA agrees that the segmented line technique provides a more
accurate estimate of the correlation threshold, about 16.7 ug Pb/dl,
and has for this reason considered changing its judgments as to the
maximum safe blood lead level for a population of children. However, as the
target geometric mean is increased the variability in response of individual
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children within the group will cause a greater percentage of children
to exceed the maximum safe individual level of 30 ug Pb/dl. EPA
estimates that at a population level of 15 ug Pb/dl 99.5 to 99.9 percent of
children will be below 30 ug Pb/dl. At 16.7 ug Pb this percentage falls
to 98.7, EPA points out that the number of children predicted to be below
30 ug Pb/dl is the critical health consideration, not the detection
threshold for the correlation. For this reason, EPA has maintained its
estimate of 15 ug Pb/dl as the target for population blood lead.
The Incidence of Health Effects in Populations Residing in the Vicinity
of Industrial Sources of Lead Particulate Emissions
Several comments cited situations in which proximity to significant
point sources of airborne lead emissions appear to have little or no
health impact on resident populations. This was taken to imply that the
air standard was not necessary to protect public health.
Agency Response
EPA acknowledges the variability of the impact of exposure to air lead
on the potential for adverse health consequences. It is clear that direct
exposure to air lead is only one of the routes through which human exposure
occurs. For this reason, the Agency accepts that only a portion of the
safe population mean blood lead level is attributable to air lead exposure.
The presence or absence of health effects in an exposed population is
influenced by a variety of factors including: meteorology, terrain
characteristics, geological and anthropological history, personal and
domestic hygiene, the occupation's of the population members,, and the food
and non-food materials with which they come into contact. Taking into
account such variability, it remains the Agency's belief that airborne
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lead directly and indirectly contributes to the risk of adverse health
consequences and that sufficient clinical and epidemiological evidence
is present to form a judgment as to the extent of this contribution. This
evidence includes epidemiological studies showing higher blood lead levels
in urban areas where air lead levels were elevated in comparison to rural
areas. There have also been a number of studies linking elevated blood leads
to industrial sources of lead emissions. With regard to the 1972 study
at El Paso, Texas, by the Center for Disease Control, the Criteria Document
reports:
"It was concluded that the primary factor associated with elevated
blood lead levels in the children was ingestion or inhalation or dust
containing lead. Data on dietary intake of lead were not obtained
because the climate and proximity to the smelter prevented any farming
in the area. It was unlikely that the dietary lead intakes of the
children from near the smelter and farther away were significantly
different."
(Human lead absorption - Texas. Center for Disease Control. Morbidity
and Mortality Weekly. Report 22(49): 405-407, December, 1973).
With regard to the report of Yankel et. al at Kellogg, Idaho, the Criteria
Document states:
"Five factors influenced,.in a statistically.significant manner, the
probability of a child developing an excessive blood lead level:
1. Concentrations of lead in ambient air (yg/m ).
2. Concentration of lead in soil (ppm).
3. Age (years).
4. Cleanliness of the home (subjective evaluation coded 0, 1, and 2, with
2 signifying dirtiest).
5. General classification of the parents' occupation (dimensionless).
Although the strongest correlation found was between blood lead level and
air lead level, the authors concluded that it was unlikely that inhalation
of contaminated air alone could explain the elevated blood lead levels
observed. "
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(Yankel, A.J., I. von Lindern, and S. 0. Walter. The Silver
Valley lead study.. The relationship between childhood blood
lead levels and environmental exposure. J. Air Pollut. Cont.
Assoc. 27:763-767, 1977.)
The Appropriate Relationship Between Lead _in_ Air and Lead j_n_ Blood
Several commenters questioned the Agency's estimate that, for children,
one microgram of lead per cubic meter air results in an increase of two
micrograms lead per deciliter blood.
Agency Response:
EPA acknowledges that the air lead to blood lead relationship in
children has been reported by some investigators as closer to 1:1. However,
as the criteria document states:
"One assumption inherent in the calculation of the regression of
blood lead on air lead using standard least squares is that the air lead
values have been measured with no error. Obviously, the monitored air
lead values are not the exact values inhaled by the subjects in the
exposure area." "In general, the calculation regression coefficients are
underestimates of the true values." The use of personal dosimeters to
measure exposure reduces the measurement error. For this reason, EPA
regards the study of Azar in adult males using dosimeters as one of the
strongest for estimating the air lead/blood lead relationship. The
grouping of data by an air lead level indicates that the relation is
curvilinear, that is, the ratio changes with changing air and blood leads.
In the range of the proposed air standard, Azar's data indicate a ratio
of 1:1.43 to 1:2.57. Because children are known to have a greater net
respiratory intake of lead as well as greater net absorption and retention
of this metal than adults, it is reasonable to assume that the air lead
to blood lead relationship for this sensitive population, exposed to air
lead levels in the range of the proposed standard, is equal to if not greater
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than that for adults. EPA also notes that the air lead/blood lead
relationship is non-linear and may have a higher ratio at lower air levels.
Finally, EPA has estimated this factor at the top of the range given in the
Criteria Document for margin of safety considerations. It is the conclusion
of the Agency therefore, that an air lead to blood lead relationship of 1:2
is the appropriate factor for deriving the standard.
The Statistical Form and Period of the Standard
One commenter expressed the view that, due to the log normal distribution
of air leads, a not to be exceeded standard of 1.5 ug/m calendar month
average would require sources of air lead to achieve control of their
3
emissions to a geometric monthly mean of 0.41 ug/m in order to prevent the
occurrence of a violation. Another individual expressed the opinion that, with
the continued operation of a six day sampling regimen, the number of samples
which could be collected in the course of a calendar month would not provide
a statistically valid estimate of the actual lead air quality for the period.
Comments by several individuals questioned the health basis for the
selection of the calendar month averaging period.
EPA Response
EPA accepts the consensus of comments received on the scientific and
technical difficulties presented by the selection of a calendar month averaging
period. The Agency believes that the key criterion for the averaging period is
the protection of health of the sensitive population. In proposing the 1.5 ug/m
standard, EPA concluded that this air level was safe for indefinite exposure
of young children. Critical to the determination of the averaging period is the
health significance of possible elevations of air lead above 1.5 ug/m which
could be encountered without violation of the standard. In the proposed
standard, EPA chose a monthly averaging period on the basis of a study showing
an adjustment period of blood lead level with a change of exposure. Because of
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the scientific and technical difficulties of the monthly standard, EPA
has reexamined this question and concludes that there is little reason to
expect that the slightly greater possibility of elevated air lead levels
sustainable by the quarterly standard is significant for health. This
conclusion is based on the following factors:
(1) from actual ambient measurements, there is evidence that the
distribution of air lead levels is such that there is little
possibility that there could be sustained periods greatly
above the average value.
(2) while it is difficult to relate the extent to which a monitoring
network actually represents the exposure situation for young
children, it seems likely that where elevated air lead levels
do occur, they will be close to point or mobile sources. Typically
young children will not encounter such levels for the full twenty-
four hour period reported by the monitor.
(3) there is medical evidence indicating that blood lead levels reequili-
brate slowly to changes in air exposure which serves to dampen
the impact of a short-term period of exposure to elevated air lead.
(4) since direct exposure to air is only one of several routes of
total exposure, a change in air lead would not impact proportionately
on blood lead levels.
On balance, the Agency concludes that a requirement for the averaging of
air quality data over calendar quarter will improve the validity of air quality
data gathered without a significant reduction of the protectiveness of the
standard.
The Appropriate Margin of_ Safety
Several comments received by the Agency criticized the proposed standard
as incorporating an excessively large margin of safety. Conversely, some
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EPA Response
One approach to the satisfaction of the Clean Air Act requirement
for an "adequate margin of safety" in ambient air quality standards
has been the establishment of a threshold for adverse effects in the
sensitive population with the selection of the final standard at some
point below this level. The extent of the margin applied is largely
dependent on the severity of the health effects and uncertainties
associated with the scientific data base.
In the case of lead air pollution, the estimate of margin of safety
is complicated by the multiple sources and media of lead exposure. EPA has
elected to use margin of safety considerations in determinations of each
of the intermediate factors rather than in a single final adjustment
to the calculated air level. It is EPA's conclusion that the incorporation
of conservative estimates of intermediate factors, where uncertainty exists,
is a reasonable approach to margin of safety determination, and that the
Agency's judgments have not been shown to be excessively or deficiently pro-
tective of human health.
The Importance of_ the Respirable Fraction of Total Air Lead Level
The Agency received a number of comments expressing concern that
because the respirable fraction of airborne particulate lead is more readily
absorbed into the blood stream, an air standard based on total air lead
is unnecessarily protective of health.
Agency Response
EPA acknowledges the important role of respirable lead as a con-
tributor to total lead body burden. It is not reasonable to conclude, however,
that the presence of particles beyond this range do not represent an
exposure condition. In addition to the indirect route of ingestion and
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absorption from the gastrointestinal tract, non-respirable lead in the
environment may, at some point, become respirable through weathering
or mechanical action. EPA concludes, therefore, that total airborne
lead, both respirable and non-respirable fractions, is appropriate as a
measure of total air exposure.
The Economic Impact of the Proposed Standard
In general, the comments received by the Agency were supportive of
the draft Economic Impact Assessment. Commentors critical of the
assessment argued that the forecast underestimated the severity of the
economic impact to certain lead industries.
Agency Response
The comments critical of the draft impact statement did not include
data which would allow EPA to confirm the possibility of more severe
economic impacts. Since the analytical methods employed were not brought
into question, it is the Agency's view that the impact statement, with
modifications necessitated by the change in averaging period, is a reasonable
forecast of the economic consequences of implementation of the standard.
The Proposed State Implementation Plan (SIP) Regulations
A summary of comments and the Agency response is included in the
preamble to the final regulations published elsewhere in this Federal Register.
The Federal Reference Method for Monitoring Lead Air Quality
A summary of comments and the Agency's resolution is included in the
preamble to the final method published elsewhere in this Federal Register Notice.
The Administrative Procedures Employed Jjy_ EPA rn_ the Development of the
Proposed Standard and the Provision for Public Participation
Two commenters requested that cross examination of witnesses be
allowed in the post-proposal public hearing on the proposed standard and
21
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implementation regulations. EPA also received a request to postpone
the public hearing and to extend the comment period, citing the need to
complete ongoing studies.
Agency Response
Both the request for cross examination and for extension of the
comment period were denied by the Agency. In the former case, it is the
Agency's view that cross examination would be counter to the informal
rulemaking procedures followed by the Agency. Due to the extensive review.
opportunities available at all stages of regulatory development, an extension
of the comment period was not felt to be sufficiently necessary to further
delay the schedule for the preparation of the final rule.
Clarification of Elements of the Standard
From reviewing the comments received, EPA wishes to clarify the following
points in the presentation of the proposed standard:
(1) EPA is making a distinction between the blood lead level that
is seen as the threshold for detection of the biological effect,
EP elevation, and the blood lead level seen as the point where
that effect can be regarded as adverse to health.
(2) EPA is making a distinction between estimating a maximum safe
blood lead level for an individual, and establishing a target
as the geometric mean for the blood lead level for the sensitive
population.
(3) EPA is making a distinction between estimating what the con-
tribution to blood lead levels from non-air sources actually
is and estimating the appropriate goal for blood lead attributed
to non-air sources.
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Derivation of the Numerical Level of the Final Standard
EPA's objective in setting the level of the standard is to estimate
the concentration of lead in the air to which all groups within the
general population can be exposed for protracted periods without an unacceptable
risk to health.
This estimate is based on EPA's judgment in four key areas:
(1) determining the "sensitive population" as that group within
the general population which has the lowest threshold for
adverse effects or greatest potential for excessive
exposure. EPA concludes that young children, aged 1-5,
are the sensitive population.
(2) determining the safe level of total lead exposure for the
sensitive population, measured as concentration of lead in
the blood. EPA concludes that the maximum safe level of
blood lead for an individual child is 30 ug Pb/dl and that
population blood lead, measured as the geometric mean, must be
15 ug Pb/dl in order to place 99.5 - 99.9 percent of children
in the United States below 30 ug Pb/dl.
(3) determining the contribution to blood lead fron non-air pollution
sources. EPA concludes that 12 ug Pb/dl of population blood lead
for children should be attributed to non-air exposure.
(4) determining the air lead level which is consistent with main-
taining population blood lead below 15 ug Pb/dl. Taking into
account exposure from other sources, 12 ug Pb/dl, EPA has
designed the standard to limit air contribution to 3 ug Pb/dl.
On the basis of an estimated relationship of air lead to blood
23
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lead of 1:2, EPA concludes that the ambient air standard should
be 1.5 ug Pb/m3.
Each of these four areas is discussed further in the following sections.
SENSITIVE POPULATION
As in the discussion supporting the proposed lead standard, EPA believes
that the health of young children is at increased risk due to lead exposure.
This is because children have a greater physiological sensitivity to the
effects of lead than do adults, and are at higher risk of greater exposure
to environmental lead. Other sensitive populations identified by EPA include
those occupationally exposed, and pregnant women and the fetus. Comments
received on the proposed standard did not challenge EPA's arguments for the
selection of young children as the most sensitive population for determining
the standard. A number of comments did point out that within the general
population of children there were subgroups with enhanced risk due to
genetic factors, dietary deficiencies, or residence in urban areas. EPA
acknowledges the higher risk status of such groups but does not have
information either in the air quality criteria or in the comments received
for estimating a threshold for adverse effects separate from that of all
children. Concern about these high risk subgroups has, however, influenced
EPA's determination of an adequate margin of safety.
EPA continues to be concerned about the possible health risk of lead
exposure for pregnant women and fetuses. This concern is based on the
suggestion that the stress of pregnancy may place pregnant women in a
state more susceptible to the effects of lead, and that transplacental
transfer of lead may effect the prenatal development of the child. There
is, however, insufficient scientific information for EPA to either confirm
or dismiss this suggestion, and to establish that pregnant women and
fetuses are more at risk than young children.
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THE MAXIMUM SAFE EXPOSURE FOR CHILDREN
In determining the maximum safe exposure to lead for children, EPA
has taken the measurement of blood lead as the indicator of total lead
dose. There are other possible indicators of exposure, for example
the level of zinc protoporphyrin (ZPP), but the great preponderance of
health studies reported in the criteria have utilized blood lead levels
as indications of mobile body burden. The criteria document reports the
following table of effect thresholds for children at increasing blood
lead levels.
Summary of Lowest Observed Effect Levels in Young Children
S-ALAD inhibition 10 ug Pb/dl
Erythrocyte protoporphyrin elevation 15-20 ug Pb/dl
Increased urinary 6-ALA excretion 40 ug Pb/dl
Anemia 40 ug Pb/dl
Coproporphyrin elevation 40 ug Pb/dl
Cognitive (CNS) deficits 50-60 ug Pb/dl
Peripheral neuropathies 50-60 ug Pb/dl
Encephalopathic symptoms 80-100 ug Pb/dl
The first physiological effect associated with increasing blood lead levels
is the inhibition of the enzyme <5- Amino - levulinic - acid - dehyaratase
(S-ALAD), both in red blood cells, erythrocytes, and in cells in other
tissues. This enzyme catalyzes the condensation of two molecules of
6-aminolevulinic acid (6-ALA) to form porphobilinogen, one of the components
involved in the cellular synthesis of heme. The criteria document reports
that the threshold for 6-ALAD inhibition in children is 10 ug Pb/dl.
At blood lead levels above 10 ug Pb/dl, the function of 5-ALAD is
increasingly inhibited by lead. The criteria document states that
25
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40 ug Pb/dl is the threshold for elevation of «S-ALA-U in the urine, an
indication that 5-ALA has begun to accumulate in cells.
EPA does not regard the inhibition of o-ALAO above 10 ug Pb/dl
as adverse to health because of the absence of the evidence that there is
an impairment of heme synthesis until a threshold of 40 ug Pb/dl is reached.
The accumulation of 6-ALA above normal levels, indicated by 6-ALA-U in urine,
is regarded as adverse to health, both because of impaired heme synthesis,
and the possibility that o-ALA accumulation is toxic to cells.
The criteria document reports that above a threshold of 15-20 ug Pb/al
there is an elevation of protoporphyrin in erythrocytes.
Protoporphyrin is an organic chemical compound used by all cells in
the production of heme. In the final stage of heme synthesis protoporphyrin
and iron are brought together in the cell mitochondria. In the presence of
lead, this step is blocked, possibly by inhibition of the enzyme ferrochelatase
or by interference in the transport of iron across the mitochondria! membrane.
As the impairment of heme synthesis increases, a declining amount of heme
is available for formation of critical heme proteins, such as hemoglobin.
Without incorporation into heme, the levels of protoporphyrin in the
cell become elevated. In red blood cells, protoporphyrin takes the place
of heme in hemoglobin, and persists for the life of the cell as a
defective hemoglobin molecule which cannot carry oxygen.
From its review of the information provided by air quality criteria
as well as the evidence and arguments offered by medical professionals
commenting on the proposed standard, EPA concludes that the effects of
lead on the cellular synthesis of heme, as indicated by elevated erythrocyte
26
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protoporphyrin, are potentially adverse to the health of young children.
EPA does not believe that there is significant risk to health at the
point where the elevation of EP can first be correlated with an increase
in blood lead. For this reason, this correlation threshold was adopted
as a maximum safe population blood lead level in deriving the level of
the proposed standard. On the other hand, EPA regards as clearly
adverse to health the impairment of heme synthesis, and other lead effects
which result in clinically detectable anemia above 40 ug Pb/dl. For this
reason, EPA has concluded that the maximum safe blood lead level for an
individual child is in the range between 15 and 40 ug Pb/dl.
EPA believes that information provided in the air quality criteria
is consistent with the recommendation of the Center for Disease Control
of the Public Health Service, as endorsed by the American Academy of
Pediatrics that a blood lead level of 30 ug Pb/dl should be considered
undue lead exposure for an individual child.
The criteria document points out that data from epidemiological
studies show that the log values of measured individual blood lead values
in a uniformly-exposed population are normally distributed with a standard
geometric deviation of 1.3 to 1.5. Using standard statistical techniques,
it is possible to calculate the mean population blood lead level which would
place a given percentage of the population below the level of an effects
threshold. With a standard geometric deviation of 1.3, a mean population
blood lead level of 15 yg Pb/dl would place 99.5 to 99.9 percent of a
population of children below the Center for Disease Control guidelines of
30 ug Pb/dl, depending on the effect of measurement error.
27
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In EPA's view, use of the 99.5 - 99.9 percent range is not excessive.
From 1970 statistics, there are approximately 20 million children in the
United States below the age of 5 years, 12 million in urban areas, and 5
million in the center city where lead exposure may be high. Again, know-
ledge that there are special high risk groups of children within the
general population deters EPA from considering lower percentages.
28
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CONTRIBUTION TO TOTAL LEAD EXPOSURE FROM NON-AIR SOURCES
In the proposed standard, EPA argued that the air standard should
take into account the contribution to blood lead levels from lead sources
unrelated to air pollution. No comments were received challenging this
argument. EPA continues to base its calculation of the ambient air
standard on the assumptions that, to an extent, the lead contribution
to blood lead from non-air sources should be subtracted from the
estimate of safe mean population blood lead. Without this subtraction
the combined exposure to lead from air and non-air sources would result
in a blood lead concentration exceeding the safe level.
In its proposal, EPA also argued that it was appropriate to use
a reasonable target for non-air contribution to blood lead rather than
a more typical exposure level which alone may exceed the total safe
blood lead level. EPA contends that this approach recognizes the need
for multimedia regulation of environmental lead and the need to avoid
placing extreme requirements on sources of air lead emissions where non-
air sources have made a significant contribution to population blood lead
levels.
Finally, in the preamble to the proposed standard, EPA presented data
which it used to estimate 12 ug Pb/dl as the appropriate target for non-air
contribution to blood lead. In the absence of criticial comment, this
information is :resentec in the fom it appeared in the proposal preamble.
29
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The level of the standard is very strongly influenced by judgments
made regarding the size of non-air contribution to total exposure. EPA has
encountered difficulties in attempting to estimate exposure from various
lead sources in order to determine the contribution of such sources to
blood lead levels:
(1) Studies reviewed in the Criteria Document do not provide detailed
or widespread information about relative contribution of various sources
to young children. Estimates can only be made by inference from other
empirical or theoretical studies, usually involving adults.
(2) It can be expected that the contribution to blood lead levels
from non-air sources can vary widely, is probably not in constant pro-
portion to air lead contribution, and in some cases may alone exceed the
target mean population blood lead level.
In spite of these difficulties, EPA has attempted to assess available
information in order to estimate the general contribution to population
blood lead levels from air and non-air sources. This has been done with
evaluation of evidence from general epidemiological studies, studies
showing decline of blood lead levels with decrease in air lead, studies
of blood lead levels in areas with low air lead levels, and isotopic
tracing studies.
Studies reviewed by the Criteria Document show that mean blood lead
levels for children are frequently above 15 ug Pb/dl. In studies reported,
the range of mean population blood lead levels for children was from 16.5
ug Pb/dl to 46.4ug Pb/dl with most studies showing mean levels greater than
25 ug Pb/dl (Fine, 1972; Landrigan, 1975; von Lindern, 1975). EPA believes
that for most of these populations, the contribution to blood lead levels
from non-air sources exceeds the desired target mean blood lead level.
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In a number of studies, it is apparent that reduction in air lead
levels results in a decline in children's blood lead levels. A study of
blood lead levels in children in New York City showed that children's
mean blood lead levels from from 30.5 ug Pb/dl to 21.0 ug Pb/dl from 1970
to 1976, while during the same period air lead levels at a single monitoring
site fell from 2.0 ug Pb/dl to 0.9 ug/Pb (Billlck, 1977). Studies at
Omaha, Nebraska (Angle, 1977) and Kellogg, Idaho (Yankel, von Lindern, 1977)
also show a drop in mean blood lead levels with declines in air lead
levels. However, as air lead levels decline there appears to be a rough
limit to the drop in blood lead levels. EPA has also examined epidemiological
studies in the Criteria Document where air lead exposure is low, and can be
assumed to be a minor contributor to blood lead. These studies provide
an indication of blood lead levels resulting from a situation where non-air
sources of lead are predominant.
Studies Reporting Blood Lead Levels in Children Exposed to Moderate to Low
Investigator
Hammer, 1972
Angle, 1974
Goldsmith, 1974
Johnson, Tillery,
Air Lead
Blood
lead (in
micro-
grams
of lead
per
deci-
liter)
11.6
14.4
13.7
13.3
10.2
Levels
Air
lead (in
micro-
grams
of lead
per
cubic
meter)
0.1
0.14
0.2-0.7
0.3-0.6
0.6
Comment
Children in Helena, Mont.
Suburban children ages
1 to 4 in Omaha
Children in Benecia, Calif.
Children in Crocket, Calif.
Female children - mean age
1975 in Lancaster, Calif.
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The range of mean blood lead levels in those studies is from 10.2 ug
to 14.4 u9 Pb/dl, with an average at 12.7 ug Pb/dl.
In addition to epidemiological investigations, EPA has reviewed
studies that examine the source of blood lead by detecting characteristic
lead isotopes. A study using isotopic tracing (Manton, 1977) suggests
that for several adults in Houston, Texas, 7 to 41 percent of blood lead
could be attributed to air lead sources. An earlier isotopic study
(Rabinowitz, 1974) concluded that for two adult male subjects studied,
approximately one-third of total daily intake of lead could be attributed
to exposure to air lead levels of 1-2 ug Pb/m3. While these results
cannot be directly related to children, it is reasonable to assume that
children may exhibit the same or higher percentages of air lead contribution
to blood lead level because of a greater potential for exposure to indirect
air sources, soil and dust.
From reviewing these areas of evidence, EPA concludes that:
1. In studies showing mean blood lead levels above 15 ug Pb/dl,
it is probable that both air and non-air sources of lead contribute
significantly to blood lead with the possibility that contributions from
non-air sources exceed 15 ug Pb/dl.
2. Studies showing a sustained drop in air lead levels show a
corresponding drop in blood lead levels, down to an apparent limit in
the range of 10.2 to 14.4 ug Pb/dl. These studies show the rough range
of the lowest blood lead levels that can be attributed to non-air sources.
3. Isotopic tracing studies show air contribution to blood lead to
be 7-41 percent in one study and about 33 percent in another study.
In considering this evidence, EPA notes that if, from the isotopic
studies, approximately two-thirds of blood lead is typically derived
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from non-air sources, a mean blood lead target of 15 ug Pb/dl would
attribute 10 ug Pb/dl to non-air sources. On the other hand, the
average blood lead level from studies EPA believes to represent the least
amount of blood lead attributable to non-air sources is 12.7 ug Pb/dl. In the
absence of more precise information, EPA is proposing that the lead
standard be based on the assumption that in general, 12 ug Pb/dl of the
blood lead level in children is derived from lead sources unaffected by the
lead air quality standard. EPA is aware that actual population blood
lead levels, either individually or as a population mean, may exceed this
benchmark. However, if EPA were to use a larger estimate of non-air
contribution to blood lead, the result would be an exceptionally stringent
standard, which would not address the principal source of lead exposure.
Conversely, EPA believes that it should not adopt an estimate of non-air
contribution below the. level shown in .available studies to be the lowest
mean blood lead level documented in the Criteria Document.
THE RELATIONSHIP BETWEEN AIR LEAD EXPOSURE AND RESULTING BLOOD LEAD LEVEL
On the basis of clinical and epidemiological studies evaluated, the
Criteria Document concludes:
"The increase in blood lead level resulting from an increase in
air lead concentration is not constant in magnitude over the
range of air lead levels commonly found in the environment. The
relationship is dependent on many factors, including rate of
current exposure and the history of past exposure. The observed
ratios vary from air lead level to air lead level; they are generally
between 1 and 2. Evidence suggests that the ratios for children
may-be higher than those of adults; also it suggests that ratios
for males may be higher than those for females."
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The range of ratios for children's blood lead response to a one ug
increase in air lead cited in the Criteria Document is from 1.2 to 2.3.
The lower ratio comes from studies at Kellogg, Idaho, where dust levels
of lead were separately correlated with blood lead. In view of the
tendency of children to experience higher ratios both due to greater
intake and absorption of air lead, EPA has selected a ratio of 1:2 in
calculating the impact of air lead levels on blood lead levels in children.
EPA recognizes the difficulty in selecting a single air lead/blood
lead relationship which describes the contribution of air lead to blood
lead levels in children. This is in part because there is evidence
in the literature that the relationship between lead in air and lead in
blood is not a simple linear regression which can be expressed as a ratio,
but that it is actually curvilinear in nature. However, for use as a
basis for calculating an air standard, EPA has chosen the constant
relationship of 1:2 for children, which appears appropriate over the range
of observed air lead levels.
Although available data which associate air lead levels with
blood lead levels in children are limited, there are a number of studies
which develop air lead/blood lead relationships for adults. Among these,
the Azar study and the Rabinowitz study provide evidence that the air lead/
blood lead relationship for adults may exceed 1:2. EPA has not data to
indicate that the air lead/blood lead relationship for children would be
lower than those observed for adults. To the contrary, in view of the
fact that children are more susceptible to the adverse effects of lead
exposure and that ingestion of air-derived lead from dust and dirt is a
significant source of exposure for children, the relationship of 1:2
34
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for children is reasonable. Margin of safety considerations have also
entered into the judgment that the relationship of 1:2 is appropriate
for the most sensitive population.
CALCULATION OF THE AIR STANDARD
EPA has calculated the standard based on the conclusions reached
in the previous sections:
1. Sensitive population: children, ages 1-5.
2. Health basis: impaired heme synthesis as indicated by elevated
erythrocyte protoporphyrin (EP) in a significant proportion of
the sensitive population at a level of lead in the blood of
30 ug/dl.
3. Maximum safe blood lead mean for the sensitive population,
based on the maintenance of 99.5 - 99.9 percent of the
sensitive population below the 30 ug/dl level of concern:
15 ug/dl.
4. Assumed goal for contribution to blood lead level from non-air
sources: 12 ug/dl.
5. Allowable contribution to blood lead from air sources:
15 ug Pb/dl - 12 ug Pb/dl = 3 ug Pb/dl.
6. Air lead target consistent with blood lead contribution from
air sources:
3 ug Pb/dl x 1 ug/m3 air = 1.5 ug Pb/m3
2 ug/dl blood
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SELECTION OF THE AVERAGING PERIOD FOR THE STANDARD
Based on comments received and consideration by the Agency, the
proposed averaging period of a calendar month is extended to a calendar
quarter. EPA believes that the change will significantly improve the
validity of the lead air quality data which will be gathered to monitor
progress towards attainment without placing an undue burden on state and
local environmental agencies or significantly reducing the protectiveness
of the final standard.
The Agency believes that the key criterion for the averaging
period is the protection of the health of the sensitive population.
In proposing the 1.5 yg/m standard, EPA concluded that this air level
was safe for the indefinite esposure of young children. Critical to the
determination of the averaging period is the health significance of
possible elevations of air lead above 1.5 ug/m which could be encountered
without violation of the standard. In the proposed standard, EPA chose a
monthly averaging period on the basis of a study showing an adjustment
period of blood lead level with a change in exposure. Because of the
scientific and technical difficulties of the monthly standard, EPA
has reexamined this question and concluded that there is little reason
to expect that the slightly greater possibility of elevated air lead
levels sustainable by the quarterly standard is significant for health.
This conclusion is based on the following factors:
(1) from actual ambient measurements, there is evidence that the
distribution of air lead levels is such that there is little
possibility that there could be sustained periods greatly
above the average value.
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(2) while it is.difficult to relate the extent to which a monitoring
network actually represents the exposure situation for young
children, it seems likely that where elevated air lead levels
do occur, they will be close to point or mobile sources.
Typically,young children will not encounter such levels for
the full twenty-four hour period reported by the monitor.
(3) there is medical evidence indicating that blood lead levels
reequilibrate slowly to changes in air exposure which serves to
dampen the impact of a short-term period of exposure to
elevated air lead.
(4) since direct exposure to air is only one of several routes of
total exposure, a change in air lead would not impact
proportionally on blood lead levels.
On balance, the Agency concludes that a requirement for the averaging
of air quality data over a calendar quarter will improve the validity of
air quality data gathered without a significant reduction in the
protectiveness of the standard.
MARGIN OF SAFETY
The Clean Air Act instructs EPA to set the level of an ambient atr
quality standard at a level which protects the public health with a margin
of safety. This is normally achieved by estimating the air concentration
of a pollutant that is the threshold for the first adverse effect detected
with increasing air levels, and then setting the air standard at a somewhat
lower level. The extent of the margin between the standard and the estimated
threshold for adverse effects is influenced by such factors as the severity
or irreversibility of effects, the degree of uncertainty about known or
suspected health effects, the size of the population at risk, and possible
interactions of several pollutants in potentiating health effects.
37
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While the margin of safety is based on available scientific information,
this factor is judgmental in that the Administrator must weigh the
acceptability of known risk and uncertainty along with scientific data.
