Lead Monitoring Network Design Training

1. Lead Monitoring Network Design Training

2. Agenda • Source-oriented monitors • Requirement • Waiver process • Siting criteria • Timeline • Non-source-oriented monitors • Requirement • Siting criteria • Timeline • Petition to reconsider

3. Source Oriented Monitoring - Requirement • Monitor near Pb sources which are “expected to or have been shown to” contribute to ambient Pb concentrations in excess of the NAAQS • Minimum requirement of 1 monitor for sources emitting 1 tpy or more • Monitor at maximum concentration taking into account logistics and potential for population exposure • RA can grant “waivers” where estimated impact < 50% of NAAQS • RA can require additional monitoring beyond the minimum requirements where “the likelihood of Pb air quality violations is significant” • Paragraph 4.5(a) of Appendix D to 40 CFR Part 58

4. Source Oriented Monitoring – Waiver Process (1 of 2) • Actual Pb emissions less than 1 ton per year • Monitoring agencies should work with their emission inventory colleagues to review Pb estimates in the 2005 NEI. • Revised estimates must be based on reliable source testing, application of appropriate emission factors or use of other credible approaches. • Document revised emission estimate in annual network plan • Submit new emission estimate to National Emissions Inventory • Subject to review of EPA Regional Administrator as part of Pb monitoring plan

5. Source Oriented Monitoring – Waiver Process (2 of 2) • Estimated maximum Pb impact less than 50% of the NAAQS • Based on historical Pb monitoring data or estimated based on dispersion modeling • Estimate must be in the form of the standard (i.e., maximum 3-month rolling average over a 3 year period) • Must request and be granted a “waiver” from the source-oriented monitoring requirement from the EPA Regional Administrator

6. Source-Oriented Monitor Siting Requirements • Monitors are to be “micro-scale” sited at the location of estimated maximum concentration in ambient air • May consider logistics and the potential for population exposure when selecting site • Monitors must also meet the siting requirements of Appendix E to 40 CFR Part 58

7. Timeline for Source-Oriented Monitoring • States must identify proposed site locations in annual network plan due July 1, 2009 • Include recommended site locations and supporting documentation (e.g., modeling, improved emission inventories) • Include any waiver requests and supporting documentation • Sites must be operational by January 1, 2010

8. Non-source-oriented Monitoring Requirement • Non-source-oriented monitoring required in CBSA (large urban areas) with ≥ 500,000 population • Focused on non-traditional sources in urban areas • Roadways • Airports • Closed facilities • Hazardous waste sites • Construction and demolition • Population estimates based on most recent CENSUS estimates • No “waiver” provisions

9. Non-source-oriented Monitor Siting • Rule states that non-source-oriented monitors are to be sited at “neighborhood scale” • This is a disconnect with the purpose of these monitors • Monitoring agencies should consider siting monitors at “micro-” or “middle-” scale near non-traditional sources • Monitors must also meet the siting requirements of Appendix E to 40 CFR Part 58

10. Non-source-oriented Monitoring Timeline • States must identify proposed site locations in annual network plan due July 1, 2010 • Sites must be operational by January 1, 2011 • Monitoring agencies should not rush to site and install these sites early as requirements may change

11. Existing ambient lead (Pb-TSP) monitoring sites (133) CBSA with population of 500,000 or more (101) 1. Ambient lead monitoring sites measure lead in total suspended particulate (Pb-TSP). The 133 monitoring sites shown are those operating in 2008. 2. The current monitoring network for lead is not sufficient to determine whether many areas of the country would meet the 2008 lead standards. EPA is re-designing the nation’s lead monitoring network to allow assessment of compliance with the revised standard. EPA is requiring Pb-TSP monitors in areas near lead sources with emissions greater than or equal to 1.0 ton per year, and a monitor in every urban area with population of 500,000 or greater. 3. The emissions estimates used to develop this map are based on EPA’s 2002 National Emission Inventory (NEI) with modifications documented in Tom Pace’s 05/01/08 memorandum and Marion Hoyer’s 05/12/08 and 05/14/08 memoranda to the docket. Notes Estimated New Network Facilities that emit 1.0 or more tons of lead per year (135)

12. Petitions to Reconsider • The EPA has received two petitions to reconsider dealing with monitoring issues • Petitions deal with – • 1 tpy threshold for source oriented monitors • Waiver provision • Need to consider population exposure when siting monitors • How monitoring agencies should proceed • Full speed ahead on source-oriented monitors • Plan for but don’t install non-source-oriented monitors at this time

13. Additional Information • Technical notes on Pb network design monitoring issues • Network design issues • Modeling of Pb sources • Review of Pb emission inventories • 2005 Pb National Emission Inventory • http://www.epa.gov/ttn/amtic/pb-monitoring.html

14. Questions?