Got Lead? Lead Reporting Rule Finalized

If you’ve “got lead” at your facility, then you’ll want to read this blog regarding the recently published final rule on reporting of lead (Pb) emissions. The final rule published on February 19, 2015 (80 FR 8787) amends the emissions inventory reporting requirements in 40 CFR Part 51, Subpart A [Air Emissions Reporting Requirements (AERR)] to align the point source reporting threshold for Pb emissions sources in the AERR with the National Ambient Air Quality Standard (NAAQS) for Pb and the associated revisions to Pb Ambient Air Monitoring Requirements (Appendix D to 40 CFR Part 58).

The following actions were taken in the final rule:

• Lowered the threshold for reporting Pb emissions as point sources,
• Eliminated the requirement to report emissions from wildfires and prescribed fires, and
• Replaced a requirement for reporting mobile source emissions with a requirement for reporting input parameters that can be used to run the U.S. EPA models that generate emissions estimates. 

U.S. EPA lowered the point source threshold for Pb emissions to 0.5 tons per year (tpy) of actual emissions in order to match the requirements of the Pb Ambient Air Monitoring Requirements rule, which required monitoring agencies to install and operate source-oriented ambient monitors near sources emitting 0.50 tpy or more of actual Pb emissions by December 27, 2011.  The monitoring and now AERR criteria are based on actual emissions rather than the potential-to-emit (PTE) approach taken for other criteria pollutant and precursor thresholds.

For other Pb considerations, you may want to revisit our May 2013 blog post for more thoughts on Pb emissions.  In the meantime, now is an opportune time to revisit your Pb emission factor selection and emissions estimates while compiling your 2014 annual reported emissions. Specifically:

If you have emission units that emit Pb, take a close look at the facility-wide total emissions.  If you are close to the 0.5 tpy threshold, review the emission factors that you use to develop the annual emission inventory and make sure that the data are the most current data that reflect existing operations. Doing this now will also help you refine your Toxic Release Inventory (TRI) reports due in July 2015 – perhaps an updated emission factor means you no longer need to report lead emissions in your TRI.

1. Think about developing new data for Pb emissions.  Have you changed the way your process operates?  Have you installed a new air pollution control system?  Have you changed the filters that you use?  Are the Pb emission factors that you rely on more than 10 years old?  If you can answer yes to any of these questions, it may be time to develop some new data or review other available data.
2. “Own” your inventory.  The inventory for your facility is available for everyone to see and is being used in ways that you probably didn’t think of – so recognize this and act accordingly.  Take the time and spend the resources to update your facility’s inventory to reflect the best and most current data for your facility.

Contact us if you have any questions regarding Pb emission factor selection or annual emissions reporting.