In actual practice, selecting a standard is rarely straight forward. In
the case of lead air pollution, the estimate of margin of safety is complicated
by the multiple sources and media of lead exposure EPA has elected to consider
a margin of safety in determining each of the intermediate factors rather than
in a single final adjustment to the calculated air level.
Some commenters on the proposed standard argued that the process
is in fact a multiple addition of safety factors which results in an
unreasonably large margin, the magnitude of which is not presented as a
single factor.
Other commenters have argued that in determining the intermediate
factors EPA has done nothing more than make reasonable judgments
which do not constitute a margin of safety at all.
EPA believes that determining the appropriate margin of safety
for air lead should include consideration of the above points as well
as the following considerations:
1) in addition to the pivotal health effect discussed in
determining the health effects threshold - impaired heme synthesis
indicated by EP elevation - the air quality criteria document
reports multiple biological involvements of lead in practically
all cell types, tissues, and organ systems.
38
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2) the criteria document reports that there are well documented
and increasingly serious toxic effects of lead at levels close to the
CDC estimate for undue exposure - 30 ug Pb/dl. These include anemia
at a threshold of 40 ug Pb/dl and CNS deficiencies at 50 ug Pb/dl.
3) there are no beneficial effects of lead at environmental levels.
4) EPA has incomplete data about the extent to which children are
indirectly exposed to lead from air lead which moves to other
other environmental media, such as water, soil &'dirt, and food.
5) lead is persistent and accumulates both in human tissue and in
the environment.
6) there is a possibility that lead exposure resulting
in blood lead levels previously considered safe may in fact in-
fluence the neurological development and learning abilities of the
young child. EPA does not have evidence, however, that provides
more than a suggestion that this could occur at blood lead levels
below 30 Pb/dl for individual children.
From all of these factors, EPA concludes that while the air standard
which it has calculated has used some conservative estimates of
intermediate factors, the net effect of these is not excessive in terms
of margin of safety.
IMPACT OF LEAD DUSTFALL ON BLOOD LEAD
In the preamble for the proposed air standard for lead, EPA pointed
out that the significance of dust and soil lead as indirect routes of
39
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exposure has been of particular concern in the case of young children.
Play habits and mouthing behavior between the ages of one and five have
led to the conclusion that greater potential may exist in these children
for ingestion and inhalation of the lead available in dust and soil.
EPA is also concerned that the deposition of lead particles can lead to
general contamination of the environment and increased lead exposure from
surface waters and foodstuffs.
Studies reviewed in the Criteria Document indicate a correlation between
soil and dust levels and childrens' blood lead levels in highly con-
taminated environments (Yankel and von Lindern, 1977; Sarltrop, 1974;
Galke, in press). The lead threshold for concern has been reported as
1,000 ppm in soil (Yankel and von Lindern, 1977); at exposures of 500
and 1,000 ppm soil the document concludes that blood levels begin to in-
crease. A two-fold increase in soil concentration in this range is
predicted to result in a 3-6 percent rise in blood lead levels. Below
500 ppm soil, no correlation has been observed with blood lead levels.
The normal background for lead in soil is cited in the Criteria
Document as 15 ppm. Due to human activities, the average levels in most
areas of the U.S. are considerably higher. Soil studies conducted by
EPA's Office of Pesticides Programs from 1974-1976 in 17 urban areas
reported only 3 cities with arithmetic mean concentrations in excess of
200 ppm, with the highest value 537 ppm. Concentrations in the soils
surrounding large point sources of lead emissions, or heavily-travelled
roads may reach several thousand ppm.
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Because of the many factors involved, EPA is unable to predict the
relationship between air lead levels, dustfall rates, and resulting
soil accumulation. Complicating factors include: particle size distri-
bution, rain-out, other meteorological factors, topographical features
affecting deposition, and removal mechanisms.
EPA believes, however, that significant impacts on blood lead of
soil and dust lead are mainly limited to areas of high soil concentration
(in excess of 1,000 ppm) around large point sources and in major urban
areas which also experience high air lead levels. Evidence suggests that
soil lead levels in areas with air lead levels in the range of the pro-
posed standard are well below the threshold for lead impact (Johnson,
Tillery, 1975; Johanson, 1972; EPA, 1975 Air Quality Data and Soil Levels).
Some comments received on the proposed standard argued that the lead
air standard should be limited to respirable size of lead particulate, as
larger particles would fall to the ground without being deposited or
absorbed by the lung. EPA has decided not to accept this recommendation
because as discussed above, larger particles can contribute to lead dose
by human ingestion of airborne particles or by contamination of other
environmental media.
WELFARE EFFECTS
Comments received on the proposed lead air quality standard did
not address the issue of welfare effects and the need for a secondary
air quality standard more restrictive than the primary standard. EPA
maintains its position that the primary air quality standard will adequately
protect against known and anticipated adverse effects on public welfare.
A more restrictive secondary standard does not appear justified by
evidence at this time.
41
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Available evidence cited in the Criteria Document indicates that
animals do not appear to be more susceptible to adverse effects from lead
than man,nor do adverse effects in animals occur at lower levels of exposure
than comparable effects in humans.
There is evidence that lead has both harmful and beneficial effects
on plants. Lead is absorbed but not accumulated to any great extent by
plants from soil. Lead is either unavailable to plants or is fixed in
the roots and only small amounts are transported to the above ground
portions. Lead may be deposited on the leaves of plants and present a
hazard to grazing animals. Although some plants may be susceptible to
lead in the natural environment, it is generally in a form that is largely
non-available to them.
There is no evidence to indicate that ambient levels of lead result
in significant damage to man-made materials. Effects of lead on visibility
and climate are minimal.
Based on such data, EPA promulgates the secondary air quality standard
•5.
for lead at 1.5 yg Pb/m , calendar quarter average.
Economic Impact Assessment
As required by Executive Orders 11821, 12044, March 24, 1978, EPA has
conducted a general analysis of the economic impact which might result from
the implementation of the lead regulations. This analysis was not intended
for nor was it used in the development or promulgation of the standard and was
issued for informational purposes only. Ten organizations submitted written
comments or presented testimony regarding the Economic Impact Assessment at the
February public hearing for the implementation of the lead air quality standard,
The comments were basically supportive of the Economic Impact Assessment
in terms of industries which would be impacted. However, the comments
forecast more severe impacts within some of these industries than did the
42
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Economic Impact Assessment. Because the comments do not include data which
would allow EPA to confirm the assertions of more severe impact, the
Economic Impact Assessment has not been revised.
The Economic Impact Analysis points out that the categories of sources
likely to be affected by control of lead emissions are primary lead and
copper smelters, secondary lead smelters, gray iron foundries, gasoline lead
additive manufacturers, and lead storage battery manufacturers. This
analysis further indicates that primary and secondary lead smelters and
copper smelters may be severely strained economically in achieving emission
reductions that may be required in implementing the proposed air quality
standard.
There are, however, uncertainties associated with evaluating the
impact of attaining the standard. For smelters and foundries, attaining
the standard may require control of fugitive lead emissions, i.e.,
those emissions escaping from individual process operations, other than
emissions from smoke stacks. Fugitive emissions are difficult to estimate,
measure, and control; and it is also difficult to predict their impact on
air quality near the facility. From the information available to EPA,
non-ferrous smelters may have great difficulty in achieving lead air quality
levels consistent with the proposed standard in areas immediately adjacent to
the smelter complex.
43
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The change in averaging time from a monthly average to a calendar
quarter average will affect the economic impacts associated with the lead
standard because for the given level of the standard, a longer averaging
time is theoretically less stringent than a shorter averaging time.
Other Lead Regulatory and Control Programs
EPA's ambient air quality standard is only one cf a number of Federal,
state, and local programs designed to limit exposure to lead. Within
EPA, there exist standards and regulations relating to lead in drinking
water, industrial effluent, ambient waters, pesticides,and hazardous
waste. Lead in food is controlled by FDA, and CPSC and HUD have programs
addressing lead in paint on environmental surfaces. CDC has a program of
blood lead screening for children. There are a large number of control programs
operated by state, local, and private organizations. Also, Federal and
academic institutions sponsor a diverse program of research*relating to
environmental lead and its effects. EPA expects that the ambient air
standard can, by control of one of the principal sources of environmental
lead, contribute to goals and objectives common to all of these programs.
In developing the lead air standard, EPA has estimated both individual
and population blood lead levels which it regards as safe targets. The
Agency believes that these targets should not necessarily serve as
precedents for other regulatory programs. There are two reasons for this
view:
1) these targets were selected on the basis of what the Clean
Air Act requires. Other programs have other legislative
requirements which would lead to adoption of different but
equally legitimate goals.
44
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2) the scientific data provided by the air quality criteria allowed
comparison of air levels with blood lead levels, but analagous
information is not available for other media. At this cime, there
does not appear to be the same extent of information about the
impact on b'.ood lead of lead in food, water, and non-food ingested
items. Because of this EPA, FDA and CPSC standards have been
based on estimates of acceptable daily dose rather than on blood
lead targets.
Comments by other Federal Agencies
Comments on the proposed lead air quality standard were received
from eight Federal agencies. Five of the agencies endorsed the air
standard while three of the agencies commented on specific issues and
neither endorsed nor opposed the standard. The Center for Disease
Control and the U.S. Public Health Service voiced support for the proposed
standard of 1.5 lag Pb/m and urged basing the decision on the standard
solely on considerations of the public health. CDC is fully satisfied
that EP elevation does indeed represent a subclinical manifestation of lead
toxicity and that young children are the population most at risk from lead
exposure, while some subgroups of children are at special risk to lead
because of conditions such as malnutrition, genetic factors, or iron
deficiency.
The Consumer Product Safety Commission endorsed the approach and
some of the judgments made in arriving at the air standard. CPSC con-
curs with the position that children are the population at enhanced
risk to lead exposure, and that the goal of a mean population blood
lead level for children of 15 ug Pb/dl is sufficiently low to be protective
of the population at enhanced risk of exposure. CPSC views the selection
of EP elevation as the adverse health effect of concern as open to
challenge and suggests basing the standard on a more generally recognized
severe health effect. CPSC concurs that the contribution of non-air
-------
sources to lead body burden must be evaluated in setting the air standard
and suggests that a larger non-air contribution, such as 13.5 yg Pb/dl
used in the California standard, might be considered.
The Food and Drug Administration commended EPA's proposal of an
ambient air quality standard for lead. FDA agrees that children aged
1-5 years old comprise the most critically sensitive population. FDA
concurs that 15 yg Pb/dl is a reasonable maximum blood lead level to use
as an average national goal for children aged 1 to 5, although FDA
suggests that for young children the margin of safety is disturbingly
narrow. The division of the 15 yg Pb/dl into 12 yg Pb/dl for non-air
sources and 3 yg Pb/dl for air sources was not unreasonable in FDA's view.
The Occupational Safety and Health Administration endorsed EPA's
proposed standard for lead and agrees with EPA that 15 yg Pb/dl as an
average national blood lead level goal for youag children is reasonable.
OSHA views their proposed standard of 100 yg Pb/m3, 8-hour time weighted
average, and their establishment of 40 yg Pb/dl as the threshold effect level
for workers as consistent with the EPA proposed standard.
The Department of Transportation (DOT) endorsed the proposed standard
of 1.5 yg Pb/m . Based on an analysis of the impact of the
proposed standard on the highway program, DOT concluded that it is highly
probable that transportation-related violations of the proposed standard
would be limited to large urban areas.
In commenting on the proposed standard, the Department of the Interior
(DOI) expressed concern that the burden for meeting the proposed standard
will fall primarily on lead and copper smelters and battery manufacturers,
and commented on the impact of lead dustfall on ground water quality.
The Tennessee Valley Authority provided specific comments on the proposed
State Implementation Plan Regulations and the proposed Federal Reference
46
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Method. The Department of Commerce offered comments on the
potential impacts of the standard t pointing out that more consideration
should be given to the potential impact of the standard on the petroleum
industry.
The Occupational Safety and Health Administration proposed regulations
in 1975 to limit occupational exposure to lead to 100 ug Pb/m , 8-hour
time weighted average. The exposure limit was based on protecting against
effects, clinical or subclinical, and the mild symptoms which may occur
below 80 ug Pb/dl, providing an adequate margin of safety. The level of
100 ug Pb/m3 anticipated to limit blood lead levels in workers to a mean
40 yg Pb/dl and a maximum of 60 ug Pb/dl. OSHA is presently reviewing the
latest information on lead exposure and health effects in preparation for
promulgation of the workplace standard for lead.
The Department of Housing and Urban Development (HUD) has requirements
for reducing human exposure to lead through the prevention of lead
poisoning from ingestion of paint from buildings, especially residential
dwellings. Their activities include (1) prohibition of use of lead-based
paints on structures constructed or rehabilitated through Federal funding
and on all HUD-associated housing; (2) the eliminations of immediate
lead based paint hazard; (3) notification of purchases of HUD-associated
housing constructed prior to 1950 that such dwellings may contina lead-
based paint; and (4) research activities to develop improved methods of
detection and elimination of lead-based paint hazards, and the nature
and extent of lead poisoning.
The Consumer Product Safety Commission (CPSC) promulgated regulations
in September 1977 which ban:(l) paint and other surface coating materials
containing more than 0.06 percent lead; (2) toys and other articles
intended for use by children bearing paint or other similar surface coating
47
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material containing more than 0.06 percent lead; and (3) furniture coated
with materials containing more than 0.06 percent lead. These regulations
are based on CPSC's conclusion that it is in the public interest to reduce
the risk of lead poisoning to young children from ingestion of paint
and other similar surface-coating materials.
The Food and Drug Administration adopted in 1974 a proposed tolerance
for lead of 0.3 ppm in evaporated milk and evaporated skim milk. This
tolerance is based on maintaining children's blood lead levels below
40 ug Pb/dl. FDA also has a proposed action level of 7 ug/ml for
Teachable lead in pottery and enamelware, although the exact contribution
of such exposure to total human dietary intake has not been established.
The Center for Disease Control concluded in 1975 that undue or increased
lead absorption exists when a child has confirmed blood lead levels of
30-70 ug Pb/dl or an EP elevation of 60-189 ug Pb/dl except where the
elevated EP level is caused by iron deficiency. This guideline is presently
accepted by the scientific community but because of more recent data is
being reevaluated.
Other EPA Regulations on Lead
In 1975, EPA promulgated the national interim primary drinking water
regulation for lead. The standard was aimed at protecting children from
undue lead exposure and limiting lead to 0.05 milligrams per liter (mg/1)
which was considered as low a level as practicable. In 1977, the National
Academy of Sciences evaluated the interim drinking water standards and
concluded that a lead level at which adverse health effects are observed cannot be
48
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set with assurance at any value greater than 0.025 mg/1. The Office of
Water Supply is currently reviewing the need to revise the interim
drinking water standard for lead.
Based on its toxicity, EPA included lead on its 1977 list of priority
pollutants for which effluent guidelines will be developed by early 1979.
Effluent guidelines for non-ferrous smelters, the major stationary source
emitters of airborne lead, are being developed based on achievement of
best available technology.
EPA's Office of Pesticide Programs has promulgated regulations based
on toxicity of lead which require the addition of coloring agents to the
presticide lead arsenate and specify disposal procedures for lead pesticides.
Use of lead in pesticides is a small and decreasing proportion of total lead
consumption in the U.S.
The Resource Conservation and Recovery Act of 1976 through which EPA
is to establish standards on how to treat, dispose, or store hazardous wastes,
provides a means for specifying how used crankcase oil and other waste streams
containing lead should be recycled or safely disposed of. At the present
time, no regulatory actions related to wastes containing lead have been proposed,
EPA has regulations for reducing the lead content in gasoline to 0.5 grams/
gallon by October 1, 1979, and regulations providing for lead-free gasoline
required for cars equipped with catalytic converters and other vehicles
certified for use of unleaded fuel. The former regulations are based on
reducing exposure to airborne lead to protect public health. Other EPA
actions which result in the reduction of airborne lead levels include
ambient standards and State implementation plans for other pollutants such
49
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as particulate matter and sulfur dioxide and new source performance
standards limiting emissions of such pollutants. Existing and new
sources of particulate matter emissions generally use control techniques
which reduce lead emissions as one component of particulate matter.
The Federal Reference Method
The Federal Reference Method for Lead describes the appropriate tech-
niques for determining the concentration of lead and its compounds as
measured as elemental lead in the ambient air. A total of eight
organizations submitted written comments on the method and two persons
made comments at EPA's February public hearing on the proposed air quality
standard. Since proposal of the Federal Reference Method for lead, EPA has
completed additional testing of the method and added new information on the
precision of the extraction analysis procedure.
Two of the commenters recommended the addition of a nitric plus
hydrochloric acid extraction procedure. The extraction procedure of the
proposed method contains only nitric acid. Use of a mixed acid procedure
would permit the analyst to quantitatively extract more metals than just
lead, thereby allowing him to analyze the same extract for more than one
metal. The analysis for lead would not be affected. EPA agrees that a
mixed acid extraction procedure should be added, and the revised method
contains a mixed nitric-hydrochloric acid extraction procedure.
One commenter questioned the reliability of the air volume measured
in the sampling procedure because of differences between initial and
final flow rates caused by build-up of particulate matter on the collecting
filter. The method of sampling specifies that initial and final flow
50
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rates must fall between 40 and 60 cubic feet per minute and variations
within this range cause only a slight error. If the flow rate specification
is not met, the sample should be voided. For these reasons, EPA believes the
air volume measurement does not suffer unduly from inaccuracies.
A question was raised as to the effect of variation in lead content
across the filter of the collected sample on lead analysis, since the
method calls for analysis of only one strip or one-twelfth of the
filter. Our work has shown that strips taken from different positions
within the filter can, on occasion, produce different lead values,
but the effect appears to be significant only when sampling near a heavily
traveled roadway. The proposed method recommends analyzing additional
strips, when sampling near a roadway, to minimize this error.
One commenter pointed out that the proposed sampling procedure
does not collect gaseous (organic) lead compounds and recommended that EPA
consider requiring the use of a method for monitoring gaseous lead. As
the Criteria Document states,reported ambient levels of gaseous lead are
very low and EPA has determined that the effort required to carry out
the difficult task of monitoring for ambient gaseous lead is not justified
in view of the extremely low concentration.
It was pointed out in the preamble to the proposed method that other
analytical principles would probably be handled by provision for approval
of the equivalent methods (40 CFR Part 53) proposed elsewhere in this Federal
Register. Two organizations submitted requests that alternate methods (x-ray
fluorescence and anodic stripping voltametry) for lead analysis be declared
equivalent to the reference method. These requests will be considered when
the procedures for determining equivalency are promulgated.
The final Federal Reference Method is based on measuring the lead con-
tent of suspended particulate matter or glass fiber filters using high
51
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volume sampling. The lead is then extracted from the particulate matter with
nitric acid facilitated by heat or by a mixture of nitric acid and
hydrochloric acid facilitated by ultrasonication. Finally, the lead
content is measured by atomic absorption spectrometry.
The reference method specified for lead measures the lead for a
single sampling period by extraction of a portion of a high-volume
glass fiber filter used to collect particulate matter over a 24-hour
period. Some agencies may perfer to composite filter strips from a
number of sampling periods and extract and analyze it for lead. This
procedure is acceptable provided the agency shows that the compositing
procedure results in the same average lead value as would be obtained
from averaging individual values.
Date Administrator
52
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The Agency amends Title 40, Part 50, of the Code of Federal
Regulations by adding a new §50.12 and a new Appendix G as follows:
The national primary and secondary air quality standards
for lead and its compounds, measured as elemental lead
by a reference method based on Appendix G to this Part, or
by an equivalent method, are: 1.5 micrograms per cubic
meter, maximum arithmetic mean averaged over a calendar
quarter.
(Sections 109 and 301(a) of the Clean Air Act as amended
(42 U.S.C. 7409, 7601(a)J.)
53
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REFERENCE METHOD FOR THE DETERMINATION OF LEAD IN
SUSPENDED PARTICULATE MATTER COLLECTED FROM AMBIENT AIR
U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF RESEARCH AND DEVELOPMENT
ENVIRONMENTAL MONITORING AND SUPPORT LABORATORY
RESEARCH TRIANGLE PARK, NORTH CAROLINA 27711
JULY 1978
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July 1978
REFERENCE METHOD FOR THE DETERMINATION OF LEAD IN
SUSPENDED PARTICULATE MATTER COLLECTED FROM AMBIENT AIR
1. Principle and Applicability
1.1 Ambient air suspended particulate matter is collected on a
glass-fiber filter for 24-hours using a high volume air sampler.
1.2 Lead in the particulate matter is solubilized by extraction with
nitric acid (HNO-), facilitated by heat or by a mixture of HN03 and hydrochloric
acid (HC1) facilitated by ultrasonication.
1.3 The lead content of the sample is analyzed by atomic absorption
spectrometry using an air-acetylene flame, the 283.3 or 217.0 nm lead absorption
line, and the optimum instrumental conditions recommended by the manufacturer.
1.4 The ultrasonication extraction with HN03/HC1 will extract metals
other than lead from ambient particulate matter.
2. Range, Sensitivity and Lower Detectable Limit
The values given below are typical of the methods capabilities. Absolute
values will vary for individual situations depending on the type of instrument
used, the lead line, and operating conditions.
3
2.1 Range. The typical range of the method is 0.07 to 7.5 ug Pb/m
assuming an upper linear range of analysis of 15 ug/ml and an air volume of
2400 m3.
2.2 Sensitivity. Typical sensitivities for a 1% change in absorption
(0.0044 absorbance units) are 0.2 and 0.5 ug Pb/ml for the 217.0 and 283.3 nm
lines, respectively.
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2.3 Lower Detectable Limit (LDL). A typical LDL is 0.07 yg Pb/m3.
The above value was calculated by doubling the between-laboratory standard
deviation obtained for the lowest measurable lead concentration in a colla-
borative test of the method.15 An air volume of 2400 m was assumed.
3. Interferences
Two types of interferences-are possible: chemical, and light scattering.
3.1 Chemical. Reports on the absence T'2'3'4'5 Of chemical inter-
ferences far outweigh those reporting their presence, therefore, no correction
for chemical interferences is given here. If the analyst suspects that the
sample matrix is causing a chemical interference, the interference can be
verified and corrected for by carrying out the analysis with and without the
method of standard additions.
3.2 Light Scattering. Non-atomic absorption or light scattering,
produced by high concentrations of dissolved solids in the sample, can produce
2
a significant interference, especially at low lead concentrations. The inter-
ference is greater at the 217.0 nm line than at the 283.3 nm line. No inter-
ference was observed using the 283.3 nm line with a similar method.
Light scattering interferences can, however, be corrected for
instrumentally. Since the dissolved solids can vary depending on the origin
of the sample, the correction may be necessary, especially when using the
217.0 nm line. Dual beam instruments with a continuum source give the most
accurate correction. A less accurate correction can be obtained by using a
non-absorbing lead line that is near the lead analytical line. Information
on use of these correction techniques can be obtained from instrument manu-
facturers' manuals.
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If instrumental correction is not feasible, the interference can
be eliminated by use of the ammonium pyrrolidinecarbodithioate-methylisobutyl
g
ketone, chelation-solvent extraction technique of sample preparation.
4. Precision and Bias
4.1 The high-volume sampling procedure used to collect ambient air particulate
matter has a between-laboratory relative standard deviation of 3.7% over the range
80 to 125 ug/m3.9 The combined extraction - analysis procedure has an average with-
in-laboratory relative standard deviation of 5 to 6% over the range 1.5 to 15 yg
Pb/ml, and an average between laboratory relative standard deviation of 7 to 9% over
the same range. These values include use of either extraction procedure.
4.2 Single laboratory experiments and collaborative testing indicate that
there is no significant difference in lead recovery between the hot and ultrasonic
extraction procedures.
5. Apparatus
5.1 Sampling.
5.1.1 High-volume sampler. Use and calibrate the sampler as described
in reference 10.
5.2 Analysis.
5.2.1 Atomic Absorption Spectrophotometer. Equipped with lead hollow
cathode or electrode!ess discharge lamp.
5.2.1.1 Acetylene. The grade recommended by the instrument manufacturer
should be used. Change cylinder when pressure drops below 50-100 psig.
5.2.1.2 Air. Filtered to remove particulate, oil and water.
5.2.2 Glassware. Class A borosilicate glassware should be used through-
out the analysis.
3
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5.2.2.1 Beakers. 30 and 150 ml. graduated, Pyrex.
5.2.2.2 Volumetric flasks. 100-ml.
5.2.2.3 Pipettes. To deliver 50, 30, 15, 8, 4, 2, 1 ml.
5.2.2.4 Cleaning. All glassware should be scrupulously cleaned. The
following procedure is suggested. Wash with laboratory detergent, rinse, soak
for 4 hours in 20% (w/w) HN03, rinse 3 times with distilled-deionized water,
and dry in a dust free manner.
5.2.3 Hot plate.
5.2.4 Ultrasonication water bath, unheated. Commercially available
laboratory ultrasonic cleaning baths of 450 watts or higher'"cleaning power", i.e.,
actual ultrasonic power output to the bath have been found satisfactory.
5.2.5 Template. To aid in sectioning the glass-fiber filter. See
Figure 1 for dimensions.
5.2.6 Pizza cutter. Thin wheel. Thickness <1 mm.
5.2.7 Watch glass.
5.2.8 Polyethylene bottles. For storage of samples. Linear polyethylene
gives better storage stability than other polyethylenes and is preferred.
5.2.9 Parafilm "M".* American Can Company, Marathon Products, Nennah,
Wisconsin, or equivalent.
5. Reagents
6.1 Sampling
6.1.1 Glass fiber filters. The specifications given below are intended
to aid the user in obtaining high quality filters with reproducible properties.
These specifications have been met by EPA contractors.
*Mention of commercial products does not imply endorsement by the U.S. Environmental
Protection Agency.
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6.1.1.1 Lead content. The absolute lead content of filters is not critical,
but low values are, of course, desirable. EPA typically obtains filters with a
lead content of <75 yg/filter.
It is important that the variation in lead content from filter to
filter, within a given batch, be small.
6.1.1.2 Testing.
6.1.1.2.1 For large batches of filters ( > 500 filters) select at random
20 to 30 filters from a given batch. For small batches (< 500 filters) a lesser
number of filters may be taken. Cut one 3/4" x 8" strip from each filter any-
where in the filter. Analyze all strips, separately, according to the directions
in Sections 7 and 8.
6.1.1.2.2 Calculate the total lead in each filter as
- n DhAnl v ] °° ""1 y 12 StHpS
b- yg Pb/ml x ^pjp- x fi
where:
Fb= Amount of lead per 72 square inches of filter,
6.1.1.2.3 Calculate the mean, Fb, of the values and the relative standard
deviation (standard deviation/mean x 100). If the relative standard deviation
is high enough so that, in the analysts opinion, subtraction of Fb, (Section 10.3)
may result in a significant error in the yg Pb/m3, the batch should be rejected.
6.1.1.2.4 For acceptable batches, use the value of Fb to correct all lead
analyses (Section 10.3) of particulate matter collected using that batch of filters.
If the analyses are below the LDL (Section 2.3) no correction is necessary.
6.2 Analysis
6.2.1 Concentrated (15.6 M) HNO^ ACS reagent grade HN03 and commer-
cially available redistilled HN03 has been found to have sufficiently low lead con-
centrations.
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6.2.2 Concentrated (11.7 M) HC1. ACS reagent grade.
6.2.3 Distilled-deionized water. (D.I. water).
6.2.4 3 M HN03. Add 192 ml of concentrated HN03 to D.I. water in a
1 SL volumetric flask. Shake well, cool, and dilute to volume with D.I. water.
CAUTION: Nitric Acid Fumes Are Toxic. Prepare in a well ventilated fume hood.
6.2.5 0.45 M HN03. Add 29 ml of concentrated HN03 to D.I. water in
a H volumetric flask. Shake well, cool, and dilute to volume with D.I. water.
6.2.6 2.6 M_ HN03 + 0 to 0.9 M. HC1. The concentration of HC1 can be
varied from 0 to 0.9 M_. Directions are given for preparation of a 2.6 M HN03 +
0.9 M HC1 solution. Place 167 ml of concentrated HN03 into a H volumetric flask
and add 79 ml of concentrated HC1. Stir 4 to 6 hours, dilute to nearly H with
D.I. water, cool to room temperature, and dilute to H.
6.2.7 0.40 M HN03 + X M HC1. Add 26 ml of concentrated HN03, plus the
ml of HC1 required, to a U volumetric flask. Dilute to nearly H with D.I. water,
cool to room temperature, and dilute to U. The amount of HC1 required can be
determined from the following equation:
79 ml x 0.15 x "
0.9 M
where:
y = ml of concentrated HC1 required
x = molarity of HC1 in 6.26
0.15 = dilution factor in 7.2.2
6.2.8 Lead Nitrate, Pb(N03)2- ACS reagent grade, purity 99.0%. Heat
for 4-hours at 120°C and cool in a desiccator.
6.3 Calibration Standards
6.3.1 Master standard, 1000 ug Pb/ml in HN03- Dissolve 1.598 g of
Pb(N03)2 in 0.45 M HN03 contained in a 1 t volumetric flask and dilute to volume
with 0.45 M HN03.
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6.3.2 Master Standard, 1000 yg Pb/ml in HN03/HC1. Prepare as in
6.3.1 except use the HN03/HC1 solution in 6.2.7.
Store standards in a polyethylene bottle. Commercially avail-
able certified lead standard solutions may also be used.
7. Procedure
7.1 Sampling. Collect samples for 24-hours using the procedure
described in reference 10 with glass-fiber filters meeting the specifications in
6.1.1. Transport collected samples to the laboratory taking care to minimize
contamination and loss of sample.
7.2 Sample Preparation.
7.2.1 Hot Extraction Procedure
7.2.1.1 Cutt a 3/4" x 8" strip from the exposed filter using a template
and a pizza cutter as described in Figures 1 and 2. Other cutting procedures may
be used.
Lead in ambient particulate matter collected on glass fiber
filters has been shown to be uniformly distributed across the filter ' '
12
suggesting that the position of the strip is unimportant. However, another study
has shown that when sampling near a road-way lead is not uniformly distributed across
the filter. The nonum'formity has been attributed to large variations in particle
size. Therefore, when sampling near a road-way, additional strips at different
positions within the filter should be analyzed.
7.2.1.2 Fold the strip in half twice and place in a 150-ml beaker. Add
15 ml of 3 N[ HN03 to cover the sample. The acid should completely cover the sample.
Cover the beaker with a watch glass.
7.2.1.3 Place beaker on the hot-plate, contained in a fume hood, and boil
gently for 30 min. Do not let the sample evaporate to dryness. CAUTION: Nitric
Acid Fumes Are Toxic.
7
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7.2.1.4 Remove beaker from hot plate and cool to near room temperature.
