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MEMORANDUM 

To: Docket No.: EPA-HQ-OAR-2011-0344 

From: Chuck French, Project Lead 

Risk and Technology Review – National Emissions Standards for Hazardous Air 

Pollutants (NESHAP) for Secondary Lead Smelting 

Date: April, 2011 

Subject: Draft Estimated Time Needed to Comply with the Proposed Revisions to the 

NESHAP 

The purpose of this memorandum is to present the results of an analysis to estimate the 

time required for the 14 secondary lead smelting facilities operating in the U.S. to comply with 

the proposed revisions to the existing secondary lead smelting NESHAP. 

1.0 SUMMARY OF PROPOSED REVISIONS 

As part of the Risk and Technology Review (RTR) for the Secondary Lead Smelting 

source category, EPA is proposing revisions to the stack and fugitive emissions standards in the 

existing NESHAP. 

For stack emissions, EPA is proposing to lower the current lead-based concentration limit 

of 2.0 milligrams per dry standard cubic meter (mg/dscm) applicable to all stacks in the source 

category to 1.0 mg/dscm. Additionally, EPA is proposing to add a facility-wide flow-weighted 

average lead concentration limit of 0.2 mg/dscm. 

For fugitive emissions, EPA is proposing that facilities must operate all lead-bearing 

processes within total enclosures that are maintained at negative pressure and are vented to a 

control device. EPA is also proposing additional work practices beyond those required in the 

existing NESHAP. As an alternative to construction of total enclosures for lead-bearing 

processes, facilities may install ambient lead monitors at or near their fencelines to demonstrate 

that lead concentrations in air near their facilities do not exceed the National Ambient Air 

Quality Standards (NAAQS) for lead (i.e., 0.15 μg/m3) for any 3-month rolling average. If this 

compliance option is chosen, facilities would still be required to implement the additional 

fugitive work practices. 

EPA is proposing these revisions under Sections 112(d)(6) and 112(f)(2) of the Clean Air 

Act (CAA). As outlined in the Act, sources must comply with any standards proposed under 

112(f)(2) within 90 days of promulgation. However, the Administrator may grant a waiver 

allowing up to a two year compliance period if the Administrator finds that “such period is 

necessary for the installation of controls and that steps will be taken during the period of the 
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waiver to assure that the health of persons will be protected from imminent endangerment” 

(CAA Section 112(f)(4)(A)-(B)). In this memorandum, we estimate the time that will be 

required for facilities in this source category to comply with the proposed revisions to the 

Secondary Lead Smelting NESHAP. The results of our analyses are presented in the following 

sections. 

2.0 STACK EMISSION STANDARDS 

Based on the proposed revisions to the stack emissions limits described in section 1.0 of 

this memorandum, we estimate that five facilities would not be in initial compliance with the 

flow weighted average stack emissions limit of 0.2 mg/dscm. However, we expect that three of 

these facilities would come into compliance with the flow weighted average limit after 

installation of the total enclosures and associated control devices that would be required under 

the proposed revisions to the fugitive emissions standards described in section 1.0. 

We estimate that two facilities would need to replace existing baghouses at two stacks 

(see Draft Cost Estimates Impacts of the Revised NESHAP for the Secondary Lead Smelting 

Source Category for more details). We estimate that a replacement control device would require 

21 to 24 months to be fully operational. This includes 2-4 months for evaluation of existing 

control devices and development of an engineering plan to meet the revised emissions limits, 2-4 

months for engineering of replacement control device(s), 2-3 months for capital approval, 5-7 

months for delivery of the control device, 2-4 months for construction and installation, and 2-3 

months of operation until stack testing is conducted. These two facilities would also likely have 

several other ongoing projects to comply with the proposed revisions to the fugitive emissions 

standards. 

3.0 FUGITIVE EMISSION STANDARDS 

Based on the revisions to the fugitive emissions standards described in section 1.0, we 

estimate that 12 of the 14 secondary lead smelting facilities would be required to implement 

additional fugitive emissions control work-practices. We also estimate that 7 facilities would 

need to construct total enclosures for their lead-bearing processes if they do not currently exist. 

