EPA Revises Lead Ambient Air Monitoring Requirements



Air Quality Testing for several parameters.

On December 14, 2010, the Environmental Protection Agency (EPA) published the final lead (Pb) ambient air monitoring requirements.  The purpose of this revision was to expand the nation’s lead monitoring network to better assess compliance with the revised National Ambient Air Quality Standards (NAAQS) for lead issued in 2008.  In 2008, EPA substantially strengthened the lead NAAQS by revising the level of the primary (health-based) standard from 1.5 micrograms per cubic meter (μg/m3) to 0.15 μg/m3, measured as total suspended particles (TSP).  The agency revised the secondary (welfare-based) standard to be identical to the primary standard.  EPA in this final rule (Dec. 2010) also changed the emission threshold that state monitoring agencies (such as New York State Department of Environmental Conservation [NYS DEC]) must use to determine if an air quality monitor should be placed near an industrial facility that emits lead. The new emission threshold is 0.5 tons per year (tpy), reduced from the previous threshold of 1.0 tpy. Any new monitors located near an emissions source must be operational no later than one year after this rule is published in the Federal Register.  EPA maintained a 1.0 tpy lead emission threshold for airports.  However, EPA is requiring a 1-year monitoring study of 15 additional airports (beyond those currently required to monitor at the existing 1.0 tpy emission threshold) for the New York area this includes Brookhaven and Republic airports. The study will help EPA determine whether airports that emit less than 1.0 tpy have the potential to cause the surrounding areas to exceed the lead NAAQS of 0.15 micrograms per cubic meter (μg/m3).  The monitors participating in the study must be operational no later than one year after this rule is published in the Federal Register.
EPA is also requiring lead monitoring in large urban areas (Core Based Statistical Areas, or CBSAs, with a population of 500,000 people or more).  Monitors will be located along with multi-pollutant ambient monitoring sites (known as the “NCore network”).  Lead monitoring at these sites will begin January 1, 2012.

• The NCore network will consist of approximately 80 monitoring sites, of which 63 will be in large urban areas.  The requirement to add these monitors replaces an existing requirement to place lead monitors in each CBSA with a population of 500,000 or more people.

The above revisions were made based on comments received on EPA’s proposed revisions.

Related articles

• "EPA to study 15 airports for lead levels" and related posts (generalaviationnews.com)
• The Environmental Protection Agency's End-Run Around Democracy (pajamasmedia.com)
• Pennsylvania DEP Secretary Announces Progress Made in Achieving Cleaner Air (prnewswire.com)
• "EPA Identifies Areas Violating Lead Standards" and related posts (aaenvironment.blogspot.com)
• More Protections to Keep Children Safe From Lead (doyourpart.com)
• EPA Announcement on Lead Pollution Monitoring is a Holiday Message to Children: We're Watching Out For You! (switchboard.nrdc.org)
• Major U.S. Cities Violate New EPA Lead Standards (scientificamerican.com)

Space Deodorants May Cause Reduced Lung Function

A study done by the National Institute of Environmental Health Sciences (NIEHS) has determined that the volatile organic compound 1, 4 dichlorobenzene (1,4 DCB) may cause a modest reduction in lung function. 1,4 DCB is a white solid compound with a distinctive aroma and is typically found in space deodorants such as many air fresheners, toilet bowl cleaners, mothballs, and other deodorizing products. According to Stephanie London, M.D., the lead investigator for the NIEHS study, "even a small reduction in lung function may indicate some harm to the lungs" and "the best way to protect yourself, especially children who may have asthma or other respiratory illnesses, is to reduce the use of products and materials that contain these compounds." Isn't it interesting how people looking for better smelling air (better air quality?) end up making their air worse (harmful?) by choosing products that try to simulate nature but don't quite smell right. There are plenty of books and information out there on creating natural deodorants for the home, but probably the best will be to open a window and let the fresh air in (assuming you don't live in a city with air quality problems).

VAT Article from our 2007 Spring Newsletter.