7.2.1.5 Quantitatively transfer the sample as follows:
7.2.1.5.1 Rinse watch glass and sides of beaker with D.I. water.
7.2.1.5.2 Decant extract and rinsings into a 100-ml volumetric flask.
7.2.1.5.3 Add D.I. water to 40 ml mark on beaker, cover with watch glass,
and set aside for a minimum of 30 minutes. This is a critical step and cannot
be omitted since it allows the HN03 trapped in the filter to diffuse into the
rinse water.
7.2.1.5.4 Decant the water from the filter into the volumetric flask.
7.2.1.5.5 Rinse filter and beaker twice with D.I. water and add rinsings
to volumetric flask until total volume is 80 to 85 ml.
7.2.1.5.6 Stopper flask and shake vigorously. Set aside for approximately
5 minutes or until foam has dissipated.
7.2.1.5.7 Bring solution to volume with D.I. water. Mix thoroughly.
7.2.1.5.8 Allow solution to settle for one hour before proceeding with
analysis.
7.2.1.5.9 If sample is to be stored for subsequent analysis, transfer to
a linear polyethylene bottle.
7.2.2 Ultrasonic Extraction Procedure
7.2.2.1 Cut a 3/4" x 8" strip from the exposed filter as described in
Section 7.2.1.1.
7.2.2.2 Fold the strip in half twice and place in a 30 ml beaker. Add
15 ml of the HN03/HC1 solution in 6.2.6. The acid should completely cover the
sample. Cover the beaker with Parafilm.
The Parafilm should be placed over the beaker such that none of
the Parafilm is in contact with water in the ultrasonic bath. Otherwise, rinsing
of the Parafilm (Section 7.2.2.4.1) may contaminate the sample.
8
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7.2.2.3 Place the beaker in the ultrasonication bath and operate for
30 minutes.
7.2.2.4 Quantitatively transfer the sample as follows:
7.2.2.4.1 Rinse Parafilm and sides of beaker with O.I. water.
7.2.2.4.2 Decant extract and rinsings into a 100 ml volumetric flask.
7.2.2.4.3 Add 20 ml D.I. water to cover the filter strip, cover with para-
film, and set aside for a minimum of 30 minutes. This is a critical step and
cannot be omitted. The sample is then processed as in Sections 7.2.1.5.4 through
7.2.1.5,9. NOTE: Samples prepared by the hot extraction procedure are now in
0.45 M^HNO-. Samples prepared by the ultrasonication procedure are in 0.40 M HNO.,
X MHC1.
8. Analysis
8.1 Set the wavelength of the monochromator at 283.3 or 217.0 nra.
Set or align other instrumental operating conditions as recommended by the manu-
facturer.
8.2 The sample can be analyzed directly from the volumetric flask, or
an appropriate amount of sample decanted into a sample analysis tube. In either
case, care should be taken not to disturb the settled solids.
8.3 Aspirate samples, calibration standards and blanks (Section 9.2)
into the flame and record the equilibrium absorbance.
8.4 Determine the lead concentration in ug Pb/ml, from the calibration
curve, Section 9.3.
8.5 Samples that exceed the linear calibration range should be diluted
with acid of the same concentration as the calibration standards and reanalyzed.
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9. Calibration
9.1 Working Standard, 20 ug Pb/ml. Prepared by diluting 2.0 ml
of the master standard (6.3.1 if the hot acid extraction was used or 6.3.2 if
the ultrasonic extraction procedure was used) to 100 ml with the same acid con-
centration as in the master standard.
9.2 Calibration standards. Prepare daily by diluting the working
standard, with the same acid matrix, as indicated below. Other lead concen-
trations may be used.
Volume of 20 yg/ml Final Concentration
Working Standard, ml Volume, ml yg Pb/ml
0 100 0.0
1.0 200 0.1
2.0 200 0.2
2.0 100 0.4
4.0 100 0.8
8.0 100 1.6
15.0 100 3.0
30.0 100 6.0
50.0 100 10.0
100 100 20.0
9.3 Preparation of calibration curve. Since the working range of
analysis will vary depending on which lead line is used and the type of instrument,
no one set of instructions for preparation of a calibration curve can be given.
Select standards (plus the reagent blank), in the same acid concentration as the
samples, to cover the linear absorption range indicated by the instrument manu-
facturer. Measure the absorbance of the blank and standards as in Section 8.0.
Repeat until good agreement is obtained between replicates. Plot absorbance
10
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(y-axis) versus concentration in ug Pb/ml (x-axis). Draw (or compute) a straight
line through the linear portion of the curve. Do not force the calibration curve
through zero. Other calibration procedures may be used.
To determine stability of the calibration curve, remeasure - alternately -
one of the following calibration standards for every 10th sample analyzed: con-
centration £ 1 ug Pb/ml; concentration £ 10 pg Pb/ml. If either standard deviates
by more than 5% from the value predicted by the calibration curve, recalibrate
and repeat the previous 10 analyses.
10. Calculation.
10.1 Measured air volume. Calculate the measured air volume as
Qi +Qf
V = x T
vm 2 x '
where:
2
V = Air volume sampled (uncorrected), m
3
Q- = Initial air flow rate, m /min.
3
Q- = Final air flow rate, m /min.
T = Sampling Time, min.
The flow rates Qi and Q- should be corrected to the temperature and pressure
conditions existing at the time of orifice calibration as directed in addendum B
of reference 10, before calculation of V .
10.2 Air volume at STP. The measured air volume is corrected to reference
conditions of 760 mm Hg and 25°C as follows. The units are standard cubic meters,
sm .
11
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VSTP = Vmx
Pl XT2
VSTp = Sample volume, sm3, at 760 mm Hg and 298° K
V = Measured volume from 10.1
m
P2 = Atmospheric pressure at time of orifice
calibration, mm Hg
P.| = 760 mm Hg
T2 = Atmospheric temperature at time of orifice
calibration, °K
T] = 298°K
10.3 Lead Concentration. Calculate lead concentration in the air sample,
(yg Pb/ml x 100 ml/strip x 12 strips/filter) - Fb
C =
VSTP
where:
C = Concentration, yg Pb/sm
yg Pb/ml = Lead concentration determined from Section 8
100 ml /strip = Total sample volume
,„ . . ..... Useable filter area, 7" x 9" _
12 strips/filter = Exposed area of one strip, 3/4" x /"
7. = Lead concentration of blank filter, yg, from Section
D
6.1.1.2.3
= Air volume from 10. 2
11. Quality Control
3/4" x 8" glass fiber filter strips containing 80 to 2000 yg Pb/strip
(as lead salts) and blank strips with zero Pb content should be used to
12
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determine if the method - as being used - has any bias. Quality control charts
should be established to monitor differences between measured and true values.
The frequency of such checks will depend on the local quality control program.
To minimize the possibility of generating unreliable data, the user should
follow practices established for assuring the quality of air pollution data,
and take part in EPA's semi-annual audit program for lead analyses.
12. Trouble Shooting
1. During extraction of lead by the hot extraction procedure, it is
important to keep the sample covered so that corrosion products - formed on
fume hood surfaces which may contain lead - are not deposited in the extract.
2. The sample acid concentration of 0.45 M^ should minimize corrosion
of the nebulizer. However, different nebulizers may require lower acid concen-
trations. Lower concentrations can be used provided samples and standards have
the same acid concentration.
3. Ashing of particulate samples has been found, by EPA and contractor
laboratories, to be unnecessary in lead analyses by Atomic Absorption. Therefore,
this step was omitted from the method.
4. Filtration of extracted samples, to remove particulate matter, was
specifically excluded from sample preparation, because some analysts have observed
losses of lead due to filtration.
5. If suspended solids should clog the neublizer during analysis of samples,
centrifuge the sample to remove the solids.
13. References
1. Scott, D. R. et al. Atomic Absorption and Optical Emission Analysis
of NASN Atmospheric Particulate Samples for Lead. Envir. Sci. and
13
-------
Tech., TO., 877-880 (1976).
2. Skogerboe, R. K. et al. Monitoring for Lead in the Environment.
pp. 57-66, Department of Chemistry, Colorado State University,
Fort Collins, Colorado 80523. Submitted to National Science
Foundation for publication, 1976.
3. Zdrojewski, A. et al. The Accurate Measurement of Lead in Airborne
Particulates. Inter. J. Environ. Anal. Chem., 2_, 63-77 (1972).
4. Slavin, W. Atomic Absorption Spectroscopy. Published by Inter-
science Company, New York, NY (1968).
5. Kirkbright, G. F., and Sargent, M. Atomic Absorption and Fluorescence
Spectroscopy. Published by Academic Press, New York, N.Y. 1974.
6. Burnham, C. D. et al. Determination of Lead in Airborne Particulates
in Chicago and Cook County, Illinois by Atomic Absorption Spectroscopy.
Envir. Sci. and Tech., 3., 472-475 (1969).
7. Proposed Recommended Practices for Atomic Absorption Spectrometry.
ASTM Book of Standards, Part 30, pp. 1596-1608 (July 1973).
8. Koirttyohann, S. R., and Wen, J. W. Critical Study of the APCD-MIBK
Extraction System for Atomic Absorption. Anal. Chem., 45, 1986-1989
(1973).
9. Collaborative Study of Reference Method for the Determination of
Suspended Particulates in the Atmosphere (High Volume Method).
Obtainable from National Technical Information Service, Department
of Commerce, Port Royal Road, Springfield, Virginia 22151, as
PB-205-891.
10.' Reference Method for the Determination of Suspended Particulates in
the Atmosphere (High Volume Method). Code of Federal Regulations, Title 40,
Part 50, Appendix B, pp. 12-16 (July 1, 1975).
14
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MANILA FILE FOLDER - TO PREVENT
FILTEH FROM SUCKING TO PLASTIC
RIGID PLASTIC
GLASS riDFR FIL I F.R
FOLDED (LENGTHWISE) IN HALF
-«-WIDTH OF GROOVE
6 nun
WIDTH OF
GdOQVr. \ cm
ALL GROOVES
2mm DEEP
25mm (1"» WIDE —
Figure 1
Apparatus and Procedure for Cuttinq
Fiber Filter Strips
-------
19mm ('/«")
STRIPS FOIl
OTHER ANALYSES
U" x 0" STRIP FOR
LEAD ANALYSIS
Figure 2
Apparatus and Procedure for Cutting Glass Fiber Filter Strips
-------
11. Dubois, L., et al. The Metal Content of Urban Air. JAPCA, 16,
77-78 (1966).
12. EPA Report No. 600/4-77-034, June 1977. Los Angeles Catalyst Study
Symposium. Page 223.
13. Quality Assurance Handbook for Air Pollution Measurement Systems.
Volume 1 - Principles. EPA-600/9-76-005, March 1976.
14. Thompson, R. J. et al. Analysis of Selected Elements in Atmospheric
Particulate Matter by Atomic Absorption. Atomic Absorption News-
letter, 9_, No. 3, May-June 1970.
15. To be published. EPA, QAB, EMSL, RTP, N.C. 27711
16. Hirschler, D. A. et al. Particulate Lead Compounds in Automobile
Exhaust Gas. Industrial and Engineering Chemistry, 49, 1131-1142
(1957).
17. Quality Assurance Handbook for Air Pollution Measurement Systems.
Volume II - Ambient Air Specific Methods. EPA-600/4-77-027a, May 1977.
15
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TAB B- Federal Register Preamble and Regulations for State
Implementation (Signature Item)
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Title 40~Protection of Environment
CHAPTER I—ENVIRONMENTAL 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 COMMENTS 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,1 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
-------
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 S 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 §§ 51.80 ("Demonstration of attainment") and
-------
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 included 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
ug/m3 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,
-------
and therefore EPA will avoid setting criteria in 4C 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 commenter suggested that EPA recommend 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.
-------
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 cornmenter 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.
-------
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
2
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
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
8
-------
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 ph'asedown 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
-------
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 is 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
commenters enumerated the problems with instituting further control of
the lead content of gasoline. The commenters 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.
10
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EPA recognizes this problem and advises the States to consider the
comment. Also, under S 211(c)(4)(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 conmenters 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
11
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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 arcbient 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
conmenters 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
12
-------
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 coinnenter 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 commenter 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
13
-------
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 frame 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.
14
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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 burn 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
15
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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
16
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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
17
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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 commenter 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
18
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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 i-n lead air
19
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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).4 In a forthcoming action,
EPA currently intends to propose 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 modifica-
tions would be to propose the change, hold a public hearing, and submit
20
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the change to EPA as a plan revision. EPA 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 forthcoming proposed requirements concerning air
quality monitoring, however, will 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 FECERAL 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
21
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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.
22
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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
'H LEAD.
5 jjg/m1
(1975)
URBANIZED AREAS WITH LEAD-AIR CONCENTRATIONS
EXCEEDING OR EQUAL TO 1.5 jjg/nT3, MAXIMUM QUARTERLY MEAN
AQCR# AREA
004 Binningham, Ala.
005 Jackson, Miss.
015 Phoenix, Ariz.
031 Fresno,. Calif.
024 Los Angeles—Long Beach, Cal-if.
028 Sacramento, Calif.
033 San Bernardino—Riverside, Calif.
029 San Diego, Calif.
030 San Francisco—Oakland, Calif.
030 San Jose, Calif.
036 Denver, Colo.
043 New York, H.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
25
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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 § 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:
§ 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 S 50.1 of this chapter.
29
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5. A new subpart E is added as follows:
Subpart E—Control Strategy: Lead
S 51.80 Demonstration of attainment.
§ 51.81 Emissions data.
§ 51.82 Air quality data.
S 51.83 Certain urbanized areas.
§ 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.
§ 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 51.32 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 lead 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
4.0 ug/m , quarterly mean measured since January 1, 197^, 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.
S 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.
§ '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.
S 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))
35
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TAB C- List of External Comments Opposing or Endorsing the
Proposed Standard
-------
COMMENTS RECEIVED OPPOSING THE PROPOSED STANDARD
OF 1.5 yg/m3 AS EXCESSIVELY STRINGENT
COMPANY
OPPOSED 1.5 ug/nT
calendar month
Amax Lead and Zinc, Inc. X
American Mining Congress X
American Petroleum Institute X
ASARCO X
Associated Octel X
Battery Council International X
Bethlehem Steel X
Bunker Hill Company X
C & D Batteries X
DuPont X
ESA Laboratories X
Ethyl X
General Battery Corporation X
General Motors Corporation
Getty Refining and Marketing X
HECLA Mining Company X
Houston Chemical X
Hunt Oil X
Kerr-McGee
Lead Industries Association X
Nalco Chemical X
N L Industries X
Prestolite Battery X
Secondary Lead Smelters
Association X
Shell Oil X
St. Joe Minerals X
Texaco, Inc. X
United Machinery Group
Vulcan Materials Company
ENDORSED 5.0 yg/m ,
calendar quarter (or
other averaging period)
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Summary: 45 comments received from 29 corporations or their representatives
25 of the 29 firms opposed the proposed standard of 1.5 yg/m ,
calendar month average;
o
20 endorsed an alternative standard of 5.0 yg/m , calendar
quarter average (or other averaging period).
-------
COMMENTS RECEIVED OPPOSING PROPOSED LEAD AIR QUALITY
STANDARD OF 1.5 ug/m3, CALENDAR MONTH
IN FAVOR OF A MORE STRINGENT STANDARD
Natural Resources Defense Council
Sergio Piomelli, Pediatric Hematology, Mew York University Medical Center
Public Interest Campaign
University of Connecticut Health Center
COMMENTS RECEIVED ENDORSING PROPOSED LEAD AIR QUALITY
STANDARD OF 1.5 uq/m3. CALENDAR MONTH AVERAGE
State and Local Agencies
California Department of Health
Massachusetts Department of Public Health
;New York Stata Ceparc.Tient of £ry/iy%onmental Ccnser-vation
Mew York CHy Department of Env. '•onmerKa' Protection
Tennessee Department of Public Health
Texas Air Control Board
Wisconsin Department of Natural Resources
Federal Agencies
Center for Disease Control, Public Health Service
Department of Transportation
Food and Drug Administration
Occupational Safety and Health Administration
Public Interest Groups and the Medical Community
Committee on Environmental Hazards, American Academy of Pediatrics
D.C. Committee for Lead Elimination in the District
League of Women Voters of the U.S.
National Urban League
Herbert Needleman, Boston Children's Hospital Medical Center
University of North Carolina School of Public Health
-------
TAB D- Summary of Significant Comments and Agency Disposition
-------
The comments received by EPA did not challenge three aspects of the
proposed standard:
1. the basic structure of the rationale used by the Agency in
deriving the level of the proposed .standard.
2. the selection of young children as a population particularly
at risk to lead exposure.
3. the Agency's estimate of 12 ug Pb/dl as an appropriate target
for the mean population blood lead level attributable to non-air
sources of lead exposure.
Significant comments were received, however, on a number of key areas
relating to the standard:
1. the validity of using a subclinical effect, EP elevation, as the
critical adverse health effect rather'than clinically detectable
anemi a.
2. the appropriate blood lead threshold for elevated EP.
3. the incidence of health effects in populations residing in the
vicinity of industrial sources of lead particulate emissions.
a. the appropriate causal relationship between micrograms of
lead in the air and micrograms of lead in the blood.
5. the statistical form and period of the standard.
6. the appropriate margin of safety.
7. the importance of the respirabla fraction of total air lead level.
3. the economic impact of the standard.
9. the State Implementation Plan regulations.
-------
10. the Federal Reference Method for monitoring lead air quality.
11. the administrative procedures employed by EPA in the develop-
ment of the standard and the provision for public participation.
A review of the comments received and their disposition has been
placed in the rulemaking docket (OAQPS 77-1) for public inspection. The
following paragraphs summarize the significant comments and present the
Agency's findings.
The Health Significance of_ Ervthrocyte Protooorohyrin Elevation
Ten commentors disagreed with EPA's conclusion that the impairment
of heme synthesis associated-with elevated erythrocyte protoporphyrin
(EP) constituted an adverse health effect for the purposes of standard
setting. Reasons for this disagreement included:
1. An elevated level of EP is not itself toxic to the cells in
in blood or other tissues.
2. EP elevation, while indicating a change in the heme synthetic
pathway, does not-indicate an insufficient production of heme
or hemoglobin.
3. EP elevation and the alteration of heme synthesis do not imply
impairment of other tnitcchondrial functions.
A. EP elevation is not associated with impairment of the production
of other heme proteins, particularly cytochrome P-450.
5. Elevated EP may be caused by conditions other than exposure to
lead, particularly iron deficiency.
Five other commentors agreed with EPA's conclusions about the health
significance of elevated EP citing the following arguments:
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The Blood Lead Threshold for Elevated Erythrocyte Protooorphyri'n
Comments provided by tan organizations challenged EPA's conclusion
that the threshold far the elevation of EP occurs at a blood lead level
in children of 15 ug/dl. Evidence offered for a higher threshold included:
1. the threshold accepted by EPA is based on a study in which an
inappropriate statistical technique, probit analysis, was employed.
2. application of a more appropriate technique, segmented line
analysis, results in a higher threshold.
3. the study in question excluded data on children with blood lead
levels in excess of 30 ug/dl.
4. other investigators have reported higher thresholds.
Comments in support of the 15 ug/dl threshold maintained.:
1. it is proper to exclude values, considered abnormal if the intent
of the analysis is to determine a~n unbiased effect threshold.
2. other studies have reported thresholds with error bands which
include 15 ug/dl.
3. probit analysis is an appropriate technique and differs only
slightly from the results obtained from segmented line analysis.
Agency Response
The-threshold for EP elevation in children is primarily a statistical
concept rather than a physical fact. Even at blood lead levels below
15 ug/dl some members of a population of children will exhibit elevated
EP. The choice of an analytical technique is largely a matter of
preference. In this regard, the Agency admits a preference for a segmented
line analysis of the data which results in a statistical threshold of
16.7 ug/dl blood lead.
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In the rationale for the proposed standard, EPA accepted a statistical
estimate of the £? elevation threshold as a maximum safe population blood
lead level. The basis for this choice was an awareness that because of
individual variation, many children would have blood lead levels and,
consequently, increased probability of EP elevation, in excess of the
population mean blood lead level. Upon reflection, EPA concludes that an
alternative method for deriving a safe population mean blood lead level
consists of determining the level of concern for an individual member of
the sensitive population and then calculating a mean target blood lead
level for the population which will insure that a certain percentage of
that population's members will not exceed the level of concern.
In the case of lead, the criteria document reports that blood lead
levels in populations with fairly homogeneous exposure to lead are
log normally distributed with a standard geometric deviation of 1.3 to
1.5. To insure that 99.5 percent of the sensitive population falls below
a level of concern of 30 ug~ Pb/dl blood requires that the target mean
for the population be 15 ug/dl. EPA concludes, therefore,
that, based on a statistical estimate of the threshold for £? elevation
as well as the protection of a reasonable percentage of the sensitive
population from undue exposure, a target population mean blood lead level
of 15 ug/dl is required.
The Incidence of Health Effects in Populations Residing in the_ Vicinity
of_ Industrial Sources of_ Lead Particulata Emissions
Several comments cited situations in which proximity to significant
point sources of airborne lead emissions appear to have little or no
health impact on resident populations.
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1. the interference of lead in a fundamental cellular function to
the extent that there is accumulation of a substrate is
physiological impairment even without the presence of clinical
evidence of"disease.
2. there are numerous instances in which it is prudent-medi cal
practice to intervene where subclinical indicators of physiological
impairment are present.
3. the impairment of heme synthesis resulting from genetic or
dietary factors places a child at enhanced risk to lead exposure.
4. there is evidence to suggest that impaired heme synthesis may
have effects on other tissues as well as on red blood cells.
Agency Response
EPA agrees with the comments received that the onset of EP elevation
as a rfsult of exposure to lead may not connote a diseased state or a
clinically detectable decrement in performance. It is equally reasonable
that the extent of impairment of the heme synthetic pathway resulting from
the presence of lead in an amount sufficient to move an individual child
beyond the threshold for EP elevation does not create an intolerable
metabolic condition. It is clear, however, that this impairment increases
progressively with lead dose and leads to clinically observable symptoms
(anemi a).
The fact that other conditions, such as iron deficiency, may produce
similar impairment, does not obviate the concern that lead in these
circumstances is interfering with an essential biological function. The
possibility of a nutritional imbalance is an additional stress to this
system which may increase the sensitivity of a child LO lead exposure.
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Heme and heme-containing proteins play important roles in the oxygen
fixation pathways in all cells. The effects of low-level lead exposure
on the heme synthetic pathway in the red cell component of blood have
been extensively studied in part because of the ease with which this
tissue may be obtained. Other cellular metabolic systans utilizing
heme are less well understood but may be similarly impaired. There is
evidence that lead's interference with the transport of iron across
the membranes of mitochondria (organelles common to all animal cells
which perform many metabolic functions) may functionally impair
brain enzyme and 1iver detoxification systems utilizing heme.
For these reasons, EPA concludes chat the state of elevated £? '
is potentially adverse to health. While the onset or a mild experience
of this condition may be tolerated by an individual, as with other subclinical
manisfestations of impaired function, it is prudent to exercise corrective
action prior to the appearance of clinical symptoms. The criteria document
reports that symptoms of anemia in children may occur at blood lead levels
of 40 ug/dl. At 30 ug/dl, decreased hemoglobin production is not
apparent, however, a significant proportion of the sensitive peculation
exhibit varying levels of EP elevation. EPA therefore concludes, in
accord with the position taken by the Center for Disease Control, thau the
elevation of E? associated with a blood lead level of 30 ug/dl is evidence
of undue lead exposure in an individual member of the sensitive population.
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Agency Response
EPA acknowledges the variability of the impact of exposure to air
lead on the potential for adverse health consequences. It ts clear that
direct exposure to air lead is only one of many routes: through which
human exposure occurs. For this reason, the Agency has held, and continues
to hold, that only a portion of the safe population mean blood lead level
.is attributable to air lead exposure. The presence or absence of health
effects in an exposed population is influenced by a variety of factors
including: meteorology, terrain characteristics, geological and anthro-
pological history, personal and domestic hygiene, the occupations of the
population members, and the food and non-food materials with which they
come into contact. Taking into account such variability, it remains the
Agency's belief that airborne lead direc-ly and indirectly contributes
to theTisk of adverse health consequences, that sufficient clinical and
epidemiclogical evidence is present to form a judgment as to the extant
of this contribution, and that a national air standard for lead must be
designed to be protective of the health of the entire population.
The Appropriate Causal Relationship Between Lead in_ Air and Lead i_n_ 31ood
Several commentors questioned the Agency's conclusion tnac, for children,
one microgram of lead per cubic meter air results in an increase of two
micrograms lead per deciliter blood.
Agency Resolution:
EPA acknowledges that the air lead to blood lead relationship in
children has been reported by some investigators as closer to 1:1. However,
as the criteria document states:
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"One assumption inherent in the calculation of the regression of
blood lead on air lead using standard least squares is that the air lead
values have been measured with no error. Obviously, the monitored air
lead values are not the exact values inhaled by the subjects in the
exposure area." "In general, the calculation regression coefficients are
underestimates of the true values." The use of personal dosimeters to
measure exposure reduces the measurement error. For this reason, EPA
regards the study of AZAR in adult males as an appropriate model for the
air lead/blood lead relationship. The grouping of data by an air lead level
indicates that the relation is curvilinear, that is, the ratio changes
with changing air and blood leads. In the range of the proposed air
standard, Azar's data indicate a ratio of 1:1.43 to 1:2.57. Because
children are known to have a greater net respiratory intake of lead as well
as greater net absorption and retention of this metal than adults,'it
is reasonable to assume tha-t the air lead to blood lead ratio for this
sensitive population, exposed to air lead levels in the range of the
proposed standard, is equal to if not greater than that for adults.
It is the conclusion of the Agency therefore, that an air lead to blood
lead ratio of 1:2 is not overly conservative.
The Statistical Form and Period of the Standard
One comraenter expressed the view that, due to the log normal distribution
of air leads, a not to be exceeded standard of 1.5 ug/m calendar month
average would require sources of air lead to achieve control of their
emissions to a geometric monthly mean of 0.41 ug/m in order to prevent the
occurrence of a violation. Another individual expressed the opinion that, with
the continued operation of a six day sampling regimen, the number of samples
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which could be collected in the course of a calendar month would not provide
a statistically valid estimate of the actual lead air quality for the period.
Comments by several individuals questioned the health basis for the
selection of the calendar month averaging period.
EPA Response
EPA accepts the consensus of comments received on the scientific and
technical difficulties presented by the selection of a calendar month averaging
period. The Agency believes that the key criterion for the averaging period is
the protection of health of the sensitive population. In proposing the 1.5 ug/m
standard, EPA concluded that this air level was safe for indefinite exposure
of young children. Critical to the determination of the averaging period is the
health significance of possible elevations of air lead above 1.5 ug/m which
could be encountered without violation of the standard. In the proposed
standard, EPA chose a monthly averaging period on the basis of a study showing
an adjustment period of blood lead level with a change of exposure. Because of
the scientific and technical difficulties of the monthly standard, EPA
has reexamined this question and concludes that there is little reason to
expect that the:slightly greater possibility of elevated air lead levels
sustainable by the quarterly standard is significant for health. This
conclusion is based on the following factors:
(1) from actual ambient measurements, there is evidence that the
distribution of air lead levels is such that there is little
possibility that there could be sustained periods greatly
above the average value.
(2) while it is difficult to relate the extent to which a monitoring
network actually represents the exposure situation for young
children, it seems likely that where elevated air lead levels
do occur, they will be close to point or mobile sources. Typically
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young children will not encounter such levels for the full twenty-
four hour period reported by the monitor.
(3) there is medical evidence indicating that blood lead levels reequili-
brate slowly to changes in air exposure which serves to dampen
the impact of a short-term period of exposure to elevated air lead.
(4) since direct exposure to air is only one of several routes of total
exposure, a change in air lead would not impact proportionately
on blood lead levels.
On balance, the Agency concludes that a requirement for the averaging
of air quality data over calendar quarter will improve the validity of air
quality data gathered without a significant reduction of the protectiveness
of the standard.
rne Apgrooriata Margin of_ Safety
Several comments received by the Agency criincized the proposed
standard as incorporating an excessively large .nargin of safety.
Conversely, seme commentors were concerned that little or no safety
margin had been applied.
EPA Resolution:
One aoproach to the satisfaction of the Clean Air Act requirement
for an "adequate margin of safety" in ambient air quality standards
has been the establishment of a threshold for adverse effects in the
sensitive population with the selection of the final standard at some
point below this level. The extant of the margin aoplied is largely
deoenoent on the severity of the health effects documented and uncertainties
associated with the scientific data. base.
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In the case of lead air pollution, the estimate of margin of
safety is comolicated by the multiple sources and media of lead exposure.
E?A has elected co use margin o" safsty consideration'; in exterminations
of each of the ir.-arras i ate rectors rather than -in a single final
adjustment to the calculated air level. It is EPA's conclusion that the
incorporation of conservative estimates of intermediate factors, where un-
certainty exists, is a reasonable approach to margin of safety determination,
and that the Agency's judgments have not been shown to be excessively or
deficiently protective of human health.
The Importance of_ the Resnirabla Fraction o£ Total Air Lead Level
The Agency received a number of comments expressing concern that
because che respirable fraction of airborne particulate lead is more
readily absorbed into the blood stream, an air standard based on total
air lead is unnecessarily protective of health.
Agency Response
EPA acknowledges the important role of respirafala lead as a contributor
to total leac body burden. It is not reasonable to conclude, however,
that the presence of particles beyond this range do not represent an
exposure condition. In addition to the indirect route of ingestion and
absorotion from che gastrointestinal tract, non-rsspirable lead in the
environment may, at some point, become respirable through weathering
or mechanical action. EPA concludes, therefore, that total airborne
lead, both respirable and non-respirable fractions, is appropriate as a
measure of total air exposure.
The Economic Impact of the Proposed Standard
In general, the comments received by the Agency were supportive of
the draft Economic Impact Assessment. Ccrnmentors critical of the
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assessment argued that the forecast underestimated the severity of the
economic impact to certain lead industries.
Agency Response
The comments critical of the draft impact statement did not include
data which would allow EPA to confirm the possibility of more severe
economic impacts. Since the analytical methods emo'.oyes v,e'-e not aro-jght
:nta question, it i; the Agency's judgment that c.is impact statement, with
fTicaifi cations necessitated by the change in averaging period, is a
reasonable forecast of the economic consequences of implementation of the
standard.
The Proposed State Implementation Plan (SIP) Regulations
A summary of comments and the Agency resolution is included in the
preamble to the final regulations published elsewhere in this Federal
Register.
The Federal Reference Method for Monitoring Lead Air Quality
A summary of comments and the Agency's resolution is included in the
e to the final ,-netnod OMQiishec elsewhere ir. this Federal Regis :er.
The Administrative Procedures employed by_ EPA in. the Development of che
Proposed Standard and the Provision for Public Participation
Two commentors requested that cross examination of witnesses be
allowed in the post-proposal public hearing on the proposed standard
and implementation regulations. EPA also received a request to postpone
the public hearing and to extend che comment period, citing the need to
complete ongoing studies.
