i 

## EXECUTIVE SUMMARY

The N onattainment A rea (NAA) for the Lead (Pb) National Ambient Air Quality Standard ( NAAQS ) consists of an area within Pike County with a radius of eight

- tenths of a mile from
the Sanders Lead Company

. From the period November 2005 to December 2008 , air quality monitoring data at the Sanders Lead site indicated that the rolling 3

- month average Pb concentrations exc eeded the 0.15 μg/m 3 NAAQS. The Environmental Protection Agency ( EPA ) designated the area as nonattainment for the Pb NAAQS, effective
December 31

, 20 10

. This document constitutes the attainment demonstration for the Troy Pb NAA . Air quality modeling conducted in support of this attainment demonstration indicates that the Troy NA A
will attain the Pb NAAQS beginning in July 2013, which is the earliest date by which all controls required by this plan will be fully implemented

. Th e model results are based upon emissions reductions from the Sanders Lead Company

, located in Troy , Alabama. The State of Alabama expects the area to attain the Pb NAAQS based upon implementation of
emissions controls

.ii 

## Table of Contents

EXECUTIVE SUMMARY

................................ ................................ ................................ ....... i

1 Introduction

................................ ................................ ................................ ................ 1

- 1

1.1 Purpose and Organization of Document

................................ .............................. 1

- 1

1.2 National Ambient Air Quality Standards (NAAQS)

................................ ............... 1

- 1

1.3 History of Alabama Lead Nonattainment Area

................................ ..................... 1

- 2

1.4 Air Quality Trends

................................ ................................ ................................ 1

- 2

1.5 Clean Air Act (CAA) Requirements

................................ ................................ ...... 1

- 4

2 Conceptual Description of the Troy Lead Non Attainment Area

................................ .. 2

- 1

2.1 Introduction

................................ ................................ ................................ ......... 2

- 1

2.2 Monitoring Data for the NAA

................................ ................................ ................ 2

- 3

3 ATTAINMENT DEMONSTRATION METHODS AND INPUTS

................................ .... 3

- 1

3.1 Background

................................ ................................ ................................ ......... 3

- 1

3.2 Modeling Protocol

................................ ................................ ............................... 3

- 1

3.3 EPA Gu idance for Attainment Demonstration Modeling

................................ ....... 3

- 1

3.4 Modeling Approach

................................ ................................ ............................. 3

- 2

4 Emissions Data

................................ ................................ ................................ .......... 4

- 1

4.1 Introduction

................................ ................................ ................................ ......... 4

- 1

4.1.1 2010 Bas e Year

................................ ................................ ............................ 4

- 1

4.1.2 2015 Future Year

................................ ................................ .......................... 4

- 1

4.1.3 Summaries of the 2010 and 2015 Emission Inventories in the Nonattainment Area (NAA)

................................ ................................ ................................ ................ 4

- 4

4.2 Emissions Data for Model Simulations

................................ ................................ 4

- 4

4.2.1 Processing of Source Emissions

................................ ................................ ... 4

- 4

4.2.1.1 Haul Road Emissions

................................ ................................ ............. 4

- 6

5 Model Performance Evaluation

................................ ................................ .................. 5

- 1

5.1 AERMOD Model Performance

................................ ................................ ............ 5

- 1

5.1.1 Meteorology

................................ ................................ ................................ .. 5

- 1

6 Control Strategy Development/RACT

................................ ................................ ........ 6

- 1

6.1 Introduction/Overview

................................ ................................ .......................... 6

- 1

6.2 Statement of Basis for Sanders Lead RACT Controls

................................ ......... 6

- 1

7 Reasonable Further Progress/Contingency Measures

................................ ............... 7

- 1

7.1 Reasonable Further Progress

................................ ................................ ............. 7

- 1

7.2 Contingency Measures

................................ ................................ ........................ 7

- 1iii 8 Model Attainment Demonstration

................................ ................................ ............... 8

- 1

8.1 Purpose of an Attainment Demonstration

................................ ............................ 8

- 1

8.1.1 Procedure for Demonstrating Attainment

................................ ...................... 8

- 1

8.1.2 Attainment Year

................................ ................................ ............................ 8

- 1

8.2 Suppor ting Weight of Evidence Analysis

................................ ............................. 8

- 1

8.3 Proposed Control Strategy

................................ ................................ .................. 8

- 1

9 Data Access

................................ ................................ ................................ .............. 9

- 1

10 Quality Assuran ce/Quality Control

................................ ................................ ........ 10

- 1

10.1 Quality Assurance Objectives

................................ ................................ ......... 10

- 1

10.2 Emissions Inputs and Outputs

................................ ................................ ........ 10

- 1

10.3 Meteorological Inputs

................................ ................................ ..................... 10

- 1

10.4 Air Quality Model Inputs and Outputs

................................ ............................. 10

- 2

11 Conclusions

................................ ................................ ................................ ........... 11

- 1iv 

## List of Tables

Table 1.4

- 1 Lead Design Values 2005

- 2011

................................ ................................ ..... 1

- 4

Table 2.2

- 1 FRM monitoring sites within the Troy Pb NAA

................................ .............. 2

- 3

Table 2.2

- 2 Troy, Alabama, Lead Design Values 2005

- 2011

................................ ............. 2

- 3

Table 4.1.2

- 1 Change in limits on existing stacks

................................ ............................. 4

- 2

Table 4.1.2

- 2 Summary of Reductions Achieved

................................ .............................. 4

- 3

Table 4.1.3

- 1 2010 and 2015 Pb Emissions for the Troy NAA (Pounds Per Year)

............ 4

- 4

Table 4.2.1

- 1 Pre

- Control Pb Emissions Sources and Emission Rates

............................ 4

- 4

Table 4.2.1

- 2 Post

- Control Pb Emissions Sources and Emission Rates

.......................... 4

- 5

Table 6.2

- 1 Summary of RACT Controls

................................ ................................ .......... 6

- 3

Table 6.2

- 2 Summary of Reductions Achieved

................................ ................................ . 6

- 4

Table 6.2

- 3 Pre

- and Post

- Control Emission Limits and Rates

................................ ......... 6

- 5

Table 6.2

- 4 Post

- Control Modeling Results

................................ ................................ ...... 6

- 7

Table 8.1.1

- 1 Model Results

................................ ................................ ............................. 8

- 1

Tabl e 8.3

- 1 Summary of RACT Controls

................................ ................................ ......... 8

- 2



## List of Figures

Figure 1.4

- 1 Location of Lead Monitors in the Troy NAA

................................ ................. 1

- 3 Figure 1.4

- 2 Pb Maximum 3

- Month Rolling Average (μg/m 3 )*

................................ .......... 1

- 4
Figure 2.1

- 1 Troy Pb NAA Boundaries

................................ ................................ ............ 2

- 1 Figure 2.1

- 2 Sanders Lead Plant Boundaries and Monitor Locations

............................... 2

- 2 Figure 6.2

- 1 Sanders Lead Modeling Receptor Grid

................................ ........................ 6

- 6



## List of Appendices

Appendix A: Sanders Lead Attainment Package
Appendix B: Sanders Modeling Protocol and Correspondence Appendix C: Haul Road Workgroup Findings Appendix D: Background Concentration Analysis Appendix E: Surface Characteristics Representativeness Analysis
Appendix F : Title V Permit Appendix G: LEADPOST Output1

- 1 

## 1 Introduction

1.1 Purpose and Organization of Document

This document is an a ttainment d emonstration for the Troy N AA for the 2008 Pb NAAQS.
The Troy NA A

, located in southern Alabama, is comprised of an area within Pike County
with a radius of eight

- tenth s of a mile from the Sanders Lead Company (latitude 31.7862o

, longitude 85.9786o), and excludes all other areas within Pike County

. In accordance with the Clean Air Act, this attainment demonstration is being submitted as a revision to Alabama's State Implementation Plan (SIP).
This attainment demonstration documents the State of Alabama's analysis of various control measures and the predicted impact on air quality in the Troy N A A. The analysis resul ts were used to select a practicable and reasonable control strategy

, which will result in attainment of the Pb NAAQS. The proposed control strategy will be implemented beginning
in July 201 2 , with full implementation by July 2013. A ttainment of the 2008 lead NAAQS is projected to be achieved by December 31, 201 5

