State of California 

AIR RESOURCES BOARD 

 

Proposed 

State Implementation Plan Revision 

for the Federal Lead Standard 

 Release Date: May 11, 2012 

 Hearing Date: May 24, 2012 

California Environmental Protection Agency 

Air Resources Board 
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i 

TABLE OF CONTENTS 

 Page 

OVERVIEW ................................................................................................................. 1 

INTRODUCTION ......................................................................................................... 1 

LOS ANGELES COUNTY LEAD SIP .......................................................................... 2 

 Introduction ............................................................................................................ 2 

 Air Quality .............................................................................................................. 2 

 Emissions .............................................................................................................. 3 

 Attainment Demonstration ..................................................................................... 3 

 New Source Review ............................................................................................... 4 

 Reasonably Available Control Technology and 

 Reasonably Available Control Measure ............................................................ 5 

 Enhanced Monitoring ............................................................................................. 6 

 Reasonable Further Progress ................................................................................ 6 

 Contingency Measures .......................................................................................... 7 

SUMMARY .................................................................................................................. 8 

 

APPENDIX A: FINAL – 2012 LEAD STATE IMPLEMENTATION PLAN 

LOS ANGELES COUNTY
ii 

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-1- 

Proposed State Implementation Plan Revision 

for the Federal Lead Standard 

 

 

OVERVIEW 

The purpose of this report is to summarize a proposed revision to the California 

State Implementation Plan (SIP) that provides for attaining the National Ambient 

Air Quality Standard for lead (federal lead standard) in Los Angeles County. 

The revision is required under the federal Clean Air Act (CAA). The South Coast 

Air Quality Management District (South Coast District) Governing Board adopted 

the Lead SIP at a public hearing on May 4, 2012, following a 30-day public notice 

period that included a public workshop. The Air Resources Board (ARB) is 

responsible for submitting the Lead SIP to U.S. EPA by June 30, 2012. The 

following sections provide background information on the federal lead standard 

and a summary of the South Coast District Lead SIP. The complete Lead SIP is 

provided as Appendix A: Final – 2012 Lead State Implementation Plan 

Los Angeles County. 

INTRODUCTION 

The CAA requires the United States Environmental Protection Agency 

(U.S. EPA) to establish National Ambient Air Quality Standards for criteria 

pollutants. U.S. EPA first set a federal lead standard in 1978, at a level of 

1.5 μg/m3

. Since then, the scientific evidence related to the health and 

environmental impacts of lead has expanded dramatically and shows that 

adverse impacts occur at much lower levels. Based on this new evidence, 

U.S. EPA revised the federal lead standard on October 15, 2008, lowering it to 

a level of 0.15 μg/m3

 (a 90 percent reduction). The standard is violated when 

lead concentrations, averaged over a rolling three-month period, exceed 

0.15 μg/m3

. 

When U.S. EPA revises a federal standard, the agency designates areas with 

ambient concentrations that violate the standard as nonattainment. The 

Los Angeles County portion of the South Coast Air Basin, excluding 

San Clemente and Santa Catalina islands (hereafter referred to as Los Angeles 

County), is the only area in California that violates the federal lead standard, and 

U.S. EPA designated this area as nonattainment on December 31, 2010. Under 

the CAA, a lead nonattainment area must develop a plan that outlines a strategy 

for attaining the federal lead standard. The plan must demonstrate attainment 

by the December 31, 2015, statutory deadline and constitutes a revision to the 

statewide SIP. 

 

In contrast to other air pollutants, such as ozone and particulate matter, which 

impact a large regional area, the impact of lead emissions is very localized. In 
-2- 

fact, lead concentrations throughout California, including concentrations 

throughout most of Los Angeles County, are far below the level of the federal 

standard. However, violations of the federal lead standard occasionally occur in 

the area immediately surrounding two large lead-acid battery recycling facilities, 

based on near-source monitoring. The South Coast District has identified 

emissions from these facilities as the sole contributor to lead violations in 

Los Angeles. 

The South Coast District developed a Lead SIP that demonstrates attainment of 

the federal lead standard around these facilities by December 31, 2015. While 

the attainment strategy is focused on the facilities that contribute to violations of 

the federal lead standard, it also considers lead emissions from other facilities in 

the region. Following a 30-day public notice period that included a public 

workshop, the South Coast District Governing Board adopted the Lead SIP at a 

public hearing on May 4, 2012. The South Coast District then forwarded the 

Lead SIP to the Air Resources Board (ARB), the agency responsible for 

submitting SIP revisions to U.S. EPA. 

LOS ANGELES COUNTY LEAD SIP 

Introduction 

The Lead SIP must meet a number of specific requirements, as set forth in 

CAA section 172(c). These requirements include the development of an 

emissions inventory, completion of an attainment demonstration, implementation 

of a permitting program, implementation of all reasonably available control 

technologies and control measures, a demonstration of progress towards 

attainment, and provision for implementing contingency measures. The following 

sections provide a brief summary of the various elements of the Lead SIP, as 

they relate to the requirements established in the CAA. Full details are found in 

Appendix A. 