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Agency Resolution:
3oth the request for cross examination and for extension of the
ccrrment oeriod were denied by the Agency. In the former case, it is
the Agency's view that cross examination would be counter to the in-
formal rulemaking procedures followed by the Agency. Due to the
extensive review opportunities available at all stages of regulatory
development, an extension of the comment period was not felt to be
sufficiently necessary to further delay the schedule for the pre-
of the final rule.
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TAB E- Summary and Comparison of Rationales Underlying the
Proposed and Final Standard
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SUMMARY AND COMPARISON OF RATIONALES
Underlying the Proposed and Final Statement
Proposal/December 14, 1977
1. Selection of children, ages 1-5, as the sensitive population
Rationale: Young children experience adverse effects at lower
levels of exposure, and the effects may be more severe due to
developing organic systems. Young children may be at a greater
risk of exposure to environmental lead contamination.
2. Estimate of the maximum safe mean blood lead level for children.
Rationale: accepting that the elevation of EP is the first effect
which is adverse to health, the maximum safe blood lead level was
taken to be the point where a correlation could be delicted between
increasing blook lead and elevated EP. From extensive blood sampling
in the population of New York City, children, analyzed by Piomelli,
the threshold for this correlation was estimated to be at a mean
blook lead of 15 ugPb/dl.
3. Estimate of non-air contribution to mean blood lead.
Rationale: without this estimate the air standard would not be
protective of public health. Based on mean blood lead levels in areas
with very little air lead, and certain isotopic tracing studies,
12 ygPb/dl as the maximum safe contribution for air exposure.
4. Estimate of air level contributing 3ygPb/dl to mean blood lead levels
in children.
Rationale: epidemiological studies show a realtionship between lead
in the air and lead in the blood. In the range of data available,
1:2 was adopted as the best estimate of the impact 1 ygPb/m3 on
blood lead levels for children, and with many ,„ safety Cons1derat1ons.
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5. Calculation of the Standard.
Max safe mean blood lead 15 ygPb/dl
Non-air sources of lead - 12 pgPb/dl
T ugPb/dl
air lead/blood lead relationship 1 ugPb/m /2 ugPb/dl
Proposed Standard 1.5 ugPb/m3
FINAL STANDARD
1. Selection of Children as the sensitive population
Rationale: same as for proposal
2. Estimate of Maximum Safe Blood lead level.
Rationale: commentors pointed out that this critical factor could
differ with use of different statistical techniques to estimate the
threshold for correlation of EP with bolld leads. OAWM agrees with
this point, but believes that 15 ugPb/dl should remain as the maximum
safe mean blood lead for children for two reasons: 1) it is still
in the range, although at the lower end. of estimates for this thres-
hold, 2) because of population variation this population mean level
is necessary to place most children below 30 pgPb/dl, the CDC
guideline which OAWM adopts as the maximum safe blood lead for an
individual child. OAWM further believes that any higher mean blood
lead would reduce the health risk of the sensitive sub groups
within the general population of children.
3. Estimate of non air contribution to mean blood lead.
Rationale: same as for proposal
4. Estimate of air level contributing 3ugPb/dl to mean blood lead levels
in children.
Rationale: same as for proposal
5. Calculation of the Standard.
Rationale: same as for proposal
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TAB F- Table of Alternate Standards
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Alternatives for the Level of the Final Lead Standard
Geometric standard deviation of measured blood lead values : 1.3
Non-Air Contribution to Mean blood lead : 12 ug Pb/dl
Air Lead/Blood lead Relationship 1:2
Health Effect Choice
Clinical anemia, threshold
40 ug PB/dl
Subclinical impairment of
heme synthesis indicated
by elevated Erythrocyte
Protoporplyrin, max. safe
level 30 ug Pb/dl
% of Population
Estimated Mean Blood Level
Standard
99%
99.9%
99%
99.5%
99.9%
22
18
16
15
13
5.0
3.0
2.0
1.5
0.5
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TAB G- Options for Dealing with Point Source Economic Impacts and
Attainment Difficulties
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DISCUSSION OF LEAD NONATTAINMENT PROBLEM
I. STATEMENT OF PROBLEM
In the Economic Impact Assessment, OAMR concludes that certain
point sources of lead emissions may have severe technical or economic
difficulty in attaining the standard, and that one primary lead smelter
and many secondary lead smelters may face closure. These conclusions
are based on rough estimates of emission factors for lead fugitive
emissions, technical factors for hypothetical plants, and dispersion
modeling. The actual impact of the standard will be more accurately
known with the development of State implementation plans based on
plant-specific data. Nevertheless, EPA is in the position of promulgating
the standard with clear indications of severe impacts on nonferrous
smelters, but without precise information on the extent of these impacts.
In the following sections, OANR reviews the available analysis and
possible alternatives and recommends an agency approach to dealing with
this problem.
II. ANALYSIS RESULTS
A. Mobile Sources
Even though mobile sources currently contribute about 90% of total
lead emissions nationwide, the existing EPA regulations for the phase-
down of lead in gasoline and the availability of lead-free gasoline will
result in significant reductions in lead mobile source emissions. The
OANR estimates that there will be only two AQCRs with mobile source
violations in 1982, and further decline in mobile source emissions will
eliminate mobile source violations by 1984.
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B. Stationary Sources—Air Quality Analysis
At the level of the recommended standard of 1.5 ugPb/m , quarterly
average, the principle economic impact of the standard will fall on
primary copper smelters, primary lead smelters, secondary lead smelters,
gray iron foundries, gasoline lead additive plants, and battery manufac-
turing plants. The EPA analysis was based on hypothetical sources,
however, so in actuality other source categories may need to be controlled
under certain conditions.
1. For primary lead smelters, the analysis predicts required
control greater than 95 percent to meet the standard if the highest
estimated fugitive emission rates are assumed. Best known control
technology currently available might not be sufficient to attain the
lead NAAQS around primary lead smelters with high fugitive emissions.
Therefore, enforcement of the standard could cause closure of those
smelters.
2. For secondary smelters, the analysis predicts required control
greater than 95 percent to meet the standard if either the high or
medium estimated fugitive emission rates were assumed. Again, best
available control technology might not result in attainment around some
secondary lead smelters, and some of these sources may have to be closed.
3. For the remaining four categories, the analysis predicts that
attainment can be achieved with known technology.
C. Stationary Sources—Economic Analysis
Even if all known technology were applied to a particular source,
regardless of whether the lead standard were attained near that source,
the cost of installing that equipment alone may force some primary and
secondary lead smelters and primary copper smelters to close. This
conclusion was based on a range of assumptions concerning the degree of
depreciation, tax rate, and minimally acceptable rate of return on
investment for each plant.
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D. Stationary Sources—Summary of Extent and Impact
Table 1 presents a summary of the extent and impact of the lead
nonattainment problem, giving the number of plants, the emission sources
requiring control (fugitive or stack), and the potential closures for
some plants.
III. FACTORS AFFECTING ACCURACY OF ANALYSIS
A. Lack of Representativeness of Hypothetical Sources
The economic analysis was based only on hypothetical plants. The
hypothetical plants were based on actual plants, and the meteorological
data used in the air quality model were taken from stations located in
the vicinity of actual plants. This approach was taken rather than
analysis of each facility because of the lack of data for individual
facilities and because of the amount of time and resources required for
analysis of each of the many individual sources of lead emissions.
B. Inadequate Fugitive Emission Factors
Fugitive emissions are difficult to quantify accurately since they
are dependent on a wide range of site-specific parameters. The fugitive
emission factors used in the analysis were derived from the few studies
available and those studies were performed on only a few sources. A
wide range of values was generally assumed.
C. Difficulty in Determining the Efficiency of Fugitive Control
Fugitive parti oil ate emissions are generally uncontrolled; they can
be controlled through hooding or enclosing of the operations that generate
the emissions and venting the captured emissions to a fabric filter or
other control device. OANR estimates that total operation enclosure and
venting the emissions to a fabric filter will result in an overall
capture and control efficiency of about 95 percent; the efficiency
cannot be determined directly because fugitive emissions cannot normally
be measured directly.
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TABLE I: STATIONARY SOURCE IMPACT ASSESSMENT SUMMARY
Source Category
No. of Plants Emission Sources
in U.S.A. Requiring Control
Potential Closures
for Some Plants
Primary Lead
Smelting
Secondary Lead
Smelting
Primary Copper
Smelting
Gray Iron
Foundries
Gasoline Lead
Additives
Lead Acid
Battery Mfg.
6
56
16
1500s
6
191
Fugitive
Fugitive
Fugitive
Fugitive
Stack
Stack
Yes
Yes
Yes
No
Mo
No
aThe gray iron foundry modeled had a cupola furnace. There are 841
foundries with cupola furnaces.
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D. Validity of Assumptions
1. The air quality analysis assumed that no background lead concen-
trations exist around the sources analyzed.
2. The analysis assumed that by 1982 all of the stationary sources
of lead that require SIP control for particulate matter would be in
compliance with the SIP particulate matter limitations. The more parti-
culate matter control that actually occurs, the less the lead control
needed, with the opposite situation being true. The particulate limita-
tions applied primarily to stack emissions, however, while fugitive
emissions, whose impact v/as far more significant, were assumed to be
uncontrolled.
3. The model used does not account for deposition ("fall out") of
large particles that may be present in the fugitive emissions. The
analysis assumed that the particles were sufficiently small so that they
behaved in a manner described by traditional Gaussian diffusion models.
If particles deposit closer to the source than the model predicts, the
concentrations downwind may be less than those actually calculated. The
deposited emissions themselves, however, may become an independent
source of emissions if the deposited dust is reentrained by wind or
other mechanical disturbances.
E. Economic Assumptions
The economic analysis assumed a range of values for factors such as
the degree of depreciation of the plant, the tax structure under which
the plant operates, and the minimally acceptable rate of return on
investment for the plant. These factors in actuality vary significantly
from facility to facility.
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IV. OTHER CONSIDERATIONS
A. Primary Nonferrous Smelters
The forthcoming lead standard is only one more regulatory impact on
the primary nonferrous smelters. In addition to lead, primary nonferrous
smelters emit other fugitive emissions such as particulate matter,
sulfur oxides, arsenic, cadmium, zinc, and manganese. Through revisions
of. current SIPs, fugitive particulate matter and sulfur oxides emissions
will have to be controlled. Through development of other National Ambient
Air Quality Standards under § 109 of the Clean Air Act, regulations for
designated pollutants under § lll(d) of the Act, or National Emission
Standards for Hazardous Air Pollutants under S 112 of the Act, fugitive
emissions of arsenic, cadmium, zinc, and manganese might also have to be
controlled. Complying with the forthcoming control requirements may not
be possible on technical or economic grounds. Hence, even without a
lead standard, primary nonferrous smelters could face compliance problems.
In the Clean Air Act Amendments of 1977, Section 119 recognizes the
particular economic and feasibility problems of smelters in allowing
certain relief measures to smelters in attaining the S02 standard.
B. Noncompliance Penalties
Section 120 of the Clean Air Act requires EPA to assess penalties
against major stationary sources that are not in compliance with any
emission limitation, emission standard, or compliance schedule under any
applicable plan. The penalty is to be equal to the economic benefit
that the source would experience from noncompliance.
Although primary nonferrous smelters that receive orders under
Section 119 of the Act are exempt, OGC has indicated that the smelters
are only exempt from limitations, standards, and schedules that
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pertain to SOg control. Thus, if a primary nonferrous smelter were not
in compliance with a limitation, etc., for lead, EPA (or a State that
has been delegated the appropriate authority) would have to assess a
penalty against that source even if that smelter had received a primary
nonferrous smelter order. The term "major stationary source" is defined
by the Act to mean "any stationary facility or source of air pollutants
which directly emits, or has the potential to emit, one hundred tons per
year or more of any air pollutant (including any major emitting facility
or source of fugitive emissions of any such pollutant, as determined by
rule by the Administrator)." (Emphasis added.)
V. CONCEPTS FOR ALLEVIATING ANTICIPATED ECONOMIC IMPACTS
OANR has investigated a number of concepts for alleviating the
anticipated economic impacts of setting and implementing a national
ambient air quality standard for lead. The following discusses these
concepts.
A. Two Year Extensions
Section 110(e) of the Clean Air Act allows EPA to grant an extension
of up to two years for attainment of a primary standard if certain
conditions are met. EPA could encourage States to request the two year
extension if sources could not comply more quickly with the control
measures needed.
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B. Supplemental Control Systems
Section 119 of the Clean Air Act allows the use of supplemental
control systems (SCS) for primary nonferrous smelters, but only to meet
an emission or air quality standard for SOg. Furthermore, SCS is directed
at reducing peak short-term concentrations to avoid violations of a
short term standard. Since the lead standard is a longer term standard
(i.e., 90 days), SCS does not appear to be appropriate to reduce viola-
tions.
C. Delayed Compliance Orders
Section 119 of the Clean Air Act authorizes delayed compliance
orders (DCOs) for primary nonferrous smelters, but only to meet an
emission or air quality standard for S02-
8
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Under Section 113(d) of the Clean Air Act, both the States and EPA
may issue a delayed compliance order which permits the owner or operator
of a stationary source to delay compliance with provisions contained in
a State Implementation Plan (SIP). To be eligible for a delayed com-
pliance order, a source must be unable to comply with the SIP regulations
to be covered by the order. In addition, the order must, among other
requirements, establish interim emission limits which reflect the best
practicable system of emissions reduction and a schedule which requires
compliance as expeditiously as practicable.
The maximum delay that can be authorized by a Section 113(d)(l)
order is three years after the date for final compliance required by the
SIP regulation covered by the order. If the Administrator of EPA approves
in 1979 SIP regulations designed to implement a national lead standard,
the latest date (without an extension under S 110(e)) a SIP compliance
schedule could establish for source compliance with emissions limitations
designed to achieve the standard is 1982. This date is set under Section
110(a)(2)(A) of the Act, which provides that the attainment date for a
national primary ambient air quality standard can extend up to three
years from the time the Administrator approves provisions of the SIP
designed to implement the standard. Thus, SIPs could contain compliance
schedules with increments of progress which set 1982 as the date for
compliance with lead emission regulations. If a SIP does set 1982 as
the final compliance date, a delayed compliance order, if appropriate,
could permit a source to delay compliance with the regulations up to
1985.
There are two instances where a delayed compliance order could
permit a delay in compliance beyond 1985. Under Section 110(e) of the
Act, the Administrator may extend an attainment date for two years if
-------
certain conditions are met. If a two year extension is granted regarding
attainment of a primary lead standard, a SIP compliance schedule could
provide for compliance with the lead emission limiting regulations by
1984. If a SIP did set 1984 as the date for compliance, a Section
113(d)(l) order could, if appropriate, extend compliance up to 1987.
Compliance could also be delayed beyond 1985 if the source uses a
"new means of emission limitation." If the new means is approved by the
Administrator as satisfying certain conditions in the Act, the Adminis-
trator may issue a delayed compliance order under 113(d)(4) of the Act.
The maximum delay in compliance that may be permitted by an order issued
under this subsection is five years after the date for final compliance
required by the SIP regulation covered by the order. If the SIP set a
1982 compliance date, a Section 113(d)(4) order could delay compliance
up to 1987; if the SIP set a 1984 compliance date, the order could delay
compliance up to 1989. A source granted a Section 113(d)(4) order is
•
exempted by Section !20(a)(2)(B)(i11) of the Act from liability for
noncompliance penalties based upon violation of the SIP regulation
covered by the order.
D. Research and Development Effort
A research and development effort is not expected to yield any new
technologies in the near future better than those that exist for the
control of fugitive emissions from primary and secondary lead smelters
(i.e., enclosure of operations and venting of emissions to a fabric
filter).
One kind of "R & D" effort that could be undertaken, however, is a
set of demonstration fugitive emission control projects on one or more
smelters that EPA would fund under section 103 of the Clean Air Act.
10
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These projects would actually result in some degree of control. Such an
effort could be considered a veiled attempt at Federal subsidy for
emission controls, and unless they were applied equitably from facility
to facility, EPA could be accused of creating unfair advantages for a
particular facility.
E. Definition of Ambient Air
Under this concept, EPA would continue to interpret attainment of
the standard as being required only in areas to which the general public
has access. If standards were violated on the fenced property of the
existing source but not outside the property, the standard would be
attained. EPA may consider accepting land acquisition and fencing by
the emitting facility as a control strategy.
This concept of what constitutes the ambient air, however, is
currently undergoing major reconsideration in EPA. There appears to be
a strong argument for requiring the attainment of the national standards
everywhere based on the wording of section 107(a) of the Clean Air Act,
which states, "Each State shall have the primary responsibility for
assuring air quality within the entire geographic area comprising such
state. . ." (emphasis added). The Office of General Counsel argues,
however, that this need not be applied literally and that some flexibility
concerning the placement of monitors to measure the air concentrations
can be assumed. OGC feels that the flexibility can be accomplished
through revised EPA guidelines on monitoring that could preserve substantial
discretion for the States and Regional Offices to decide not to require
monitors too close to a source if the circumstances of the situation
indicate a less stringent approach.
IT
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Land acquisition has several other problems also. The policy of
land acquisition would probably not be applicable where the sources were
not isolated; if doubt existed as to the actual source of the lead
emissions that were causing a violation of an ambient standard, Source A
could charge that emissions from Source B are the cause of the violations
of the standard or even that Source B is causing violations on the
property of Source A. Also, the lead emissions from stationary sources
contain both large and small particles. Land acquisition may solve the
problem of containing the large particles that deposit close to the
source, but the small particles may be carried beyond any amount of land
that could be economically acquired by the company.
F. Deferring Decision on Options Until SIP Submission
Under this concept, EPA would require the "traditional" approach to
developing a SIP, i.e., require each State to analyze the air quality
impact of each source based upon available data, develop and evaluate
control strategies where needed, select a control strategy that is
adequate on paper, and submit the plan to EPA. At that time, it will be
possible to determine whether—
1. the plan requires all the control that is technologically
feasible, the sources are eventually controlled to that level, and the
NAAQS is still not being attained; or
2. the level of control required would cause severe economic
impacts and plant closures.
OANR believes that a more accurate estimate of economic impacts can
be made on the basis of the SIP submissions, particularly if EPA works
12
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with the States and affected industries to develop accurate and plan-
specific emissions data. As OAQPS reviews the SIP submissions, better
judgments can be made about the possibility of compliance date extensions
under sections 110, or 113, the allowance of land acquisition, or other
steps that may mitigate the economic consequences of the control program.
If at the time of SIP review severe impacts and possible closures are
seen to be unavoidable, EPA should undertake to inform the affected
congressional delegations and appropriate congressional committees of
the projected impacts, and the restricted latitude available to EPA to
balance public health objectives with economic goals.
G. Biological Monitoring
This approach was suggested in public comments from representatives
of primary lead smelters. Under this approach, sources that could not
control emissions so that the lead standard will be met would be allowed
to conduct a public health screening and hygiene program aimed at reducing
the amount of lead that persons in the vicinity of the source take in
and ensuring that safe blood lead levels are satisfactorily maintained.
There are legal, technical, and equity problems with this approach
that render it unacceptable as a means of implementation of the national
standard.
Concerning the legal problems, such a program assumes that the air
quality standard will be violated, and presumably, the plan will not
contain a demonstration that the air quality standard will be attained.
13
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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 even 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 process envisioned by
S 110 of the Act is prevention of public health problems.
Concerning equity, the biological monitoring program would inconven-
ience the very people that are supposed to benefit from the Act. The
Act envisioned that all people have an equal right to healthy air. The
biological monitoring approach would imply that people who happen to
live in areas with elevated air 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 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.
14
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H. Financial Assistance Programs
There are a number of financial assistance programs for air pollution
control available through the Federal Government. These programs include
the following:
—Industrial development bonds, which are sold by State and local
governments to help companies obtain financing necessary to meet Federal
pollution control requirements. The interest on such bonds are tax-
free.
—Investment tax credits, which allow a firm to take 10 percent of
the cost of certain capital investments as a credit against its Federal
tax liability. Investments in the purchase and installation of pollution
control equipment are among the investments eligible for the tax credit.
—Rapid tax amortization of control equipment, which provides for a
five-year amortization election for facilities that will prevent the
creation or emission of pollutants when installed at the site of a plant
or other property in existence before January 1, 1976; there are a
number of conditions, however.
VI. CONCLUSIONS
A. States will have difficulty in developing a SIP that demonstrates
attainment of the proposed lead standard for the following reasons:
1. States will have to use available fugitive emission factors,
even though they are of questionable validity, or develop their own
factors, to perform their air quality analyses in support of their SIPs.
2. With limited resources and the nine-month period in which the
plans must be developed, the States will not be able to develop emission
factors for specific facilities.
15
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3. Any air quality model used to demonstrate the effect of a
control strategy will only yield a theoretical impact and may not accurately
represent the actual situation under study.
4. The efficiency of the fugitive emission control techniques has
only been estimated, not verified.
B. Some sources might never achieve a level of control that will
result in attainment of the proposed lead standard without ceasing
operations. This is because of the suspected magnitude of the fugitive
emissions from some sources and the suspected limitations on the degree
of control that can be technologically achieved.
C. Even if EPA does not set a NAAQS for lead, other regulatory
actions could still cause adverse economic consequences for the smelters.
D. Under the existing provisions in the Clean Air Act, there are
no options for totally alleviating the severe economic impacts on some
stationary sources of lead emissions that may arise. It should be
emphasized that the severity of the impact is only an estimate, and may
be more or less than estimated.
VII. RECOMMENDATIONS
OAWM recommends a combination of some of the concepts mentioned
above. This combination of approaches would encompass the following:
A. The States would be required to develop their SIPs under a
traditional approach (Concept F, above). That is, they would have to
(1) analyze the air quality impact of all primary and secondary lead
smelters and primary copper smelters (among other source categories)
based upon available data and emission factors, (2) develop and evaluate
control strategies where needed, (3) select a control strategy that is
16
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adequate on paper to attain and maintain the lead standard, and (4)
submit the plan to EPA. States will request two-year extensions of the
attainment dates under S 110(e) of the Act as needed.
B. In cooperation with EPA regions, State agencies, and affected
plants, OAQPS will act to improve data on critical point sources (nonfer-
rous smelters) to the extent possible in the SIP development review.
C. Sources will request extensions of compliance dates under
S 113(d) of the Act.
D. OAQPS will provide guidance to the States on the applicability
of land acquisitions as an acceptable control strategy.
E. OAQPS will re-assess economic impacts of the attainment program
at the time of SIP review, and inform all interested groups about the
results of this projection and what ameliorative steps EPA can take
under the Act. This will include discussions with members of Congress,
the executive branch, and affected industries.
F. EPA will issue an advance notice of proposed rulemaking on a
requirement for air quality monitoring in the vicinity of primary and
secondary lead smelters, and primary copper smelters. This would initiate
a program for obtaining the air quality data that is essential to both a
more accurate definition of the problem and the determination of the
effect of control measures.
G. OAQPS will request ORD to obtain more representative information
on fugitive lead emissions and will also make available reports that
describe several techniques for estimating fugitive lead emissions.
H. OAQPS will request 0PM' to undertake a study of the impact of
EPA regulations on the primary nonferrous smelters. The study would
investigate which smelters will have difficulty meeting the various
17
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environmental regulations, the magnitude of the nonattainment problem,
the area of impact around the sources, the cost of control, and the
various options available for alleviation of severe economic impacts.
18
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TAB H- Comments from Other Federal Lead Regulatory Programs
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Comments by other Federal Agencies
Comments on the proposed lead air quality standard were received
from eight Federal agencies. Five of the agencies endorsed the air
standard while three of the agencies commented on specific issues and
neither endorsed nor opposed the standard. The Center for Disease
Control and the U.S. Public Health Service voiced support for the proposed
standard of 1.5 yg Pb/m and urged basing the decision on the standard
solely on considerations of the public health. CDC is fully satisfied
that EP elevation does indeed represent a subclinical manifestation of lead
toxicity and that young children are the population most at risk from lead
exposure, while some subgroups of children are at special risk to lead
because of conditions such as malnutrition, genetic factors, or iron
deficiency.
The Consumer Product Safety Commission endorsed the approach and
some of the judgments made in arriving at the air standard. CPSC con-
curs with the position that children are the population at enhanced
risk to lead exposure, and that the goal of a mean population blood
lead level for children of 15 ug Pb/dl is sufficiently low to be protective
of the population at enhanced risk of exposure. CPSC views the selection
of EP elevation as the adverse health effect of concern as open to
challenge and suggests basing the standard on a more generally recognized
severe health effect. CPSC concurs that the contribution of non-air
sources to lead body burden must be evaluated in setting the air standard
and suggests that a larger non-air contribution, such as J3.5 yg Pb/dl
used in the California standard, might be considered.
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The Food and Drug Administration commended EPA's proposal of an
ambient air quality standard for lead. FDA agrees that children aged
1-5 years old comprise the most critically sensitive population. FDA
concurs that 15 ug Pb/dl is a reasonable maximum blood lead level to use
as an average national goal for children aged 1 to 5, although FDA
suggests that for young children the margin of safety is disturbingly
narrow. The division of the 15 ug Pb/dl into 12 yg Pb/dl for non-air
sources and 3 ug Pb/dl for air sources was not unreasonable in FDA's view.
The Occupational Safety and Health Administration endorsed EPA's
proposed standard for lead and agrees with EPA that 15 ug Pb/dl as an
average national blood lead level goal for young children is reasonable.
OSHA views their proposed standard of 100 ug Pb/m , 8-hour time weighted
average, and their establishment of 40 ug Pb/dl as the threshold effect level
for workers as consistent with the EPA proposed standard.
The Department of Transportation (DOT) endorsed the proposed standard
of 1.5 ug Pb/m . Based on an analysis of the impact of the
proposed standard on the highway program, DOT concluded that it is highly
probable that transportation-related violations of the proposed standard
would be limited to large urban areas.
In commenting on the proposed standard, the Department of the Interior
(DOI) expressed concern that the burden for meeting the proposed standard
will fall primarily on lead and copper smelters and battery manufacturers,
and commented on the impact of lead dustfall on ground water quality.
The Tennessee Valley Authority provided specific comments on the proposed
State Implementation Plan Regulations and the proposed Federal Reference
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Method. The Department of Commerce offered substantive comments on
the environmental impact statement, pointing out that more consideration
should be given to the potential impact of the standard on the petroleum
industry.
The Occupational Safety and Health Administration proposed regulations
in 1975 to limit occupational exposure to lead to 100 yg Pb/m , 8-hour
time weighted average. The exposure limit was based on protecting against
effects, clinical or subclinical, and the mild symptoms which may occur
below 80 yg Pb/dl, providing an adequate margin of safety. The level of
3
100 yg Pb/m anticipated to limit blood lead levels in workers to a mean
40 yg Pb/dl and a maximum of 60 yg Pb/dl. OSHA is presently reviewing the
latest information on lead exposure and health effects in preparation for
promulgation of the workplace standard for lead.
The Department of Housing and Urban Development (HUD) has requirements
for reducing human exposure to lead through the prevention of lead
poisoning from ingestion of paint from buildings, especially residential
dwellings. Their activities include (1) prohibition of use of lead-based
paints on structures constructed or rehabilitated through Federal funding
and on all HUD-associated housing; (2) the eliminations of immediate
lead based paint hazard; (3) notification of purchases of HUD-associated
housing constructed prior to 1950 that such dwellings may contina lead-
based paint; and (4) research activities to develop improved methods of
detection and elimination of lead-based paint hazards, and the nature
and extent of lead poisoning.
The Consumer Product Safety Commission (CPSC) promulgated regulations
in September 1977 which ban:(l) paint and other surface coating materials
containing more than 0.06 percent lead; (2) toys and other articles
intended for use by children bearing paint or other similar surface coating
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material containing more than 0.06 percent lead; and (3) furniture coated
with materials containing more than 0.06 percent lead. These regulations
are based on CPSC's conclusion that it is in the public interest to reduce
the risk of lead poisoning to young children from ingestion of paint
and other similar surface-coating materials.
The Food and Drug Administration adopted in 1974 a proposed tolerance
for lead of 0.3 ppm in evaporated milk and evaporated skim milk. This
tolerance is based on maintaining children's blood lead levels below
40 yg Pb/dl. FDA also has a proposed action level of 7 ug/ml for
Teachable lead in pottery and enamelware, although the exact contribution
of such exposure to total human dietary intake has not been established.
The Center for Disease Control concluded in 1975 that undue or increased
lead absorption exists when a child has confirmed blood lead levels of
30-70 yg Pb/dl or an EP elevation of 60-189 yg Pb/dl except where the
elevated EP level is caused by iron deficiency. This guideline is presently
accepted by the scientific community but because of more recent data is
being reevaluated.
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TAB I- Final Environmental Impact Statement
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AIR QUALITY STANDARD
FOR LEAD
FINAL DRAFT
ENVIRONMENTAL IMPACT STATEMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
Of f ice of ~A ir and Wa ste Ma n a g em en t
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
July 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 yg/m3,
1.5 yg/nr and 2.0 yg/m3) and a quarterly averaging period.
iii
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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 1n 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 Air Quality 3-14
3.2.1.1 Lead Emissions 3-15
3.2.1.2 Ambient Concentrations 3-18
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-
Term 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
vi
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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
vm
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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
trations 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 Air 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 recommending 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 emissions 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 lead 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 grams 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, the^U. S. Court of Appeals for the District
of Columbia Circuit aet aside the phase-down regulations, following
a petition by members 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 reduction 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 de_lays 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.
3
On December 14» 1977 4 EPA proposed a level of 1.5 ug/ni , calenaar
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-protect!veness 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 anti-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
-------
(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 burn 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 monoxide 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).
2-2
-------
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 is 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
-------
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
A- 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
52.3
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
-------
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
89.3
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
-------
were so equipped and it 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
limited voluntary use of unleaded gasoline for pre-1975 cars. In
1974, this use amounted to slightly more than one percent of total
gasoline consumption (Federal Energy Administration, 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
miles, 21.0 percent were truck miles, and only 0.4 percent were bus
miles (Svercl, 1977).