. This chapter presents the background information and the sequence of events that have necessitated the development of this attainment demonstration. Technical data, methods, analyses and conclu sions which support this attainment demonstration are provided in the following chapters:
Chapter 2: Conceptual Description of the Troy Lead Non Attainment Area
Chapter 3: A ttainment D emonstration M ethods and I nputs
Chapter 4: Emissions Data
Chapter 5 : Model Performance Evaluation
Chapter 6 : Control Strategy Development /RACT
Chapter 7 : Reasonable Further Progress/Contingency Measures
Chapter 8 : Model Attainment Demonstration
Chapter 9 : Data Access
Chapter 1 0 : QA/QC
Chapter 1 1 : Conclusion s



### 1.2 National Ambient Air Quality Standards (NAAQS)

The Clean Air Act (CAA) , which was last amended in 1990, requires the EPA to set NAAQS for pollutants considered harmful to public health and the environment. The CAA established two types of NAAQS : p rimary standards set limits to protect public health, including the health of "sensitive" populations such as asthmatics, children, and the elderly
and s econdary standards set limits to protect public welfare, inclu ding protection against visibility impairment, damage to animals, crops, vegetation, and buildings.CHAPTER 1 INTRODUCTION

1

- 2 The primary and secondary NAAQS for the Pb standard are identical at 0.15 μ g/m 3 . P b is a heavy metal found naturally in the environment and in some manufactured products

. The standard for Pb is met when the 3

- month average Pb concentrations during each rolling
3

- month period evaluated over a 3

- year period at designated monitoring sites in an area is less than or equal to 0.15 μ g/m 3

.



### 1.3 History of Alabama Lead Nonattainment Area
On October 5, 1978, EPA promulgated primary and secondary NAAQS for Pb. Both primary and secondary standards were set at a level of 1.5 μ g/m 3

. In 1995, the entire state of Alabama was designated as attainment for the 1978 standard.

On October 15, 2008

, EPA revised both the level and the form of the NAAQS

, lowering the
standard from 1.5 μ g/m 3 to 0.15 μ g/m 3 and changing the form from a 3

- month block average to a maximum rolling 3

- month average over a three year period (73 FR 67039)

. O n October 1, 2009

, t he s tate of Alabama submitted designation recommendations. The S tate recommended that only the portion of Pike County within a radius of 0.8 miles from the Sanders Lead Company should be designated nonattainment for the Pb NAAQS. All other
areas were recommended as unclassifiable/attainment.

In a letter dated June 14, 2010

, EPA agreed with the State’s recommendations for the nonattainment area, but deferred making designation decisions for all other areas in Alabama. Designations were published on November 22, 2010

, (75 FR 71033)

, with an effective date of December 31, 2010

. EPA agreed with the S t ate’s recommendations for all other areas of Alabama and designated all other areas as unclassifiable/attainment.



### 1.4 Air Quality Trends

Section 110(a)(2)( C ) of the CAA requires that each s tate provide for the establ ishment and operation of an ambient air quality monitoring network to monitor, compile, and analyze data on ambient air quality for comparison to the NAAQS. The Pb monitoring network for the Troy area includes one State

- owned monitor located just offsite of the Sanders Lead Company

, along with a co

- located monitor for data substitution

. There are also two monitors owned by Sanders Lead sited near the facility

, as indicated in Figure 1. 4

- 1

. These monitors
collect ambient Pb data as required by Title 40 of the Code of Federal Regulations (40 CFR), Parts 50, 53, and 58

.CHAPTER 1 INTRODUCTION

1

- 3 Figure 1.4

- 1 Location of Lead Monitors in the Troy NAA

Federal regulations require that in “any area designated as nonattainment for the Pb NAAQS, the State must submit an attainment demonstration showing that the area will attain the standard as expeditiously as practicable ”

. The following table provides the design values for the 200 5

- 2011 time period for the ADEM monitor. Figure 1.4

- 2 bel ow depicts the downward trend of the Pb design values

.CHAPTER 1 INTRODUCTION

1

- 4 Table 1.4

- 1 Lead Design Values 2005

- 2011

Pb Maximum 3

- Month Rolling Average *
Design Value Years (μg/m 3 )

2005

- 2007 1.35

2006

- 2008 1.35

2007

- 2009 1.35

2008

- 2010 1.18

2009

- 2011 1.03

* Airs Monitor # 01

- 109

- 0003

* Airs Monitor # 01

- 109

- 0003 Figure 1.4

- 2 Pb Maximum 3

- Month Rolling Average (μg/m 3 ) *

As can be seen in the T able 1.4

- 1 above, Sanders met the 1978 lead standard in each recent design value year.



### 1.5 C lean Air Act (C AA ) Requirements

Section 172(c)

, as amended, of the C A A

, and t he 2008 Lead (Pb) National Ambient Air Quality Standar ds (NAAQS) Implementation Questions and Answers document

, released July 8, 2011 , contain the requirements and guidance for s tates developing a federally enforceable State SIP for Pb NAAs

. The SIP documents how an area will attain the NAAQS and generally c ontains four elements: emission inventory, modeled attainment demonstration, Reasonably Available Control Technology/Reasonably Available Control Measures (RACT/RACM) analysis, and adoption of controls. 0 0.2 0.4 0.6 0.8

1 1.2 1.4 1.6

2005

- 2007 2006

- 2008 2007

- 2009 2008

- 2010 2009

- 20112

- 1 

## 2 Conceptual Description of the Tro y Lead Non Attainment Area

2.1 Introduction

In a letter dated September 30, 2009 , ADEM provided EPA input regarding the extent of potential nonattainment areas in Alabama for the 2008 Pb NAAQS. The monitoring data indicated that a small portion of Pike County, Alabama

, did not meet the 2008 Pb NAAQS.
A s a result, EPA designated an area with a radius of 0.8 miles surrounding the Sanders Lead Company in Troy, Alabama, as “nonattainment” ( Figure 2.1

- 1 below).
In order to improve air quality in a nonattainment area, states must draft a S tate Implementation Plan (S IP ) , which outlines the measures that the state will take in order to improve air quality. Once a nonattainment area meets the standards and additional redesignation requirements in the Clean Air Act [Section 107(d)(3)(E)], EPA will designate
the area to attainment as a "maintenance area."

Figure 2.1

- 1 Troy Pb NAA Boundaries

Troy is located in southeastern Alabama, in Pike County, approximately 70 kilometers southeast of Montgomery, Alabama. Troy is located in a gently rolling area with noCHAPTER 2 CONCEPTUAL DESCRIPTION

2

- 2 significant local topographical features which affect wind flow and climate. The Sanders
Lead Company is located at 1 Sanders Road in Troy, Alabama. Sanders Lead is a secondary lead smelting and refining facility which processes scrap metal and lead bearing by

- products into refined lead alloys. The facility is the only source being evaluated as part of this attainment demonstration. In addition to complying with the 2008 Pb NAAQS, the facility is subject to the revised Secondary Lead MACT (40 CFR 63, Subpart X). Figure 2 .1

- 2 displays the facility, with the plant boundaries outlined in red and t he air quality monitors noted by the blue dots. The facility is located at UTM coordinates 596.744 East and 3517.284 km North at an elevation of approximately 160 meters ASL. The area surrounding the facility is largely rural with a good percentage of th e area made up of trees and vegetation.

Figure 2.1

- 2 Sanders Lead Plant Boundaries and Monitor LocationsCHAPTER 2 CONCEPTUAL DESCRIPTION

2

- 3 

### 2.2 Monitoring Data for the NAA

There are three air quality monitors sited in the vicinity of the Sanders Lead facility. ADEM operates two FRM lead monitors. The ADEM monitor is located at the northwestern edge of the Sanders Lead facility, approximately 175 meters from plant property. There is a co

lo cated monitor at the site to ensure data completeness. These monitors were sited by ADEM and approved by EPA Region 4

. Additionally, Sanders maintains two monitors in the general vicinity of the facility, one to the northwest, in line with the ADEM monit or but slightly further out, and another on the western boundary of the facility, located south

- southwest of the predominate sources.

