This example describes how the Guide for Developing a Multi-Metals, Fence-Line Monitoring Plan for Fugitive Emissions Using X-Ray Based Monitors (Guide) can be applied to develop a fugitive emissions characterization and monitoring plan for a primary lead smelter. Primary lead smelters are large industrial facilities that process ore into lead metal. Hazardous air pollutants (HAP) associated with primary lead smelters include lead, arsenic, and cadmium. Ambient lead pollution is a national concern, and lead is the only metal listed in the National Ambient Air Quality Standards (NAAQS) promulgated by the United States Environmental Protection Agency (U.S. EPA). Lead is a potent neurotoxin, with many documented health effects from exposure including mental impairment in adults and significant developmental disabilities in children. In 2008 the lead NAAQS was reduced from 1.5 µg/m to 0.15 µg/m, which reflected the growing scientific understanding that no blood level of lead is safe for humans. While ambient levels have fallen dramatically since the phase out of leaded gasoline in the early 1970s, there are still numerous locations in the United States out of attainment with the 2008 lead NAAQS. Most of the areas out of attainment are located near metals fabrication facilities, primary lead smelters and secondary lead smelters. The ambient lead NAAQS functions as
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