Air Quality 

Over the past four decades, lead air quality throughout California has improved 

dramatically, primarily because of State and federal regulations that phased-out 

the use of lead as an anti-knock agent in gasoline for motor vehicles. Although 

lead has been virtually eliminated from motor vehicle fuel, it is still used as an 

additive in general aviation gasoline, which is used in general aviation aircraft 

with piston engines. The South Coast District has collected ambient lead data in 

Los Angeles County since 1975 via its regional monitoring network. The South 

Coast District has also monitored ambient lead concentrations near general 

aviation airports – specifically, near Van Nuys Airport, which is California’s 

largest airport in terms of lead emissions. Monthly average lead concentrations 

at all of these sites show dramatic reductions – from concentrations as high as 
-3- 

7.49 μg/m3

 in 1976, to the current levels of 0.04 μg/m3 or less, far below the level 

of the revised standard. 

In contrast to these monitors, a network of near-source monitors surrounding 

specific lead-related facilities occasionally records violations of the federal lead 

standard. These violations are limited spatially, because lead particles are 

relatively heavy, and therefore, concentrations decrease rapidly with distance 

from the source. The current violations of the federal lead standard are 

attributable to emissions from two large lead-acid battery recycling facilities, one 

located in Vernon and the other in the City of Industry. The South Coast District 

has been proactive in adopting and implementing rules to address these 

violations. As a result, lead concentrations have decreased and have been 

below the level of the federal lead standard since December 2011. 

 

Emissions 

Similar to the rest of the nation, lead emissions in Los Angeles County have 

declined dramatically over the last four decades. This reduction in emissions is 

reflected in the decrease in ambient lead concentrations at population-oriented 

monitors. As discussed in the previous section, the current lead violations In 

Los Angeles County are the result of emissions from two large lead-acid battery 

recycling facilities. These two facilities have been identified as the only sources 

contributing to violations in the area. 

These large lead-acid battery recycling facilities are broadly categorized as 

secondary lead smelters. U.S. EPA has determined that secondary lead 

smelters are some of the largest stationary source lead emitters in the United 

States. Overall, there are 15 facilities in the nation, including the two facilities in 

Los Angeles County. The recycling process consists of sorting, crushing, and 

melting lead-acid batteries and other lead-bearing materials to recover the lead. 

As a result of these activities, lead can be directly emitted through a stack or 

control device, or it can settle as dust that can then be dispersed into the air. 

The CAA requires the SIP to include a current inventory of emissions affecting 

ambient lead concentrations, including an inventory of emissions from all sources 

in the nonattainment area that emit more than 0.5 tons of lead per year. The 

South Coast District compiled a comprehensive lead emissions inventory for 

2010 (base year) and for 2015 (future year). The mandated attainment year is 

2015, and the 2015 inventory reflects projected emissions based on growth 

factors and compliance requirements between 2010 and 2015. 

Attainment Demonstration 

The main purpose of the Lead SIP is to demonstrate attainment of the federal 

lead standard by the December 31, 2015, statutory deadline. To address lead 
-4- 

emissions from the large lead-acid battery recycling facilities in Los Angeles 

County, the South Coast District adopted Rule 1420.1– Emissions Standard for 

Lead from Large Lead-Acid Battery Recycling Facilities in November 2010. 

Rule 1420.1 limits lead emissions from stacks, requires total enclosures of dust, 

and contains stringent housekeeping requirements. In combination with these 

emission controls is a requirement for frequent monitoring of lead levels around 

the recycling facilities. This strategy, based on emission controls, in tandem with 

air quality monitoring, should be more effective in attaining the federal lead 

standard than the traditional approach based on emission reductions, alone. 

To assess the effectiveness of the control strategy, the South Coast District 

completed an attainment demonstration based on atmospheric dispersion 

modeling. The modeling analysis used the AERMOD modeling system and 

followed the procedures outlined in U.S. EPA guidance. The South Coast District 

modeled the two large lead-acid battery recycling facilities to determine 

three-month average lead concentrations for a 2010 base year and the 2015 

attainment year. The modeling runs included both stack emissions and fugitive 

source emissions. The 2015 future year emission rates reflect the emission 

limits specified in Rule 1420.1, permit conditions, and other control factors unique 

to each facility. Modeling results show future year (2015) ambient lead 

concentrations below the level of the federal standard for both facilities. Thus, 

the modeling analysis demonstrates attainment of the federal lead standard by 

the December 31, 2015, statutory deadline. 

New Source Review 

In addition to rules such as Rule 1420.1 that control emissions from existing 

stationary sources, there are rules that apply to newly constructed stationary 

sources and to major modifications of existing stationary sources. These rules 

are referred to as New Source Review or NSR rules. The goal of NSR is to 

assure that emissions from new and modified stationary sources do not slow 

progress toward attainment. 

For the federal lead standard, NSR requirements apply to all new stationary 

sources that emit at least 100 tons per year of lead, as well as to major 

modifications of existing sources that would increase lead emissions by more 

than 0.6 tons per year. The South Coast District’s current NSR rule 

(Regulation XIII, originally adopted in 1979) satisfies federal NSR requirements. 

However, because of the size of lead-related facilities, it is unlikely that the lead 

NSR requirements would ever be triggered. The combined lead emissions from 

all stationary sources in Los Angeles County are less than 15 tons per year, and 

the total lead emissions from any one source are less than 0.35 tons per year. 

Both of these are well below the lead NSR threshold levels for new or modified 

sources. Nevertheless, the South Coast District has all of the required NSR 

provisions in place. 
-5- 

In addition to the NSR provisions, South Coast District Rule 1420.1 contains 

additional requirements for the siting of new large lead-acid battery recycling 

facilities similar to those that currently contribute to lead nonattainment. Under 

Rule 1420.1, any new battery recycling facility that begins construction or 

operations will not be allowed to locate in an area nearby residences or other 

sensitive receptors. 