Fuel Economy (miles per gallon). In general, average motor fuel
mileage per gallon declined during the period from 1950 to 1973, and
then improved 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 31.3
mpg for cars in the 2,250 pound weight class to 12.7 mpg for cars in
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
2-6
-------
TABLE 2-3
FUEL CONSUMPTION CHARACTERISTICS BY VEHICLE, 1950 THROUGH 1975
ITEM
AVERAGE GALLONS PER VEHICLE
CARS
BUSES
TRUCKS
AVERAGE MILEAGE PER GALLON
CARS
BUSES
TRUCKS
1950
728
603
3,752
1,257
12.87
14.95
5.57
8.57
1955
759
644
3,021
1,278
12.67
14.53
5.85
8.37
1960
777
661
3,040
1,330
12.42
1.428
5.26
7.96
1965
775
656
2,844
1,347
12.49
14.15
5.35
8.60
1970
830
722
2,491
1,365
12.14
13.58
5.34
8.39
1971
838
723
2,382
1,368
12.16
13.73
5.38
8.38
1972
859
730
2,165
1,446
12.07
13.67
5.80
8.59
1973
851
736
1,991
1,361
11.85
13.29
5.86
8.45
1974
788
676
1,920
1,269
12.13
13.49
5.90
8.55
1975
790
712
1,937
1,227
12.20
13.53
5.75
8.68
INJ
I
Source of 1975 Data: Svercl, Paul. March 8, 1977. Highway Engineer, Federal Highway Adminis-
tration. Telephone conversation.
Source of 1950 through 1974 Data: Bureau of the Census. 19765. Statistical Abstract of the
United States: 1976. U.S. Department of Commerce.
-------
CO
Cn
CT>
O
O
t—i
a.
2T
i—i
_l
O
CD
120
110
100
90
80
70
60
50
40
30
•v.':-:':':::°'
1950 1955 1960 1965 1970 1971 1972 1973 1974 1975
YEAR
Note: Data for 1950, 1955 and 1960 include off-highway uses; data for other years are for highway uses
only.
Bureau of the Census. 1976b. Statistical Abstract of the United States. 1976. U.S. Department
of Commerce.
Motor Vehicle Manufacturers Association. 1975a. Automobile Facts and Figures. 1975. March 8,
1977.
Svercl, Paul. March 8, 1977. Highway Engineer, Federal Highway Administration. Telephone Con-
versation.
FIGURE 2-1
MOTOR FUEL CONSUMPTION IN THE UNITED STATES, 1950 THROUGH 1975
-------
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, 19765).
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, New 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 (TML) 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
-------
I
o
3.0
2.5
ro
o>
m
s_
Dl
o
CJ
2.0
1.5
0.02-
0.01-
0
W = winter
S = summer
_y
W S
1 J 1
VI
1
S
1
W
1
S
1
W
1
S
1
UNLEADED
4
W
1
,4
V
S
1
\*
W
1
/•
A ,
S
1
1970
1971
1972
1973
1974
1975
YEAR
1976
Source: Adapted from various semi-annual issues of Motor Gasolines. Ella Mae Shelton. Energy
Research and Development Administration, Bartlesville, Oklahoma.
FIGURE 2-2
LEAD CONTENT OF GASOLINE-NATIONAL AVERAGES, 1970 THROUGH 1976
-------
for TEL and TML are dwindling be-ause of low-lead legislation in
foreign countries (Edwards, 1973). The average lead content of all
gasoline in 1970 was <£.3 grams per gallon, compared to 1.7 grams per
gallon in 1975.
With the installation of lead-sensitive catalytic converters
on most new cars manufactured in the United States since 1974, the
proportions of gasoline sales represented by premium and regular
grades have dropped significantly, while unleaded gasoline sales
have risen correspondingly (see Table 2-4).
2.1.1.2 Current and Potential Control Technology. The
following general control options may be applied to reduce lead
emissions from mobile sources. They are:
(a) Mechanical devices added to exhaust systems (e.g.,
particulate lead traps);
(b) Transportation control plans;
(c) Fuel modification; and
(d) Automobile engine modifications.
Lead Traps. The removal of lead directly from the exhaust
gases can theoretically be accomplished by means of particulate
traps. To be effective, such traps must be able to collect a
wide range of particle sizes. In addition, exhaust back pressure
must be kept to a minimum to maintain engine efficiency.
At the present time, lead traps would be considered only for
the decreasing population of vehicles burning leaded gasoline.
2-11
-------
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 Q)
(percent)
55.8
57.3
60.4
66.2
74.3
72.9
62.8
UNLEADED...
SALES (3)
(percent)
1.6
1.6
1.5
1.4
1.2
7.9 (T)
22.0 (T)
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 Motor Gasoline from the Mandatory Allocation
Price Regulations. Washington, D.C.
2-12
-------
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
-------
there are presently at least two metal -based additives which have been
considered. A recently developed compound Is Cerium ( 2,2,6, 6-tetramethyl •
S.S-heptanedionate)^, 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 is methyl cyclopentadienyl manganese tricarbonyl (MMT),
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 toxicity
of manganese* 'and the low concentrations that would be used in
gasoline (Faggan et al . , 1976; Ter Haar, 1975), the use of MMT 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 MMT 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 p-g/m3 for lead (Occupational Safety and Health
Administration, 1976).
2-14
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- -". . ':-*.• ,uiis !;'_- iocludeu the use of natural
gas -nd hydrogen to*- Tiore 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
tne 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
I'-.obile sources. The regulations are: "EPA Regulations on Control
of Air Pollutants from Motor Vehicles and Mew 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
-------
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 80), 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 27.5 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
-------
During 1975, the average motor 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 torvs 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/gallon (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
-------
TABLE 2-5
SUMMARY OF AUTOMOTIVE FACTORS
YEAR
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1995
PERCENTAGE OF
PRE-1975 CARS
100.0
88.8
74.5
61.5
49.4
39.6
29.2
21.3
15.0
10.3
7.1
5.2
3.9
2.8
2.1
1.7
0.0
0.0
AVERAGE FUEL
ECONOMY (mi/gal)
12.4
12.5
__
13.3
14.0
14.8
15.7
16.8
17.9
19.1
20.4
21.7
--
__
--
—
26.2
27.4
POOLED AVERAGE, LEAD
IN GASOLINE (g Pb/gal)
2.0
1.9
1.6
1.2
1.0
0-5\/T\
O.SJ^
0.47
0.34
0.25
0.19
0.15
0.13
0.11
0.09
0.08
0.05
0.05
1X3
I
_j
O3
1. Based on the gasoline additive phasedown regulation.
Source: Wilson, James. July 14, 1976a. U.S. Environmental Protection Agency. Personal
correspondence.
-------
(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
-------
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 in average fuel economy resulting
from the Energy Policy and Conservation Act will taper off after
1985, reaching a plateau by 1997. At the same 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 mobi.le 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
-------
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
-------
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 106 tons
326,000 tons
27.8 x 106
tons of- lead
processed
182,200 MWe
78,420 MWe
11.67 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/MWe
56.1 Ibs/MWe
0.6 Ib/ton
©
0.012-0.3
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 ©
95 ©
92.6 ©
92
70
92
0
64
©
25 to 27
97.3
98
CONTROLLED ©
84
100
2,734
954
3,461
1,333
1,841
403 ©
2,200 ©
1 ,254 ©
1,227
544
124
52
2-22
-------
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
-MENT PRODUCTION
Wet
Dry
LEADED GLASS
AUTOMOBILE
EMISSIONS
1975
PRODUCTION
500,000 tons
73,000 tons
500,000 tons of
lead processed
134 x 106
base boxes
6.3 x 106 tons
113,503 tons
32.5 x 106 tons
39.5 x 106 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 0%
0
93
95
--
CONTROLLED ©
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
-------
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 1C6 tons (2.01 x 106
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 since 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 Alkyl Production).
There are 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
alkyl 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
2-26
-------
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
-------
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 412 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 ppm 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 106 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
-------
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
-------
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. Some 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
-------
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
-------
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 103
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 Technology 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 small 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 acfm) and high particulate con-
centrations, the venturi 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 e> Dressed 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
-------
year, and (3) a compliance control factor. This last factor is used
to account for the amount of control 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 Oivison 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
-------
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 (NSPS) 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
-------
TABLE 2-7
FACTORS FOR PROJECTING FUTURE LEAD EMISSIONS
INDUSTRY
FERROALLOY
STORAGE BATTERY
PRIMARY LEAD SMELTER
SECONDARY LEAD SMELTER
PRIMARY COPPER SMELTER
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
-------
their SIP's and Appendix B of the Requirement for Preparation,
Adoption, and Submittal 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
particulate (e.g., baghouse, scrubbers, and electrostatic precipi-
tators) are the same as for control of lead emissions, and therefore
the NAAQS for particulate matter has already and will continue to
result in some 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 stack emissions in 1982
relative to 1975.
NSPS 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 which "causes or
contributes significantly to air pollution which may reasonably be
anticipated to endanger public health or welfare." The first standards
2-38
-------
of performance for new stationary sources (New Source Performance
Standars, or NSPS) were promulgated in December 1971. By January 13,
1977, particul ate 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 in 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 nonum'form 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
-------
in the immediate vicinity of particular stationary lead emission
sources. This information, presented 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 Aerometric 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 NAOB files
(eight AQCR's in Alaska, Hawaii, American 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 th«»ir 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 NADB 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 NADB 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
-------
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 ^g/m3. 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 which 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 ^.g/m^ or above, 40 had concentra-
tions of 2 ng/m3 or above, 18 had at least one quarterly mean of 3
(j.g/m3 or greater, and 8 had concentrations above 4 ug/m^. 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/MD/VA
FL/GA
S.E. FL
W. FL
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
(W/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
-------
TABLE 2-8 (continued)
MAXIMUM QUARTERLY LEAD CONCENTRATIONS FOR SELECTED AQCR'S
AQCR NUMBER
30
82
83
85
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
CENT. MN
N. NC
S.W. MO
S.W. MT
W. NV
PA/NJ
CENT. NM
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
-------
TABLE 2-8 (concluded)
MAXIMUM QUARTERLY LEAD CONCENTRATIONS FOR SELECTED AQCR'S 0
AQCR NUMBER
184
193
195
196
197
200
202
207
208
209
211
214
215
216
217
218
220
221
222
223
225
226
229
234
239
240
244
LOCATION
CENT. OK
OR/WA
CENT. PA
S. PA
S.W. PA
CENT. SC
N.W. SC
TN/VA
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
(yg/m3)
2.71
1.19
1.57
1.45
4.38
1.83
1.81
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
2.31
YEAR
1974
1974
1974
1974
1974
1974-1975
1975
1975
1974
1975
1975
1975
1975
1975
1974
1974
1975
1974
1975
1975
1974
1974
1974
1975
1974
1974
1974
Selected AQCR's are those with an estimated maximum quarterly
concentration exceeding 1 .0
Source: See Appendices S, T, and U.
2-46
-------
lead emissions in the 8 AQCR's with maximum quarterly concentrations
above 4 ^g/m3 reveals specific types of situations which can lead
to relatively high ambient lead levels. Most of the quarterly values
are estimates based on reported amoient concentrations for other
averaging times.
The Eastern-Washington-Northern Idaho Interstate AQCR (No. 62)
has the highest proportion of ambient concentrations above 4 ng/m3
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
4.4jj.g/m3). 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 fj.g/m^ (State Depart-
ment of Health and Enviromental 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 4.9 H-g/tn^. 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 Corners Region of Arizona, New Mexico, Utah, and
Colorado (AQCR 14), the maximum quarterly mean concentration
was over 4 jig/m^. 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 in 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
quarterly value of 6.7 ug/nr (Air Resources Board, California,
2-48
-------
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 yg/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 67) 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 ng/m3.
The other two AQCR's with concentrations near 4 ng/m3 are
located in Northern Maryland (AQCR 115, 3.6 M-g/m3 maximum monthly
value), and in Central Minnesota (AQCR 131, 3.5 pg/m3 estimated
maximum quarterly concentrations). Each AQCR has a few battery plants,
secondary lead smelters, and coal-fired power plants. In addition,
AQCR 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.
Maximum quarterly lead concentrations in the 170 AQCR's
for which monitoring data have been received indicate the extent
Qf. potential problems due to airborne lead, as defined by three
different levels of airborne lead concentrations, 1.0, 1.5 and 2.0
jig/m3 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
-------
I/I
150
>
i
M£
-"'!'.' 100
-i o
Lr -.,
•'I
UJ
o !D
76
85
1 .0
162 AQCU'S UlifOKTlNU 1975 DATA
JVi A(JCH'S Kl'l'OUTlNO 1974 DATA
32
7y
13
I«J7A DATA
1975 DATA
J.5 2.0 3.0
MAXIMUM QUAUTI'KI.Y AVIiliACK l.liAl) CONCIiNTKATUJN
FIGURE 2-3
NUMBER OF AIR QUALITY CONTROL REGIONS (AQCR'S) WITH 1975 AMBIENT
LEAD CONCENTRATIONS EXCEEDING VARIOUS PROPOSED STANDARDS
-------
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 H-g/m3 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
ng/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/m3, 103 of the 170 AQCRs with
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/m3, and to 38 (22 percent) that have at least one concentration
2 ug/m3. Geographically, the 103 AQCRs which have maximum quarterly
lead concentrations above 1.0 jig/m3 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
-------
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. No 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
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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 (j.g/m3
at the closest receptor (0.2 mile away) to 0.9 ng/m3 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 jig/m3, while the average of the
monthly concentrations at any receptor was never more than 1.8
ng/m3. Also, no monthly concentration exceeded 3 H-g/m3, and no
average of the monthly concentrations exceeded 0.9 \±g/m3 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
-------
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 ng/m3, while the average
24-hour value was 12.5 ng/m3. 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/m3 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 mile). The annual mean concentration at the receptor near
the Bunker Hill smelter (12.5 |j.g/m3) is also larger than at the El
Paso receptor (10.2 iig/m3). 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 |j.g/m3
as a 24-hour maximum, while the two receptors 2.5 and 4.5 miles from
the smelter had 2.5 and 7.0 ng/m3 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
-------
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 ng/m3, with no values
exceeding 0.6 |j.g/m3. 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/m3,
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 ng/m3 is far less than the average values around the primary
lead smelters described above, and no concentration exceeded 0.7
2-56
-------
3. 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 cul 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 ng/m3. 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 ng/m3, and maximum concentration of 1.3
fig/m3 at the receptors 3.1 miles from the smelter.
All receptors greater than 0.4 mile from the lead and copper
smelters had 58 percent or more of their monthly lead concentrations
below the level of 2 |j.g/m3. If receptors near the El Paso and
Kellogg smelters are excluded from the analysis, then over 94 percent
of the 24-hour 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 ng/m3 for an average
of all 24-hour values at one receptor, while at another receptor over
35 percent of the observations were above 5 ng/m3, 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 ng/m3 at a distance of 50 yards (46
meters), and a maximum 24-hour value of 160 ng/m3 at a receptor 275
yards (251 meters) away. Current lead concentrations at these same
2-58
-------
two receptors are 2.5 fig/m3 (average 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 H-g/m3, with no single 24-hour value
exceeding 3.2 ng/m3. However, in 1970 the average 24-hour lead
concentrations at two monitors 150 yards from the plant were 15.2 and
33.2 H-g/m3 with maximum 24-hour values of 72 p.g/m3 and 140 n9/ro3i
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
may be important contributors to overall concentration levels.
2-59
-------
Another receptor 1,330 yards (1,210 meters) away recorded an average
concentration of 2.7 vg/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 ng/m^.
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 ng/m3 near two
secondary lead smelters, from 2.5 to 4.2 ng/m3 near a ferroalloy
producer, and from zero to 50.9 ^q/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
-------
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 ng/m3 compared to a similar
mean of 0.8 jig/m3 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
-------
1,000
^ 500
s
90
2 100
o
i s°
s-i
I 10
< 5
a
&
o
7 1.0
5 0.5
0.1
••
LEAD CONCENTRATIONS NEAR:
• Primary Lead Smelters
A Secondary Lead Smelters
10 m
t
50 m 100 a 500 m 1 km
3ECEFTOR DISTANCE (meters)
FIGURE 2-4
LEAD CONCENTRATIONS VERSUS DISTANCE FPOM
PRIMARY AND SECONDARY LEAD SMELTERS
5 ka
10
1
^^
T
00
3.
^•^
|
H
0
|
a
«
|
CM
S
Ij
uuu
500
100
50
10
5
1.0
0.5
0.1
—
p^
A
A
A *
_ A
a
A •
A •
LEAD CONCENTRATIONS NEAR: 4
- • •
• Primary Copper Smelters * *
^
A Gray Iron Foundries *
II II 1
10 m 50 m 100 m 500 m 1 km 5 km 10
RECEPTOR DISTANCE "(meters)
FIGURE 2-5
LEAD CONCENTRATIONS VERSUS DISTANCE FROM
PRIMARY COPPER SMELTERS AND GRAY IRON FOUNDRIES
2-62
-------
1,000
500
n
s
oo
a.
~ 100
2 50
U
a
10
5
2 1.0
T
S 0.5
S
0.1
-LEAD CONCENTRATIONS JTEAR:
• Battery Planes
I I
I
1
10 m
50 m 100 m 500 m 1 km
RECEPTOR DISTANCE (meters)
5 km 10 km
FIGURE 2-6
LEAD CONCENTRATIONS VERSUS DISTANCE FROM BATTERY PLANTS
2-63
-------
TABLE 2-9
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
General Battery— Hamburg , PA
General Battery— Laurel dale, PA
Prestolite 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
Trinity Valley Iron and Steel —
Fort Worth, TX
Green's Bayou Foundry — Houston, T^
McKinley Iron Works— Fort Worth, TX
American Darling Foundry— Beaumont, TX
PERCENTAGE OF MONTHLY AVERAGES
EXCEEDING GIVEN LEVELS ( g/m3)
0.5
96
TOO
27
96
0
7
0
0
0
93
100
100
100
100
100
100
100
0
100
100
100
100
100
100
1.5
49
100
0
49
0
0
0
0
0
60
100
79
92
100
100
100
100
0
100
0
100
100
100
100
2.0
35
100
0
35
0
0
0
0
0
47
100
79
67
100
100
100
100
0
100
0
100
100
100
100
3.0
20
100
0
20
0
0
0
0
0
30
57
64
67
100
100
100
100
0
100
0
0
100
100
100
5.0
13
87
0
13
0
0
0
0
0
17
0
57
33
0
100
100
0
0
100
0
0
100
100
100
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
1
1
1
Note: (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. 1974g. Smelter Study, 1973-1974.
Department of Environmental Resources, Pennsylvania.
Sampling Data.
1976a. Hi-Vol
A Report of Typical Element
Texas.
Texas Air Control Board. April 1974a.
Emissions from Texas Smelters. Austin,
Texas Air Cont' il Board. April 1974b. A Report of Typical Element
Emissions from Texas Foundries. Austin, Texas.~
2-64
-------
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-rece;. jr 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
amount 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
2-65
-------
modeling of lead emissions and 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 mini-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 (ADT) in that AQCR and the location of
2-66
-------
that count. The type of road and its location were noted in order
that the correct line source diffusion model classified according to
one of four different roadway configurations could be applied.
The location and condition of each roadway where the maximum ADT
was observed permitted a classif.cation according to one of the four
following configurations.
(1) outside an urban area; limited access; free traffic
flow (60 miles/hour average speed);
(2) within influence of an urban area; limited or non-
limited access; somewhat restricted traffic flow
(48 miles/hour average speed);
(3) within an urban area; limited or nonlimited access;
moderately congested traffic flow (38 miles/hour
average speed);
(4) within an urban central business district; nonlimited
access; heavily congested traffic flow (15 miles/hour
average speed).
The lead emissions rate per vehicle for each of these roadway
configurations was based on the average lead content of gasoline and
the average fuel economy considering traffic speeds. Lead content
was assumed constant for all configurations, and equals 1.69 g Pb/
gallon based on gasoline usage requirements in 1975 (see Section
2.1.1.3). The average fuel economy, determined from traffic speeds
for the different configurations and the age distribution of vehicles
in 1975, varied from 10.2 miles/gallon (mpg) for Configuration 4 to
21.4 mpg for Configuration 2. The emission rate, in g/m-sec, was
determined from these variables plus the traffic count, and then
2-67
-------
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/m ), 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, reprecAnting 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
*0ue to SIP regulations for particulates,
2-68
-------
TABLE 2-10
ESTIMATED AIR QUALITY IN AQCR'S WITHOUT MONITORING DATA
AQCR
1
6
10
11
19
20
23
34
35
37
38
39
40
41
44
48
51
63
66
71
72
74
86
89
90
91
93
96
97
98
POTENTIAL
QUARTERLY
LEAD
CONCENTRATION
(/ig/m3)
1.23
0.83
NAV fi\
WAV W
1.17
2.32
0.56
0.85
0.54
1.25
1.10
0.61
0.36
3.65
0.61
4.99
2.56
0.35
1.13
0.94
1.00
2.42
1.93
1.49
1.09
2.10
0.88
0.72
0.25
0.60
LEAD
CONCENTRATION
MTAD
NtAK
MOBILE SOURCES
(^9/m3)
1.07
0.83
1.09
1.26
0.56
0.85
0.53
1.25
1.03
0.61
0.32
2.32
0.61
3.09
1.26
0.35
1.10
0.88
0.67
0.81
1.22
1.46
1.09
2.10
0.86
0.56
0.25
0.44
LEAD CONCENTRATION NEAR
FERRO- BATTERY PRIMARY SECONDARY
ALLOY PLANTS LEAD LEAD
<0.01 0.16
—
0.16
0.16
0.06
0.03
0.16
0.05
INDICATED STATIONARY SOURCES (pg/m3) ©
PRIMARY GAS CAST
COPPER ADDITIVE IRON
0.03
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
<0.01
0.03
<0.01
0.03
<0.01
0.03
<0.01
<0.01
<0.01
<0.0]
COAL-FIRED
POWER PLANTS
0.01
<0.01
0.07
0.03
0.03
0.06
0.32
0.03
0.72
0.16
OIL-FIRED
POWER PLANTS
0.08
1.05
1.33
1.90
1.30
1.61
0.08
-------
TABLE 2-10 (continued)
ESTIMATED AIR QUALITY IN AQCR'S WITHOUT MONITORING DATA
AQCR
100
108
111
117
134
135
137
138
144
149
150
154
155
156
157
165
168
169
171
175
177
179
180
182
183
187
190
191
192
194
POTENTIAL
QUARTERLY
LEAD
CONCENTRATION
0'9/m3)
0.39
1.08
0.36
0.66
3.32
1.48
1.32
12.04
1.60
0.67
2.06
0.86
0.54
1.17
0.59
1.55
1.26
1.51
3.13
1.18
0.82
1.63
0.60
1.15
1.75
0.66
0.98
0.34
0.38
1.09
LEAD
CONCENTRATION
MCAD
NtAK
MOBILE SOURCES
fog/m3)
0.32
1.08
0.36
0.66
1.51
1.44
1.24
1.08
1.60
0.47
1.89
0.86
0.54
1.17
0.59
1.19
1.26
1.47
3.00
1.16
0.79
1.35
0.53
1.15
1.59
0.66
0.96
0.34
0.38
1.09
LEAD CONCENTRATION NEAR
FERRO- BATTERY PRIMARY SECONDARY
ALLOY PLANTS LEAD LEAD
—
0.05
11.00
—
0.13
0.05
0.07
0.05
0.06 0.16
0.02 - T-
<0.01
INDICATED STATIONARY SOURCES (j/g/m3) (?)
PRIMARY GAS CAST
COPPER ADDITIVE IRON
<0.01
<0.01
<0.01
<0.01
<0.01 <0.07
<0.01
<0.01
<0.01
<0.01
0.03
<0.01
0.03
<0.01
0.03
<0.01
COAL-FIRED
POWER PLANTS
—
0.08
0.12
0.17
0.37
0.03
0.07
0.02
<0.01
0.28
<0.01
0.15
—
OIL-FIRED
POWER PLANTS
0.66
1.82
—
—
—
—
—
-------
TABLE 2-10 (concluded)
ESTIMATED AIR QUALITY IN AQCR'S WITHUUi MONITORING DATA
AQCR
198
199
201
203
204
206
219
224
227
228
230
231
232
233
235
236
245
246
POTENTIAL
QUARTERLY
LEAD
CONCENTRATION
(^g/m3)
1.09
3.66
0.80
0.58
2.03
0.39
0.97
2.07
0.68
0.86
1.41
0.45
0.85
0.91
0.89
0.95
NAV /7\
NAV ^
LEAD
CONCENTRATION
NEAR
MOBILE SOURCES
(/*g/m3)
0.83
2.19
0.76
0.58
1.99
0.39
0.93
2.03
0.65
0.86
1.41
0.45
0.85
0.91
0.64
0.95
LEAD CONCENTRATION
FERRO- BATTERY PRIMARY SECOh
ALLOY PLANTS LEAD LE
0.02
0.05
0.03
<0.01
NEAR INDICATED SJATIONARY SOURCES 0/g/m3) Q
IDARY PRIMARY GAS CAST
AD COPPER ADDITIVE IRON
<0.01
<0.01
<0.01
<0.0l
<0.01
<0.01
<0.01
<0.01
•0.01
-0.01
COAL-FIRED
POWER PLANTS
0.07
0.03
0.03
0.02
0.05
0.25
OIL-FIRED
POWER PLANTS
1.47
—
--
-_ -._ -.. — » — - — — — - " —
1. Data were not available for determining ambient lead concentrations from iron and steel plants and municipal incinerators
(Scruggs, 1977).
2. NAV = not available; AQCR outside continental United States.
3. Stack emissions are assumed to be negligible. Fugitive emissions only are modeled.
126,200 tons/year production 8.69 x 10"5 ^g/m3/ton product {Scruggs, 1977) = ll.Opg/m3.
-------
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/m3 while only 11 percent would have
been out of compliance for a standard of 2.0 ng/m3.
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
-------
CO
o
B 60 -
Z CO
O LU
O =3
i^ 50 •
N-» a
X LU
^B 40 -
Z *™|
i— a
•— ' Z
CO LU 30 *
QSO
C_J CO
9""*
*= 20 •
u_
o
| 10-
74 AQCR'S WITH ESTIMATED DATA
36
-
19
13
1.0 1.5 2.0
MAXIMUM MONTHLY LEAD CONCENTRATION Cug/m3)
FIGURE 2-7
NUMBER OF AQCR'S WITH MAXIMUM ESTIMATED
LEAD CONCENTRATIONS ABOVE INDICATED VALUES
2-73
-------
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2-74
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AIRBORNE LEAD IN THE ENVIRONMENT: SOURCES AND AMBIENT LEVELS
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AIRBORNE LEAD IN THE ENVIRONMENT: SOURCES AND AMBIENT LEVELS
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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. "Methyleyelopentadienyl Manganese
Tricarbonyl as an Antiknock: Composition and Fate of
Manganese Exhaust Products," Journal of the Air Pollution
Control Association. Vol. 25(81:858-860.
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.
2-77
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REFERENCES (Concluded)
AIRBORNE LEAD IN THE ENVIRONMENT: SOURCES AND AMBIENT LEVELS
U.S. Environmental Protection Agency. April 19745. Report to
Congress. Waste Oil Study. Washington, D.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. l
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. 1975h. 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 ana 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 j/g/m (quarterly average). To meet the
less stringent candidate standards (1.5/^g/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
-------
PROPOSED
STANDARD
NUMHER OF AQCR'S WITH AH111ENT LEAD
CONCENTRATIONS EXCEEDING VARIOUS PROPOSED STANDARDS
20
60
ao
100
120
160
180
1.0
1.5
2.0
113
53
:n
I.
Based on 243 AQCR's for which 1975 ambient conditions wore estimated or reported (plus eight A()CR's
lor which 1974, or earlier, ami)lent data were reported).
2. Quarterly averaging time.
FIGURE 3-1
NUMBER OF AQCR'S WITH MAXIMUM QUARTERLY CONCENTRATIONS
ABOVE INDICATED VALUES
-------
the number of AQCR's requiring control should be substantially reduced
due to existing EPA regulations which affect lead emissions to the
atmosphere (SIP and f.'SPS control for particulates 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."1. the rollback tschrique 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-
nique 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 lead concentration - proposed level of NAAQS 100
maximum lead concentration - background lead concentration
where natural background lead concentration is =sti.~aT:ed at 0..005
(National Academy of Sciences, 1972).
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 en *r= prevailing levels o^ airborne
lead, the control philosophy followed, and the control strategy devised.
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 an 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 mqre 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 followed, one
develoos control strategies consisting of selected options.
3-5
-------
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
2
.0 ug/m3
Number of AQCR's Requiring Additional Control for
t 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
.5 ug/m3
Number of AQCR's Requiring Additional Control for
a 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
.0 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 only
plus mobile sources
a Primary lead smelters - fugitive and stack emissions
plus mobile sources
Total AQCR's Requiring Control Measures
YEAR
1982
1
1
1
2
5
1
1
2
-
4
1
1
1
-
3
1983 1985
-
1
1
2
4
1
2
1
-
4
1
1
1
-
3
-
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
3-7
-------
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/m3.
Four AQCR's would require additional control in 1983. For a standard
of 1.5 iig/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 jjg/m3,
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
-------
any less stringent standard, mobile-only controls would be unneces-
sary. In subsequent years, for a given standard, there is a shift
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 BACT) and could prove to be highly unattractive economically
with the result that the smelter operators so affected may decide to
3-10
-------
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/nr)
1.0
1.5
2.0
YEAR
1982
1,265,300
106,500
58,000
1985 (7)
49,100
26,900
26,900
1995 ©
8,800
4,900
0
Pre-1975 autos and medium-size trucks obtaining their second
particulate trap plus model-year medium-size trucks.
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//g/m ,
monthly average), the most stringent level (1.0 /*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/m3 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/m3, a 15 percent reduction would be implied, and for
a standard of 2.0 ug/m3, 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
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 faccors and is independent of the level
of the standard. In 1985, the rollback required 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).
3-17
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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 particulates as well as no-lead in gasolirie—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 of the standards. For a standard of 1.0 ug/m3, 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
*Best available control technology.
3-18
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ug/m3. 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 NAAOS 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/m3 standard were adopted. It should also be noted, though, that
3
four AQCR's would need lead controls in 1995 using the 2.0 ug/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.
3-19
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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 parciculate 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 pg/m standard—approxi-
mately 1.3 million units, by 1982—with a sharp falloff in production
*Includes hoods, ducts, fans, and baghouses.
3-20
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in subsequent years (see Table 3-2). For years later than 1982 and/
or for standards greater than 1.0 ug/m , the demand for particulate
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
•3 12
for a standard of 1.5 ug/nr are expected to be 3.12 x 10 and 1.74
3-21
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x 1012 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-1- 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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TABLE 3-4
NATIONWIDE ENERGY COSTS ASSOCIATED WITH FUGITIVE LEAD EMISSIONS CONTROL
AT PRIMARY COPPER AND LEAD SMELTERS, 1982
LEVEL OF
STANDARD
(pg/m3)
1.0
1.5
2.0
CAPITAL ENERGY
1012 BTU
6.7
4.9
3.0
EQUIVALENT BARRELS OF OIL
(x 106)
1.15
0.84
0.51
OPERATING ENERGY
1012 BTU/yr
1.44
1.06
0.67
EQUIVALENT BARRELS OF OIL PER YEAR
(x 106)
0.25
0.18
0.12
I
ro
CO
-------
more steel and/or aluminum, would be 542,000 barrels of oil. In some
cases the particulate 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 particulars 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 yg/m standard presented
above.
