i

EXECUTIVE SUMMARY 

The Nonattainment Area (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 exceeded the 0.15 μg/m3 NAAQS. The Environmental Protection 

Agency (EPA) designated the area as nonattainment for the Pb NAAQS, effective 

December 31, 2010.

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 NAA

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. The 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 Guidance 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 Base 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........................................................................................ 7-1
iii

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 Supporting Weight of Evidence Analysis ............................................................. 8-1

8.3 Proposed Control Strategy .................................................................................. 8-1

9 Data Access .............................................................................................................. 9-1

10 Quality Assurance/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...........................................................................................................11-1
iv

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

Table 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/m3

)*.......................................... 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 Output
1-1

1 Introduction

1.1 Purpose and Organization of Document

This document is an attainment demonstration for the Troy NAA for the 2008 Pb NAAQS. 

The Troy NAA, located in southern Alabama, is comprised of an area within Pike County 

with a radius of eight-tenths 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 NAA. The analysis results 

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 2012, with full implementation by July 2013. Attainment of the 2008 lead NAAQS is 

projected to be achieved by December 31, 2015.

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 conclusions which support this attainment demonstration are provided in the 

following chapters:

Chapter 2: Conceptual Description of the Troy Lead Non Attainment Area

Chapter 3: Attainment Demonstration Methods and Inputs

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 10: QA/QC 

Chapter 11: Conclusions

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: primary standards set limits to protect public health, 

including the health of "sensitive" populations such as asthmatics, children, and the elderly

and secondary standards set limits to protect public welfare, including 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 μg/m3

. Pb 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 μg/m3

.

1.3 History of Alabama LeadNonattainment 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 μg/m3

. 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 μg/m3 to 0.15 μg/m3 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). On October 

1, 2009, the state of Alabama submitted designation recommendations. The State 

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 State’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 state provide for the establishment 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 2005-2011 time period for the ADEM monitor. Figure 1.4-2 below 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/m3)

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/m3)*

As can be seen in the Table 1.4-1 above, Sanders met the 1978 lead standard in each 

recent design value year.

1.5 Clean Air Act (CAA) Requirements

Section 172(c), as amended, of the CAA, and the 2008 Lead (Pb) National Ambient Air 

Quality Standards (NAAQS) Implementation Questions and Answers document, released 

July 8, 2011, contain the requirements and guidance for states developing a federally

enforceable State SIP for Pb NAAs. The SIP documents how an area will attain the NAAQS 

and generally contains 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 2009-2011
2-1

2 Conceptual Description of the Troy 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. 

As 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 State 

Implementation Plan (SIP), 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 no 
CHAPTER 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 the 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 the area made up of trees and 

vegetation.

Figure 2.1-2 Sanders Lead Plant Boundaries and Monitor Locations
CHAPTER 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 colocated 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 monitor 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 Type 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/m3. 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/m3*

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

3-1

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 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. 

Consequently, the State of Alabama is required to submit a Pb SIP to EPA that includes a 

control plan and a demonstration that the area will attain the Pb NAAQS. The CAA

attainment date for this demonstration is December 31, 2015.

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 Corporation, 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 was 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 regulations, 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 entitled “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 

demonstration. 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 

regulations 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, volume and 

mobile sources at the Sanders Lead Company;

• Using the American Meteorological Society/Environmental Protection Agency 

Regulatory Model (AERMOD) modeling system (v12060), develop model inputs 

including: 

o Using the AERMOD pre-processors AERMET (v11059) 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 characteristics for the modeling, 

including Surface Roughness, 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 (v12114) 

deriving the maximum 3 month average rolling design value across the 5 year 

meteorological data period;

• Document the results in a report suitable for inclusion as an appendix for the Troy 

Pb SIP.
4-1

4 Emissions Data

4.1 Introduction

This chapter describes the data used to prepare the 2010 base year and the 2015

attainment year emissions inventories utilized in the attainment demonstration. Table 4.1.3-

1 presents the emissions for the 2010 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 2010 Base Year

Because lead is more source-specific, the basis for the base year point inventory is the 

actual 2010 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 assured 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 2008 NEI v.2. Area source 

emissions were obtained from the Emissions Inventory System (EIS) maintained by EPA. 