If they choose the ambient lead monitoring compliance option, we still estimate that they would 

need to construct total enclosures for at least one of the specified fugitive emissions sources in 

order to reduce the concentrations of lead in air near their facility to levels below the lead 

NAAQS. Table 2-1 presents a summary of the actions that we expect would be taken by the 

facilities to comply with the revised fugitive emissions standards. 

We estimate that construction of new enclosures for one or more of the specified fugitive 

emissions sources would require 21 to 24 months. This includes an estimated 5-7 months for 

engineering analysis and design, 2-3 months for capital approval, and 12-16 months for 
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construction of the enclosure, installing additional ventilation systems and duct work, and 

ensuring appropriate venting of gases to the control devices. 

Table 3-1. Summary of Required Actions for Compliance with the Proposed Revisions to the 

Fugitive Emissions Standards in the Secondary Lead Smelting NESHAP. 

Number of 

Facilities that 

would need to do 

action 

Construct Total Enclosures

Implement 

Additional 

Work 

Practices 

Develop an SOP, 

and submit the 

SOP for review 

and approval by 

the Administrator 

Furnace 

Area 

Raw 

Materials 

Storage 

Area 

Refining 

and 

Casting 

Area 

Battery 

Breaker 

Area 

1 ü ü ü

1 ü ü ü ü

2 ü

3 ü ü ü ü ü ü

3 ü ü ü ü ü

4 ü ü

Some facilities already have all of the specified fugitive emissions sources in total 

enclosures and would only need to develop and implement additional fugitive work practices. 

We estimate that development and implementation of the additional work practices would 

require a minimum of 6 months. While the majority of the work-practices should not require a 

significant amount of time to implement, the newly required rooftop cleanings would require 

installation of a water supply with the appropriate piping at each facility. In addition to the new 

water supply, we believe that some facilities would need to hire additional employees to dedicate 

to the new work-practices. Thus, an estimated 2-4 months would be required to hire and train 

new employees. All facilities would also need to develop standard operating procedures (SOPs) 

and submit those draft SOPs to the Administrator for review and approval. They may potentially 

then need to revise those plans based on comments by the Administrator and resubmit the 

revised SOPs for further review and approval. Finally, the facilities would need to implement 

those work practices pursuant to the approved SOP. We estimate that this overall process could 

take 6-9 months. 

Facilities have the option of installing ambient lead monitors to demonstrate compliance 

instead of constructing full enclosures. If chosen, we estimate that the minimum amount of time 

required to have the necessary monitoring equipment operational would be approximately 6-8 

months. This includes time to draft a monitoring plan, submit that draft plan to the 

Administrator for review, revise the monitoring plan as appropriate, and potentially resubmit to 

the Administrator for further review. Once an agreement with the permitting authority is 

reached, the facilities would need to purchase the appropriate equipment, acquire the necessary 

monitors, set up the necessary power supply, set-up and test the equipment, do QA/QC, and 
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eventually put these compliance monitors in full operation. Once the ambient monitors are 

operational, facilities would need a minimum of 3 months of ambient lead data (beyond the 6-8 

months required for setup) to demonstrate initial compliance with the primary lead NAAQS, for 

a total of 9 to 11 months. 

4.0 CONCLUSIONS 

Based on our analysis, at least half of the secondary lead smelting facilities affected by 

the proposed revisions to the existing NESHAP would need 21 to 24 months to complete the 

projects necessary for compliance. With regard to the steps that will be taken during the period 

to assure that the health of persons will be protected from imminent endangerment, we conclude 

that the public will be protected from imminent endangerment during these extra months because 

facilities will continue to comply with the existing 1997 NESHAP and various State programs 

which ensure emissions are limited. Therefore, we believe that a two year compliance period 

would be appropriate for all secondary lead smelting facilities.