Table 2.2

- 1 FRM monitoring sites within the Troy Pb NAA

Site ID Monitor T ype Longitude Latitude

Henderson Road

- Lead Troy #1 01

- 109

- 0003 POC:1 SLAMS 85.979167 31.790556

Henderson Road

- Lead Troy #2 01

- 109

- 0003
POC:2 QA Collocated 85.979167 31.790556

Sanders Anderson Facility Operated 85.98131 31.79356

Sanders Murphree Facility Operated 85.98117 31.782144

Prior to the 2008 NAAQS revision, Sanders was in compliance with the existing NAAQS of
1.5 μg/m 3

. The following table depicts the design values for the area.

Table 2.2

- 2 Troy, Alabama, Lead Design Values 2005

- 2011

Pb Maximum 3

- Month Rolling Average
Design Value Years (μg/m 3 *

2005

- 2007 1.35

2006

- 2008 1.35

2007

- 2009 1.35

2008

- 2010 1.18

2009

- 2011 1.03

* Airs Monitor # 01

- 109

- 00033

- 1 

## 3 ATTAINMENT DEMONSTRATION METHODS AND INPUTS

3.1 Background

On November 22 , 2010 , the EPA designated a small portion of the Troy , Alabama

, area ( Pike County ) as nonattainment for the Pb NAAQS (75 FR71033) . This designation triggered the requirement for the development of a SIP that would be due to EPA by June 30, 2012

. Guidance from EPA indicated that a significant requirement of Pb SIPs would be

an attainment demonstration u sing, at least in part, modeling analyses to define effective emissions control strategies and to confirm that attainment can be achieved after implementation of the strategies.
Consequently, the State of Alabama is required to submit a P b SIP to EPA that includes a control plan and a demonstration that the area will attain the P b NAAQS. The CAA
attainment date for this demonstration is December 31, 20 15

. The details of the modeling analyses used as the basis for this SIP can be found in Appendix A.



### 3.2 Modeling Protocol

In the summer of 2011, the URS C orporation, representing the Sanders Lead Company, began to coordinate the modeling methodology to be used in the attainment package for submittal to ADEM. On August 30, 2011, ADEM received the draft modeling protocol for review, and on September 8, 2011, ADEM forwarded the draft modeling protocol to EPA Region 4 for review and comment. The modeling protocol set forth the procedures, data sources and modeling approach that w as used in performing the attainment modeling for
the Troy NAA. The protocol was reviewed by ADEM and EPA Region 4 , and was revised
as needed. The modeling protocol, as well as correspondence between all parties, is included as Appendix B of this SIP.



### 3.3 EPA Guidance for Attainment Demonstration Modeling

Lead SIP regulati ons , found at 40 CFR 51.117

, require states to employ atmospheric dispersion modeling for the demonstration of attainment for areas in the vicinity of point

sources

. Dispersion modeling should follow the procedures outlined in EPA’s latest guidance document entit led “ Guideline on Air Quality Models’’ (GAQM) , 40 CFR 51, Appendix W

. This guideline indicates the types of historical records for data necessary for modeling demonstrations as well as the appropriate modeling system to apply to the
demonstr ation

. The GAQM is intended to ensure consistent air quality analyses for activities regulated at 40 CFR 51.112, 51.117, 51.150, 51.160, 51.166 and 52.21. EPA originally published the GAQM in April 1978 and it was incorporated by reference in the regulati ons for the Prevention of Significant Deterioration (PSD) of Air Quality in June 1978.
EPA revised the GAQM in 1986 and updated it with supplement A in 1987, supplement B in July 1993, and supplement C in August 1995. Additional modeling guidance for Pb SIPs was issued on July 8, 2011. These documents are the basis for the attainment
demonstration.3

- 2 

### 3.4 Modeling Approach

The following is an overview of the Sanders Lead modeling approach. This approach was developed by the URS Corporation on behalf of Sanders Lead and refined based on
comments received from ADEM and EPA

. The basic procedures are outlined as follows:

• Start with the most recent 2010 emissions estimates for point, area, vol ume and mobile sources at the Sanders Lead Company;

• Using the American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) modeling system ( v12060 ) , d evelop model inputs including:

o Using the AERMOD pre

- processors AERMET (v1105 9) and AERMINUTE (v11325) to process 2006

- 2010 1

- minute meteorological data (KMGM)

, based on ADEM land use classifications;

o Using the AERMOD pre

- processor AERMAP (v11103) to generate terrain inputs for the receptors, based on a digital elevation mapping (DEM) database from the National Elevation Dataset developed by the U.S. Geological Survey;

o Using the AERMOD pre

- processor AERSURFACE (v08009) to generate direction specific land use based surface c haracteristics for the modeling,
includ ing Surface Roughn ess, Monin

- Obukhov length, and Albedo;

o Define a Cartesian receptor grid across the NAA boundary (approximately 0.8 miles around the Sanders Lead facility), with 100 meter spacing in ambient air to ensure maximum concentrations are captured;

o Developing all other input options commensurate with the Regulatory Modeling Guidance;

• Perform current and post control dispersion modeling using the EPA approved AERMOD modeling system;

• Process AERMOD output through EPA’s LEADPOST post processor (v1 2114 )
deriv ing the ma ximum 3 month average rolling design value across the 5 year meteorological data period;

• Document the results in a report suitable for inclusion as an a ppendix for the Troy Pb SIP.4

- 1 

## 4 Emission s Data

4.1 Introduction

This chapter describes the data used to prepare the 20 10 b ase year and the 201 5 attainment year emission s inventor ies utilized in the attainment demonstration

. Table 4 .1.3

- 1 present s the e missions for the 201 0 base year and the 2015 attainment year, highlighting
the estimated emissions reductions that will contribute to attainment

. The development and submittal of the 2010 inventory is per the 172(c)(3) requirement of the Clean Air Act for the attainment SIP.

4.1.1 20 1 0 Base Year

Because lead is more source

- specific, the basis for the base year point inventory is the
actual 201 0 Pb emissions reported by Sanders Lead, as it is the only source of Pb emissions above 0.5 tpy within the NAA. These emissions were calculated by data collected through stack tests and the application of AP

- 42 emissions factors for each source and quality as sured by ADEM.
Area sources are only required to be submitted for the National Emissions Inventory (NEI) every three years, according to the Air Emissions Reporting Rule (AERR). The most recent public release of the NEI that includes area sources is the 2 008 NEI v.2. Area source emissions were obtained from the Emissions Inventory System (EIS) maintained by EPA.

Nonroad emissions

, w hich would normally be derived from the Nonroad Model

, are negligible and therefore assumed to be zero for the purpose of t his SIP

. This is supported by Pb not being included as a pollutant in the Nonroad 2008a model. Off

- road categories (air, rail and commercial marine vessel) were pulled from the 2008 NEI v.2 release. Airports are in the NEI as point sources, but are incl uded as nonroad in th is SIP. Aircraft, rail and
commercial marine vessel s are included in the NEI as nonpoint, but are included as
nonroad in th is SIP.

Onroad emissions of Pb are negligible and therefore assumed to be zero. This is supported by Pb not be ing included as a pollutant in the MOVES 2010b model and the 2008 NEI having no Pb emissions listed for the onroad source categories.

4.1.2 201 5 Future Year
Projected future year actual emissions for Sanders Lead were established for each existing stack and for each new stack. Following installation of all improvements necessary to comply with the recently revised Secondary Lead MACT (40 CFR 63, Subpart X), Sanders performed compliance tests on each existing stack to ensure the emissions were within the acceptable individual limits. The estimated actual 2015 emissions are based on these tests. For each new stack, a control efficiency for the installed controls was applied to the base year actual emissions that are now routed to that stac k. Due to the nature of the construction of the controls, reductions cannot be reflected stack to stack in most instances. The total reduction achieved through this control strategy is estimated to be 6

, 216 pounds
per year. The following discussion prov ides greater detail.CHAPTER 4 EMISSIONS DATA

4

- 2 The existing stacks include 1, 5, 4, 4a and 10. Each of these is subject to the Secondary Lead MACT (40 CFR 63, Subpart X) which restricts the individual allowable lead concentration for each stack. The following table summarizes the pre

- MACT limits and the post

- MACT limits. Sanders performed compliance tests on each of the existing stacks to ensure the individual allowable stack limits were being met. The future year estimated
emissions are based on these tests.

