:
] GUIDELINE SERIES
OAQPS NO. 1.2-122

GUIDELINE FOR SHORT-TERM LEAD
MONITORING IN THE VICINITY
OF POINT SOURCES
US. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina

-------
Corrections and Additions to the
Guideline for Short-Term Lead Monitoring
in the Vicinity of Point Source
Section 2.3
Line 6 should read, "monthly surface wind and	"
Add last paragraph:
If on-site meteorological data are determined to be most
representative for the source location, such data should continue
to be collected during the ambient monitoring program and reported
as outlined in Section 2.9. Meteorological instrumentation
should meet the specifications in EPA's "Ambient Monitoring Guidelines
for Prevention of Significant Deterioration (PSD)."
Section 2.4
Line 8 should read, "expected maximum concentration from the 	"
Section 2.9
Add last paragraph:
Quarterly wind and precipitation roses for the representative
meteorological site should be submitted with the lead monitoring
data and conform to the same 3-month period. The roses should be
based on hourly data, stratified according to NWS wind speed
categories. Tabulations of these hourly data should also be submitted.
These data should be accompanied by a brief narrative that discusses
meteorological representativeness of the sampling quarter compared
to the quarter used to select monitor site locations.

-------
GUIDELINE FOR SHORT-TERM LEAD MONITORING
IN THE VICINITY OF POINT SOURCES
OAQPS NO. 1.2-122
Monitoring and Data Analysis Division
Office of Air Quality Planning and Standards
and
Environmental Monitoring and Support Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Office of Air, Noise and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina-27711
March 26, 1979

-------
FOREWORD
Different individuals were involved in the preparation of this document
and should be contacted if any questions arise in the application of the
guideline.
Subject Area
Meteorological Monitoring
Contact
James Dicke
Phone Number
(area code 919) FTS #
541-5381
629-5381
Lead Air Quality Monitoring
Stanley Sleva
David Lutz
Alan Hoffman
541-5351
629-5351
Quality Assurance (Lead)
Thomas Clark
Darryl vonLehmden
541-2723
541-2415
629-2723
629-2415
Lead Implementation Policy	Joseph Sableski	541-5437 629-5437
and Interpretation of	Dan de Roeck
Regulations

-------
TABLE OF CONTENTS
Page
FOREWORD	i
1.	INTRODUCTION	1
2.	LEAD MONITORING	3
2.1	Monitoring Objectives and Data Uses	3
2.2	Monitoring Options	3
2.3	Meteorological Considerations	4
2.4	Number and Location of Monitors	4
2.5	Duration and Frequency of Sampling	5
2.6	Sample Method and Procedures	6
2.7	Monitor Siting	6
2.8	Monitoring Plan	7
2.9	Data Reporting	7
3.	QUALITY ASSURANCE FOR AIR QUALITY DATA	9
3.1	Special Performance Audit Program	9
3.1.1	Performance Audit of High-Volume Sampler	9
Flow Rate
3.1.2	Performance Audit of Lead Analysis	9
3.2	Split Sample Analysis Program	10
3.3	Technical Assistance	10
TABLE 1. MINIMUM CONTENTS OF LEAD MONITORING PLAN	8
ii

-------
1
1. INTRODUCTION
On October 5, 1978, EPA promulgated a national ambient air quality
standard for lead and requirements for the submittal of an implementation
plan by each State to achieve the new standard. 40 CFR 51.80 requires
each State to demonstrate that the national lead standard will be
attained in areas in the vicinity of the following significant point
sources: primary lead smelters, secondary lead smelters, primary copper
smelters, lead gasoline additive plants, lead-acid storage battery manu-
facturing plants that produce more than 2,000 batteries per day, and any
other stationary source that actually emits 25 or more tons per year of
lead or lead compounds. Also, Section 51.84 requires that the State
plans calculate the maximum lead air quality concentrations resulting
from the above sources through the application of atmospheric dispersion
modeling.
The SIPs should be based on ambient air data which reflect normal source
operations. The significance of such ambient data for the development of the
lead SIP is manifold. Clearly, ambient lead data collected from the vicinity
of the source will help to identify concentrations exceeding the national
standard. Additionally, ambient data is essential in the calibration of
models used to calculate the maximum lead concentrations in the vicinity
of lead point sources. The ambient data will also be useful for checking
the validity of available emission factors and particularly for developing
more accurate estimates of fugitive emissions. States may have difficulty
in meeting the SIP requirements due to the small amount of ambient lead
data that have been collected around the significant sources of lead men-
tioned above. Therefore, in order to correct this deficiency, it may be
necessary to obtain additional ambient data prior to the submittal of the
SIPs. Consequently, guidance is being provided herein for those States
that need to obtain additional ambient air quality data through the operation
of a short-term (i.e., 3-6 months) monitoring program. Because of serious
restraints involving both time and resources, the monitoring effort is
generally being focused on primary and secondary lead smelters, and primary
copper smelters. These sources are believed to have the greatest environmental
impact for lead, particularly from their fugitive emissions.