Reasonably Available Control Technology and 

Reasonably Available Control Measure 

The CAA requires nonattainment areas to implement economically and 

technically feasible emission controls on existing stationary sources in the 

nonattainment area. Collectively, these controls are generally referred to as 

Reasonably Available Control Technology (RACT) and Reasonably Available 

Control Measure (RACM). All sources that emit at least 0.5 tons per year of lead 

are required to undergo a RACT/RACM review. This emissions threshold 

captures those stationary sources that have the potential to cause violations of 

the federal lead standard. The South Coast District has conducted the required 

RACT/RACM analysis on existing lead sources and therefore, fully meets this 

requirement. 

In general, the RACT/RACM review includes analysis of emission controls 

adopted in other nonattainment areas, as well as controls identified by U.S. EPA 

in guidelines or other documents. To satisfy the RACT/RACM requirement, the 

South Coast District identified and evaluated all lead control measures it has 

implemented or plans to implement and compared them with measures 

implemented by other agencies both within and outside of California, as well as 

with the available U.S. EPA guidelines. 

Based on this evaluation, the South Coast District developed Rule 1420.1, which 

focuses on the two facilities in Los Angeles County that contribute to violations of 

the federal lead standard. Rule 1420.1 provisions are equivalent to or more 

stringent than those developed by other air pollution control agencies or 

suggested in recent U.S. EPA guidance1

. The Rule 1420.1 provisions are 

consistent with and, in some cases, go beyond U.S. EPA RACT/RACM for the 

federal lead standard. The control provisions specified in Rule 1420.1 will ensure 

attainment of the federal lead standard by the statutory deadline. 

 

1

 U.S. EPA. Implementation of the 2008 Lead National Ambient Air Quality Standards – Guide to 

Developing Reasonably Available Control Measures (RACM) for Controlling Lead Emissions. 

Document # EPA-457/R-12-001. March 2012. 
-6- 

Enhanced Monitoring 

The federal lead standard is different from other federal air quality standards in 

that attainment is based on source-oriented monitoring. Therefore, the 

attainment demonstration must address those specific facilities that contribute to 

violations of the national standard. The attainment strategy for Los Angeles 

County is based on a combination of lead emissions reductions, in tandem with 

an ambient monitoring program that is more stringent than current federal 

monitoring requirements. 

In addition to rules that limit emissions from lead sources, the South Coast 

District requires source-oriented lead monitors around large lead-acid battery 

recycling facilities, the only sources with the potential to cause violations of the 

federal lead standard. Under South Coast District Rule 1420.1, large lead-acid 

battery recycling facilities must maintain a minimum of four source-oriented 

monitors that sample for lead once every three days. These fence-line monitors 

are located in areas of maximum expected ground-level concentration. As of 

January 1, 2012, a source must implement additional lead emissions controls 

when concentrations at a source-oriented monitor exceeds 0.15 μg/m3

, averaged 

over a 30-day period. The Rule 1420.1 source-oriented lead monitoring 

requirements are more stringent than the federal requirements, which specify a 

once every six days sampling frequency, a rolling three-month averaging period, 

and a compliance date of December 31, 2015. Thus, the South Coast District’s 

Rule 1420.1 should be more effective at ensuring attainment of the federal lead 

standard than the current federal requirements. 

Reasonable Further Progress 

For most pollutants, attainment relies on a specific set of emission control 

measures, phased-in over a period of time. Reasonable Further Progress (RFP) 

requirements are designed to track progress, thereby ensuring the nonattainment 

area will attain the federal standard by the statutory deadline. In Los Angeles 

County, lead violations are attributable to two large lead-acid battery recycling 

facilities. As discussed previously, the South Coast District has already adopted 

and implemented Rule 1420.1 to ensure compliance with the federal lead 

standard. 

 

The South Coast District adopted Rule 1420.1 in November 2010, and ARB 

subsequently submitted the Rule to U.S. EPA for approval. Rule 1420.1 

specifies a compliance deadline of July 1, 2011, for implementing all required 

control measures and emissions limits and a compliance deadline of 

January 1, 2012, for meeting the ambient monitoring limit of 0.15 μg/m3

. 

Because the deadline for compliance with Rule 1420.1 has already passed, both 

large lead-acid battery recycling facilities have already demonstrated RFP by 

achieving the mandated emission reductions. Emissions at one facility are at the 
-7- 

allowable limit established in Rule 1420.1 and should either decrease or remain 

stable through 2015. In contrast, lead emissions at the second facility are 

currently below the allowable limit established in Rule 1420.1. Based on growth 

factors, lead emissions at this facility could increase between now and 2015, but 

would still remain well below the allowable limit established in Rule 1420.1. 

The effectiveness of Rule 1420.1 has been demonstrated through the substantial 

reductions in ambient concentrations that have already occurred. Since 

December 2011, no source-oriented monitor around either large lead-acid battery 

recycling facility has recorded a 30-day average lead concentration above the 

level of the federal lead standard. 

Contingency Measures 

Contingency measures are fully adopted rules or control measures that can be 

implemented without significant action by the State or U.S. EPA, should an area 

fail to attain the federal standard or demonstrate sufficient progress. The South 

Coast District has several contingency measures in place for lead that are 

already fully adopted as part of Rule 1420.1. Furthermore, these measures 

apply to the facilities that contribute to violations of the federal lead standard in 

Los Angeles County: 

 

- Compliance Plan: If a source-oriented monitor measures a 

30-day rolling average lead concentration of 0.12 μg/m3

 or 

more, the facility must submit a Compliance Plan identifying 

measures that will be automatically implemented if ambient 

concentrations exceed 0.15 μg/m3, calculated as a 30-day 

rolling average; the Compliance Plan is subject to South Coast 

District approval. 