Table 4.1.2

- 1 Change in limits on existing stacks

Source ID Description pre

- MACT limit (lb/hr) MACT limit (lb/hr) Difference (lb/hr)

Stack 1 Blast Furnaces 1, 2 and Reverberatory Furnace 2.82 0.258 2.562

Stack 5 Blast Furnaces 3

, 4 and Alloying Kettles 3.00 0.258 2.742

Stack 4 Sanitary Baghouse for Furnaces 1 and 2 and Alloying Kettle Flue System 0.81 0.022 0.788

Stack 4a Sanitary Baghouse for Furnaces 3 and 4 and the Three (3) Dust Bins 0.81 0.022 0.788

Stack 10 Slag Treatment Building 0.115 0.023 0.092 Allowable Total (lb/hr) 7.555 0.583 6.972

Each of the volume sources and two of the haul roads, which were sources of fugitive emissions, are to be enclosed and the emissions routed to a new stack. The furnace and refining building operations (pre

- construction source D) is being enclosed and canopy hoods are being installed over each blast furnace . These emissions will then be routed through a cartridge

- style baghouse and HEPA filter (new Stack 11) at a 99.99% control efficiency.
The battery breaker/shredder operations building (pre

- construction source A) will be enclosed with emissions routed through a cartridge

- style baghouse and HEPA filter (new Stack 12) at a 99.99% control efficie ncy. Sanders is relocating the industrial battery decasing operation (pre

- construction source B) to the inside of the existing raw material storage building (pre

- construction source C). This building will be enclosed with emissions routed through a cart ridge

- style baghouse and HEPA filter (new Stack 13) at a 99.99% control efficiency.
Sanders is installing a building connection tunnel for the transport of materials from the shredder (pre

- construction source A) to the raw materials storage building (pre

- c onstruction source C). Half of the emissions from this tunnel will be routed to new Stack 12 and half to new Stack 13.
The alloying kettle s and the alloying kettle flue system, emissions from which went to both Stack 4 and Stack 5, will now be controlled by a cartridge

- style baghouse and HEPA filter (new Stack 14) at a 99.99% control efficiency.
The following table summarize s the emissions reductions achieved.4

- 3 Table 4.1.2

- 2 Summary of Reducti ons Achieved

Pre

Construction

Source ID Description Emissions (lbs/yr) Post

Construction

Source ID Description Emissions (lbs/yr) Reductions (lb s /yr)

Stack 1 Blast Furnaces 1, 2 and Reverberatory Furnace 3,241.20 Stack 1 Blast Furnaces 1, 2 and Agglomeration Furnace 411.72 2,829.48

Stack 5 Sanitary Baghouse for Furnaces 1 and 2 and Alloying Kettle Flue System 805.92 Stack 5 Blast Furnaces 3 and 4 227.76

963.59 New Stack 14 Alloying Kettles 0.01

Stack 4 Sanitary Baghouse for Furnaces 1 and 2 and Alloying Kettle Flue System 595.68 Stack 4 Sanitary Baghouse for Furnaces 1 and 2 210.24

Stack 4a Sanitary Baghouse for Furnaces 3 and 4 and the Three (3) Dust Bins 96.36 Stack 4a Sanitary Baghouse for Furnaces 3 and 4 61.32 35.04

Stack 10 Slag Treatment Building 227.76 Stack 10 35.04 192.72

Source D Furnace/Refining Building Operations 1,489.20 New Stack 11 Canopy Hoods 0.15 1,489.05

Source A Shredding and Separation Fugitive 237.12 New Stack 12 Breaker/Shredder Building 0.03 281.33 Haul Road 1 Material from breaker to main building 44.24

Source B De

- casing of Industrial Batteries 366.08

New Stack 13 Raw Material Storage 0.04 424.91 Source C Raw Material Storage Building Operations 10.51

Haul Road 1 Material from breaker to main building 44.24

Haul Road 3 Raw material (coke, limestone, scrap iron) to main building 4.12

Total Pre

- Control Emissions 7,162.43 Total Post

- Control Emissions 946.31
Total Emissions Reduction 6,216.12CHAPTER 4 EMISSIONS DATA

4

- 4 The new allowable limits for each stack (see Table 4.1.2

- 1 and Table 6.2

- 3) are a part of the Title V permit and, therefore, federally enforceable.
For area and nonroad emissions, emissions were assumed to remain level. No growth was applied.

4.1.3 Summaries of the 20 1 0 and 201 5 Emission Inventories in the Non a ttainment Area (NAA)
The following table summarize s the 20 1 0 base year as well as the projected 2015 attainment year emissions inventories. Emissions are presented in pounds per year.

Table 4.1.3

- 1 2010 and 2015 Pb Emissions for the Troy NAA (P ounds P er Y ear )

Year Onroad Nonroad Area Point

2010 0 205.94 0.56 7, 162

2015 0 205.94 0.56 946

Total Reduction 0 0 0 6,216



### 4.2 **Emissions Data for Model Simulations**

4.2.1 Processing of Source Emissions
Two sets of modeling analyses were completed for this SIP. The first represented a pre

control scenario at the Sanders Lead Company, and the latter represented the post

- control
scenario

, which forms the basis for the attainment modeling. Tables 4 .2.1

- 1 and 4 .2.1

- 2 contain the sources, respectively, that were modeled for the two scenarios. It should be noted that the pre

- const ruction modeling was performed to evaluate current impacts, and not to benchmark the modeling. It should also be noted that the pre

- construction modeling is based on actual emissions rates, while the post

- construction modeling is based on new
allowable emi ssion rates. AERMOD (v12060) is the approved model for this analysis and
ADEM relied on its status as an A ppendix A model in the GAQM as justification for its use.

Table 4.2.1

- 1 Pre

- Control Pb Emissions Sourc es and Emission Rates

Source ID Type Source Description Emission Rate (lb/hr)

Stack 1 Point Blast Furnaces 1, 2 and Reverberatory Furnace 0.37

Stack 5 Point Blast Furnaces 3, 4 and Alloying Kettles 0.092

Stack 4 Point Sanitary Baghouse for Furnaces 1 and 2 and Alloying Kettle Flue System 0.068

Stack 4a Point Sanitary Baghouse for Furnaces 3 and 4 and the Three (3) Dust Bins 0.011CHAPTER 4 EMISSIONS DATA

4

- 5 Source ID Type Source Description Emission Rate (lb/hr)

Stack 10 Point Slag Treatment Building 0.026

Haul Road 1 Volume Material from breaker to main building 0.010

Haul Road 2 Volume Material to Slag Treatment building 0.0014

Haul Road 3 Volume Raw material (coke, limestone, scrap iron) to main building 0.00047

Haul Road 4 Volume Delivery of raw coke, limestone and scrap iron 0.0029

Haul Road 5 Volume Delivery of batteries to Breaker 0.0052

Source A Volume Shredding and Separation Fugitive 0.057

Source B Volume De

- casing of Industrial Batteries 0.222

Source C Volume Raw Material Storage Building Operations 0.0012

Source D Volume Furnace/Refining Building Operations 0.17

Table 4.2.1

- 2 Post

- Control Pb Emissions Sources and Emission Rates

Source ID Type Source Description Emission Rate (lb/hr)

Stack 1 Point Blast Furnaces 1, 2 and Agglomeration Furnace 0.258

Stack 5 Point Blast Furnaces 3 and 4 0.258

Stack 4 Point Sanitary Baghouse for Furnaces 1 and 2 0.022

Stack 4a Point Sanitary Baghouse for Furnaces 3 and 4 0.022

Stack 10 Point Slag Treatment Building 0.023

New Stack 11 Point Canopy Hoods 0.191

New Stack 12 Point Breaker/Shredder Building 0.044

New Stack 13 Point Raw Material Storage 0.030

New Stack 14 Point Alloying Kettles 0.038

Haul Road 1 Volume Material from breaker to main building Enclosed

Haul Road 2 Volume Material to Slag Treatment building 0.0014CHAPTER 4 EMISSIONS DATA

4

- 6 Source ID Type Source Description Emission Rate (lb/hr)

Haul Road 3 Volume Raw material (coke, limestone, scrap iron) to main building Enclosed

Haul Road 4 Volume Delivery of raw coke, limestone and scrap iron 0.0029

Haul Road 5 Volume Delivery of batteries to Breaker 0.0052

Source A Volume Shredding and Separation Fugitive Enclosed

Source B Volume De

- casing of Industrial Batteries Enclosed

Source C Volume Raw Material Storage Building Operations Enclosed

Source D Volume Furnace/Refining Building Operations Enclosed

More specific information for each source can be found in Chapter 7 of this summary and in Appendix A.

