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NYS Air Toxics Program and Advancements in Control Technologies Case Study:

Revere 2° Lead (Pb) SmelterDonald Ward, Ph.D.

NYSDEC Division of Air Resources: Air Toxics Section

2019 Annual AWMA/NYWEA Joint SeminarPittsford, NYFebruary 13, 2019

Presentation Topics• Pb Toxicity• Sources of Pb• Past Pb Exposure Reducing Activities• Acceptable Blood Lead Levels (BLLs)/BLLs and IQ• Pb National Ambient Air Quality Standard (NAAQS)• Pb in NYS and Orange County Specifically• Revere Smelting & Refining Corp. (RSR)• Co-located Pb-TSP:Pb-PM10 Data Correlation Analyses

µg/dl

EPA/NTP/IARC:Probable Human

Carcinogen

EPA/NTP/IARC:Probable Human

Carcinogen

Brain Continues Maturing

Areas performing more basic functions mature earlier; areas for higher-order functions (emotion, self-control) mature later. The pre-frontal cortex, which handles reasoning and other "executive" functions, emerged late in evolution, and is among the last to mature.

Childhood Lead Exposure Typically Affects Integrative Systems that Mature Later in Development

The developing brain is especially sensitive to toxins (such as lead) that can disrupt the finely tuned sequence of events that lead to a mature, normally functioning nervous system, resulting in significant functional problems.

Pb NAAQS set at 1.5 µg/m3

Airborne lead concentrations in the U.S. have decreased over 90% since 1980

Revere Smelting & Refining (RSR)

• Large secondary lead smelter & refiner• Accepts lead acid car batteries from all over

the Northeast & Mid-Atlantic States• Operates around the clock• Recycles 25 to 30 million batteries annually

Orange County Pb-TSP Data

27 Industrial Driv.Ballard Road, Town (1)Ballard Road, Town (2)Ballard Road, Town (3)

1987‐1994Air pollution control effectiveness evaluation with appropriate response actions occurred

1987• Violation of Pb NAAQS• 1 monitoring station active• Max 24‐hr conc. of 13.69 µg/m3

1988• Rebuild baghouse cells and add 1 more• Install new bags• Max 24‐hr conc. of 5.29 µg/m3

1989• Consent order signed• Max 24‐hr conc. of 6.06 µg/m3

1990• 2 additional Pb monitors sited• New baghouse on all refinery EPs• Max 24‐hr conc. of 2.61 µg/m3

1991• Fugitive emission sources enclosed• Refinery air captured• New baghouses installed • Max 24‐hr conc. of 4.27 µg/m3

1992• Raw feed piles storage bldg. enclosed• Refinery bldg. put under neg. pressure• Open door alarms installed (refinery)• Max 24‐hr conc. of 4.82 µg/m3

1993• Max 24‐hr conc. of 2.61 µg/m3

1994• BACT determination made by DEC• 13 separate baghouses installed• 16 Pb EPs controlled• Max 24‐hr conc. of 0.33 µg/m3

2° Pb Smelter NESHAP 1995: Updated rule promulgated2000: RTR process with SAB guidance

2° Pb Smelter NESHAP 1995: Updated rule promulgated2000: RTR process with SAB guidance2012: Updated rule promulgated emulating controls and work practices done at RSR

Kiln Dryer 200’ Stack

Baghouse Units

µg/dl

Evidence of adverse effects below 10 µg/dl blood lead

‐ no known threshold

µg/dl

Steeper slope of IQ loss per unit increase in blood Pb at lower BLLs as compared to higher BLLs.

Pb NAAQS History• 1978: 1.5 ug/m3 as Pb‐TSP with quarterly ave. not to be exceeded• 1990: Reviewed but no change to the level was made• 2008: ?

Pb NAAQS History• 1978: 1.5 ug/m3 as Pb‐TSP with quarterly ave. not to be exceeded• 1990: Reviewed but no change to the level was made• 2008: Revisiting appropriately altering the level 30 years later based

on new science

Every 5 years as the EPA Administrator was directed to do in 1977?

Pb NAAQS History• 1978: 1.5 ug/m3 as Pb‐TSP with quarterly ave. not to be exceeded• 1990: Reviewed but no change to the level was made• 2008: ?

CD: 2,247 pages

R/EA: 1,047 pages

SP: 344 pages

ANPR: 214 pages

CASAC documents

Pb NAAQS Factors Considered

• Significant IQ loss? to be prevented• Slope factor of IQ loss per BLL unit

decrease in the proposed NAAQS range• Ambient air Pb concentration to Blood Lead

Level (BLL) Ratio 1978- 1:1 to 1:2 2008- 1:5 (WHO)/1:7 (1° Pb Smelter)/1:10 (CASAC)

During the 2008 PbNAAQS review, the EPA Administrator concluded that a mean IQ loss of 1‐2 points at the population level could be significant from a public health perspective so the level of the standard should be selected to avoid IQ loss in excess of this range.

Pb NAAQS Levels Considered

• ANPR (1st time being used): Huge Range Revoke Pb NAAQS/De-List Pb Maintain Current NAAQS (1.5 µg/m3) EPA Staff Paper Range of 0.1-0.2 µg/m3 down

to 0.02 µg/m3 or Lower• CASAC: 0.06-0.2 µg/m3 down to 0.025 µg/m3

• EPA: Proposed Range of 0.1-0.3 µg/m3 (invited comments down to zero and up to 0.5 µg/m3)

Pb NAAQS Levels Considered

• ANPR (1st time being used): Huge Range Revoke Pb NAAQS/De-List Pb Maintain Current NAAQS (1.5 µg/m3) EPA Staff Paper Range of 0.1-0.2 µg/m3 down

to 0.02 µg/m3 or Lower• CASAC: 0.06-0.2 µg/m3 down to 0.025 µg/m3

• EPA: Proposed Range of 0.1-0.3 µg/m3 (invited comments down to zero and up to 0.5 µg/m3)

Pb NAAQS History• 1978: 1.5 ug/m3 as Pb‐TSP with quarterly ave. not to be exceeded• 1990: Reviewed but no change to the level was made• 2008: 0.15 ug/m3 as Pb‐TSP* with 3‐mo rolling ave. not to be exceeded

EPA chose a rolling 3‐month average not to be exceeded

µg/dl

Pb-TSP:Pb-PM10 Data Correlation Analyses Conclusions

• Strong correlation between Pb-TSP and Pb-PM10 data• Pb-PM10 to Pb-TSP Adjustment Factor (AF) of 1.49 derived 0.005 µg/m3 cut point used to reduce variability by

removing the low conc. data with its accuracy concerns• AF is meant to be site specific as opposed generic• Should not result in “false” exceedances of the Pb NAAQS• Agree with EPA that the Pb-PM10 monitor be replaced with

a Pb-TSP monitor if the rolling 3-mo conc. ≥0.1 µg/m3

Source: J & C Engineering website

New 2° PbSmelter NESHAP MACT Floor?

Pb NAAQS History• 1978: 1.5 ug/m3 as Pb‐TSP with quarterly ave. not to be exceeded• 1990: Reviewed but no change to the level was made• 2008: 0.15 ug/m3 as Pb‐TSP* with 3‐mo rolling ave. not to be exceeded• 2016: Reviewed but no change to the level was made

Thank You!

Questions?

Donald F. Ward Jr., Ph.D.NYSDEC Research ScientistBureau of Air Quality Analysis and ResearchDivision of Air Resources625 Broadway, 9th FloorAlbany, N.Y. 12233‐3259(518) 402‐8402donald.ward@dec.ny.govwww.dec.ny.gov