Nonroad emissions, which would normally be derived from the Nonroad Model, are 

negligible and therefore assumed to be zero for the purpose of this 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 included as nonroad in this SIP. Aircraft, rail and 

commercial marine vessels are included in the NEI as nonpoint, but are included as 

nonroad in this SIP.

Onroad emissions of Pb are negligible and therefore assumed to be zero. This is 

supported by Pb not being 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 2015 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 stack. 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 provides 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 efficiency. 

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 cartridge-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-construction 

source C). Half of the emissions from this tunnel will be routed to new Stack 12 and half to 

new Stack 13.

The alloying kettles 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 summarizes the emissions reductions achieved.
4-3

Table 4.1.2-2 Summary of Reductions Achieved

PreConstruction 

Source ID

Description Emissions 

(lbs/yr)

PostConstruction 

Source ID

Description Emissions 

(lbs/yr)

Reductions 

(lbs/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 6,216.12
CHAPTER 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 2010 and 2015 Emission Inventories in the Nonattainment Area

(NAA)

The following table summarizes the 2010 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 (Pounds Per Year)

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 precontrol 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-construction 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 emission rates. AERMOD (v12060) is the approved model for this analysis and 

ADEM relied on its status as an Appendix A model in the GAQM as justification for its use.

Table 4.2.1-1 Pre-Control Pb Emissions Sources 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 0.011
CHAPTER 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 0.0014
CHAPTER 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 roads 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 precontrol scenario and three haul roads were modeled in the post-control scenario. The 

recommended Volume Source Configuration 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 height

• 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, this chapter would

focus primarily on the methods and techniques recommended by EPA for evaluating the 

performance of the air quality modeling system. However, this SIP differs in that there is a 

sole contributor to the nonattainment problem in the area. The model used in the analysis, 

the AERMOD modeling system (v12060), 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 this modeling. Given the nature of the terrain in the area and the 

dominance of upper air synoptic scale meteorological conditions, the two datasets were

deemed representative of Troy, Alabama.

The data sets used in the AERMET meteorological processing included: standard hourly 

surface data for the Montgomery Airport’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) database for the Birmingham Airport, 

and archived 1-minute ASOS wind data (format TD-6405) obtained from the National 

Climatic Data Center (NCDC) website for Montgomery (KMGM) 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 

dramatically, and even more so when the ice free sonic anemometer was installed in mid2009. Similarly, the percentage of variable winds dropped using the 1-minute data. This is 

particularly important in that the modeling system is able to calculate concentrations 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) 

necessary 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 that all 

RACM, including RACT, have been adopted. In determining whether specific control 

measures must be adopted as RACM, states must consider the cumulative impact of 

implementing the available measures. Potential measures that are reasonably 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 

meeting 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 technological feasibility of applying an 

emission reduction method to a particular source considers the source's processes,

operating procedures, raw materials, and physical 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. All 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

On March 5, 2012, Sanders Lead submitted a plan to achieve NAAQS compliance (the plan 

was updated on July 17, 2012). The plan included the following:

Enclosure and Control of Furnace Building

The emissions from the Blast Furnaces are controlled by 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 furnace 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. Sanders 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). 

Relocate 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/Shredder 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 point 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 order 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 leaded 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 RACT 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 ACFM 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 Shredder Building 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 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 

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 

outside 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

PreConstruction 

Source ID

Description Emissions 

(lbs/yr)

PostConstruction 

Source ID

Description Emissions 

(lbs/yr)

Reductions 

(lbs/yr)

Stack 1 Blast Furnaces 1, 2 and 

Reverberatory Furnace 3,241.20 Stack 1 Blast Furnaces 1, 2 andAgglomeration 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 6,216.12
CHAPTER 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)

PreControls 

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 dispersion 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/m3

. 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), AERMAP (v11103), AERMINUTE (v11325) and AERSURFACE 

(v08009) 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 (effective 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 layer 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 the 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 modeling receptor grid for this analysis consisted of receptors spaced 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 (v12114), 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 

overall 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 Lead with a background concentration of 

0.009 μg/m3 to be applied to all maximum rolling 3-month averages. This concentration is 

based on an assessment of speciated PM2.5 data from the Montgomery, Alabama, ambient 

air monitor #01-101-1002-88502-5. A copy of the analysis performed by ADEM can be 

found in Appendix D of this document.