4.2.1.1 Haul Road Emissions
Specific attention was paid to the quantification of haul road emissions at Sanders Lead. Specifically, the road s were characterized following EPA’s Haul Road Workgroup Final Report Submission , which incorporated several memorandum evaluating variations on modeling the impacts of haul roads. Five haul roads were modeled at the facility in the pre

control scenario and three haul roads were modeled in the post

- control scenario. The recommended Volume Source Confi guration used in the modeling included the following:

• Adjacent Volume Source

• Top of Plume Height

– 1.7 x VH (vehicle height)

• Volume Source Release Height

– 0.5 x Top of Plume he ight

• Width of Plume

– VW (vehicle width) + 6m for single lane roadways / Road Width + 6m for two lane roadways.

• Initial Sigma Z

– Top of Plume / 2.15

• Initial Sigma Y

– Width of Plume / 2.15

• Emissions input as g/s
Copies of the Haul Road Workgroup reports can be found in Appendix C of this document.5

- 1 

## 5 Model Performance Evaluation

5.1 AERMOD Model Performance

There are many aspects of model performance. In a traditional SIP, t his chapter w ould focus primarily on the methods and techniques recommended by EPA for evaluating the performance of the air quality modeling system. However, t his SIP differs in that there is a
sole contributor to the nonattainment prob lem in the area. The model used in the analysis,
the AERMOD modeling system (v 12060 )

, has undergone extensive and vigorous model performance and is a GAQM Appendix A model. As a result, no model performance analysis is needed to justify the use of this model. The EPA model performance analyses for the AERMOD modeling system can be found at http://www.epa.gov/ttn/scram/dispersion_prefrec.htm#aermod

.

5.1.1 Meteorology
Through the AERMET pre

- processor (v11059) , AERMOD is able to use data from a single surface site and a single upper air sounding site. The KMGM (Montgomery, Alabama)
surface site was used in combination with the KBMX ( Birmingham , Alabama) upper air sounding site in th is modeling. Given the nature of the terrain in the area and the dominance of upper air synoptic scale meteorological conditions, the two datasets w ere deemed representative of Troy, Alabama

. The data sets used in the AERMET meteorological processing incl uded: standard hourly surface data for the Montgomery A irport ’s Automated Surface Observation System (ASOS) site obtained in the Integrated Surface Hourly Data format (DSI

- 3505, ISHD), upper air data obtained from the Forecast System Laboratory (FSL) datab ase for the Birmingham A irport

, and archived 1

- minute ASOS wind data (format TD

- 6405) obtained from the National Climatic Data Center (NCDC) website for Montgomery (K MGM ) for the period 2006

- 2010. The final meteorological data set used in AERMOD modeling consisted of standard ISHD
data and 1

- minute ASOS observations for wind , processed through EPA’s AERMINUTE
pre

- processor (v11325) . Other parameters such as temperature, cloud cover, etc. were
based on the original ISHD values. Only wind speeds and directions were substituted. The hourly average data was derived from 1

- minute ASOS data. With the use of the 1

- minute ASOS observations, the number of calms in the original hourly dataset was reduced
dra matically, and even more so when the ice free sonic anemometer was installed in mid

2009. Similarly, the percentage of variable winds dropped using the 1

- minute data

. This is parti cularly important in that the modeling system is able to calculate concent rations under many more hours that would have been previously calculated, ensuring a more accurate characterization of dispersion

.6

- 1 

## 6 Control Strategy Development /RACT

6.1 Introduction/Overview

40 CFR 51 Subpart Z states that SIPs must include provisions for RACT/RACM and reasonable further progress (RFP) as necessary to demonstrate attainment. States must establish that all RACM have been adopted (including RACT for stationary sources)

necessar y to demonstrate attainment as expeditiously as practicable and to meet any RFP requirements. The SIP revision must contain the list of control measures considered by the State and the information and analysis sufficient to support the State's judgment th at all RACM, including RACT , ha ve been adopted . In determining whether specific control measures must be adopted as RACM, s tates must consider the cumulative impact of implementing the available measures. Potential measures that are reasona bly available considering technological and economic feasibility must be adopted as RACM if, considered collectively, they would advance the attainment date by one year or more. EPA defines RACT as the lowest emissions limitation that a particular source is capable of

m eeting by the application of a control technology that is reasonably available, considering technological and economic feasibility. EPA has determined that an approach to the RACT requirement in which RACT varies in different nonattainment areas based on reductions needed for attainment as expeditiously as practicable is appropriate for implementation of the Pb NAAQS. States are required to conduct a RACT analysis and to identify reasonably available controls for all affected stationary sources. Sanders Lead has been identified as the only source contributing to the NAAQS violation. The technolog ical feasibility of applying an emission reduction method to a particular source considers the source's process es, operating procedures, raw materials, and phys ical plant layout.
The proposed RACT measures will be implemented through a legally enforceable mechanism. Major source operating permits will be revised accordingly

. (The proposed Title V permits are located in Appendix F. ) The implementation of RACT by the Sanders Lead Company provides enforceable and permanent emissions reductions needed to attain and maintain the Pb NAAQS. The discussion of the control measures for attainment of the 2008 Pb NAAQS are presented below. A ll of the modifications to the facility described in this document will be completed by December 31, 2012

, with full implementation by July 2013

.



### 6.2 Statement of Basis for Sanders Lead RACT Controls

O n March 5, 2012, Sanders Lead submitted a plan to achieve NAAQS compliance (the plan was updated on Ju ly 17 , 2012). The plan included the following:
Enclosure and Control of Furnace Building

The emissions from the Blast Furnaces are controlled b y the Stack 1 Baghouse and the Stack 5 Baghouse. Emissions from furnace charging, slag taps, and lead taps are captured by sanitary hoods and controlled by Sanitary Baghouse Stack 4 and Sanitary Baghouse Stack 4a. Sanders Lead proposes to enclose the fur nace building and install canopy hoods over each blast furnace. The furnace building would be maintained at negative pressure and the emissions captured by the new canopy hoods would be controlled by a new cartridge

- type baghouse followed by HEPA filters (Stack 11).CHAPTER 6 CONTROL STRATEGY DEVELOPMENT/RACT

6

- 2 Enclosure and Control of Baghouse Hoppers
Sanders Lead proposes to control fugitive emissions from the baghouse hoppers and the transport of the baghouse dust by enclosing the base (including the access doors and removable panels) of Baghouses 1 & 5. The enclosures would be ventilated to the existing baghouses.
Enclosure and Control of Refining Operations
The emissions from the refining kettles are vented to Baghouse Stack 5 with the combustion gases vented to Sanitary Baghouse Stack 4. Sande rs Lead proposes to control emissions from the refining kettle with a new cartridge

- baghouse followed by HEPA filters (Stack 14). Additionally, the refining building would be enclosed and ventilated to the proposed Furnace Building Baghouse (Stack 11).