- Feasibility Study: If facility emissions contribute to an 

ambient lead concentration exceeding 0.12 μg/m3

, 

calculated as a 30-day rolling average, the facility must 

submit within 30 days, a study addressing the technical, 

economic, and physical feasibility of achieving a total facility 

mass lead emission rate of 0.003 pounds per hour from all 

lead point sources. 

- Ambient Monitoring: A facility may not discharge lead 

emissions that contribute to ambient concentrations 

exceeding 0.15 μg/m3, calculated as a 30-day rolling 

average, as measured by any source-oriented monitor; 

ambient concentrations exceeding this level trigger the 

implementation of daily monitoring, a Compliance Plan, and 

a Feasibility Study.
-8- 

Given that the 30-day rolling average specified in Rule 1420.1 is more stringent 

than the rolling three-month average specified in the federal lead standard, 

provisions of the Rule will be triggered before ambient concentrations violate the 

federal lead standard. In addition to the Rule 1420.1 requirements, the South 

Coast District plans to amend its Rule 1420 to include the same lead trigger level 

of 0.12 μg/m3

, calculated as a 30-day rolling average. Rule 1420 applies to all 

non-vehicular sources of lead in Los Angeles County. 

SUMMARY 

ARB staff reviewed the Lead SIP for Los Angeles County and concurs with the 

South Coast District that it meets the CAA requirements. Thus, ARB staff 

recommends the Board approve the Lead SIP as a revision to the statewide SIP. 

The cornerstone of the Lead SIP is South Coast District Rule 1420.1, which 

specifically addresses emissions from the two large lead-acid battery recycling 

facilities that contribute to violations of the federal lead standard in Los Angeles 

County. The requirements of Rule 1420.1, which was adopted in 2010, are more 

stringent than federal requirements and have been effective in reducing ambient 

lead concentrations. Ambient lead concentrations have been below the level of 

the federal lead standard since December 2011. Continued compliance with 

Rule 1420.1 requirements will provide for attainment of the federal lead standard 

by the December 31, 2015, statutory deadline. 
APPENDIX A 

FINAL – 2012 LEAD STATE IMPLEMENTATION PLAN 

LOS ANGELES COUNTY
South Coast Air Quality Management District

FINAL 2012 LEAD STATE IMPLEMENTATION PLAN

LOS ANGELES COUNTY

May 4, 2012

Deputy Executive Officer

Planning, Rule Development and Area Sources

Elaine Chang, DrPH

Assistant Deputy Executive Officer

Planning, Rule Development and Area Sources

Laki Tisopulos, Ph.D., P.E.

Manager

Planning and Rules

Philip Fine, Ph.D.

Authors: Victoria Moaveni Senior Air Quality Engineer

Jillian Baker, Ph.D. Air Quality Specialist 

Andrea Polidori, Ph.D. Air Quality Specialist

Reviewed by: Barbara Baird District Counsel

William Wong Principal Deputy District Counsel

Tom Chico Program Supervisor

Contributors: Ed Eckerle Program Supervisor

Ali Ghasemi Program Supervisor

Kathy Hsiao Program Supervisor

Eugene Kang Air Quality Specialist

James Koizumi Air Quality Specialist

Steve Smith, Ph.D. Program Supervisor

Susan Yan Air Quality Specialist

Xinqiu Zhang, Ph.D. Air Quality Specialist
SOUTH COAST AIR QUALITY MANAGEMENT DISTRICT

GOVERNING BOARD

CHAIR: WILLIAM A. BURKE, Ed.D.

Speaker of the Assembly Appointee

VICE CHAIR: DENNIS YATES

Mayor, City of Chino 

Cities of San Bernardino County

MEMBERS:

MICHAEL D. ANTONOVICH

Supervisor, Fifth District

Los Angeles County Representative

JOHN J. BENOIT

Supervisor, Forth District

Riverside County Representative

JANE CARNEY

Senate Rules Committee Appointee

MICHAEL A. CACCIOTTI

Mayor, City of South Pasadena

Cities Representative, Los Angeles County, Eastern Region

JOSIE GONZALES

Supervisor, Fifth District

San Bernardino County Representative

RONALD O. LOVERIDGE

Mayor, City of Riverside

Cities Representative, Riverside County

JOSEPH K. LYOU, Ph.D.

Governor’s Appointee

President & CEO, Coalition for Clean Air

JUDITH MITCHELL

Councilmember, City of Rolling Hills Estates

Cities Representative, Los Angeles County, Western Region

SHAWN NELSON

Supervisor, Fourth District

Orange County Representative

JAN PERRY

Councilmember, 9

th District

Cities Representative, Los Angeles County

MIGUEL A. PULIDO

Mayor, City of Santa Ana

Cities Representative, Orange County

EXECUTIVE OFFICER:

BARRY R. WALLERSTEIN, D.Env.
LIST OF ACRONYMS AND ABBREVIATIONS

AER Annual Emissions Reporting

AERMIC American Meteorological Society/Environmental Protection 

Agency Regulatory Model Improvement Committee

AQMD South Coast Air Quality Management District

AQS Air Quality Systems

ATCM Airborne Toxic Control Measure

Avgas Aviation Gasoline

Basin South Coast Air Basin

CAA Clean Air Act

CAAQS California Ambient Air Quality Standard

CARB California Air Resources Board

CASAC Clean Air Scientific Advisory Committee

CEQA California Environmental Quality Act

CTG Control Technique Guidelines

DTSC California Department of Toxic Substances Control

EPA U.S. Environmental Protection Agency

FEM Federal Equivalent Method

FRM Federal Reference Method

H&SC Health & Safety Code

HRA Health Risk Assessment

ISC Industrial Source Complex

LAER Lowest Achievable Emissions Rate

MDAB Mojave Desert Air Basin

MICR Maximum Individual Cancer Risk

NAAQS National Ambient Air Quality Standards

NESHAP National Emissions Standards for Hazardous Air Pollutants

NLCD National Land Cover Data

NSR New Source Review

RACM Reasonably Available Control Measure

RACT Reasonably Available Control Technology

RFP Reasonable Further Progress

SIP State Implementation Plan

SSAB Salton Sea Air Basin

TAC Toxic Air Contaminant

T-BACT Best Available Control Technology for Toxics

TPY Tons Per Year

TSP Total Suspended Particulate

USGS U.S. Geologic Survey
Draft 2012 Lead SIP Table of Contents

TOC – i April 2012

TABLE OF CONTENTS

TABLE OF CONTENTS .................................................................................................. i

LIST OF TABLES........................................................................................................... iii

LIST OF FIGURES ......................................................................................................... iv

EXECUTIVE SUMMARY 

Introduction........................................................................................................ES-1

Lead Air Quality and Regulatory Background ..................................................ES-1

Guide to the 2012 Lead SIP...............................................................................ES-2

Questions and Answers Regarding the 2012 Lead SIP .....................................ES-3

CHAPTER 1 – INTRODUCTION

Purpose................................................................................................................. 1-1

Setting / Population.............................................................................................. 1-1

The Lead Nonattainment Area............................................................................. 1-4

History of Lead NAAQS ..................................................................................... 1-4

Emission Sources................................................................................................. 1-5

Lead Health Effects.............................................................................................. 1-6

History of Control Efforts.................................................................................... 1-7

Impact of Control Efforts..................................................................................... 1-9

CAA Planning Requirements Addressed by this SIP .......................................... 1-9

State Law Requirements.................................................................................... 1-12

CHAPTER 2 – LEAD AIR QUALITY IN LOS ANGELES COUNTY

Introduction.......................................................................................................... 2-1

Ambient Measurements....................................................................................... 2-2

Measurements at Source-Oriented Sites.............................................................. 2-6

Fence-Line Measurements................................................................................. 2-11

Summary............................................................................................................ 2-17

CHAPTER 3 – LEAD INVENTORY

Introduction.......................................................................................................... 3-1

Emission Inventories............................................................................................ 3-1

Base and Future Year Emissions ......................................................................... 3-2

Uncertainty in the Inventory .............................................................................. 3-12

CHAPTER 4 – LEAD CONTROL STRATEGY

Introduction.......................................................................................................... 4-1

Overall Attainment Strategy ................................................................................ 4-1
Draft 2012 Lead SIP Table of Contents

TOC – ii April 2012

Existing Lead Emissions Control Regulations .................................................... 4-2

AQMD’s Existing Rules...................................................................................... 4-3

AQMD’s Proposed Lead Control Measure.......................................................... 4-8

Implementing Agency.......................................................................................... 4-9

CHAPTER 5 – FUTURE AMBIENT LEAD CONCENTRATIONS

Introduction.......................................................................................................... 5-1

Modeling Approach ............................................................................................. 5-1

Model Results by Facility .................................................................................... 5-5

CHAPTER 6 – CLEAN AIR ACT REQUIREMENTS

Introduction.......................................................................................................... 6-1

Federal Clean Air Act Requirements................................................................... 6-1

Specific Lead Planning Requirements................................................................. 6-1

Nonattainment New Source Review (NSR) Program.......................................... 6-2

Contingency Measures......................................................................................... 6-3

Reasonable Further Progress (RFP)................................................................... 6-14

Reasonably Available Control Measures (RACM) and Reasonably 

Available Control Technology (RACT) Requirements..................................... 6-17

APPENDIX I – LEAD AIR QUALITY IN LOS ANGELES COUNTY

APPENDIX II – RULES 

APPENDIX III – MODELING AND ATTAINMENT DEMONSTRATION

APPENDIX IV – SOCIOECONOMIC REPORT FOR RULE 1420.1

APPENDIX V – RESPONSE TO COMMENTS
Draft 2012 Lead SIP Table of Contents

TOC – iii April 2012

LIST OF TABLES

Table 1-1 Population Growth 1-4

Table 1-2 Nonattainment Plan Provisions 1-10

Table 1-3 General CAA Requirements for Implementation Plans 1-11

Table 2-1 AQMD’s monitoring network sites in the Los Angeles County 

Portion of the Basin measuring Total Suspended Particulate 

(TSP) lead since 1975 with available design values for the 

2008-2011 timeframe

2-4

Table 2-2 AQMD’s source oriented sites in the Los Angeles County 

Portion of the Basin measuring Total Suspended Particulate 

(TSP) lead since 1991 with available design values for the 

2008-2011 timeframe

2-9

Table 2-3 Name and location of all fence-line and off-site monitoring 

stations operated by Exide Technologies (Vernon Facility)

2-12

Table 2-4 Name and location of all fence-line monitoring stations 

operated by Quemetco Inc.