3.3.1.2 Operating Energy
The operating energy for point source control is associatsd 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
for 1982 at a standard of 1.5 yg/m3 are 0.63 x 1012 and 0.43 x 1012
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 vg/m are computed to be less than 1 x 10
3-24
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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
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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^'-frion 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 BEFF'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/m . 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
(/ig/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
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3.3.3.2 Landfill Considerations
For a standard of 1.5 ng/m , the nationwide amounts of total
parti oil ate 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/m3) 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 particulate 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 particulates. 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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TABLE 3-6
TRACE METALS—ESTIMATED FUGITIVE EMISSIONS AND THEIR REDUCTIONS
TRACE ELEMENT
Arsenic
Cadmium
Chromium
Mercury
Zinc
Beryl 1 i urn
Antimony
1975 UNCONTROLLED NATIONWIDE EMISSIONS (TPY)
PRIMARY COPPER
SMELTERS
2,990
265
6
50
1,900
1
23
PRIMARY LEAD
SMELTERS
70
520
1
5
330
0.2
4
TOTAL
SMELTERS
3,060
783
7
55
2,230
1.2
27
1982 EMISSIONS REDUCED AT SMELTERS (TPY)
STANDARD (*g/m3)
1.0
970
310
2.3
18
740
0.4
9
1.5
590
280
1.6
11
500
0.3
6
2.0
130
260
0.7
4
220
0.1
3
Source of 1975 Arsenic Data: U.S. Environmental Protection Agency. July 1976. Air Pollutant Assess-
ment Report on Arsenic.
-------
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.
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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 this1 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
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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 essentially 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. On 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 buMt 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 archaeoIon leal
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 BEFF 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 NAAQS 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 the 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 impacts are
likely to occur. These would include such community services as
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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
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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 BEFF 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 Mg/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
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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 particulate traps would
be. Based on the reduction of lead in air, it would appear that the
particulate 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 reduction 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 BEFF's in abandoned mines which may be owned by
the primary lead and primary copper smelting companies. To reduce
the 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
-------
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.
3-46
-------
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.
3-47
-------
REFERENCES
ENVIRONMENTAL IMPACTS OF THE PROPOSED STANDARD
Bureau of the Census. 1967. Census of Manufacturers. 1967: Summary
and Subject Statistics. Vol. 1, pp. 6-235 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 P.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
Infonnation 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.
3-49
-------
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 1977.Office 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 PB-247 000.
3-50
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TAB J- Final Economic Impact Assessment
-------
ESTIMATED RESOURCES REQUIRED BY STATE AND LOCAL CONTROL AGENCIES FOR IMPLEMENTATION OF A 1.5 ug/m3 STANDARD
(SUMMARIZED BY EPA REGION)
FIRST YEAR REQUIREMENTS ON-GOING REQUIREMENTS
REGION LEAD COPPER
SHELTERS SHELTERS
I
11
III
IV 1
V 1
VI 1 3
VII 3
VIM 1 2
IX 8
X 1 1
SUBTOTALS 6 16
LEAD
SHELTERS
1
5
10
10
16
7
1
1
4
1
56
STORAGE
BATTERY
MANUF.
15
11
10
25
37
14
14
4
40
12
190
SOURCES
AFFECTED
118
156
241
268
613
1 38
125
37
129
55
1910
HAN
YEARS
1.4
1.8
2.6
5.1
12.4
4.5
1.7
2.2
6.2
2.4
40.3
TOTAL
COST
(IN THOUSANDS)
31.8
41.5
60.0
117.3
283.1
103.7
38.2
50.8
141.1
54.5
922
CAPITAL
COST
(IN THOUSANDS)
22.7
36.2
44.2
100.0
61.8
65.4
36.2
19.6
78.9
21.1
486.0
MAN
YEARS
4.2
5.5
8.0
14.1
22.8
10.2
5.1
3.6
12.2
4.3
90
TOTAL
COST
(IN THOUSANDS)
95.8
125.6
184.2
324.0
523,4
233.3
118.0
83.4
279.7
97.6
2065
OPERATING
COST
3.3
4.6
7.1
14.1
9.0
9.9
4.6
2.3
11.3
2.8
69
10TALS '910 40.3 1408 90 2225
Mncludes grev 1ror> foundries, primary lead smelters, primary copper smelters, battery manufacturers, secondary lead smelters, & gasoline additive plants.
-------
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
Office of Air Quality Planning and Standards
Office of Air and Waste Management
U.S. Environmental Protection Agency
June 28, 1978
-------
Preface
The "Economic Impact Assessment for the National Ambient Air
Quality Standard for Lead" (EIA) was issued when the Agency proposed a
1.5 ug/m3 monthly average standard. Subsequent to proposal the Agency
received several public comments on the EIA. Most were generally
supportive of the EIA in terms of the industries affected by the
standard. In some instances however the commentors forecast more
severe impact. Because the commentors1 supporting documents did not
allow verification of the assumptions underlying the forecasts, the
EIA was not altered.
The Agency also received comments on the proposed standard itself.
In view of those comments, the Agency intends to promulgate a 1.5 ug/m3
quarterly average standard. The EIA issued at proposal did not analyze
the economic impact of that standard. Hence, the EIA issued at proposal
is supplemented by an analysis of the 1.5 ug/m3 quarterly average standard,
This analysis is found after page 56 of the EIA issued at proposal and is
entitled "The Economic Implications of a Quarterly Mean Averaging Time
for the Lead National Ambient Air Quality Standard".
-------
ECONOMIC IMPACT ASSESSMENT FOR THE
NATIONAL AMBIENT AIR QUALITY STANDARD FOR LEAD
Office of Air Quality Planning and Standards
Office of Air and Waste Management
U.S. Environmental Protection Agency
November 22, 1977
-------
ECONOMIC IMPACT ASSESSMENT
Chapter 1 Summary and Introduction
1.1 Summary
1.2 Introduction
Chapter 2 Stationary Source Assessment
2.1 Primary Lead Smelting
2.1.1 Industry Structure
2.1.2 Model Plant Specifications and Dispersion Model Results
2.1.3 Control Costs
2.1.4 Model Plant Closure Assessment
2.2 Secondary Lead Smelting
2.3 Primary Copper Smelting
2.4 Grey Iron Foundry Casting
2.5 Gasoline Lead Additives Manufacturing
2.6 Lead-Acid Battery Manufacturing
Chapter 3 Other Affected Sectors
3.1 Mobile Source Assessment
3.2 State and Local Control Agency Assessment
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1.0 SUMMARY AND INTRODUCTION
1.1 Summary
The purpose of this analysis Is to estimate the economic impact
which can be expected from a constant air quality for lead. This analysis
examines three levels which are deemed to fall within the likely range of
the final standard. It should be noted, however, that this economic assess-
ment is not a basis for selecting the standard since the Clean Air Act
requires that the standard be based solely on health and welfare criteria.
This assessment considers three possible standards: 1.0, 1.5, and 2.0
ug/m (monthly average). The economic impact assessment emphasizes the impacts
upon stationary source lead emitters but also discusses the impacts upon
mobile source lead emitters and state and local control agencies
charged with implementing the standard.
Dispersion models indicate that plants in at least six industries may
be required to install control devices to meet the alternative standards
under consideration. These control devices would be in addition to those
control systems required by typical state regulations for control of particulate
or other emissions. The six industries under consideration are primary lead
smelting, secondary lead smelting, primary copper smelting, grey iron foundries,
gasoline lead additive manufacturing, and lead-acid storage battery manufacturing,
The economic impact assessment is based primarily upon the use of model
plants and estimated emission factors. The model plant emissions were used in
a meteorological dispersion model that predicts maximum ambient lead concen-
trations. The dispersion modeling results were then used to estimate which
emission sources needed additional control to meet the alternative ambient
standards and the extent of control required. The resulting control
requirement then determined the type of control equipment needed and
the cost of the equipment. Control costs to meet alternative standards were
-------
then factored into a discounted cash flow model that served as the basis for
evaluating potential plant closures.
As expected, the results of the economic impact analysis indicate
that model plants of the six industries mentioned above will be affected
in varying degrees by the alternative standards under consideration. As
shown in Table 1-1, annualized compliance costs expressed as a percent
of model plant revenues range from zero to over 7 percent depending upon
the level of the standard and the type of model plant being analyzed.
It is possible that some plants, facing control costs of the magnitude
shown in Table 1-1, may choose to close rather than comply with emission
regulations required to achieve a given ambient lead standard. An
analysis of this issue shows that, for lead air quality standards of
either 1.5 or 2.0 yg/m , potential plant closures may be possible in the
primary lead industry, the secondary lead industry, and the primary
copper industry. In addition, at an ambient standard of 1.0 ug/m plant
closures may be possible for some grey iron foundries. Plant closures are
not projected for gasoline lead additive plants or lead-acid battery
plants for any of the alternative standards under consideration.
The economic impacts described above are based upon a number of factors
such as emission rates, plant profit margins, and terrain and weather conditions
in the vicinity of the source. Since these variables are difficult to quantify
with any reasonable degree of precision, it must be borne in mind that impacts
at any one specific source may vary considerably from the impacts described here.
It should be noted that a rollback analysis (an analysis that assumes a linear
relationship between the percent of air quality improvement and emission
reductions) indicated that only two industries— primary lead smelting and
-------
Table 1-1. RELATIVE COSTS OF ALTERNATIVE AMBIENT LEAD STANDARDS - MODEL
PLANT ANNUALIZED COSTS AS A PERCENT OF ANNUAL REVENUE
Alternative Ambient Standards
monthly average)
Model Plant Type
Primary Lead
Secondary Lead
Primary Copper
Grey Iron
Gasoline Lead Additives
Lead Acid Batteries
2.0
0.9% to 7.7%*
7.4%**
0.0% to 3.3%
0.0% to 2.0%
0.2%
0.0% to 0.1%
1.5
1.2% to 7.7%*
7.4%**
0.0% to 4.3%
0.0% to 3.8%
0.2%
0.0% to 0.1%
1.0
1.8% to 7
.7%*
7.4%**
0.0% to 5
0.0% to 6
0.2%
0.0% to 0
.2%
.2%
.1%
*The control efficiency of the costed system is assumed to be 95%. At this level of efficiency the model primary
lead smelter with high fugitive emissions could only attain an air quality standard of 3.9 pg/m3.
**The model secondary lead smelter with low fugitive emissions could meet a standard of 2.0 ng/m3 with an expen-
diture of 7.4% using the 95% control system referred to above. A model secondary lead smelter with high
fugitive emissions, however, could only meet an air quality level of 3.7 pg/m3 with the same system.
-------
primary copper smelting—would need to install control devices to meet the
alternative standards. This result is at variance with the dispersion analysis
upon which the stationary source economic impact assessment was based that
indicated six industries would need to install control devices. This fact
emphasizes the effect of various modeling assumptions upon the results of
the economic impact analysis as well as the general problem of the variability
of the results depending upon various input assumptions.
An analysis of potential impacts to mobile source lead emitters for the
ambient lead standards under consideration has also been developed. This
analysis indicates that mobile sources in portions of one to four Air
Quality Control Regions, or a possible total of 58,000 to 1,300,000 vehicles,
may have to be controlled, assuming the ambient lead standard must be achieved
in 1982. However, because of lead phasedown regulations and the increased
use of lead free gasoline for catalyst equipped vehicles, the total number of
mobile source lead emitters is expected to decrease after 1982. One control
device that may be feasible for mobile sources is a lead trap muffler. Other
means of control include reducing vehicle miles traveled and further reducing
the lead content of gasoline.
State and local air pollution control agencies will also incur costs
to develop and implement plans to achieve an ambient air quality standard for
lead. Total first year costs for all state and local agencies are estimated
to range from $1.0 - $1.7 million, or 0.6 - 1.0 percent of current expenditures,
Recurring costs are estimated to be $1.4 - $2.8 million, or 0.9 - 1.8 percent
of current expenditures. Man-year requirements, both first-year and recurring,
are similarly estimated to be less than 2 percent of current levels.
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1.2 INTRODUCTION
This report assesses the cost and economic impact of alternative
ambient lead standards. The stationary sources covered in the assessment
are model primary lead smelters, secondary lead smelters, gasoline lead
additive manufacturing plants, lead-acid battery manufacturing plants,
primary copper smelters, and grey iron foundries. In addition, the
potential costs of mobile source emission control and of requisite state
and local control agency information, administration, and enforcement
activities for alternative standards are also estimated. The alternative
3
standards considered are 2.0, 1.5, and 1.0 yg/m , monthly average. The
detailed methodology and documentation of the analysis are provided in
the report entitled "Background Document Supporting the Economic Impact
Assessment of the Lead Ambient Air Quality Standard".
1.2.1 Reasons for Selection of Sources for Consideration
In 1975, about 142 thousand metric tons of lead were emitted nationwide.
Combustion of lead containing gasoline accounted for 90% of those emissions.
Combustion of waste crankcase oil, solid waste, oil, and coal accounted for
an additional 5% of national emissions in 1975. The remaining 5% came from
19 industrial stationary source types. As a result of phasedown of lead
in gasoline, lead emissions from gasoline combustion are expected to
decrease about 60% by 1985 from current levels.2 Although this is a large
relative decline, gasoline combustion emissions are still projected to
be the greatest emission source nationally in 1985. Because of this,
-------
gasoline combustion sources (mobile sources) are included in the economic
impact assessment.
Combustion of waste crankcase oil, solid waste, oil, and coal is not
considered in the economic impact assessment. Combustion of waste crankcase
oil is not considered because the phasedown of lead in gasoline will cause
combustion of waste crankcase oil to cease to be a major source. Combustion
of solid waste is not considered in the analysis since many solid waste
combustion facilities (i.e., municipal incinerators) are scheduled to be closed.
Therefore, lead emissions from this source category will be substantially
reduced. Finally, sources burning oil and coal are not considered since
dispersion modeling and ambient data analysis near these sources have indicated
that oil and coal combustion will probably not result in violations of any of
the alternative ambient standards under consideration.
Growth projections as well as analyses of estimated emissions and measured
ambient impacts were developed for the 19 industrial stationary source types
previously mentioned. As a result, 8 of the 19 were identified as sources
probably requiring additional emission control. These 8 industrial source
types are primary lead smelters, secondary lead smelters, primary copper
smelters, gasoline lead additives manufacturing plants, lead-acid battery
manufacturing plants, grey iron foundries, ferroalloy plants, and lead ore
crushing and grinding plants. The economic impact assessment includes the
first six of the aforementioned source types. Ferroalloy plants are not
considered in the economic impact assessment because dispersion modeling
indicated that emissions from a model ferroalloy plant in zero background-isolated
-------
•ource situations should not result in violations of any of the alternative
standards under consideration. Ore crushing and grinding plants are not
considered in the economic impact analysis because of the inability to
adequately measure fugitive emissions from these sources and also to predict
the ambient impact of these emissions. These fugitive emissions are a
function of particle density and wind speed. The density data is not
currently available nor is a dispersion model which handles windblown
emissions.
One assumption which tends to understate the economic impact of any
given ambient lead standard is that each model plant is an isolated source
with no background ambient levels of lead present. To the extent that
sources of lead emissions may be clustered, the combined ambient lead
concentrations of the cluster result in higher control costs and impacts
than assumed.
In addition, even if the isolated source assumption were valid, there
are other factors that influence the results of the economic impact analysis.
These include topographical and meteorological conditions, stack characteristics,
particulate emission factors, lead content and particle size of participate,
fugitive emissions factors, and baseline process economics. Values for many
of these factors are initially specified as range estimates with midpoints
(arithmetic means) of the ranges used in the model plant analysis. For other
factors, values used in the model plant analysis are derived from site specific
measurements. However, the degree of error in the measurement per se or in the
application of the measured value to the model plant is not well known.
-------
Variations in these data inputs (factors) among plants and source
types limit the accuracy of the economic impact assessment. However,
the assessment does explicitly address some variations via a reasonable
range analysis for certain data inputs.
1.2.2 Methodology
1.2.2.1 Stationary Source Assessment Methodology
Plant, dispersion, control cost, and discounted cash flow models provide
the bases for the economic impact assessment for the selected stationary sources
Outputs of the plant models include emission, size, process, and location
characteristics. These are inputs to the dispersion model. The dispersion
model provides maximum predicted concentrations and source contribution file
estimates. The latter relate point and fugitive emissions generated by the
*•
plant to maximum predicted ambient concentrations. The outputs of the disper-
sion model are used together with control systems engineering and cost data
to produce estimates of investment and annualized control costs. These
estimates are the outputs of the cost model. They are used together with
process economic data in the discounted cash flow models to produce a numerical
estimate of the value of a plant after control. If these calculations show a
plant is worth more closed than it is open, closure is predicted.
In situations where all control costs could be passed on without any
effect on production levels, closure would never be predicted using the
8
-------
aforementioned methodology. However, the ability of an individual plant to
pass costs on and sustain pre-control production levels becomes less likely
as alternatives to accepting the cost pass on become available to his
customers or raw materials suppliers. The assumptions of the economic impact
assessment and the competitive structure of the industries analyzed imply
many alternatives to accepting a cost pass on. Consequently, no cost pass-on
is considered in the closure analysis.
1.2.2.2 Mobile Source Assessment Methodology
A 1975 source emissions inventory and projected mobile and stationary
source growth rates are used to estimate a 1982 lead emissions inventory for
each Air Quality Control Region. In a similar manner, ambient concentrations
are rolled forward. If the alternative ambient standards are predicted to be
exceeded, the 1982 source emissions inventory and ambient concentrations are
rolled back so that the standard is achieved. Of course, several different
combinations of mobile and stationary source control can achieve the same
rollback. In this analysis mobile source control is assumed used as a last
resort and then with emission reduction effectiveness limited to 75%.
The 1982 stationary source emissions inventory used in the mobile source
assessment includes eleven types of process sources. These are primary lead
smelting, secondary lead smelting, primary copper smelting, grey iron production,
gasoline lead additives production, lead-acid storage battery production,
ferroalloy production, coal-fired power generation, oil-fired power generation,
solid waste incineration, and iron and steel production. It is important to
note that only primary lead smelting and primary copper smelting were projected
to require additional rollback in 1982. This runs counter to the dispersion
-------
model findings of the stationary source assessment which identify the first 6
of the 11 aforementioned sources as requiring further control, This apparent
inconsistency is a function of the different methodologies employed and serves
to underscore another source of variability. Moreover, like data variability,
this inconsistency limits our ability to make accurate judgements regarding impact.
1.2.2.3 State and Local Control Agency Assessment Methodology
The state and local control agency assessment builds on the stationary
and mobile source assessments. Control requirements for the stationary source
model plant assessments for the three alternative standards are aggregated to a
national level and used as inputs to EPA's Air Pollution Strategy Resource
Estimator (APSRE). APSRE then provides an estimate of additional stationary
source related state and local control agency needs. Additional resource
requirements resulting from mobile source control are developed as supplementary
calculations using the findings of the mobile source assessment.
10
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2.1 PRIMARY LEAD SMELTING
2.1.1 Industry Structure
Six primary smelters owned by four corporations comprise the domestic
industry. Company names, the plant capacities and locations are given
in Table 2-1.
The four corporations smelting lead are both vertically and horizontally
integrated. For example, they mine lead ore and refine smelted lead. In
addition, they mine, smelt, and/or refine zinc, silver, coal, molybdenum,
and copper. The dependence that these corporations have on lead varies,
ranging from 6.1% of revenues for AMAX to 17.9% for Gulf Resources and Chemical.
Lead is an intermediate good. As such, the demand for lead is derived
from the demand from lead-using products. These include batteries, gasoline
lead additives, electrical cables and sheathing, paints, sheeting, plumbing,
and ammunition. Through the year 2000, U.S. lead demand is projected to grow
at 1.5% per year.
Lead is a small percent of end product value and has few close substitutes.
Therefore, its demand is character!cterized as price inelastic. This means
that when lead prices increase, total revenue (price times quantity sold) increases
Price inelastic demand notwithstanding, domestic primary smelters still
could face competitive pressures from other lead suppliers. For example,
unilateral price increases by domestic primary smelters could foster increased
competition from domestic secondary producers. Also, unilateral price increases
by domestic primary smelters could also foster increased competition from foreign
producers. As indicated in Table 2-2, foreign producers' prices
11
-------
Table 2-1. U. S. PRIMARY LEAD SMELTERS
Company
Amax
ASARCO
Gulf Resources
& Chemical
St. Joe Minerals
Corp.
Plant(s) Locatlon(s)
Boss, Missouri
East Helena, Montana
El Paso, Texas
Glover, Missouri
Kellogg, Idaho
Herculaneum, Missouri
1974 Capacity
(thousands of metric tons)
127
82
82
1QO
118
204
713
Source: U.S. EPA, October 1974. Background Information for New Source Performance Standards: Primary
Copper. Zinc, and Lead Smelters; Volume 1: Proposed Standards. Bureau of Mines Minerals Fact's
and Problems, 1975.
-------
Table 2-2. LEAD PRICES
(Average annual price, cents per kilogram)
Year London Metals Exchange New York
1964 27.8 30.0
1965 31.8 35.3
1966 26.3 33.6
1967 22.7 30.9
1968 24.1 29.1
1969 28.9 32.9
1970 30.5 34.7
1971 25.4 30.7
1972 30.2 33.1
1973 43.0 36-°
1974 59.2 49.7
1975 41.5 47.5
1976 45.3 51.0
Source: Bureau of Mines, Mineral Facts and Problems, 1975.
Bureau of Mines, Minerals and Materials. December, 1976.
Bureau of Mines, Minerals Yearbook. 1970, 1972, 1974.
-------
{London Metals Exchange) have been consistently less than domestic
producers' prices (New York Exchange). Anticipated reaction by foreign
producers to domestic primary smelter price increases may determine
whether domestic smelters elect to absorb long run cost increases or
push them forward as price increases.
2.1.2 Model Plant Specifications and Dispersion Model Results
The model plant specifications used in the economic impact assessment
are primarily dependent on the assumptions and data requirements of the
dispersion model. The dispersion model employed in the assessment is
the Single Source (CRSTER) Model. It is a steady state Gaussian
plume dispersion model. CRSTER will be recommended to the states to
develop lead emission regulations for isolated stationary sources.
Flat terrain is a basic assumption inherent in the CRSTER dispersion
model, and hence is one of the model primary lead smelter's specifications.
The flat terrain assumption may be important in predicting the distance
of the maximum concentration from plant. The maximum concentration for
the model primary lead smelter is predicted to be 300 meters away from
the plant. With rugged terrain, the maximum concentration could be expected
to be closer to the plant. A review of topographical maps for all six
smelters indicates elevations greater than the smelter site within 300
meters of the plant. Consequently, the maximum concentration may occur
closer to the plant than 300 meters.
14
-------
Data requirements of the dispersion model include meteorological
conditions such as wind speed, wind direction, and ambient temperature.
Such data is not always available for every plant location. St. Louis
meteorological data is available and is used in the analysis, since three
of the six smelters are located near St. Louis.
Data requirements of the dispersion model also include emission
characteristics such as stack gas exit velocity and temperature as well
as point and fugitive emission rates and release heights. These emission
characteristics are sometimes related to plant size. The production rate
used in the dispersion modeling is 62 thousand metric tons annual production.
This size is smaller than the current production rates of 4 of the 6
-elters. However, this size was chosen because fugitive emission
measurements were available for a plant of that size. Furthermore, because
emission characteristics are dependent on factors other than size, scaling
up the fugitive emission measurements of the model plant to be consistent
with an average plant size could provide atypical results.
The model smelter is assumed to have both stack and fugitive emissions
of lead particulate. Stack emissions are assumed controlled to average
SIP particulate allowable process weight rates. The fugitive emissions
are assumed uncontrolled. These emissions come from the sinter machine
building, blast furnace building, reverberatory furnace building, zinc
fuming area, and the zinc furnace building.
Stack emissions from the model smelters have a negligible effect on
oredicted maximum ambient lead concentrations. Moreover, higher stack emission
.ates within a range thought to be reasonable do not change this finding.
15
-------
Fugitive emissions have the predorainent impact on predicted ambient
concentrations, and this impact appears to vary significantly from
smelter to smelter. For example, fugitive emission rates derived from
measurements at a Montana primary lead smelter result in a maximum
predicted concentration for the model smelter of 3.8 ug/m , monthly
average. Fugitive emission rates derived from measurements at an Idaho
smelter are higher and result in a maximum predicted concentration before
control of 78.2 ug/m , monthly average.
2.1.3 Control Costs
2.1.3.1 Model Plant
The alternative ambient standards considered here are 2.0, 1.5, and
1.0 ug/m , monthly average. The predicted ambient concentrations
from both sets of fugitive emission rates mentioned above are greater than
the alternative standards. Hence, control costs corresponding to reduced
fugitive emission rates which achieve the alternative ambient standards should
be developed for the model primary lead smelter. Control costs representing
the least costly means of achieving the three standards were developed for
the lower set of derived fugitive emission rate. For the higher set, control
costs corresponding to 95% control efficiency were developed. The 95% estimate
is an engineering judgement based on the best demonstrated control system
currently available (building evacuation to a fabric filter). However, 95%
control applied to the higher set of fugitive emission rates still results in
2
a predicted maximum concentration of 3.9 ug/m which exceeds any of the alternative
standards. The control efficiencies required to get to 2.0, 1.5, and 1.0
ug/m3, respectively, are estimated to be 97.4%, 98.1%, and 98.7% as compared
with 95% which is judged to be the maximum attainable.
16
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The absolute and relative magnitude (as a percent of annual revenue)
of the developed investment and annualized costs are presented in Table 2-3.
For the lower fugitive emission rates, relative annualized control costs range
from 0.9% to meet a standard of 2.0 ug/m to 1.8% to meet a standard of
1.0 ug/m . For the higher fugitive emission rates, relative annualized costs
are 7.7% to meet an ambient level of 3.9 ug/m •
2.1.3.2 Industry
The most critical factor in the model plant control cost assessment is
the fugitive emission rates. As indicated previously, these rates have been
derived from fugitive emission measurements at two of the six currently
existing primary lead smelters. However, site specific topographical,
meterological, and smelter size, configuration, and emission rates data are
required to assess the ambient and cost impact at these six smelters with
reasonable certainty. Assuming all primary lead smelters have the same site
specific characteristics as the model smelter, five of the six existing
smelters would probably have low fugitive emission rates and hence have
ambient impacts closer to 3.8 than to 78.2 ug/m , monthly average. For
three (the Missouri smelters) of the five smelters this judgement is based
primarily on the presumption that since these smelters are newer they are
better controlled. For the other two of the five smelters (Montana and Texas),
similarity to the hypothetical smelter in terms of size, lower measured
fugitive emissions, and/or lower measured ambient concentrations is the
basis for the judgement. Higher measured fugitive emission and ambient
concentrations are the reasons for classifying the Idaho smelter (the
sixth smelter) as having ambient impacts closer to 78.2 ug/m .
17
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Table 2-3. CONTROL COSTS FOR THE MODEL PRIMARY LEAD SMELTER
Maximum Predicted Ambient Levels
(uQ/m3 , monthly average)
Higher Fugitive
Emission Rates
3.9
2.0
1.5
1.0
Investment
000's of $
as a % of
annual revenue
10800
34.4%
Annualized Cost
000's of $'s
as a % of
annual revenue
Z40U
7.7%
Lower Fugitive
Emission Rates
Investment
000's of $'s
as a % of
annual revenue
Annualized Cost
000's of $'s
as a % of
annual revenue
0
0
0
0
1300
4.0%
300
u.9%
1600
5.2%
400
1.2%
<^uu
7.5%
600
1.8%
*The control efficiency of the best demonstrated control system is limited
according to engineering judgement to 95%. This is not sufficient to achieve
the alternative ambient standards for the model plant with higher fugitive
emission rates.
18
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To draw further inferences from the model plant assessment is tenuous.
However, assuming production is proportional to the number of smelters
in each category and the model smelter costs can be extrapolated linearly to
higher production volumes, industry control cost estimates can be developed.
For 83.3% of the industry (current production share at the five plants
assumed to have low fugitive emission rates), the respective investment costs
in 1982 for meeting the 2.0, 1.5, and 1.0 yg/m standards are $11.9 million,
$15.3 million, and $22.4 million. The corresponding annualized costs are $2.8
million, $3.5 million and $5.3 million. For the remaining 16.7% of the industry
(current production share of the other smelter), control cost estimates are
those corresponding to 95% control efficiency. They are $20.5 million for
investment and $4.6 million for annualized costs.
2.1.4 Model Plant Closure Assessment
Using a discounted cash flow analysis technique, synthesized model plant
process economics, the aforementioned control costs, and assuming no other
lead emitters in the vicinity, the potential for closing the smelter on
financial grounds is assessed. Process economics (e.g., revenues, costs) were
developed using Bureau of Mines data as well as financial data from specific
companies.
Given the lower set of derived fugitive emission estimates, the model
smelter should not close regardless of the level of the standard. This finding
is true for several sets of circumstances. They include a range of marginal
tax rates and minimum acceptable return rates thought to be reasonable, full
19
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absorption of control costs, low profit margin and fully depreciated smelter,
and full absorption of operation and maintenance cost required for the proposed
Occupation Safety and Health Administration Lead Standard (100 ug/m , 40 hour
time weighted average and 60 yg/100 g whole blood).
Given the higher set of derived fugitive emission estimates, the ability
of the model smelter to achieve maximum (95%) control of fugitive emissions
(assuming this amount of control is satisfactory) and remain open is unclear.
The critical factors among previously described set of circumstances are the
marginal tax rates and the minimum acceptable return rates. Marginal tax rates
are the rates applicable to plant and not, for example, to the parent firm.
Minimum acceptable return rates are the profits available from the next best
investment opportunity. If the minimum acceptable return rates are not
realized, the plant will close; and, the next best investment opportunity will
be capitalized. If the tax and return rates are on the high end of the range
thought to be reasonable, it would be in the best financial interest of model
smelter to close. If the rates are lower, the model smelter with higher
fugitive emission rates should make the expenditures to achieve 95% control
and remain open.
20
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2.2 SECONDARY LEAD SMELTING
2.2.1 Industry Structure
The secondary lead smelting industry is a subset of the secondary lead
industry. The latter includes melters as well as smelters. Unfortunately,
industry structure statistics are only available for the secondary lead industry.
The secondary lead industry in the United States supplied 545,000 metric
tons or 39 percent of total lead consumption in 1974. Approximately 90
companies operating 130 plants produce lead and lead alloys for industrial
Q
use from recycled materials, principally old batteries. Two companies, ML
Industries, Inc., and RSR Corporation, operating about 18 secondary plants,
g
account for over 50 percent of the total secondary lead production. Thirteen
other companies operating approximately 24 plants that manufacture storage
batteries and other metal products account for 45 percent of secondary lead
production.
Roughly two-thirds of "all lead produced at secondary smelters is
antimonial lead and goes into the manufacture of batteries. Therefore, demand
for secondary lead in the future is tied to growth in battery use. While new,
longer lasting batteries are becoming more and more popular, demand for
replacement batteries is still expected to be 35 percent of total demand each
year until the end of the decade.