R elocate Industrial Battery Decasing and Enclose Raw Material Handling Operations
Emissions associated with the industrial battery decasing, raw material transport, and the Raw Material Handling Building are fugitive. Sanders Lead proposes to relocate the Industrial Battery Decasing Operation into the Raw Material Storage Building. The Raw Material Storage Building would be enclosed and ventilated to a proposed new baghouse followed by HEPA filters (Stack 13).
Enclosure and Control of Battery Breaking/Shre dder Operations
Emissions associated with the Battery Breaking and Shredder Building are considered fugitive. Sanders Lead proposes to enclose the Battery Breaking/Shredder Building and install a new wet scrubber to control acid emissions from specific po int locations within the Battery Breaking/Shredder Building. The Battery Breaking/Shredder Building and the exhaust from the wet scrubber would be ventilated to a proposed new baghouse followed by HEPA filters (Stack 12).
Process Material Transport

In ord er to control fugitive emissions from the transport of material, Sanders Lead proposes to install a building connection tunnel connecting the Battery Breaker/Shredder Building to the Raw Material Storage Building.
Vehicle Maintenance and Improved Watering Plan
To reduce fugitive emissions from leaded vehicles, Sanders Lead proposes to relocate leaded vehicle maintenance to a newly enclosed area and to install transfer points at the refining, smelting, and raw material storage building exits to contain lead ed vehicles within the buildings. Additionally, Sanders Lead proposes to develop and implement a new vehicle watering plan to include an improved floor wetting system and new wet sweepers.

On June 6, 2012, Air Permit Nos. 210

– 0005

- X021, X024, X025, and X029

– X033 were issued to Sanders Lead Company for additional proposed control measures to reduce lead
emissions. Proposed Title V permits reflecting RAC T controls are included in Appendix F.
A summary of the RACT controls can be found in Table 6.2

- 1 and the reductions achieved
are in Table 6.2

- 2.CHAPTER 6 CONTROL STRATEGY DEVELOPMENT/RACT

6

- 3 Table 6.2

- 1 Summary of RACT Controls

**Description of Measure Explanation** 

Control and Enclose Furnace Operations Sanders Lead is proposing to install canopy hoods over each blast furnace with supply air to reduce worker lead exposures. Additionally, the furnace building will be enclosed. A new 318,000 CFM baghouse followed by HEPA filters will be installed to control emissions captured by the new hoods and building enclosure (including the kettle basement ventilation).

Control and Enclose Refining Operations Sanders Lead is proposing to enclose the refining building, including the elimination of sidewall fans. Area ventilation will be provided by the new 318,000 CFM baghouse discussed above.

Combustion gases and Refining Kettle Hoods Sanders Lead is proposing to control the combustion gases and kettle hoods with a new 60,000 ACFM baghouse (with HEPAs).

Relocate Industrial Battery Decasing and Enclose Raw Material Handling Operations Sanders Lead is proposing to relocate the industrial battery decasing operations to the inside of the existing raw material storage building. A new 60,000 AC FM collector with HEPA filters will be installed to control industrial battery decasing and raw material storage area.

Battery Breaker/Shredder Operations Sanders Lead is proposing to enclose the S hredder B uilding and install a new 12,000 ACFM wet scrubber to control acid emissions from specific point locations within the Shredder Building. The exhaust from this scrubber along with building exhaust will be exhausted through a new 60,000 ACFM bag collector (with HEPAs).

Enclose Baghouse Hoppers and Transport of Dust Sanders Lead is proposing to enclose the base of baghouses #1 and #5, including the access doors and removable panels on the units. Ventilation will be provided by ducting to existing baghouses.

Improve Process Material Transport to Eli minate Leaded Outdoor Traffic In order to eliminate leaded outdoor traffic, Sanders Lead is proposing to install building connection tunnel for the transport of material from shredder to the raw material storage building.

Relocate and Contain Leaded Vehicle Maintenance Sanders Lead is proposing to install transfer points at the refining, smelting and raw material storage vehicle exits to maintain “leaded” vehicles inside the building. Sanders Lead is proposing to relocate leaded vehicle maintenance to a newly enclosed constructed area.

Improved Watering Sanders Lead is proposing to develop an updated watering plan based on the new vehicle patterns and facility layout. The watering plan will include an improved floor wetting system inside and outsid e the building, as well as purchasing new wet sweepers for the outside buildings.CHAPTER 6 CONTROL STRATEGY DEVELOPMENT/RACT

6

- 4 Table 6.2

- 2 Summary of Reductions Achieved

Pre

Construction

Source ID Description Emissions (lbs/yr) Post

Construction

Source ID Description Emissions (lbs/yr) Reductions (lb s /yr)

Stack 1 Blast Furnaces 1, 2 and Reverberatory Furnace 3,241.20 Stack 1 Blast Furnaces 1, 2 and Agglomeration Furnace 411.72 2,829.48

Stack 5 Sanitary Baghouse for Furnaces 1 and 2 and Alloying Kettle Flue System 805.92 Stack 5 Blast Furnaces 3 and 4 227.76

963.59 New Stack 14 Alloying Kettles 0.01

Stack 4 Sanitary Baghouse for Furnaces 1 and 2 and Alloying Kettle Flue System 595.68 Stack 4 Sanitary Baghouse for Furnaces 1 and 2 210.24

Stack 4a Sanitary Baghouse for Furnaces 3 and 4 and the Three (3) Dust Bins 96.36 Stack 4a Sanitary Baghouse for Furnaces 3 and 4 61.32 35.04

Stack 10 Slag Treatment Building 227.76 Stack 10 35.04 192.72

Source D Furnace/Refining Building Operations 1,489.20 New Stack 11 Canopy Hoods 0.15 1,489.05

Source A Shredding and Separation Fugitive 237.12 New Stack 12 Breaker/Shredder Building 0.03 281.33 Haul Road 1 Material from breaker to main building 44.24

Source B De

- casing of Industrial Batteries 366.08

New Stack 13 Raw Material Storage 0.04 424.91 Source C Raw Material Storage Building Operations 10.51

Haul Road 1 Material from breaker to main building 44.24

Haul Road 3 Raw material (coke, limestone, scrap iron) to main building 4.12

Total Pre

- Control Emissions 7,162.43 Total Post

- Control Emissions 946.31
Total Emissions Reduction 6,216.12CHAPTER 6 CONTROL STRATEGY DEVELOPMENT/RACT

6

- 5 Table 6.2

- 3 Pre

- and Post

- Control Emission Limits and Rates

Stack ID Old Allowables (lb/hr) Pre

Controls Modeled Actuals (lb/hr) Proposed
New Limit (lb/hr) Projected Actuals (lb/hr)

1 2.82 0.370 0.258 0.047

5 3.00 0.092 0.258 0.026

4 0.81 0.068 0.022 0.024

4a 0.81 0.011 0.022 0.007

10 0.115 0.026 0.023 0.004

11 NA NA 0.191 0.00002

12 NA NA 0.044 0.000003

13 NA NA 0.030 0.000005

14 NA NA 0.038 0.038
Total (lbs/hr) 7.56 0.567 0.886 0.145

Air d ispersion modeling was performed for the Sanders Lead Company to validate whether the proposed control strategies show compliance with the 2008 Pb NAAQS, which is satisfied when the maximum 3

- month rolling average over a 3

- year period is less than or equal to 0.15 μg/m 3

. Post

- control emission rates are shown in Table 6 .2

- 3

. The modeling platform used included the American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) modeling system (v12060) , including the AERMET ( v11059) , AERMA P ( v11103) , AERMINUTE ( v11325) and AERSURFACE ( v 08009) pre

- processors. AERMOD is a steady state Gaussian plume model and it employs many features that make it the preferred model of choice for this SIP, specifically that through final rulemaking (effectiv e December 9, 2005), the Agency established AERMOD as the preferred air dispersion model in its “Guideline on Air Quality Models.” (40 CFR 51, Appendix W), and in Pb guidance memorandum. Based on an advanced characterization of the atmospheric boundary la yer turbulence structure and scaling concepts, AERMOD is applicable to rural and urban areas, flat and complex terrain, surface and elevated releases, and multiple sources (including point, area, or volume sources). Modeling was done in accordance with th e Sanders Lead SIP Modeling Protocol submitted to ADEM and EPA Region 4 for comment and approval.