A study published in the 2003 issue of “Applied Occupational and Environmental Hygiene” magazine titled “Asbestos Release During Removal of Resilient Floor Covering Materials” by Marion Glenn Williams, Jr. and Robert N. Crossman, Jr. of the University of Texas Health Center indicated that worker's exposure to asbestos during vinyl asbestos floor tile (VAT) removal may be under reported. Because we work in New York (NYS), we are very familiar with the limitations of polarized light microscopy (PLM) analysis on VATs or for that matter on any nonfriable organically bound (NOB) material. Under NYS Environmental Laboratory Accreditation Program (ELAP) requirements materials that are considered NOBs must go through a multiple step process for analysis. This process ends with analysis by Transmission Electron Microscopy (TEM) for samples that are negative for asbestos. This method is required for VATs because the type of asbestos typically used was Grade 7 asbestos known as Shorts & Floats. Grade 7 asbestos is no longer sold and was the cheapest asbestos material sold. The dimensions of this grade of asbestos was ultra-fine. With fiber dimensions approaching the less than 5 micron range. This study was done to determine if there was fiber release at the less than 5 micron level that was not being analyzed by the Phase Contrast Microscopy (PCM). PCM is used for air sample analysis and only analyzes greater than 5 micron fibers with a 3:1 or greater length to width ratio. The study found the following issues:

• When removing a non-asbestos sheet vinyl flooring with an asbestos felt backing the PCM method only reported 5-7% of the fibers counted by the TEM method.


• When removing an asbestos containing 12x12 VAT with asbestos containing mastic the PCM method only reported 2-2.5% of the fibers counted by TEM.


• When removing an asbestos 9x9 VAT with an asbestos mastic the PCM method reported 0-2.5% of the fibers counted by TEM.


• When removing mastic using a mastic remover (TEM levels were between 1.319-1.749 structures/cubic centimeter (s/cc)) versus amended water (TEM levels were between 0.094-0.184 s/cc).

This study shows that air sample results are significantly underreported using the PCM method of analysis. When performing VAT removals asbestos air monitors and project monitors should be using TEM analysis for clearance (at the very least) and they should be running a few TEM samples during the actual removal of the VATs. These would give us a better understanding of what is happening during VAT removals and ensure that the asbestos abatement was thoroughly completed.

New Indictments Handed-Out in Plattsburgh Area

On March 29, 2007, the US Department of Justice handed out indictments to John Wood, Mark Desnoyers, and Curtis Collins for numerous illegal activities related to the removal of asbestos in commercial and public buildings and private homes. Wood operated an asbestos abatement company called J&W Construction. Collins worked for Wood, and later started his own company called Adirondack Asbestos. Desnoyers operated Adirondack Environmental Associates an air monitoring company.

The indictments allege that Wood and Collins performed illegal asbestos removals throughout central and upstate New York, while Desnoyers falsified many laboratory samples in order to convince clients that all asbestos was properly removed from their businesses and homes when gross contamination remained.

If convicted Wood faces a maximum possible term of incarceration of 63 years and a fine of $2,500,000; Collins faces a maximum possible term of incarceration of 10 years and a fine of $500,000; and Desnoyers faces a maximum possible term of incarceration of 25 years and a fine of $1,250,000.

New Asbestos Regulation Goes Into Effect

September 5, 2006, the new Asbestos Regulation for New York State, Industrial Code Rule 56, went into effect. While we were in Plattsburgh training, in one of the refresher classes we heard that NYSDOL gave violations to the asbestos contractor and the asbestos consultant working in the area doing asbestos floor tile removal. The contractor's violations involved not removing all the asbestos material, and mastic remover leaking out from containment. The violations to the asbestos consultant were not being onsite while air sampling, and not performing the visual inspection properly. The interesting violations are the ones to the asbestos consultant, because this indicates they will be reviewing the visual inspection and the requirement that the air sampler be onsite while air sampling is being performed. This is the first we are hearing how enforcement of the new regulation may occur. Especially since the new regulation is much stricter than the old regulation. We already know that site specific variances must be submitted by certified Project Designers that have Asbestos Company Licenses from September 5, 2006 on. It will be interesting how many other parts of the regulations they will enforce.