-------
2
The purpose of this guideline is to provide recommended procedures
for a short-term monitoring program to obtain ambient lead data essential
to the development of a lead control strategy. The guideline also describes
associated air quality data assurance and reporting procedures.
The guideline has been kept as general as possible, because the States
will need some flexibility in implementing the requirements on a case-by-case
basis due to the diversity and complexity of the many factors that affect
air quality concentrations. However, this guideline should still provide
for consistency between States when implementing a source monitoring
program.
EPA believes that a more comprehensive data base will ultimately be
necessary to assess compliance of significant lead point sources with the
lead ambient air quality standard. Such information will have to be
obtained from a more extensive network than that described herein.
Additional monitoring guidance is currently being prepared to help States
establish a more comprehensive network design to determine if significant
lead point sources will cause violations of the national standard by the
mandated attainment date, and to estimate the contribution of fugitive
emissions to such violations.

-------
3
2. LEAD MONITORING
2.1	Monitoring Objectives and Data Uses
The objective for conducting the short-term ambient lead monitoring
is to obtain quantitative information on lead concentrations around
primary and secondary lead smelters and primary copper smelters. The
reasons for selecting these sources were discussed in Section I. The
monitoring data obtained will then be used_to determine compliance
with the NAAQS.
2.2	Monitoring Options
There are two approaches available to States to obtain the necessary
lead air quality data. The first approach involves a decision on the part
of the State to establish a monitoring program and conduct ambient lead
monitoring in the vicinity of the affected lead point source(s). The
alternative is to have the source take full responsibility for the moni-
toring program. The obvious advantage of the latter course of action is
that the State is not overburdened by the additional resources required to
perform the special short-term monitoring. . Some States have indicated,
however, that they would prefer to do the monitoring themselves.
Where the States choose to make the source responsible for the acquisition
of lead air quality data, each State is encouraged to work out a cooperative
agreement with each affected source whereby the source would voluntarily agree
to conduct the the monitoring and provide the data to the State agency.
Where it is evident, however, that the source will not respond voluntarily,
the State may obtain the necessary authority to require the source owner
or operator to conduct the monitoring pursuant to Section 114(b) (1) of the
Clean Air Act. In order to obtain this authority, a State must submit
to EPA an approvable procedure for requiring the source to carry out the
monitoring responsibility and for reporting the data to the State. The
Administrator may approve such procedure and delegate the appropriate
authority to the State.
Regardless of whether the source voluntarily performs the monitoring
or is legally required to do so, the actual monitoring should be preceded
by the submittal of a monitoring plan as described in Section 2.8 of this
guideline. The State should approve such plans prior to the commencement
of monitoring activities. Monitoring should commence as soon as possible
in 1979.

-------
4
2.3	Meteorological Considerations
In order to best determine the proper placement of lead monitors
to detect the maximum impact of stack and fugitive emissions as well
as background concentrations, monthly surface wind and precipitation
roses should be used for guidance. The meteorological data used for the
monthly surface and precipitation roses should be the best that is currently
available and should also best represent the conditions at the smelter
site. Such data may be derived from routine measurements by National
Weather Service (NWS) stations. The data are available as individual
observations and in summarized form from the National Climatic Center,
Federal Building, Asheville, North Carolina 28801.
The meteorological data are to be used to determine the predominant
wind direction during the months lead data will be collected as discussed
in Section 2.5. Lead monitors should then be sited based on this predominant
wind direction.
2.4	Number and Location of Monitors
The location of the monitors is important in order to meet the
required monitoring objectives and data uses. The upwind background
concentration monitor should be located so that it measures ambient
concentrations which do not have significant air quality impact from
the source under study. The location of the downwind monitors is also
critical because the monitor location has to be within the general
location of expected maxima dispersion areas of the pollutant cloud.
Factors, such as the emission rate from the source, wind speed, and
wind direction must be taken into account by dispersion modeling
techniques using the monthly meteorological data obtained previously.
The monitoring network around the source should be designed to
measure the impact of both fugitive and stack emissions. There are
different network configurations that could be used to measure the
fugitive and stack emission impact. A network design which incorporates
a minimum number of monitors (two or three) to provide sufficient data
to estimate the emission impacts is discussed below. Changes from this
type of network may be approved by the State because the ultimate place-
ment and number of monitors is decided on a case-by-case basis due to many
different factors, such as meteorological conditions, terrain, and other
lead sources which may be nearby. In complex terrain situations,
additional sites may be needed.