Sanders ’ modeling included the effects of buildings on stack plumes at the facility, and utilized two sets of surface characteristics in the modeling, retaining the most conservative
estimates. The model ing receptor grid for this analysis consisted of receptors s paced at
100 meter intervals located within the non

- attainment area, an area within Pike County with a radius of eight

- tenths of a mile from the Sanders Lead Company . The maximum predicted 3

- month rolling average concentrations were found within this grid . As such, no additional modeling was required to isolate the maximum concentrations. Figure 6.2

- 1 below depicts the receptor grid used in the modeling.CHAPTER 6 CONTROL STRATEGY DEVELOPMENT/RACT

6

- 6 Figure 6.2

- 1 Sanders Lead Modeling Receptor Grid

The output from the model was then input into EPA’s LEADPOST program (v12 114 ) , a FORTRAN program designed to read the monthly concentration output from the model, calculating the maximum rolling 3

- month average concentration for each receptor and the

overa ll maximum 3

- month average concentration. Output from the LEADPOST processor for this analysis can be found in Appendix G.
Due to the nature of this SIP, no additional sources beyond the Sanders Lead Company were considered in the analysis. Additionally, background concentrations are required to be added for comparison to the NAAQS to account for sources that are not explicitly modeled. For this analysis, ADEM provided URS/Sanders L ead with a background concentration of 0.009 μg/m 3 to be applied to all ma ximum rolling 3

- month averages. This concentration is based on an assessment of speciated PM 2.5 data from the Montgomery, Alabama

, ambient
air monitor #01

- 10 1

- 1002

- 88502

- 5 . A copy of the analysis performed by ADEM can be found in Appendix D of this docum ent.
The results of the modeling are summarized in Table 6

. 2

- 4 below. As can be seen, the
maximum 3

- month rolling average across all 5 years of meteorological data (2006

- 2010) is less than or equal to the 2008 Pb NAAQS of 0.15 μ g/m 3

. Output from the LEADPOSTCHAPTER 6 CONTROL STRATEGY DEVELOPMENT/RACT

6

- 7 processor (v1 2114 ) which details all of the concentrations can be found in Appendix G of
this document.

Table 6.2

- 4 Post

- Control Modeling Results

Sanders Lead Facility Impacts Max 3

- mt h Rolling Avg. Background Conc. Total Conc. NAAQS Maximum Year

Post

- Construction (NWS MET Data) 0.144 μg/m 3 0.009 μg/m 3 0.15 μg/m 3 0.15 μg/m 3 2010

Post

- Construction (Facility MET Data) 0.13 9 μg/m 3 0.009 μg/m 3 0.15 μg/m 3 0.15 μg/m 3 2010

a Final results listed in Table 6.2

- 4 are rounded according to 40CFR50, A ppendix R ; specifically 4(a) which addresses comparison with the Pb NAAQS, as well as 5(a),(b),and (c) which addresses rounding conventions.

The pre

- control analysis resulted in a predicted impact of 5.30 μg/m 3 (NWS MET data) and
3.6 4 μg/m 3 (Facility MET data). The post

- control analysis resulted in a predicted impact of 0.15 μg/m 3 (NWS MET data) and 0.15 μg/m 3 (Facility MET data). Therefore, the Depa rtment feels that the proposed controls are RACT /RACM and should be sufficient to attain the new air quality standard.7

- 1 

## 7 Reasonable Further Progress/Contingency Measures

7.1 Reasonable Further Progress

Section 172(c)( 2) the Federal Clean Air Act (CAA) requires areas that have been designated nonattainment for criteria pollutants must demonstrat e RFP in attainment demonstrations. RFP is defined in CAA §172(c)(2) as such annual incremental reductions
in emissions of the relevant air pollution as are required by part D, or may reasonably be required by the EPA for the purpose of ensuring attainment of the applicable NAAQS by the applicable attainment date.
As a result of an ambitious compliance schedule, yielding a signi ficant reduction in lead emissions from the facility and resulting in modeled attainment of the NAAQS

, this lead attainment demonstration for the 2008 Pb NAAQS fulfill s RFP for the Troy NAA

. As stated in the final L ead R ule (73 FR 67039), EPA concluded tha t it was appropriate that RFP be satisfied by the strict adherence to an ambitious compliance schedule

, which is expected to periodically yield significant emission reductions. The control measures for attainment of the 2008 Pb NAAQS included in Chapter 6 have been modeled to achieve attainment of the 2008 Pb NAAQS

. The stipulations require these control measures and resulting emissions reductions to be achieved as expeditiously as practicable.



### 7.2 Contingency Measures

Consistent with §172(c)(9) of the Act, the State must outline specific measures to be implemented should a nonattainment area fail to meet RFP requirements or a t tain the 2008
Pb NAAQS by the attainment date set by EPA. The contingency plan must be enforceable and should identify measures to be adopted, a schedule and procedure for adoption and implementation, and a specific time constraint on action to be taken by the S tate. Additionally, the plan should identify specific indicators or triggers that will be used to determine when the contingen cy measures are to be implemented.
Based on all the improvements that are planned for Sanders Lead ( Chapter 6 ), it is believed
that the new ambient air standard can be achieved on a consistent basis. However, if an exceedance of the NAAQS occurs during any three month period after July 2013 (full implementation of the control strategy) , Sanders Lead Company will , within 180 days,

s u b m i t an investigative study identifying the source (s) of excessive emissions contribut ing
to the e x c e e d a n c e so that a strateg y may be developed to eliminate the likelihood of

a nother exceedance. This strategy will contain a plan identifying which stack or stacks will
be raised and to what extent

. Within 18 months of the NAAQS violation, these measures
wi ll be fully implemented.
Potential controls which may provide some additional reductions include:
1) a ddin g a second gate on the south end of the property in order to direct significant
traffic flow to an area further away from the maximum lead impact areas ; 2) p lanting vegetation in specific areas to help control dust flow patterns and scavenge fugitive lead emissions ;CHAPTER 7 REASONABLE FURTHER PROGRESS/CONTINGENCY MEASURES

7

- 2 3) r e

- evaluate material handling procedures, patterns, etc

. , to determine if improvements can be made ; 4) r e

- evaluate housekeeping procedures, includin g dust sweeping and collection equipment ; 5) o ther improvements that may become evident based on potential source (s) of lead emissions identified during investigation.8

- 1 

## 8 Model Attainment Demonstration

8.1 Purpose of an Attainment Demonstration

An attainment demonstration consists of (a) analyses that estimate whether selected
emissions reductions will result in ambient conce ntrations that meet the NAAQS, and (b) an identified set of control measures which will result in the required emissions reductions

. The necessary emission reductions for both of these attainment demonstration components may be determined by relying on re sults obtained from air quality models. EPA’s Modeling Guidance for Pb recommends the use of the AERMOD modeling system to show compliance with the Pb NAAQS. While not explicit in the guidance, a weight of evidence analysis could be included to supplement the control strategy to further support attainment of the NAAQS.

8.1.1 Procedure for Demonstrating Attainment
The purpose of a modeling assessment for this SIP is to determine if proposed control strategies will lead to attainment of the NAAQS for Pb by 2015

. The AERMOD modeling system ( v 12060 ) was applied using EPA recommended defaults, building downwash,
terrain data and 1

- minute meteorological d ata for 2006

- 2010

. The components of the control strategy can be found in Chapter 6 of this document. The results of the p roposed control scenario projects attainment of the NAAQS, as can be seen in the table below.

Table 8.1.1

- 1 Model Results

Sanders Lead Facility Impacts Max 3

- mth Rolling Avg. Background Conc. Total Conc. NAAQS Max Year

Post

- Construction
(NWS MET Data) 0.144 μg/m 3 0.009 μg/m 3 0.15 μg/m 3 0.15 μg/m 3 2010

Post

- Construction
(Facility MET Data) 0.13 9 μg/m 3 0.009 μg/m 3 0.15 μg/m 3 0.15 μg/m 3 2010

8.1.2 Attainment Year

On December 31, 2010 , EPA designated a portion of Pike County as nonattainment of the

r evised 2008 Pb NAAQS

. The nonattainment designation triggered the requirement for the development of a SIP. EPA requires that P b SIPs include attainment demonstrations using, at least in part, modeling analyses to define effective emissions control strategies and to confirm that attainment can be achieved after implementation of the strategies. The CAA
attainment date for th is d emonstration is December 31, 2015

.8

- 1 

### 8.2 Supporting Weight of Evidence Analysis

Traditionally, a ttainment m odeling g uidance asserts that all attainmen t demonstrations should be accompanied by supplemental analyses that further support the modeling
conclusions. These supplemental analys es can include additional analysis of air quality, emissions and meteorological data, and consider modeling outputs oth er than the results of the attainment test. If the attainment test results fall short of the standard, the results of corroboratory analyses may be used in a weight of evidence determination (WOE) to show that attainment is likely, despite modeled results which may be inconclusive . However, in the case of Pb, compliance is demonstrated when the model output produces a maximum
3

- month rolling average of less than 0.15 μ g/m 3 over a 3

- year period. No additional analyses are needed to ensure compliance, and contingency measures are incorporated into the plan in the event that monitoring data does not demonstrate attainment.