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 μg/m3

. Output from the LEADPOST 
CHAPTER 6 CONTROL STRATEGY DEVELOPMENT/RACT

6-7

processor (v12114) 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-mth 

Rolling Avg.

Background

Conc.

Total

Conc. NAAQS Maximum Year

Post-Construction

(NWS MET Data) 0.144 μg/m3 0.009 μg/m3 0.15 μg/m3 0.15 μg/m3 2010

Post-Construction

(Facility MET 

Data)

0.139 μg/m3 0.009 μg/m3 0.15 μg/m3 0.15 μg/m3 2010

a Final results listed in Table 6.2-4 are rounded according to 40CFR50, Appendix 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/m3 (NWS MET data) and 

3.64 μg/m3 (Facility MET data). The post-control analysis resulted in a predicted impact of 

0.15 μg/m3 (NWS MET data) and 0.15 μg/m3 (Facility MET data). Therefore, the 

Department 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 demonstrate 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 significant reduction in lead 

emissions from the facility and resulting in modeled attainment of the NAAQS, this lead 

attainment demonstration for the 2008 Pb NAAQS fulfills RFP for the Troy NAA.

As stated in the final Lead Rule (73 FR 67039), EPA concluded that 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 attain 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 State. 

Additionally, the plan should identify specific indicators or triggers that will be used to 

determine when the contingency 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,

submit an investigative study identifying the source(s) of excessive emissions contributing

to the exceedance so that a strategy may be developed to eliminate the likelihood of 

another 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 

will be fully implemented.

Potential controls which may provide some additional reductions include:

1) adding 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) planting 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) re-evaluate material handling procedures, patterns, etc., to determine if 

improvements can be made;

4) re-evaluate housekeeping procedures, including dust sweeping and collection 

equipment;

5) other 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 concentrations 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 results 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 (v12060) was applied using EPA recommended defaults, building downwash, 

terrain data and 1-minute meteorological data for 2006-2010. The components of the 

control strategy can be found in Chapter 6 of this document. The results of the proposed

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/m3 0.009 μg/m3 0.15 μg/m3 0.15 μg/m3 2010

Post-Construction

(Facility MET Data)

0.139 μg/m3 0.009 μg/m3 0.15 μg/m3 0.15 μg/m3 2010

8.1.2 Attainment Year

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

revised 2008 Pb NAAQS. The nonattainment designation triggered the requirement for the 

development of a SIP. EPA requires that Pb 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 this demonstration is December 31, 2015. 

8-1

8.2 Supporting Weight of Evidence Analysis

Traditionally, attainment modeling guidance asserts that all attainment demonstrations 

should be accompanied by supplemental analyses that further support the modeling 

conclusions. These supplemental analyses can include additional analysis of air quality, 

emissions and meteorological data, and consider modeling outputs other 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 μg/m3 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 installation 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 with 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 for the Troy Pb NAA. Some of the RACT controls have already been 

implemented, while others are preparing to be implemented.

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

each facility must be contained in a federally enforceable permit. Concurrent with this SIP 

submittal, ADEM is renewing Sanders Lead’s Title V Permit, including the proposed RACT 

controls (see Appendix F). Table 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 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 ACFM 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 Shredder Building 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 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 

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 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

10Quality 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 suggested 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 minimizes 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;

• Output data that can be used 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 modeling 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 the 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 Facility. To establish base year and 

proposed control strategy modeling, pre-construction and post-construction permit 

emissions limits were modeled.

10.3 Meteorological Inputs

As specified in more detail in Chapter 5 of this document, the meteorological data used 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-processors 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:

• verification that correct configuration and science options were used in compiling and 

running the AERMOD modeling system;

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

• evaluation of the results to verify that model output was reasonable and consistent with 

general expectations;

• backup 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

11Conclusions

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 demonstration, ADEM has complied with all 

EPA guidance and requirements for demonstrating attainment of the Pb NAAQS in the

current Troy NAA. Air quality modeling supports this conclusion. The model results are 

based upon emissions reductions from sources at Sanders Lead. ADEM expects the Troy

area to attain the Pb NAAQS based upon implementation of a combination of controls, all of 

which were addressed in this document.