EPA Revisions to the Lead Ambient Air Monitoring Requirements

by Phil DeVita

On December 14, 2010 the EPA revised the ambient monitoring requirements for lead (Pb).  This action comes after the EPA revised the primary and secondary lead National Ambient Air Quality Standard (NAAQS) on January 12, 2009 from1.5 ug/m3 to 0.15 ug/m3.  Separate from this, the EPA published an advance notice of rulemaking on Lead Emissions from Piston Engine Aircraft Using Leaded Aviation Gasoline in April of this year regarding possible engine emissions standards for such aircraft. 

The new requirements call for monitoring near industrial facilities with emissions greater than 0.5 tons per year (tpy) which is a reduction from the previous threshold of 1.0 tpy.  EPA is maintaining the 1.0 tpy threshold for airports, however, it did identify 15 additional airports where monitoring will be required in order to evaluate the potential lead impact from airports that emit less than 1.0 tpy.  The 15 airports are:

Airport

County

State

Merrill Field Anchorage AK
Pryor Field Regional Limestone AL
Palo Alto Airport of Santa Clara County Santa Clara CA
McClellan-Palmar San Diego CA
Reid Hillview Santa Clara CA
Gillespie Field San Diego CA
San Carlos San Mateo CA
Nantucket Memorial Nantucket MA
Oakland County International Oakland MI
Republic Suffolk NY
Brookhaven Suffolk NY
Stinson Municipal Bexar TX
Northwest Regional Denton TX
Harvey Field Snohomish WA
Auburn Municipal King WA

These airports were selected since they have characteristics the EPA believes could result in higher lead concentrations than at other airports because they have ambient air within 150 meters of maximum emissions (i.e. take-offs) and the meteorological conditions were conducive to potential higher lead impacts at nearby ambient locations.

In addition to industrial facilities and airports, EPA is requiring monitoring at non source oriented sites with populations greater than 500,000 people or more.

The additional lead monitoring must be operational within 1 year of when the rule is published in the Federal Register which is expected in the next few weeks.  For the non source sites, monitoring will begin January 1, 2012.

For our aviation clients, they should understand that these monitoring requirements will be conducted by the state agencies and not the airports.  It will be the state agency’s responsibility to come up with a compliance plan if results show impacts above the lead standards near airports.  However, EPA is limited in authority under federal law for states to adopt mitigation plans.  The agency is working with the FAA and industry to evaluate alternatives to the current use of lead in Avgas which could be used to mitigate impacts.

 

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