-------
5
• Background Monitor Using Predominant Wind Direction Data
One background monitor is needed to measure the lead being
transported into the area around the source. This monitor
should be located upwind of the source considering the pre-
dominant wind direction and where the contributions from the
source would be minimal. For example, if the predominant wind
direction is from the southwest, the background station should
be located to the southwest of the source. For remote situations,
background may be assumed to be zero and no monitoring for back-
ground would be needed.
•	Impact of Stack Emission Monitoring Using Predominant Wind Direction Data
One monitor is needed to measure the impact of the stack emissions
and the general location of this monitor is determined by modeling.
The maximum concentration area from the stack emissions using
the predominant wind direction is calculated from wind speed
and direction, stack height, emission rate, etc.
•	Fugitive Emission Impact Monitors Using Predominant Wind Direction Data
The siting of monitors to measure the fugitive emission impacts is
more complex than for background and stack impact monitors because
these emissions may be from buildings, i.e., windows, doors, hood
vents, etc., or may be re-entrained from areas around the source.
In addition, the land area affected by the fugitive emissions is
probably not well defined and would probably need several monitors
to full document the area. However, for the purposes of this short-
term monitoring, one monitor is needed to measure the impact of the
fugitive emissions. It should be located downwind of the source
based on the predominant wind direction, and close to the fence line
of the source.
2.5 Duration and Frequency of Sampling
The lead monitoring should be conducted for 3 to 6 months as a minimum.
However, the monitoring can begin at any time and does not have to coincide
with the calendar quarters (beginning with January, April, July or October).
A minimum of one 24-hour sample every sixth day is necessary but
more frequent sampling is encouraged. This is consistent with standard
sampling techniques.

-------
6
2.6	Sample Method and Procedures
Particulates for lead analysis should be collected in accordance with
the reference method as described in 40 CFR 50. The analysis method may be
either the reference method as described in 40 CFR 50 or an equivalent
method. Flow control and flow recorders should also be used. The results
will be compared against the calendar quarter standard of 1.5 yg/m3. Each
filter should be analyzed separately. In the interest of economy and
quality assurance, the filter samples should be accumulated and the analysis
of each filter should be performed concurrently with other filters. The
analysis frequency of these batches should be at least once per quarter.
2.7	Monitor Siting
The lead monitors should be located in such a manner as to minimize
the contribution from other sources (stationary and mobile) and to
avoid measurement biases. Also, there should be some uniformity in
monitor siting for comparability purposes. Therefore, the following
monitor siting criteria should be followed to the extent possible.
The air intake for a lead moni:tor::should not exceed 5 meters above
the ground level. There should be a minimum separation distance of
15 meters between the monitor and the edge of the nearest roadway.
If the sampler is located on a roof or other structure, then there
should be a minimum of 2 meters separation from walls, parapets,
penthouses, etc. The sampler should also be placed at least 20 meters
from trees, since the trees may absorb, particles as well as restrict
air flow. The sampler should be located away from obstacles such as
buildings, so that the distance between the obstacles and the sampler
is at least twice the height that the obstacle protrudes above the sampler.
There should be unrestricted airflow in an arc at least 270° around
the monitor, and the direction between the monitor and the source should
be included in the 270° arc. The monitor should not be located in an
unpaved area unless there is vegetative ground cover during the period
of this short-term sampling so that the impact of re-entrained or fugitive
dusts will be kept to a minimum.

-------
7
2.8	Monitoring Plan
A monitoring plan prepared by the source should be submitted and
approved by the State before the lead monitoring is started. The number
and location of the monitors will need to be determined on a case-by-case
basis by the source and reviewed by the State. The review and approval
of the source monitoring plan by the State should ensure that the monitoring
locations are optimum for purposes of determining maximum pollutant concen-
trations. Table 1 lists the types of information that should be included
in the monitoring plan.
2.9	Data Reporting
A summary of the lead monitoring data, all individual lead values,
and the quality assurance data (discussed in Section 3) should be submitted
to the State agency on a quarterly basis and should be submitted within 30
days after the quarter ends. The State agency should also transmit the
data to appropriate EPA Regional Office quarterly. The individual lead values
are to be submitted in SAROAD format, preferably in machine readable form.
A printout of what is on the tape or cards should be included. Deviations
from these reporting requirements will need to be negotiated with the State
and appropriate EPA Regional Office. All raw data not previously submitted
(i.e., calibration data, flow rates, etc.) should be retained for 1 year
and submitted upon request to the State. The periodic submission of
data is intended to identify any problems in the data as they may occur.
At least 80 percent of the possible individual 24-hour values (with a one
in six day sampling schedule) should be obtained by the source in any
sampling period.
The monitoring data should be reviewed in light of the detailed work
history of the source. This would ensure that the monitoring data were
collected during a time that Would be representative of normal operating
conditions at the source.