2-15

Table 3-1 2010 & 2015 Lead Emission Inventory by Major Source 

Category – Los Angeles County (TPY)

3-7

Table 3-2 2010 Lead Emissions by Facility Emitting Over One Pound 

Per Year – Los Angeles County

3-9

Table 3-3 2008, 2010 & 2015 Lead Emission Inventory for Piston 

Engine Aircrafts – Los Angeles County (TPY)

3-11

Table 5-1 Dispersion Model Results by Facility for Demonstrating 

NAAQS Attainment (2015)

5-6

Table 6-1 Comparison between Rehrig lead concentrations and the 

corresponding maximum lead levels at all Exide locations

6-8

Table 6-2 Comparison of AQMD Rule 1420.1 with AQMD Rule 1420, 

the 2008 Lead NAAQS, and the NESHAP for Secondary Lead 

Smelters

6-20
Draft 2012 Lead SIP Table of Contents

TOC – iv April 2012

LIST OF FIGURES

Figure 1-1 Boundaries of the South Coast Air Basin and Lead 

Nonattainment Areas

1-3

Figure 2-1 Location of all AQMD’s network lead monitoring sites in the 

Los Angeles County portion of the Basin since 1975 

2-3

Figure 2-2 Monthly average Total Suspended Particulate (TSP) lead 

concentrations at all network sites in the Los Angeles County 

Portion of the Basin from 1975 to 2011

2-5

Figure 2-3 Location of all source-oriented sites operated by AQMD 2-8

Figure 2-4 Monthly average Total Suspended Particulate (TSP) lead 

concentrations at all source-oriented sites from 1991 to 2011

2-10

Figure 2-5 Location of all fence-line monitoring sites operated near Exide 

Technologies (Vernon facility)

2-12

Figure 2-6 Fence-line 30-day rolling average lead concentrations at the 

Exide recycling battery facility

2-13

Figure 2-7 Location of all fence-line monitoring stations operated near 

Quemetco Inc.

2-15

Figure 2-8 Fence-line 30-day rolling average lead concentrations at the 

Quemetco recycling battery facility

2-16

Figure 5-1 Summary of Dispersion Model Results by Facility 5-4

Figure 5-2 Highest monthly average lead concentrations measured near 

the Exide facility in Vernon

5-6

Figure 6-1 Comparison between Rehrig lead concentrations and the 

corresponding maximum lead levels at all Exide locations

6-7

Figure 6-2 Demonstration of RFP for Exide 6-15

Figure 6-3 Demonstration of RFP for Quemetco 6-16
EXECUTIVE SUMMARY

Introduction

Lead Air Quality and Regulatory Background

Guide to the 2012 Lead SIP

Questions and Answers Regarding the 2012 Lead SIP
Executive Summary

ES - 1

INTRODUCTION

This executive summary includes:

 Background information regarding recent changes to the National Ambient Air 

Quality Standards (NAAQS) for lead, the nonattainment area for lead in the South 

Coast Air Basin (Basin), and other relevant regulatory background;

 A quick guide to the 2012 lead State Implementation Plan (SIP) for Los Angeles 

County- (2012 Lead SIP);

 Questions and answers concerning this 2012 lead SIP

LEAD AIR QUALITY AND REGULATORY BACKGROUND

The federal Clean Air Act (CAA) requires U.S. Environmental Protection Agency (EPA) to 

set National Ambient Air Quality Standards for lead and five other criteria pollutants 

considered harmful to public health and the environment (the other pollutants are ozone, 

particulate matter (including PM10 and PM2.5, nitrogen dioxide, carbon monoxide, and sulfur 

dioxide). The law also requires EPA to periodically review the standards and the latest 

scientific information to ensure that they provide adequate health and environmental 

protection, and to update those standards as necessary. 

Lead is a criteria pollutant and is also identified as a carcinogenic Toxic Air Contaminant 

(TAC) by the California Office of Environmental Health Hazard Assessment (OEHHA). The 

EPA promulgated the initial lead standard of 1.5 micrograms per cubic meter (μg/m3) in 

1978. On October 15, 2008 (73 FR 66964; November 12, 2008), EPA tightened the standard 

by reducing it to 0.15 μg/m3, and changing the form of the standard to a rolling 3-month 

average rather than the previous quarterly average. Once EPA establishes or revises a 

NAAQS, pursuant to section 107(d) of the CAA, EPA must designate as “nonattainment” 

those areas that violate the NAAQS and those nearby areas that contribute to violations. 

On December 31, 2010, the EPA designated a portion of Los Angeles County, excluding the 

high desert areas, San Clemente and Santa Catalina Islands (Southern Los Angeles County), 

as nonattainment for the 2008 lead NAAQS based on monitored air quality data from 2007-

2009 that indicated a violation of the NAAQS for two large lead-acid battery recycling 

facilities. The CAA requires areas classified as nonattainment to attain the lead standard as 

expeditiously as practicable and within CAA deadlines, which in the case of Los Angeles 

County is no later than December 31, 2015. The South Coast Air Quality Management 

District (AQMD) is the regional air agency responsible for air quality planning and 

regulations of stationary sources in the Orange County, Los Angeles County, and portions of 

San Bernardino and Riverside Counties. Any state containing an area designated as 

nonattainment must develop and submit a SIP within 18 months of the effective date of the 

nonattainment designation, meeting the requirements of part D, Title 1, of the CAA. 