Prices are a critical factor in determining the supply of secondary lead.
Primary lead prices affect secondary lead prices in a direct way. To the
extent that the secondary industry acts as a broker, any change in the price
of primary lead will be reflected in the price of scrap. Secondary producers,
21
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therefore, could expand or contract their collection effort depending on
changes in the price of lead. Although it may vary above and below the
primary lead price, the secondary soft lead price follows the average prices
quoted in Metals Week. Historical primary lead prices are provided in
Table 2-2.
2.2.2 Model Plant Specifications and Dispersion Model Results
To provide reasonably accurate predictions of ambient impact, the model
plant specifications should be consistent with the assumptions and data
requirements of the dispersion model. CRSTER, the dispersion model employed
in the assessment, is designed to predict ambient impacts of emissions from a
plant located in flat terrain with meteorological conditions representative
of the area. To avoid modeling an atypical situation, an actual smelter located
in flat terrain with local meteorological data available is the plant modeled.
The smelter produces about 30 metric tons of lead a day. However, this is
somewhat low when compared to the midpoint of the range of plant sizes specified
in the Control Techniques Document worksheets. The range specified there is
18 to 68 metric tons per day with the midpoint being 43 metric tons per day.
But the actual size distribution of the secondary lead smelters is unknown.
Moreover, an explicit attempt is made to avoid modeling atypical situations.
Hence, the size of the model plant is not adjusted upwards to reflect the
midpoint of a size range.
The model smelter has lead particulate stack emissions controlled to
average SIP process weight rates. These emissions have a negligible impact
on the maximum predicted ambient concentrations. In addition there are
22
-------
fugitive emissions assumed for the model smelter. These emissions are
uncontrolled and result in a maximum predicted concentration of 56.6
monthly average for the midpoint (arithmetic mean) fugitive emission estimate.
For a low fugitive emission estimate the maximum predicted concentration is
33.2 yg/m . For a high fugitive emission estimate the maximum predicted
concentration is 80.5 ug/m . The maximum predicted concentrations for all
fugitive emission estimates are extremely sensitive to the assumed release
height of the fugitive emissions. For example, increasing the release height
by 5 meters for the midpoint emission estimate reduces the maximum predicted
concentration from 56.6 yg/m to 20.0 yg/m . However, the release height
assumed originally (10 meters) is thought to be typical of secondary lead
smelting release heigjits.
If the release height is typical and best demonstrated control cannot
achieve the standard, another consideration might be land acquisition. The
predicted maximum of 56.6 yg/m occurs 150 meters from the plant. If legally
feasible and cost effective, the plant may supplement the fugitive emission
control system by purchasing surrounding land which has ambient concentrations
greater than the standard. Under such a strategy, and with barriers to limit
access to these areas, the public would still be protected from the adverse
consequences of concentrations exceeding the standard. However, the feasibility
of land acquisition as a control strategy is beyond the scope of this assessment.
23
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2.2.3 Control Costs
As previously noted, the maximum predicted concentrations of 33.2 to
80.5 yg/m3, monthly average exceed the considered alternative ambient standards
for all sets of fugitive emission estimates. Consequently, fugitive emissions
will have to be reduced to some degree at the model smelter regardless of the
level of the standard. Building evacuation to a fabric filter has been applied
to secondary lead smelters before. However, the achieved level of control
efficiency is not known. At present, 95% control efficiency seems to be
the limit applied by engineering judgement on this technically demonstrated
system.
Applying a 94% or 95% efficient control system to the model smelter is estimated
to require an investment of $1.8 million which is about 32% of annual revenue.
Corresponding annualized cost is $0.4 million which is about 7% of annual revenu
3
A 94% or 95% control efficiency will achieve the 2.0 yg/m standard for the
low fugitive emission estimates, but will not achieve any of the more
restrictive alternative ambient standards. Furthermore, 95% control efficiency
will not achieve any of the considered alternative ambient standards given the
dispersion modeling results for the midpoint and high fugitive emission rate
estimates. With the midpoint fugitive emission rate estimate, 95% control
efficiency results in a predicted maximum of 2.8 yg/m3. With the high fugitive
emission rate estimate, 95% control results in a predicted maximum of
4.0 yg/m3.
2.2.4 Model Plant Closure Assessment
The model plant closure assessment for secondary lead smelting includes
24
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an analysis of high, average, and low profit margin smelters. The process
economics (e.g., revenues, costs) for these profit margins are developed using
publicly available financial data on NL Industries and RSR.
High profit margin model smelters with plants that are not fully depre-
ciated should be able to absorb the costs associated with the 94% or 95%
efficiency system and remain open. This finding holds within a range of
marginal tax rates and minimum acceptable return rates thought to be reasonable.
However, high profit margin model smelters that are fully depreciated will only
be able to remain open under similar conditions if they have relatively low
marginal tax rates and minimum acceptable return rates.
Average profit margin model smelters not having fully depreciated plants
should be able to absorb the costs associated with the 94% or 95% efficiency
system and remain open under most conditions. However, with a 94% efficiency
system, this model smelter will close if the marginal tax rates and minimum
acceptable return rates are reasonably high. With a 95% efficiency system,
this model smelter will close if the minimum acceptable return rate is
reasonably high and the marginal tax rate is within a range thought to be
reasonable.
Low profit margin model smelters regardless of the depreciation circumstances
and average profit margin model smelters that are fully depreciated would
probably close rather than absorb the cost of a 94% or 95% efficiency system.
25
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2.3 PRIMARY COPPER SMELTING
2.3.1 Industry Structure
Eight companies with a combined total of 16 smelters make up the
U.S. primary copper smelting industry. Table 2-4 lists the companies,
plants, their locations, and capacities.
Smelting is an intermediate production process proceeding refining and
fabrication and following mining, ore beneficiation, and/or scrap collection.
Consequently, the demand for smelted copper is derived from the demand for
refined and fabricated copper. Refined and fabricated copper is used primarily
by the construction, communications, and motor vehicle manufacturing industries.
Substitutes for refined and fabricated copper do exist. They include aluminum,
steel, and plastic.
Smelted copper can be supplied by secondary or primary producers either
located in the U.S. or elsewhere. Foreign producers supplied about 10% of
the 1974 U.S. demand for copper.11 Domestic producers on the other hand used
12
about 4% of the 1974 production to satisfy foreign demand for copper.
Of the domestic production used to satisfy domestic demand in 1974,
about 45% was supplied by domestic secondary producers with the remaining 55%
being supplied by primary producers.
Historical prices for domestic producers refined copper are presented
in Table 2-5.
The demand for domestic primary smelting output is projected to grow
at 3% per year.13 However, limited domestic smelter capacity could constrain
this growth resulting in excess demand and upward price pressures for blister,
refined, and fabricated copper. Given future excess demand and upward price
26
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lable 2-4. PRIMARY COPPER SMELTERS
ro
Company
The Anaconda Company
ASARCO
Cities Service Corp.
Copper Range
Inspirational Consolidated
Copper
Kennecott Copper Corp.
Newmont Mining Corp.
Phelps Dodge
Smelter Location
Anaconda, Montana
El Paso, Texas
Hayden, Arizona
Tacoma, Washington
Copper Hill, Tenn.
White Pine»Michigan
Miami, Arizona
Hayden, Arizona
Hurley, New Mexico
McGill, Nevado
Qarfield, Utah
San Manuel, Arizona
Ajo, Arizona
Douglas, Arizona
Morenci, Arizona
Hi 1dago, New Mexico
1974
Smelter Capacity Furnace Charge
(metric tons/yr)
680,000
523,000
871,000
544,000
68,000
82,000a
408,000
381,000
363,000
363,000
907,000
726,000
227,000
635,000
816,000
91,000
Measured as copper product.
Source: Background Information for New Source Performance Standards; Primary Copper. Zinc, and Lead
Smelters - Volume I - Proposed Standards. U.S. EPA. Document No! EPA-450/2-74-002a. October
1974, p. 6-3. Also ADL estimates for the EPA-MBO Study, forthcoming 1977.
-------
Table 2-5. COPPER PRICES
(average annual price, cents per kilogram)
F.O.B. Domestic Primary
Year Producer Refined Pricea
1964 70.5
1965 77.2
1966 79.8
1967 84.2
1968 92.2
1969 104.7
1970 127.2
1971 113.3
1972 m-6
1973 129.9
T974 168.9
1975 140.0
1976 151-7
aSource: Metals Week
-------
pressures, domestic smelters will probably find it better to push forward
any increases in production cost. The alternative, pushing the costs back
to the ore and matte suppliers, could spell the loss of critical raw materials
from marginal ore and matte suppliers. However, if only one domestic smelter
is faced with production cost increases, it may find it difficult to pass
them forward because of dependence on other domestic smelters following
its lead. Passing production costs forward becomes much more plausible,
however, if all or several domestic smelters incur similar production
cost increases.
2.3.2 Model Plant Specifications and Dispersion Modeling Results
As mentioned in the primary and secondary lead smelting assessments,
the requirements of the dispersion model affect the specifications of the
model plant. Terrain and meteorological conditions are the two major
influences. In essence, the model plant should be located in flat terrain
with nearby meteorological condition data available. Furthermore, to be
typical, the size and location of the model plant should correspond to an
actual plant.
The model smelter is located in flat terrain, has Tucson, Arizona
meteorological conditions, and has furnace charge capacity of 635,000 metric
tons per year. These specifications do correspond to an actual plant. More-
over, some of the other existing smelters do have similar characteristics.
For example, 5 of the 16 are located in flat terrain and 6 have meteorological
conditions similar to Tucson, Arizona.
29
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The charge rate of the model smelter is high when compared to the
industry average of 500,000 metric tons per year. However, no existing
smelters of that charge rate are located in flat terrain with nearby
meteorological condition data available. Consequently, the model smelter
size was not scaled up to the industry average.
Other model plant specifications include the process equipment. These
specifications are for an actual plant with the aforementioned terrain,
meteorology, and size characteristics. The model plant has a reverberatory
smelting furnace, Pierce-Smith converters, and multiple hearth roasters. Of
the 16 existing smelters, 12 have reverberatory smelting furnaces and 15
have Pierce-Smith converters. However, only four have multiple hearth roasters.
The others have either fluidized-bed roasters or no roasters at all. The
effect of process equipment variations among smelters on ambient air quality
is presently unknown.
The model smelter is assumed to have both stack and fugitive emissions of
lead particulate. Stack emissions are assumed controlled to average SIP
particulate allowable process weight rates. The fugitive emissions are assumed
uncontrolled and to emanate from the roaster, reverberatory furnace, and
converter buildings.
Stack emissions have a negligible predicted impact on ambient lead
concentrations. Moreover, higher emission rates within a range thought to
be reasonable do not change this finding. Fugitive emissions do have a
noticeable predicted ambient impact. However, fugitive emission estimates
are dependent on the percent lead content of the materials handled. This
-------
percentage varies among smelters. The fugitive emission estimates felt to
be most typical of a middle estimate result in a predicted maximum ambient
concentration of 3.1 pg/m , monthly average. The fugitive emission estimates
felt to represent a reasonable lower limit on the percent lead content yield
a predicted maximum ambient concentration of 0.4 pg/m , and, estimates for a
reasonable higher limit result in a maximum predicted concentration of
3
10.7 vg/m , monthly average.
2.3.3 Control Costs
2.3.3.1 Model Plant
As indicated above, the monthly maximum predicted ambient concentration
for the middle and reasonable higher limit fugitive emission estimates exceed the
alternative ambient standards (2.0, 1.5, and 1.0 ug/m3) at the model smelter.
Consequently, control costs corresponding to reduced fugitive emission rates
which will achieve the alternative ambient standards are developed. These
costs are specifically designed to approximate the least cost means of
achieving each standard. No costs are developed for the reasonable lower
limit fugitive emission estimates since the predicted maximum concentration
in that case is less than all considered alternative standards.
The investment, annualized control cost, and investment and annualized
cost as a percent of annual revenue for the model smelter are presented in
Table 2-6. The middle fugitive emission estimates investment costs range from
-3 3
$5.2 million for the 2.0 ug/m standard to $9.8 million for the 1.0 ug/m
standard. The corresponding annualized costs range from $1.1 million to
$2.1 million. With the reasonable higher limit fugitive emission estimates,
31
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Table 2-6. CONTROL COSTS FOR THE MODEL PRIMARY SMELTER
Reasonable Higher Limit
Fugitive Emission Rates
Investment
000's of $'s
as a % of annual revenue
Annualized Cost
000's of $'s
as a % of annual revenue
Maximum Predicted Ambient Levels
(yq/m3 monthly average)
2.0
22,300
15.2
4,000
3.3
1.5
28,900
19.7
6,200
4.3
1.0
35,400
24.2
7,600
5.2
Middle Fugitive Emission Rates
Investment
000's of $'s
as a % of annual revenue
Annualized Cost
000's of $'s
as a % of annual revenue
5,200
3.5
1,100
0.8
7,600
5.2
1,600
1.1
9,800
6.7
2,100
1.4
Reasonable Lower Limit Fugitive
Emission Rates 0* 0* 0*
Investment and annualized costs are zero since the maximum predicted concentration
is less than all considered alternative ambient standards.
32
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corresponding investment costs range from $22.3 million to $35.4 million.
The annualized cost range from $4.8 million to $7.6 million.
2.3.3.2 Industry
A critical factor in drawing inferences from the model plant assessment
and applying them to the entire industry is the amount of control required. To
determine the amount of control required necessitates categorizing existing
smelters as indicative of the middle, reasonable lower, or reasonable higher
limit fugitive emission estimates. On the basis of the estimated amount of
lead in the furnace charge at full capacity, three existing smelters are believed
to be indicative of the middle fugitive emission estimate; seven are indicative
of reasonable lower limit fugitive emission estimate; and six are indicative
of the higher limit fugitive emission estimate. To draw further inferences
is tenuous. However, if it is assumed that production is proportional to the
number of smelters in each category and the model smelter costs can be extrapolated
linearly to higher production volumes, industry control cost estimates can be
developed. The investment costs for the year 1982 are $184.4 million for a
standard of 2.0 ug/m , $241.8 million for a standard of 1.5 ug/m , and $298.7
million for a standard of 1.0 yg/m . The corresponding annualized costs are
$40.0 million, $52.3 million, and $64.4 million.
2.3.4 Model Plant Closure Assessment
Using a discounted cash flow analysis technique and model plant process
economics synthesized from publicly available company financial reports, the
potential for closing the smelter on financial grounds is assessed. Given
the reasonable lower limit fugitive emission estimates, the model plant should
not close. With a maximum predicted concentration of 0.4 ug/m , no control
33
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expenditures are required. Given the middle fugitive emission estimate, the
model smelter should not close even though control costs must be expended to
achieve all alternative standards. This finding is true for a range of marginal
tax rates and minimum acceptable return rates thought to be reasonable, full
absorption of all control costs, and a fully depreciated model plant.
Given the reasonable higher limit fugitive emission estimates, the ability
of the model smelter to remain open on financial grounds alone is unclear.
However, the potential for remaining open is greater with a standard of 2.0
ug/m3 than with either a standard of 1.5 or 1.0 ug/m . With a standard of
2.0 yg/m certain marginal tax rate and minimum acceptable return rate combina-
tions within a range thought to be reasonable do permit a fully depreciated
plant absorbing all the control costs to remain economically viable. With the
1.5 or the 1.0 yg/m3 standards, a fully depreciated plant absorbing all the
control cost is not economically viable under any marginal tax rate and minimum
acceptable return rate combinations judged to be reasonable.
34
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2.4 GREY IRON FOUNDRY CASTING
2.4.1 Industry Structure
14
There are about a 1000 establishments classified as grey iron foundries.
Grey iron is produced at these foundries in cupola, electric, and reverberatory
furnaces. The main output of the foundries is castings. These come in a
variety of sizes and shapes having different chemical and physical properties.
The grey iron foundry industry produces intermediate goods. Castings
become part of and/or are used in the production of automobiles and trucks,
construction machinery, railway equipment, electrical and farm machinery,
rolling mills, and machine tools. Consequently, the demand for grey iron
is a function in part of the demand for these products. Demand for grey iron
is projected to grow at 3.2% per year. 5
Historically, the average price of grey iron castings has risen slightly
faster than the Wholesale Price Index. However, what product that average
price represents is not clear. The selling price for grey iron varies
depending on the size, shape, and chemical and physical properties of the
product. In 1976 the average price of a grey iron casting was $340/metric
ton.16
2.4.2 Model Plant Specifications and Dispersion Modeling Results
The model foundry specifications are consistent with the assumptions
and data requirements of the dispersion model. For example, the model grey
iron foundry is located in flat terrain with representative meteorological
condition data available. The model foundry specifications are also
consistent with the objective of modeling a realistic situation. For
example, like 60% of the grey iron foundry establishments, the model
smelter is located in an east north central state. Moreover, like 70%
35
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of the grey iron produced nationally, the model foundry produces grey
iron in a cupola furnace. In addition, the size of the model foundry,
7.3 metric tons/hour melt rate, corresponds to an actual foundry
located in flat terrain in an East North Central State.
The model smelter has lead particulate stack emissions controlled to
average SIP process weight rates for particulate. Stack emissions have a
negligible impact on the maximum predicted ambient concentrations. Fugitive
emissions are assumed for the model grey iron foundry. These emissions are
assumed uncontrolled. For a low fugitive emission rate estimate, the maximum
predicted concentration is 0.3 ug/m , monthly average. For a midpoint fugitive
emission rate estimate, the maximum predicted concentration is 1.8
And, for a high fugitive emission rate estimate, the maximum predicted concen-
tration is 3.7 ug/m , monthly average.
Z.4.3 Control Cost
No control costs need to be developed for the low fugitive emission rate
estimate since the predicted monthly average maximum concentration of 0.3
ug/m3 is less than any of the alternative standards (i.e., 2.0, 1.5, and
1.0 ug/m3). For the midpoint fugitive emission rate estimate control costs
are developed for the 1.5 and 1.0 yg/m alternatives since the predicted
maximum (1.8 ug/m ) is greater than these levels. However, no control costs
are developed for the 2.0 ug/m alternative since the predicted maximum is
less. For the high estimate, since the predicted monthly average maximum
-3
of 3.7 ug/m is greater than the three considered alternative standards,
control costs are developed for all three standards.
36
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The investment, annualized costs, and investment and annualized costs
as a percent of annual revenue are presented in Table 2-7. The control
system costed is side draft and canopy hoods which are ducted to a fabric
filter. For the midpoint fugitive emission rate estimate, investment cost
as a percent of annual revenue is 9.8% for both the 1.5 and 1.0 yg/m standards.
Annualized cost as a percent of annual revenue for both standards is 2.0%.
3
The reason the costs do not vary between the 1.5 and 1.0 yg/m standards
is that the control system costed is assumed incapable of distinguishing
between the required control efficiencies needed to attain both standards.
For the high fugitive emission rate estimate, the required control
efficiencies for the 1.5 and 1.0 yg/m standard are greater than for the
midpoint fugitive estimate. These greater efficiencies are assumed reflected
in different control system design and operating needs, and hence in the cost.
Investment cost as a percent of annual revenue ranges from 9.8% for the
2.0 yg/m3 standard to 30.4% for the 1.0 yg/m3 standard. Corresponding
annualized cost as a percent of annual revenue ranges from 2.0% to 6.2%.
2.4.4 Model Plant Closure Assessment
The baseline process economics for the grey iron foundry model plant
are developed using financial data contained in Leo Troy's 1977 Almanac
of Business and Industrial Financial Ratios.
Assuming zero background concentrations of lead and no other lead emitters
in the area, the model grey iron foundry with low or midpoint fugitive
emission rates should remain open regardless of the level of the standard.
For the model with low fugitive emission rates, no control costs need
be expended since all alternative standards are predicted to be achieved.
37
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Table 2-7. CONTROL COST FOR THE MODEL GREY IRON FOUNDRY PLANT
Maximum Predicted Ambient Levels
(ug/m3 monthly average)
2.0 1.5 1.0
High Fugitive Emission Rates
Investment
OOO's of $'s 30° 60° 110°
as a % of annual revenue 9.8% 18.4% 30.4%
Annualized Cost
OOO's of $'s 70 130 220
as a % of annual revenue 2.0% 3.8% 6.2%
Midpoint Fugitive Emission
Rates
Investment
OOO's of $'s 0* 300 300
as a % of annual revenue 9.8% 9.8%
Annualized Cost
OOO's of $'s 0 70 70
as a % of annual revenue 0 2.0% 2.0%
Low Fugitive Emission Rates 0* 0* 0*
investment and annual ized costs are zero since the maximum predicted
concentration is less than all considered alternative ambient standards,
38
-------
Hence, it is clear that the model foundry should remain open. For the
model with midpoint fugitive emission rates, no control cost expenditures
are required for the 2.0 yg/m standard. However, the model foundry
must expend control costs to achieve the 1.5 vq/m and 1.0 ug/m standards,
Given that these costs must be absorbed, the model foundry is fully
depreciated and the foundry faces a reasonable range of marginal tax and
minimum acceptable return rates; it should remain open on financial
grounds.
The model foundry with high fugitive emission rates requires control
expenditures for all alternative standards. For the 2.0 and 1.5 ug/m
standard, the model foundry should remain open on financial grounds
given the cost absorption, depreciation, and marginal tax and return
rate conditions mentioned previously. However, with the 1.0 ug/m
standard, a fully depreciated foundry absorbing the control costs should
close for most marginal tax rate and minimum acceptable return rates
within a range thought to be reasonable. Only with marginal tax and
minimum acceptable return rates at the low end of the reasonable range
will a fully depreciated model foundry absorb the control costs needed
to meet a 1.0 yg/m standard and remain open on financial grounds.
39
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2.5 GASOLINE LEAD ADDITIVES MANUFACTURING
2.5.1 Industry Structure
Four companies with a combined total of six plants comprise the
U.S. gasoline additives (lead alkyl) industry. Table 2-8 lists the
companies, their plants, capacities, and locations. Present annual
capacity is 403 million kilograms of tetraethyl lead (TEL) equivalent.
Annual production in 1974 was about 318 million kilograms of TEL equivalent
1Q
or about 80% of capacity.
Gasoline lead additives are mixed with gasoline to raise the Octane
Number and consequently, reduce engine knock. Low production cost and
high effectiveness in raising the Octane Number resulted in widespread
use of lead additives with little competition from other compounds.
However, EPA's lead phasedown regulations will result in the
development and acceptance of other compounds and hence, slow down
20
future domestic production and consumption of gasoline lead additives.
Although most analysts agree the future U.S. production of lead additives
will be less than it is today, the exact decline in future production is
unknown. Industry representatives are optimistic with regard to export
21
possibilities even though domestic consumption will decline. However,
others feel the export market growth may not materialize if foreign
countries also adopt lead phasedown regulations.
Even with a production decline, given tight energy supplies and
projected increases in the demand for gasoline, future lead additives
prices should not decline. In 1976, pure TEL sold for about 223.3
-------
Table Z-ti. u.$. GASOLINE ADDITIVE (Lead Alkyl) MANUFACTURING PLANTS
1974 Capacity
(millions of Kg
Company Plant(s) Location(s) Tetraethvl Lead)
E.I. duPont de Nemours Antioch, California 154
& Company, Inc. Deepwater, New Jersey
Ethyl Corporation Baton Rouge, Louisiana 177
Pasadena, Texas
PPG Industries, Inc. Beaumont, Texas 54
Nalco Chemical Company Freeport, Texas 18
403
Source: Chemical Economics Handbook p. 671.5042 C, December, 1975.
-------
Table 2-9. PRICES OF 100% PURE TETRAETHYL LEAD (TEL) IN TEL MOTOR ANTIKNOCK
U/Kg)
1964 124.6
1965 127.9
1966 126.3
1967 125.0
1968 124.1
1969 127.4
1970 128.5
1971 133.6
1972 135.4
1973 137.3
1974 157.6
1975 200.0
1976 223.3
Source: Chemical Economics Handbook, "Tetraethyl Lead and Tetramethyl Lead", Stanford Research
Institute, p. 671.5042 R, December 1975. and DuPont, 1976. Antiknock mi* prices were
multiplied by 1.626 assuming 1.626 pounds of antiknock per pound of pure TEL.
-------
2.5.2 Model Plant Specifications and Dispersion Modeling Results
Of the six gasoline lead additives plants, all are located in flat
terrain, 74% of their combined capacity produces tetraethyl lead (TEL)
using the sodium-lead alloy process, three are located in Southeast Texas,
and the average capacity of each plant is 67,000 metric tons of TEL
equivalent. The model plant used in the dispersion modeling is located
in flat terrain, produces TEL using the sodium-lead alloy process, has
Houston, Texas meteorological conditions, and produces about 54 thousand
metric tons of TEL annually.
The model plant is assumed to have lead stack emissions in both the
particulate and vapor phases. The lead recovery furnace stack emits
lead in the particulate phase and is controlled to the average SIP
allowable process weight rate. The process vents and sludge pit exhaust
stacks emit lead in the vapor phase and are uncontrolled. No fugitive
emissions are assumed. The maximum predicted concentration for the lead
stack emissions is 15.7 ug/m , monthly average.
2.5.3 Control Costs
2.5.3.1 Model Plant
Since 15.7 ug/m is greater than all the considered standards,
control costs indicative of reduced stack emission rates are developed
for all the considered standards. The costed control system includes
packed scrubbers and increased pressure drop on an existing venturi
scrubber. The model plant investment, annualized control cost, and
investment and annualized cost as a percent of annual revenue are presented
43
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in Table 2-10. Investment control costs for the model plant range from $519
thousand for meeting the 2.0 ug/m standard to $521 thousand for meeting the
1.0 ug/m standard. Annualized control cost as a percent of product sales
price is about 0.2% for the three considered standards.
2.5.3.2 Industry
A critical factor in the model plant impact assessment is the
required reduction in the baseline emission rates to achieve the alternative
ambient standards. The required reduction could be greater for larger
TEL plants or for TEL plants clustered among other lead emitters.
However, to the extent that the required reductions at the six existing
gasoline lead additive plants are similar to those at the model plant,
achievement of all three alternative ambient standards would appear to
be technically possible by all plants. Furthermore, if model plant
control costs are related linearly to 1974 production, the estimated
•
1982 total industry investment costs in this industry are $3.03, $3.03,
3
and $3.05 million for the 2.0, 1.5 and 1.0 ug/m standards, respectively.
The corresponding annualized costs are $1.57, $1.57, and $1.58 million.
2.5.4 Model Plant Closure Assessment
Using a discounted cash flow analysis technique, synthesized model
plant process economics, the aforementioned control costs, and assuming
no other lead emitters in the vicinity, the potential for closing the
model plant on financial grounds is assessed. The model plant process
economics are a composite of published financial data for the U.S.
gasoline lead additives producers. The major finding of the closure
assessment is that the model gasoline lead additives plant is better off
remaining open and complying with reduced stack emission rates necessary
-------
Table 2-10. CONTROL COSTS FOR THE MODEL GASOLINE
LEAD ADDITIVES PLANT
Maximum Predicted Ambient Levels
(ug/m3 . monthly average)
2.0 1.5 1.0
Investment
OOO's of $'s 519 519 521
as a % of annual 0.4% 0.4% 0.4%
revenue
Annualized Control Cost
OOO's of $'s 270 270 271
as a % of annual 0.2% 0.2% 0.2%
revenue
-------
to achieve all standards under a variety of circumstances. These include
all marginal tax rate and minimum acceptable return rates thought to be
reasonable, fully depreciated plant, sustained production decline (25%),
an increase in the raw material lead price (as a result of the lead
ambient air quality standard, i.e., 1.8%), and full absorption of all
control costs.
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2.6 LEAD-ACID BATTERY MANUFACTURING
2.6.1 Industry Structure
Currently there are about 200 lead acid battery manufacturing
plants in the United States ranging in size from about 50 to about
11,500 batteries per day.
Two major types of lead acid storage batteries are manufactured in
the United States. Starting-Lighting-Ignition (SLI) batteries which are
used in auto, aircraft, and golf carts are one type. The units account
22
for more than 80 percent of the market. The second type includes
industrial storage batteries for such uses as low-voltage power systems
and industrial forklift trucks.
The market for lead-acid storage is composed of three segments.
The largest segment in' terms of sales is the domestic replacement market.
This includes replacement batteries for automobiles, trucks, buses, farm
machinery, and heavy equipment. The original domestic equipment market
is the second largest segment. This includes batteries sold to producers
of new vehicles and equipment. The export sector is the smallest market.
This includes replacement batteries in existing equipment and batteries
for new equipment. The overall demand for batteries in these market
23
segments is expected to grow between 3.5% and 8.2% per year.
Prices for automobile SLI batteries are about $16 to $22 f.o.b.
*y A
plant and about $35 to $50 retail. Prices for industrial storage
25
batteries range from $200 to $11,500. Because batteries represent
such a small percentage of vehicle costs and appear to have few close
47
-------
substitutes, demand is thought to be price inelastic. However, the
replacement demand market segment for batteries is thought to be less
price inelastic than the new demand segment since useful battery life
can be extended by improved maintenance, servicing, and repair.
2.6.2 Model Plant Specifications and Dispersion Modeling Results
Two model lead acid battery plants are used in the dispersion
modeling. One is capable of producing 500 batteries per day; the other
is capable of producing 6500 batteries per day. These two plant sizes
are thought to bound the reasonable range of actual industry plant sizes.
Consistent with the dispersion model, both plants are located in flat terrain
with area meteorological condition data available. This situation is not
atypical since there is an actual battery plant with similar terrain and
meteorological features.
None of the model lead acid battery plants are assumed to have
fugitive emissions. All emissions emanate from point sources. These
point sources are controlled to average SIP allowable process weight
rates. The maximum predicted concentration for the 500 battery per day
plant is 0.9 yg/m3, monthly average. The maximum predicted concentration
for a 6500 battery per day plant is 7.6 ug/m , monthly average.
2.6.3 Control Cost
Since the maximum predicted concentration for the model 500 battery
per day plant does not exceed any of the considered standards, no control
costs are developed for that model plant. Control costs are developed for the
model 6500 battery per day plant since the maximum predicted concentration
-------
(7.6 ug/m ) does exceed the considered standards of 2.0, 1.5, and
1.0 ug/m .
The only point source requiring control is the three process operation
stack. Required control efficiencies for this source are about 75
percent, 81 percent, and 88 percent for the respective standards of 2.0,
1.5, and 1.0 ug/m . A wet impingement scrubber is assumed to achieve
those control efficiencies at least cost. The investment cost is not
assumed to vary with the required control efficiency and is estimated at
$130 thousand. Operating costs are, however, assumed affected to some
degree by the required control efficiency. Respective annualized costs
for meeting 2.0, 1.5, and 1.0 standards are $57,000, $57,400, and $57,900.