-------
8
TABLE 1. MINIMUM CONTENTS OF LEAD MONITORING PLAN
I.	SOURCE ENVIRONMENT DESCRIPTION (within one mile of smelter)
•	topographical description
•	land-use description
•	topographical map of source and environs (including location of
existing stationary sources, roadways, and monitoring sites)
•	climatological description
•	monthly wind roses (from meteorological data collected at the
lead source or other representative meteorological data)
II.	SAMPLING PROGRAM DESCRIPTION
•	time period for which lead will be measured
•	rationale for location of monitors
•	rationale for joint utilization of monitoring network by other
lead sources
III.	MONITOR SITE DESCRIPTION
•	Universal Transverse Mercator (UTM) coordinates
•	height of sampler (air intake) above ground
t distance from obstructions and heights of obstructions
•	distance from other lead sources (stationary and mobile)
•	average daily traffic of nearest roadway
•	photographs of each site (five photos: one in each cardinal direction
looking out from each existing sampler or where a future sampler will
be located, and one closeup of each existing sampler or where a future
sampler will be located. Ground cover should be included in the closeup
photograph.)
IV.	MONITOR DESCRIPTION
•	name of manufacturer
•	description of calibration system to be used
•	type of flow control and flow recorder
V.	DATA REPORTING
•	format of data submission
•	frequency of data reporting
VI.	QUALITY ASSURANCE PROGRAM
•	calibration frequency
•	independent audit program
•	internal quality control procedures
t data precision and accuracy calculation procedures

-------
9
3. QUALITY ASSURANCE FOR AIR QUALITY DATA
3.1 Special Performance Audit Program
States, source owners, or their monitoring contractors should participate in
the following special performance audit program conducted by EPA:
(a)	Blind performance audit of the high-volume samler flow rate
using reference flow device (ReF device).
(b)	B1ind performance audit for lead analysis using glass fiber
filter strips containing lead.
3.1.1	Performance Audit of High-Volume Sampler Flow Rate
The frequency	for sampler flow rate audits is dependent on the
length of the monitoring program. The following audit frequency is
recommended:
If monitoring	program is <_ 6 months duration:
(a)	audit at	beginning of sampling
(b)	audit at	3 months
(c)	audit at	6 months or end of sampling if less than 6 months.
If monitoring program >6 months up to 12 months:
(a)	audit at beginning of sampling
(b)	audit at 3 months
(c)	audit at 6 months
(d)	audit at 12 months or end of sampling if less than 12 months.
3.1.2	Performance Audit of Lead Analysis
The frequency for lead analysis audits is dependent on the length of
the monitoring program. The following audit frequency is recommended:
If monitoring program _<.6 months duration:
(a)	audit at beginning of sampling; before or during the first
scheduled analysis
(b)	audit once each month if anailyses are performed monthly or
more frequently
(c)	audit each analysis, if analyses are performed less frequently
than monthly.

-------
10
If sampling ? 6 months up to 12 months:
(a)	audit at beginning of sampling; before or during the first
scheduled analysis
(b)	audit once every 6 weeks if analyses are performed every 6 weeks
or more frequently
(c)	audit each analysis, if analyses are performed less frequently
than every 6 weeks.
3.2	Split Sample Analysis Program
States, owners, or operators should participate in a EPA Split Sample
Analysis Program which will be conducted only during 1979, and includes
the following:
(a)	Duplicate 3/4 inch by 8 inch strips are cut from collected samples.
(b)	If analyses are performed monthly or more frequently, there should
be a split sample analysis once each month with EPA.
(c)	If analyses are performed less frequently than monthly, there should
be a split sample analysis during each analysis with EPA.
3.3	Technical Assistance
In order to assist States, owners, or operators in establishing an
operational monitoring program as rapidly as possible, EPA has available
a limited supply of precut (8 inch x 10 inch) glass fiber filters of suitable
quality for lead monitoring. These filters will be distributed on a first
come basis.
Information on obtaining filters and participation in the EPA performance
audit program may be obtained from Thomas Clark (phone 919-541-2723).

-------