For this demonstration , two controls are being installed that were not included in the modeling. The measures include the i nstall ation of HEPA filters on both sanitary baghouse systems (Stacks 4 and 4a) and the slag treatment building (Stack 10) . While these measures were not modeled, air quality improvements will surely occur as a result of these controls. These measures do represent a supplemental analysis that

, while not quantifiable per se, will surely support attainment of the Pb NAAQS.



### 8.3 Proposed Control Strategy
The AERMOD modeling system (v12060) was used in this attainment demonstration to show compliance wi th the Pb NAAQS for the Troy NAA. Control strategies were developed based on RACT/RACM analyses for the Sanders Lead facility. As such, it is ADEM’s contention, based on these controls, that 2015 represents attainment as expeditiously as is practicable f or the Troy Pb NAA. Some of the RACT controls have already been implemented, while others are preparing to be implemented.

Further, i n order to include the selected RACT/RACM controls in the SIP

, the controls for each facility must be contained in a fede rally enforceable permit. Concurrent with this SIP submittal, ADEM is renewing Sanders Lead’s Title V Permit

, including the proposed RACT
controls ( see Appendix F )

. T able 8 .3

- 1 summarizes the agreed upon controls for Sanders
Lead

.CHAPTER 8 MODEL ATTAINMENT DEMONSTRATION

8

- 2 Table 8.3

- 1 Summary of RACT Controls

**Description of Measure Explanation** 

Control and Enclose Furnace Operations Sanders Lead is proposing to install canopy hoods over each blast furnace with supply air to reduce worker lead exposures. Additionally, the furnace building will be enclosed. A new 318,000 CFM baghouse followed by HEPA filters will be installed to contr ol emissions captured by the new hoods and building enclosure (including the kettle basement ventilation).

Control and Enclose Refining Operations Sanders Lead is proposing to enclose the refining building, including the elimination of sidewall fans. Ar ea ventilation will be provided by the new 318,000 CFM baghouse discussed above.

Combustion gases and Refining Kettle Hoods Sanders Lead is proposing to control the combustion gases and kettle hoods with a new 60,000 ACFM baghouse (with HEPAs).

Relocate Industrial Battery Decasing and Enclose Raw Material Handling Operations Sanders Lead is proposing to relocate the industrial battery decasing operations to the inside of the existing raw material storage building. A new 60,000 ACFM collector wi th HEPA filters will be installed to control industrial battery decasing and raw material storage area.

Battery Breaker/Shredder Operations Sanders Lead is proposing to enclose the S hredder B uilding and install a new 12,000 ACFM wet scrubber to control acid emissions from specific point locations within the Shredder Building. The exhaust from this scrubber along with building exhaust will be exhausted through a new 60,000 ACFM bag collector (with HEPAs).

Enclose Baghouse Hoppers and Transport of Dust S anders Lead is proposing to enclose the base of baghouses #1 and #5, including the access doors and removable panels on the units. Ventilation will be provided by ducting to existing baghouses.

Improve Process Material Transport to Eliminate Leaded Outdoor Traffic In order to eliminate leaded outdoor traffic, Sanders Lead is proposing to install building connection tunnel for the transport of material from shredder to the raw material storage building.

Relocate and Contain Leaded Vehicle Maintenan ce Sanders Lead is proposing to install transfer points at the refining, smelting and raw material storage vehicle exits to maintain “leaded” vehicles inside the building. Sanders Lead is proposing to relocate leaded vehicle maintenance to a newly enclose d constructed area.

Improved Watering Sanders Lead is proposing to develop an updated watering plan based on the new vehicle patterns and facility layout. The watering plan will include an improved floor wetting system inside and outside the building, as well as purchasing new wet sweepers for the outside buildings.

The Title V permits can be found in Appendix F and are incorporated into this attainment demonstration SIP.9

- 1 

## 9 Data Access

The modeling input

, output and post files for the Sanders Lead attainment demonstration are reasonably large ; therefore they are not being submitted with the attainment
demonstration. Summaries of the LEADPOST output can be found in Appendix G. To request a copy of any additional files, please contact the ADEM Air Division

.10

- 1 

## 10 Quality Assurance/Quality Control

10.1 Quality Assurance Objectives
In December 2002, EPA published extensive guidance on developing a Quality Assurance Project Plan (QAPP) for modeling studies. The objective of a QAPP is to ensure that a modeling study is scientifically sound, robust, and defensible. The guidance sugges ted that a QAPP should include the following elements:

• A systematic planning process including identification of assessments and related performance criteria;

• Peer

- reviewed theory and equations;

• A carefully designed life

- cycle development process that mini mizes errors;

• Clear documentation of assumptions, theory, and parameterization that is detailed enough so others can fully understand the model output;

• Input data and parameters that are accurate and appropriate for the problem;

• O utput data that can be use d to help inform decision making; and

• Documentation of any changes from the original quality assurance plan.
Moreover, the guidance specifies that different levels of the QAPP may be required depending on the intended application of the model, with a model ing study designed for regulatory purposes requiring the highest level of quality assurance. The QAPP also provides a valuable resource for project management. It can be used to document data sources and assumptions used in the modeling study, and it can be used to guide project personnel through the data processing and model application process to ensure that choices are consistent with the project objectives.



### 10.2 Emissions Inputs and Outputs
Emissions quality assurance (QA) and quality control (QC) are th e most critical steps in performing air quality modeling studies. The goal of emissions QA/QC is to detect possible errors in the final, model

- ready emissions inputs. Since this is a sole source SIP, the QA/QC needed only to focus on the Sanders Lead Fac ility. To establish base year and proposed control strategy modeling, pre

- construction and post

- construction permit
emissions limits were modeled.



### 10.3 Meteorological I n puts
As specified in more detail in Chapter 5 of this document, the meteorological data use d in
this attainment demonstration included data from the Montgomery, Alabama, National Weather Service surface site (MGM) WBAN# 13895 and the Birmingham, Alabama

, upper air site (BMX) WBAN# 53823. ADEM processed these data for the years 2006

- 2010 using the AERMOD pre

- processor s AERMET (v11059) and AERMINUTE (v11325)

.CHAPTER 10 QUALITY ASSURANCE/QUALITY CONTROL

10

- 2 

### 10.4 Air Quality Model Inputs and Outputs

Key aspects of QA for the AERMOD input and output data included the following:

• v erification tha t correct configuration and science options w ere used in compiling and running the AERMOD modeling system ;

• v erification that correct input data sets were used when running the model;

• e valuation of the results to verify that model output was reasonable and consistent with general expectations;

• b ackup and archival of critical model input and output data.
The most critical element in the QA plan is the QA/QC of the meteorological and emissions input files (as described above). The major QA issue specifically associated with the air quality model simulations is verification that the correct science options were specified in the model itself and that the correct input files were used when running the model.11

- 1 

## 11 Conclusions

The Troy Pb NAA is comprised of a small area with a radius of 0.8 miles around the Sanders Lead Company in Troy, Alabama. While monitoring data from the ADEM Lead Monitor AIRS # 01

- 109

- 0003 showed compliance with the 1978 Pb NAAQS, the data does not comply with the revised 2008 Pb NAAQS. As a result, EPA designated the area as nonattainment for the Lead NAAQS , effective December 31, 2010.
Through the development of this attainment demonstra tion, ADEM has complied with all
EPA guidance and requirements for demonstrating attainment of the Pb NAAQS i n the
current Troy NAA

. Air quality modeling supports this conclusion. The model results are based upon emissions reductions from sources at Sand ers Lead. ADEM expect s the Troy
area to attain the P b NAAQS based upon implementation of a combination of controls, all of
which were addressed in this document.