Annualized cost as a percent of annual revenue (assumes price per battery
of $18.50) is about 0.1% for each of three standards.
2.6.4 Model Plant Closure Assessment
A low profit margin fully depreciated model 6500 battery per day
plant should be able to absorb the control costs associated with any of
the standards and still remain open. This finding holds for a range of
marginal tax rates and minimum acceptable return rates thought to be
reasonable. It also holds given the assumptions that raw material lead
prices increase as a result of the lead ambient air quality standard and
that this cost increase (1.8 percent) is absorbed.
Process economics were developed using published financial data for
Gould, Inc. and Northwest Industries, Inc.'s General Battery Division.
49
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3.0 OTHER AFFECTED SECTORS
3.1 MOBILE SOURCE ASSESSMENT
Several assumptions are used to project mobile source impact. These
include phasedown of lead in the gasoline pool, improved fuel economy,
and retirement of some older leaded gasoline using vehicles. For an ambient
standard of 2.0 ug/m3, one Air Quality Control Region (AQCR) is predicted
to require mobile source emission control in 1982. For an ambient standard
of 1.5, the number predicted is two AQCRs. And, for an ambient standard of
1.0, it is four AQCRs.
Vehicles using leaded gasoline are retired as they get older, and often
these vehicles are replaced with newer cars using unleaded gasoline. Hence,
the number of AQCRs requiring mobile source emission control might be less
in for example 1985 than in 1982. In 1985, the number of AQCRs requiring
mobile source emission control is predicted to be one for the 2.0 and
3 3
1.5 ug/m standards, and two for the 1.0 ug/m standard.
To achieve the alternative ambient standards in 1982 by retrofitting
existing leaded gasoline using light duty vehicles with 75% efficient lead
trap mufflers (if available) could affect the following number of vehicles.
For the 2.0 ug/m3 standard, the predicted number is 58,000. For the 1.5
ug/m3 standard, the predicted number is 106,500. And, for 1.0 ug/m3 standard
the predicted number of light duty vehicles affected is 1,300,000.
Of course retrofitting lead trap mufflers is not the only means of
controlling mobile source lead emissions. Reduction in vehicle miles
traveled (VMT) and further reduction in the lead content of gasoline are
alternatives. VMT reductions can be achieved many ways including
50
-------
carpooling, mass transit, and reduced trips. Further reduction in the lead
content of gasoline can also be achieved in many ways including using non-lead
gasoline additives and increasing the reforming capacity of the refineries.
Costs for these many ways to achieve alternatives to retrofitting lead trap
mufflers have not been developed. Consequently, relative cost effectiveness
of retrofitted lead traps is not known.
51
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3.2 STATE AND LOCAL AIR POLLUTION CONTROL AGENCY ASSESSMENT
Currently there are 55 state and 235 local air pollution control
agencies. Annually they spend approximately 7100 man-years of effort and
$157 million dollars implementing air pollution control regulations.
An ambient lead standard can impose additional requirements (costs)
on State and local air pollution control, agencies to administer the
standard. The added requirements could take the form of more data gathering,
enforcement, monitoring, laboratory, support, and management activities.
The previously described stationary and mobile source assessments are
the bases for estimating these added requirements. To the extent that
these bases understate the magnitude of the problem (for example the
number of source inspections) the added requirements for State and local
control agencies are also understated. But, even if the stationary and
mobile source assessments do not understate the magnitude of the problem,
control agency requirements could be understated for another reason.
The estimates of additional state and local control agency costs do not
include the requirements for developing completely new fugitive emissions
inventories. However, the estimates do include the requirements for
additional maintenance and update of existing inventories.
Some requirements (costs) are estimated to be incurred in the first year
only while others are on-going. First year requirements include the costs
for ambient monitors and laboratory equipment such as hi-vols and spectro-
photometers. In addition, there is non-recurring labor for activities
such as State implementation plan development and site preparation for monitors,
52
-------
No enforcement is assumed to take place during the first year while strategy
and regulations are being developed. Also, in the first year monitoring and
laboratory activities are limited while equipment is being installed. The
first year requirements in dollar terms range from $1.0 million with a
3
standard of 2.0 ug/m , monthly average to $1.7 million with a standard of
1.0 ug/m . The relative magnitudes of these costs compared to current
expenditures are 0.6% and 1.0%. In terms of people, the corresponding
first year requirements are 30 man-years and 40 man-years. Compared to
current man-years expenditures, these correspond to 0.4% and 0.6%, respectively.
On-going or annual costs include operating costs but not depreciation
or interest. Examples of operating costs are maintenance, supplies, and
power for ambient monitors and laboratory equipment. Operating costs also
include a labor component. For example, there are the on-going labor-using
activities of mobile and stationary source inspection and enforcement.
2
On-going costs range from $1.4 million with a standard of 2.0 ug/m to
$2.8 million with a standard of 1.0 ug/m • The relative magnitude of
these costs are 0.9% and 1.8%. The corresponding man-year requirements
are 60 and 120. Compared to current man-year expenditures these correspond
to 0.9% and 1.7%, respectively.
First year and on-going costs for the 3 considered standards are
presented in Table 3-1.
53
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Table 3-1. STATE AND LOCAL AIR POLLUTION CONTROL
AGENCY STANDARDS ADMINISTRATION COST
Alternative Ambient Standards
(ug/m3 , monthly average)
2.0 1.5 l.Q
First Year Cost
000's of $'s 1000 1400 1700
$ Expenditures as a
% of current
expenditures .6% .9% 1.0%
Man-year requirements 30 40 40
Man-year requirements
as a % of current 0.4% 0.6% 0.6%
expenditures
On-Going (Annual Costs)
000's of $'s 1400 2300 2800
$ Expenditures as a %
of current expenditures 0.9% 1.5% 1.8%
Man-year requirements 60 100 120
Man-year requirements
as a % of current 0.9% 1.4% 1.7%
expenditures
c/l
-------
References
1. PEDCo-Environmental Specialists, Inc., Draft Document prepared for
the U.S. Environmental Protection Agency, Control Techniques For Lead
Air Emissions, April, 1977, p. xix.
2. Ibid., p. xix.
3. Mitre Corporation/Metrek Division and Office of Air Quality Planning
and Standards, U.S. Environmental Protection Agency, Draft Environmental
Impact Statement for the National Ambient Air Quality Standard for Lead.
November, 1977, Chapter 2.
4. Ibid., and background information in support of the aforementioned document.
5. Bureau of the Mines, U.S. Department of the Interior, Commodity Data
Summaries: 1977, p. 91.
6. John Short and Associates, Inc., "Preliminary Technological Feasibility,
Cost of Compliance and Economic Impact Analysis of the Proposed OSHA
Standard for Lead", prepared for U.S. Department of Labor under Contract
No. J-9-F-6-004, 1/77, p. 34. See also Charles River Associates, Economic
Analysis of the Lead-Zinc Industry, prepared under contract for the U.S.
General Services Administration, revised April, 1969, p. 15.
7. Office of Air Quality Planning and Standards, U.S. Environmental Protection
Agency, Users Manual for the Single Source (CRSTER) Model. EPA-450/2-77-013,
July, 1977.
8. Bureau of the Mines, U.S. Department of Interior, Mineral Yearbook - 1974,
p. 731.
9. Federal Trade Commission, Docket 18959. 4/20/76.
10. Ibid.
11. Stanford Research Institute, Chemical Economics Handbook: Copper,
February 1976, p. 736.1000C.
12. Ibid, p. 736.1000B.
13. Office of Air Quality Planning and Standards, U.S. Environmental Protection
Agency, Background Information for New Source Performance Standards: Primary
Copper. Zinc, and Lead Smelters, Volume I: Proposed Standards, EPA-450/2-74-002a,
October, 1974, p. 6-14.
14. Bureau of the Census, U.S. Department of Commerce, 1972 Census of Manufacturers.
p. 33-B-6.
55
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15. U.S. Department of Commerce, 1977 U.S. Industrial Outlook, p. 82.
16. Office of Air Quality Planning and Standards, U.S. Environmental
Protection Agency, Standards Support and Environmental Impact Statement:
An Investigation of the Best Systems of Emission Reduction for Electric
Arc Furnaces in the Grey Iron Foundry Industry, October, 1976, p. 8-32.
17. Bureau of the Census, U.S. Department of Commerce^ op. cit.. p. 33-B-6.
18. PEDCo-Environmental Specialists, Inc., op. cit., p. 4-166.
19. U.S. International Trade Commission, Synthetic Organic Chemicals. U.S.
Production and Sales. Also, Stanford Research Institute, Chemical
Economics Handbook: Lead Alkyls, December, 1975, p. 6715042E.
20. Federal Register, December 6, 1973, 38 (234) 40CFR80: 33734-33741.
21. Stanford Research Institute, op. cit., pp. 6715042R-S.
22. Barkand, R. A. A Report by the Battery Council International Statistical
Committee. Replacement Battery, Industry Forecast 1975-1979. Globe Union,
Inc. Milwaukee, Wisconsin, p. 1.
23. Office of Air Quality Planning and Standards, U.S. Environmental Protection
Agency, Draft Standards Support and Environmental Impact Statement: Control
of Emissions from the Manufacture of Lead-Acid Storage Batteries, September,
1977, p. 3-9 and p. 8-16.
24. Compiled from Company responses to U.S. Environmental Protection Agency
inquiry regarding product prices. The inquiry was issued under Section 114
of the Clean Air Act as Amended, 1970.
25. Conversation between the staff of JACA Corporation and two battery companies:
Illinois Battery on September 8, 1977, and Moore Battery Company on
September 14, 1977.
56
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TAB K- Proposed Equivalency Regulations (Signature item)
-------
ENVIRONMENTAL PROTECTION AGENCY
[40 CFR Parts 51 and 53]
AMBIENT AIR MONITORING REFERENCE AND
EQUIVALENT METHODS FOR LEAD
Notice of Proposed Rulemaking
AGENCY: Environmental Protection Agency (EPA)
ACTION: Proposed rulemaking
SUMMARY: On December 14, 1977, new national primary and secon-
dary ambient air quality standards for lead were proposed (42FR
63076). Atmospheric lead is proposed to be measured as elemental
lead, either by the proposed reference method or "by an equiva-
lent method." The amendments proposed below would provide the
necessary and appropriate changes in the existing equivalent
method regulations (primarily contained in 40 CFR Part 53) to
allow the designation of equivalent methods for measuring atmos-
pheric lead concentrations.
DATES: Comments relative to these proposed regulations must be
received by [45 days after publication in the Federal Register].
ADDRESS: Send comments to: Mr. Larry J. Purdue
Department E (MD-76)
Environmental Monitoring and Support
Laboratory
-------
U.S. Environmental Protection
Agency
Research Triangle Park, N.C. 27711
FOR FURTHER INFORMATION CONTACT: Mr. Larry Purdue, Telephone
919/541-3076 (FTS 629-3076).
INCIDENTAL INFORMATION: The proposed reference method for mea-
suring atmospheric lead, as well as much associated information,
was published in the December 14, 1977 issue of the Federal
Register (Volume 42), starting on page 63076.
SUPPLEMENTARY INFORMATION:
Background
When the first National Ambient Air Quality Standards were
promulgated in 1971 (36 FR 8186, April 30, 1971), EPA established
the concept that measurements of ambient air pollutants used to
determine compliance with the standards must be made with either
a specified "reference method" or with an alternate method which
could be shown to be "equivalent" to the reference method. The
air quality standards are now contained in Part 50 of Title 40 of
the Code of Federal Regulations (40 CFR Part 50). Appendixes to
Part 50 specify either a prescribed reference method, or a measure-
ment principle and calibration procedure applicable to reference
methods, for each pollutant for which a standard has been promulgated.
-------
On February 18, 1975, EPA promulgated regulations to estab-
lish definitive requirements and procedures by which methods for
measuring specified air pollutants may be designated "reference
methods" or "equivalent methods" (40 FR 7044, February 18, 1975).
These regulations are contained in 40 CFR Part 53. Originally
these "equivalency" regulations were applicable only to methods
for measuring S02, CO, and photochemical oxidants (03), but were
subsequently amended to cover methods for N02 as well (41 FR
52692, December 1, 1976).
On December 14, 1977, EPA proposed amendments to 40 CFR Part
50 to establish new National Primary and Secondary Ambient Air
Quality Standards for lead. Also proposed was a new appendix to
Part 50 specifying a reference method for measuring atmospheric
lead. The method proposed measures the lead content of suspended
particulate matter collected on glass fiber filters using high
volume samples. The lead is extracted from the particulate
matter and measured by atomic absorption spectroscopy. The
procedure proposed is necessarily very restrictive and specific
in order to maintain the high level of accuracy and reproduci-
bility and the low level of variability requisit for a reference
method. However, other procedures are available for measuring
lead which are likely to be as good as the reference method and
may be advantageous to particular users. For example, using the
same sampling procedure as the reference method (high volume
sampler), several alternate analytical principles (flameless
atomic absorption, optical emission spectrometry, and anodic
stripping voltametry) are known to be suitable for lead analysis.
-------
If these alternate procedures can be designated as "equivalent"
methods, then users would have much more flexibility in selecting
a method for lead measurements which fits their own circumstances
of available equipment, personnel, and expertise.
Also, EPA sees no reason why lead measurements must be
restricted to a particular sampling technique, such as the high
volume sampler. For example, low volume particulate samples can
be analyzed for lead by X-ray fluorescence. Other non-high
volume techniques may also be available or under development. By
allowing for the possibility of qualifying such alternate methods
as equivalent methods, EPA hopes to permit and encourage contin-
ued advancement in the technology of measuring atmospheric lead.
For the reasons given above, EPA believes it is advantageous
to propose appropriate amendments to 40 CFR Part 53 to extend the
equivalent method regulations to cover methods for measuring lead
in the atmosphere. Since most, if not all, candidate equivalent
methods for lead are likely to be manual methods, EPA expects
relatively little initial incentive for commercial organizations
to apply for equivalent method determinations. Consequently,
most equivalent method applications for lead methods will have to
be originated by EPA under section 53.7 "Testing of methods at
the Initiative of the Administrator." Specifically, EPA intends
to pursue designation of some of the methods noted earlier, which
are already in use among some monitoring agencies. These would
include methods which use the same sampling procedure as the
reference method, but use alternate analytical principles such as
flameless atomic absorption, optical emission spectrometry, and
-------
anodic stripping voltametry. Direct analysis of high volume
filters by X-ray fluorescence is also a likely candidate method
for early designation by EPA.
General Approach
As suggested above, any method which purports to measure
atmospheric lead could be considered as a candidate equivalent
method, regardless of the sampling procedure or analytical tech-
nique used. To be designated as an equivalent method, the candi-
date method must demonstrate a "consistent relationship" to the
reference method. This is done by taking simultaneous measure-
ments with both methods in accordance with the procedures and
requirements to be specified in 40 CFR Part 53. In addition, the
candidate method must also demonstrate adequate precision among
repeated analyses of the same sample.
Since the proposed reference method provides 24-hour inte-
grated measurements, candidate methods would have to be compared
on that basis. Shorter-term integrated methods or even automated
methods could be considered as candidate methods. But only 24-
hour averages could be compared to the reference method. There-
fore, any subsequent designation of such a method as an equivalent
method would apply only to 24-hour averages.
Amendments to 40 CFR Part 51
Paragraph (a) of section 51.17a provides general requirements
-------
for air quality monitoring methods used by States in their Imple-
mentation Plan monitoring networks. Subparagraph (1) requires use
of reference or equivalent methods for S02, CO, 03 and N02,
and would be amended to also include lead. Subparagraph (3)
provides certain "grandfather" periods for use of existing methods
for S02, CO, 03 and N02. It would be amended by adding a similar
"grandfather" provision allowing existing methods for lead to be
used until February 18, 1980--the same expiration date as that for
existing methods for S02, CO, and Oy
Amendments to Part 53
Subpart C of Part 53 contains the test procedures prescribed
for determining a consistent relationship between the reference
method and a candidate equivalent method. Since these test pro-
cedures were originally designed for gaseous pollutants, several
significant changes and additions are required to adapt the proce-
dures for lead.
Determination of Consistent Relationship
Section 53.30, paragraph (a) pertaining to the determination
of a consistent relationship would be changed to indicate that the
specifications for lead appear in a separate table (table C-3)
than the specifications for S02> CO, 03 and N02.
-------
Test Site
Section 53.30, paragraph (b), pertaining to test sites would
be changed in several ways. First, the paragraph would be subdi-
vided to differentiate the various requirements applicable to (1)
all methods, (2) methods for gaseous pollutants, and C3) methods
for lead. Multiple test sites would be allowed for lead methods
in order to facilitate measurements in the required range, since
pollutant augmentation would not be feasible for particulate
methods. Also, a new provision would allow an applicant to request
approval of the test site or sites from EPA prior to conducting
the tests.
A final minor change proposed for paragraph (b) would delete
the stipulation that test sites be "...away from large bodies of
water...". This change has nothing to do with-lead, but is prompted
by general confusion among applicants as to its specific meaning.
Since the requirement is not essential, the current revision of
the paragraph provides a good opportunity to eliminate both the
stipulation and the confusion.
Other General Provisions
Paragraphs (c), (d), and (e) of section 53.30 would also be
revised and reorganized to reflect the differences in requirements
for methods for gaseous pollutants and for lead particulates.
Revised paragraph (c) specifies the general requirement for simul-
taneous measurements at the test site in each of the required
-------
concentration ranges indicated by Tables C-l or C-3. Paragraph
(d) would be revised and subdivided to clarify the different
requirements for sample collection. Subparagraph (1) indicates
the general requirement for homogenous samples. Subparagraph (2)
specifies the use of a common distribution manifold and allows
artificial pollutant augmentation for gaseous pollutants. Sub-
paragraph (3) specifies the relative location requirements for
lead samplers. And paragraph (4) would specifically allow the use
of a common sample when the candidate method uses a sampling
procedure identical to that of the reference method. Finally, the
present paragraph (d) on "Submission of Test Data..." would be
changed to paragraph (e).
Test Conditions
In section 53.31 on "Test Conditions," paragraphs (a), (c),
and (d) would be revised slightly to clarify certain differences
between gaseous and particulate methods, and to clarify the re-
quirements pertaining to calibration and range.
Test Procedures
Because the test procedures being proposed for lead differ
considerably from those for gaseous pollutants, existing section
53.32 would be retitled "Test procedures for gaseous pollutants"
and a new section 53.33, "Test procedures for lead," would be
added. The proposed new section 53.33 is similar in form to
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section 53.32, but the specific requirements for lead methods
differ in several ways from the requirements for gaseous pollutant
methods. First, a new Table C-3 summarizes the test specifications
pertinent to methods for lead. Only one concentration range is
specified, into which 5 or more of the measurements must fall.
The difference specification for lead is specified as a per cent
of the reference method measurement, as opposed to the fixed,
absolute values specified for gaseous pollutant methods. An
accuracy specification for the reference method based on analysis
of audit samples supplied by EPA is specified. In addition, a
performance specification for analytical precision is also being
proposed to apply to lead methods.
Because most methods for lead provide a result only after
collected samples are analyzed in a laboratory, the test accep-
tance criteria are based on a single sampling plan rather than the
double sampling plan prescribed for gaseous pollutant methods.
Ten or more Csimultaneous) samples are collected and analyzed to
provide at least 5 samples which fall into the required range of
0.5 to 4.0 yg/m3. Each sample is analyzed 3 times and the results
of all samples in the range are subjected to both the precision
test prescribed in paragraph (e) and the consistent relationship
test prescribed in paragraph (f). For the candidate method to
qualify for designation, no test failures would be permitted in
either test.
Public Participation
Interested persons are invited to comment on any aspect of
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these proposed amendments. Comments should be submitted in dup-
licate and must be received by [45 days after publication in the
Federal Register]. Address comments to:
Mr. Larry Purdue
Department E (MD-76)
Environmental Monitoring and Support Laboratory
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Date Administrator
It is proposed to amend Chapter I, Title 40, Code of Federal
Regulations, as follows:
PART 51— REQUIREMENTS FOR PREPARATION, ADOPTION, AND SUBMITTAL
OF IMPLEMENTATION PLANS
1. In section 51.17a, paragraph (a) is revised to read as follows
§51.17a Air quality monitoring methods.
(a) General requirements. (1) Except as otherwise provided
in this paragraph (a), each method for measuring S02> CO, 03, N02,
or lead used for purposes of §51.17(a) shall be a reference method
or equivalent method as defined in §53.1 of this chapter. ***
(2)
***
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(3) *** Any manual method for lead in use before [date
of promulgation of these amendments] may be used for purposes of
§51.17(a) until February 18, 1980.
PART 53—AMBIENT AIR MONITORING REFERENCE AND EQUIVALENT
METHODS
2. In section 53.30, paragraphs (a), (b), (c), (d), and (e) are
revised to read as follows:
§53.30 General Provisions
(a) *** A consistent relationship is shown for S02, CO, 03
and N02 methods when the differences between (1) measurements made
by a candidate manual method or by a test analyzer representative
of a candidate automated method, and (2) measurements made simul-
taneously by a reference method are less than or equal to the
value specified in the last column of Table C-l. A consistent
relationship is shown for lead methods when the differences be-
tween (1) measurements made by a candidate method and (2) measure-
ments made simultaneously by the reference method are less than or
equal to the value specified in Table C-3.
(b) Selection of Test Sites. (1) All methods. Each test
site shall be in a predominantly urban area which can be shown to
have at least moderate concentrations of various pollutants. The
site shall be clearly identified and shall be justified as an
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appropriate test site with suitable supporting evidence such as
maps, population density data, vehicular traffic data, emission
inventories, pollutant measurements from previous years, concurrent
pollutant measurements and wind or weather data. If desired, a
request for approval of the test site or sites may be submitted
prior to conducting the tests. The Administrator may in his dis-
cretion select a different site (or sites) for any additional tests
he decides to conduct.
(2) Methods for gaseous pollutants. All test measure-
ments are to be made at the same test site. If necessary, the
concentration of pollutant in the sampled ambient air may be aug-
mented with artificially generated pollutant to facilitate measure-
ments in the specified ranges. (See paragraph (d) (2) of this
section.)
(3) Methods for lead. Test measurements may be made at
any number of test sites. Augmentation of pollutant concentrations
is not permitted, hence an appropriate test site or sites must be
selected to provide lead concentrations in the specified range.
Test sites for lead measurements must be between 5 and 100 meters
from the edge of a heavily-traveled roadway.
(c) Test Atmosphere. Ambient air sampled at an appropriate
test site shall be used for these tests. Simultaneous concentra-
tion measurements shall be made in each of the concentration
ranges specified in Table C-l or Table C-3.
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(d) Sample Collection. (1) All methods. All test concen-
tration measurements or samples shall be taken in such a way that
both the candidate method and the reference method receive air
samples that are homogenous or as nearly identical as practical.
(2) Methods for gaseous pollutants. Ambient air shall
be sampled from a common intake and distribution manifold designed
to deliver homogenous air samples to both methods. Precautions
shall be taken in the design and construction of this manifold to
minimize the removal of particulates and trace gases, and to
insure that identical samples reach the two methods. If necessary,
the concentration of pollutant in the sampled ambient air may be
augmented with artificially generated pollutant. However, at all
times the air sample measured by the candidate and reference
methods under test shall consist of not less than 80 percent
ambient air by volume. Schematic drawings, physical illustrations,
descriptions, and complete details of the manifold system and the
augmentation system (if used) shall be submitted.
(3) Methods for lead. The intake points of the candi-
date and reference samplers for lead shall be located between 3 and
5 meters apart, and between 1.5 and 5 meters above ground level.
(4) Methods employing a common sampling procedure.
Candidate methods which employ a sampler and sample collection
procedure which are identical to the sampler and sample collection
procedure specified in the reference method may be tested by ana-
lyzing common samples in accordance with the candidate and refer-
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ence analysis procedures. The common samples are to be collected
according to the sample collection procedure specified by the
reference method, and must be divided such that identical portions
are analyzed by the analysis procedures of the two methods.
(e) Submission of Test Data and Other Information. All
recorder charts, calibration data, records, test results, proce-
dural descriptions and details, and other documentation obtained
from (or pertinent to) these tests shall be identified, date,
signed by the analyst performing the test, and submitted.
3. In section 53.31, paragrphs (a), (c), and (d) are revised to
read as follows:
§53.31 Test Conditions.
(a) All Methods. All test measurements made or test samples
collected by means of a sample manifold as specified in §53.30 (d)
(2) shall be at a room temperature between 20° and 30°C, and at a
line voltage between 105 and 125 volts. All methods shall be
calibrated as specified in paragraph (c) of this section prior to
initiation of the tests.
(b)
***
(c) Calibration. The reference method shall be calibrated
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according to the appropriate appendix to Part 50 of this Chapter
(if it is a manual method) or according to the applicable operation
manual(s) (if it is an automated method). A candidate manual
method (or portion thereof) shall be calibrated if such calibration
is a part of the method. ***
(d) Range. (1) Except as provided in paragraph (d) (2) of
this section, each method shall be operated in the range specified
for the reference method in the appropriate appendix to Part 50
(for manual reference methods), or specified in Table B-l of this
part Cfor automated reference methods).
(e)
(2)
*•**
***
4. In section 53.32, the title of the section is revised to read
as follows:
§53.32 Test procedures for gaseous pollutants.
5. A new section is added to read as follows:
§53.33 Test procedure for lead methods.
(a) Sample collection. Collect simultaneous 24-hour samples
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(filters) of lead at the test site or sites with both the reference
and candidate methods until at least 10 filter pairs have been
obtained. If the conditions of §53.30 (d)(4) apply, collect at
least 10 common samples (filters) in accordance with §53.30 (d)(4)
and divide each to form the filter pairs.
(b) Audit samples. Three audit samples must be obtained from
the Director, Environmental Monitoring and Support Laboratory,
Department E, United States Environmental Protection Agency, Research
Triangle Park, N.C. 27711. The audit samples are 3/4 x 8 inch
glass fiber strips containing known amounts of lead at the following
nominal levels: 100 yg/strip; 300 yg/strip; 750 yg/strip. The
true amount of lead in total yg/strip will be provided with each
audit sample.
(c) Filter Analysis . (1) For both the reference method and
the audit samples, analysis each filter extract 3 times in accord-
ance with the reference method analytical procedure. The analysis
of replicates should not be performed sequentially (i.e. any single
sample should not be analyzed 3 times in sequence). Calculate the
indicated lead concentrations for the reference method samples in
yg/m3 for each analysis of each filter. Calculate the indicated
total lead amount for the audit samples in yg/strip for each ana-
lysis of each strip. Label these test results as RIA> RIB, RIC,
R2A, R2B, ..., Q1A, Q1B, QTC , where R denotes results from
the reference method samples; Q denotes results from the Audit
samples; 1,2,3 indicates filter number and A,B,C indicates the
first, second and 3rd analysis of each filter, respectively.
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(2) For the candidate method samples, analyze each
sample filter or filter extract 3 times and calculate, in accord-
ance with the candidate method, the indicated lead concentration in
wg/m3 for each analysis of each filter. Label these test results
as C-,A, CIB, C2C, ..., where C denotes results from the candidate
method. (For candidate methods which provide a direct measurement
of lead concentrations without a seperable procedure, CIA = CIB =
C1C' C2A = C2B = C2C' etc'^
(d) For the reference method, calculate the average lead
concentration for each filter by averaging the concentrations
calculated from the 3 analyses:
RJA "*" °in "*" "i r
R. = — 12 — , where i is the filter number.
i ave •j
(e) Disregard all filter pairs for which the lead concentra-
tion as determined in the previous paragraph (d) by the average of
the 3 reference method determinations, falls outside the range of
0.5 to 4.0 ug/m3. All remaining filter pairs must be subjected to
both of the following tests for precision and consistent relation-
ship. At least 5 filter pairs must be within the 0.5 to 4.0 yg/m
range for the tests to be valid.
(f) Test for precision. (1) Calculate the precision (P) of
the analysis (in per cent) for each filter and for each method, as
the maximum minus the minimum divided by the average of the 3
concentration values, as follows:
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R. max - R. min C. max - C. min
P ' * 10°*' °r P ' x 10M-
Ri R~~ivlA IUWA" UI rCi C. ave
where i indicates the filter number.
(2) If any reference method precision value (PRi)
exceeds 15 per cent, the precision of the reference method analy-
tical procedure is out of control. Corrective action must be
taken to determine the source(s) of imprecision and the reference
method determinations must be repeated according to paragraph (c)
of this section, or the entire test procedure (starting with para-
graph (a)) must be repeated.
(3) If any candidate method precision value (?ci)
exceeds 15 per cent, the candidate method fails the precision test.
(4) The candidate method passes this test if all pre-
cision values (i.e. all PRi's and all PCI'S) are less than 15 per
cent.
(g) Test for accuracy. 0) For tne audit samples calculate
the average lead concentration for each strip by averaging the
concentrations calculated from the 3 analysis:
QiA + QiB + Qic
Qi ave = -^ 3^ Ik.
where i is audit sample number.
Calculate the percent difference (D ) between the indicated lead
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concentration for each audit sample and the true lead concentration
(T ) as follows:
Qi ave ' Tai
D . = -2—. 91 x 100
qi Tqi
(2) If any difference value (D .) exceeds ±5 percent the
accuracy of the reference method analytical procedure is out of
control. Corrective action must be taken to determine the source
of the error(s) (e.g. calibration standard discrepancies, extrac-
tion problems, etc.) and the reference method and audit sample
determinations must be repeated according to paragraph (c) of this
section or the entire test procedure (starting with paragraph (a))
must be repeated.
(h) Test for consistent relationship. (1) For each filter
pair, calculate all 9 possible percent differences (D) between the
reference and candidate methods, using all 9 possible combinations
of the 3 determinations (A, B, and C) for each method, as:
Cii ' Rik
D. = —^ - x 100%, where i is the filter number, and n
in Rik
numbers from 1 to 9 for the 9 possible difference combinations for
the 3 determinations for each method (j = A, B, C, candidate; k = A,
B, C, reference).
(2) If none of the cent differences (D) exceeds ± 20
percent, the candidate method passes the test.
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(3) If one or more differences (D) exceeds ± 20 per
cent, the candidate method fails the test for consistent relation*
ship.
(i) The candidate method must pass both the precision test
and the consistent relationship test to qualify for designation as
an equivalent method.
TABLE C-3 TEST SPECIFICATIONS FOR LEAD METHODS.
Concentration range, yg/m3: 0.5 to 4.0.
Minimum number of 24-hour measurements: 5
Maximum analytical precision, per cent: 15%
Maximum analytical accuracy, per cent: ± 5%
Maximum difference, per cent of reference method: ±20%
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TAB L- Advance Notice of Proposed Rulemaking - ambient monitoring
requirements for significant lead point sources (Signature item)
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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; FTS—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 2
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
studies2 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 impact 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
§ 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.
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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.
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—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
requi rements.
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. sourca 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"erf"
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-600/2-76-089a.
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. E°A-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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