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Implementation of the Pb NAAQS:

Implementation of the Pb NAAQS:. A Regional Point of View. Howard D. Schmidt, M.S., M.B.A. U.S. EPA Region 3 Air Protection Division Air Quality Analysis Branch. So Much Work… So Little Time. 1.5 m g/m 3. 0.15 m g/m 3. Pb NAAQS Implementation Timing. The Long & Winding Road.

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Implementation of the Pb NAAQS:

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  1. Implementation of the Pb NAAQS: A Regional Point of View Howard D. Schmidt, M.S., M.B.A. U.S. EPA Region 3 Air Protection Division Air Quality Analysis Branch

  2. So Much Work… So Little Time

  3. 1.5 mg/m3

  4. 0.15 mg/m3

  5. Pb NAAQS Implementation Timing

  6. The Long & Winding Road • Follow timeline from Final Rule • Emission Inventory – NEI, TRI, ABC, XYZ? • Atmospheric Modeling – Quantity? Location? Source Identification? • Instrumentation – We have to measure for WHAT????? WHERE????? • Lab Analysis – Old methods... Can we tweak ‘em?

  7. January 1, 2010 • Contact with OAQPS • Conduit of information and supply assistance to states & locals • Monthly conference calls

  8. Emission Inventory • Region 3 has not seriously thought about Pb or a Pb network for 10… 20… maybe 30 years?!?!? • 2005 NEI v2??? TRI??? State inventories??? • Clean it up!!! Incorrect emissions & factors, defunct facilities, erroneous geographic information, etc. • Examples

  9. First Glance at Pb Network

  10. R3 2005 NEI v2 Pb Sources Red: >= 1 tpy Green: 0.5 – 0.99 tpy

  11. R3 2007 State Inventory Pb Sources Red: >= 1 tpy Green: 0.5 – 0.99 tpy

  12. R3 2007 State Inventory Pb Sources with Population Based Monitors Red: >= 1 tpy Green: 0.5 – 0.99 tpy White: MSA > 500,000

  13. Total Maximum R3 Pb Monitors As of 2/24/09

  14. HUGE Discrepancy • 2005 NEI v2 shows a Pb point source in DE with emissions of 4.35 tons per year (tpy) • 2007 DE state inventory shows same Pb point source with emissions of 6 x 10e-7 tpy!!! • What’s going on here?

  15. Resolution? • Emissions Inventory Group at OAQPS received data on a hazardous waste incinerator from the Sector Policies & Programs Division (SPPD) • OAQPS was given no other info than source name, city, and lat / lon • Source was matched to a facility in the NEI based on a lat / lon with minimal significant figures.. BUT, actually belonged to another facility down the road • Source originated in 1992, and similar data continued to be sent to OAQPS from SPPD in 2002, 2005, and 2008 • Verification on current status of incinerator from state + investigation by R3 = correction in 2005 NEI v2 by OAQPS

  16. 2005 v 2007 PbInventory Issues • Neglected to include a 98% efficiency baghouse • Changed grinding media from metal to non-leaded • Consultant error – doubled emissions • Former employee miscalculation • Three cogen facilities used emission factor for uncontrolled pulverized coal – rather than controlled • Company reported a transcription error • Material previously being sandblasted now has less lead due to changes in paint formulation

  17. Atmospheric Modeling • Used to determine the effects of nearby Pb sources… each < 1 tpy • May show sources < 1 tpy are exceeding NAAQS due to unique geography, source characteristics, etc. • RA can grant waivers for sources >= 1 tpy if impacts estimated to be 0.075 mg/m3 or less

  18. Beaver County, PA

  19. Beaver County, PA

  20. More Worlds to Conquer???

  21. Pb-TSP Samplers • Appendix B to 40 CFR Part 50 • Concentration & particle size ranges • Precision & accuracy • Error (flow, volume, sample loss, foreign matter, humidity, timer, etc.) • Quantity – how many do we have/need? • Condition – field ready or not? • Rehab – can we fix them? • Purchase – from who for how much?

  22. We Have Samples… Now What? • Laboratories – Who will analyze? State, Regional, Private • Capacity / Manpower • FRM – Appendix G to 40 CFR Part 50 • FEMs, there are 21, so, what’s the problem? • Cost

  23. Four months of work… in 20 minutes

  24. Questions ? ? ?

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