Accordingly, the SIP for lead must be submitted to EPA by July 1, 2012.

The purpose of this SIP is to outline the strategies, planning and pollution control activities 

needed to demonstrate attainment of the lead NAAQS as expeditiously as practicable, but no 
Executive Summary

ES - 2

later than December 31, 2015. The AQMD’s SIP submittal process includes a public 

workshop, 30 days public notice, and a public hearing before the AQMD Governing Board 

prior to submittal to CARB, who then submits it to EPA.

GUIDE TO THE 2012 LEAD SIP

The 2012 Lead SIP addresses the recent revision to the lead NAAQS, and outlines the 

strategies, planning and pollution control activities that demonstrate attainment of the lead 

NAAQS before December 31, 2015. This document is organized into six chapters, each 

addressing a specific topic. The following summarizes the purpose and contents of each 

chapter:

Chapter 1, “Introduction,” describes the purpose of the 2012 lead SIP and some brief 

background information on the lead nonattainment area, the history of lead NAAQS, the 

history and impact of lead control efforts, and the CAA planning requirements for 

nonattainment areas. 

Chapter 2, “Lead Air Quality in Los Angeles County,” discusses the lead air quality as 

measured by monitors in Los Angeles County as well as historical trends in ambient lead 

concentrations. 

Chapter 3, “Lead Inventory,” estimates current emissions of lead by different sources and 

source categories, and provides projections of future year emissions.

Chapter 4, “Lead Control Strategy,” presents the overall attainment strategies in achieving 

the emission reductions necessary for the attainment of the revised NAAQS for lead by 2015.

Chapter 5, “Future Ambient Lead Concentrations,” describes the modeling approach and 

modeling results used to demonstrate attainment of the lead NAAQS under the control 

strategy described in Chapter 4. 

Chapter 6, “Clean Air Act Requirements,” discusses specific federal requirements and how 

they are satisfied by this 2012 Lead SIP.
Executive Summary

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QUESTIONS AND ANSWERS REGARDING THE 2012 LEAD SIP

Why is this 2012 Lead SIP being prepared?

On December 31, 2010, EPA designated the Los Angeles County portion of the Basin as

nonattainment for the 2008 Lead NAAQS. The federal CAA requires lead nonattainment 

areas to prepare a SIP outlining the strategies, planning and pollution control activities 

that demonstrate attainment of the lead NAAQS. 

Is lead air quality improving?

Yes. Over the past forty years, the lead air quality in the Basin has dramatically 

improved due to comprehensive control strategies implemented to reduce pollution from 

mobile and stationary sources. There have been no violations of the federal and state 

ambient air quality standards at the AQMD’s regional air monitoring stations since 1982. 

The reduction before 1990 is largely due to the phase-out of lead from gasoline for onroad vehicles. Substantial emission reductions have also been achieved due to enhanced 

controls in the metals processing industry. 

AQMD has been collecting lead monitoring data in the Los Angeles County portion of 

the South Coast Air Basin since 1975 throughout its regional monitoring network. 

Trends in monthly average lead concentrations for all available network sites show that 

lead levels have been reduced by two orders of magnitude since 1975 (from values as 

high as 7.49 μg/m3in 1976 to an urban background level of about 0.01 μg/m3). Although 

past controls have resulted in substantial lead emission reductions, the revised 2008 

NAAQS for lead of 0.15 μg/m3 resulted in the Los Angeles County’s non-attainment 

designation for the 2008 federal lead NAAQS. This designation was not due to AQMD’s 

regional network lead monitors, but instead was based on AQMD’s source-oriented 

monitors near specific facilities. These monitors have shown that emissions from two 

large lead-acid battery recycling facilities, Exide Technologies (located in the City of 

Vernon) and Quemetco Inc. (City of Industry), have exceeded and have the potential to 

exceed the new federal lead NAAQS. As a result, the AQMD Governing Board adopted 

Rule 1420.1 in November 2010 which applies to these large lead-acid battery recycling 

facilities. The purpose of the rule is to protect public health by reducing exposure to 

lead, and to provide the additional emissions reductions necessary to ensure the Basin can 

achieve and maintain the revised lead standards. 
Executive Summary

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What are the major sources contributing to lead nonattainment areas and what 

is the overall control strategy to meet the revised lead air quality standards?

Based on monitoring data, the AQMD staff has identified large lead-acid battery 

recycling facilities as the only source of lead in the Basin that have caused or have the 

potential to cause exceedances of the new lead NAAQS. Therefore, the overall control 

strategy relies upon emission reductions from large lead-acid battery recycling facilities 

which have already been addressed through the 2010 adoption AQMD Rule 1420.1 –

Emissions Standard for Lead From Large Lead-Acid Battery Recycling Facilities. 

What are the main challenges for attainment of lead standards? 

The main challenge for future attainment of the lead standard is the inherent uncertainties 

in quantifying fugitive dust emissions. Given the difficulty in quantifying fugitive lead 

emissions, and given the known importance of fugitive emissions at lead-acid battery 

recycling facilities, the ambient monitors required by AQMD Rule 1420.1 provide the 

most effective means of ensuring compliance with the NAAQS since they capture all lead 

emissions. As a result, this attainment demonstration relies heavily on ambient 

monitoring to capture the direct impact of fugitive and all other emissions on ambient 

concentrations, in a manner similar to, but more stringent, than federal requirements for 

NAAQS monitoring.
CHAPTER 1

INTRODUCTION

Purpose

Setting / Population

The Lead Nonattainment Area

History of Lead NAAQS

Emission Sources

Lead Health Effects

History of Control Efforts

Impact of Control Efforts 

CAA Planning Requirements Addressed by this SIP

State Law Requirements
Chapter 1: Introduction

1 - 1

PURPOSE

The Clean Air Act (CAA) requires the U.S. Environmental Protection Agency (EPA) to set 

National Ambient Air Quality Standards (NAAQS) for lead and five other criteria pollutants

as well as any criteria pollutants that EPA may identify in the future. The law also requires 

EPA to periodically review the existing standards and the latest scientific information to 

ensure that they provide adequate health and environmental protection, and to update those 

standards as necessary.

The EPA established the initial lead standard of 1.5 micrograms per cubic meter (μg/m3) in 

1978. Since then, scientific evidence about lead health effects, environmental effects, and 

lead in the air has expanded dramatically, and shows that adverse effects occur at much lower 

levels of lead in the blood than previously thought. As a result, the EPA revised the lead 

NAAQS on October 15, 2008 (73 FR 66964; November 12, 2008) significantly strengthening 

the standard from 1.5 μg/m3to 0.15 μg/m3. In conjunction with strengthening the lead

NAAQS, EPA also established new criteria for the siting of ambient lead monitors. EPA 

found that the pre-existing ambient lead monitoring networks were inadequate for 

determining whether many areas are meeting the revised lead NAAQS. Additional monitors 

meeting the new network siting requirements were to begin operation January 1, 2010. 

On December 31, 2010, the EPA designated the Los Angeles County portion of the South 

Coast Air Basin, excluding San Clemente and Santa Catalina Islands (Southern Los Angeles 

County), as nonattainment for the 2008 Lead NAAQS based on monitored air quality data 

from 2007-2009, indicating a violation of the NAAQS, pursuant to section 107 (d)(1) of the 

CAA.

The AQMD is the air agency responsible for air quality planning and regulations of 

stationary sources in the Orange County, Los Angeles County, and portions of San 

Bernardino and Riverside Counties. The Purpose of this State Implementation Plan (SIP) is 

to outline the strategies, planning and pollution control activities that demonstrate attainment 

of the lead NAAQS as expeditiously as practicable, but no later than December 31, 2015. 

The SIP will be submitted to EPA upon approval by AQMD’s Governing Board and the 

California Air Resources Board (CARB). 

SETTING /POPULATION

The AQMD jurisdiction covers an area of approximately 10,743 square miles, consisting of 

the four-county South Coast Air Basin (Basin), and the Riverside County portions of the 

Salton Sea Air Basin (SSAB) and Mojave Desert Air Basin (MDAB). The Basin, which is a 

sub-region of the AQMD’s jurisdiction, is bounded by the Pacific Ocean to the west and the 

San Gabriel, San Bernardino, and San Jacinto mountains to the north and east. It includes all 

of Orange County and the non-desert portions of Los Angeles, Riverside, and San 

Bernardino counties. The Riverside county portion of the SSAB is bounded by the San 

Jacinto Mountains in the west and spans eastward up to the Palo Verde Valley. The federally 
Chapter 1: Introduction

1 - 2

designated nonattainment area for lead consists only of the Los Angeles County portion of 

the Basin, excluding San Clemente and Santa Catalina Islands (Southern Los Angeles 

County). 

The AQMD portion of Los Angeles County, where the major lead emissions sources are 

located, is surrounded by mountains which act as barriers to airflow between the Basin and 

Mojave Desert. Although there are a limited number of gaps in these mountains where 

transport has been documented, transport of lead emissions from the South Coast into the 

Mojave Desert is highly unlikely, given the size and weight of lead particles and the rapid 

decrease in concentration with distance from a source. As a result, emission sources in the 

Los Angeles County are not expected to have an impact on lead concentrations in the Mojave 

Desert portion of the County. 

The South Coast Air Basin region is shown in Figure 1-1 with the lead nonattainment areas 

highlighted.
Chapter 1: Introduction

1 - 3

FIGURE 1-1

Boundaries of the South Coast Air Basin

and Lead Nonattainment Areas

Population

Since the end of World War II, the Basin has experienced faster population growth than the 

rest of the nation. Although growth has slowed somewhat, the region’s population is 

expected to increase significantly through 2020. Table 1-1 shows the projected growth based 

on Southern California Association of Government’s (SCAG) regional growth forecast.

Population exposure to air pollutants has declined significantly over the years, primarily due 

to the impacts of federal, state, and regional air quality control programs. Although 

population exposure to pollution has been substantially reduced in the Basin through several 

decades of implementing pollution controls, increases in the population over that time have 

made overall emission reductions more difficult. Many sources, such as major stationary 

sources and automobiles, have significantly reduced emissions through technology advances. 
Chapter 1: Introduction

1 - 4

TABLE 1-1

Population Growth

Year 1990 2000 2010 2013 2015

Population 13.0 million 14.8 million 16.9 million 17.3 million 17.6 million

THE LEAD NONATTAINMENT AREA

In May 2010, CARB recommended to EPA that the Los Angeles County portion of the South 

Coast Air Basin, excluding San Clemente and Santa Catalina Islands (Southern Los Angeles 

County), be designated as nonattainment for the 2008 lead NAAQS based on air quality data 

from 2007-2009. CARB’s recommendation was based on data from Federal Reference 

Method (FRM) or Federal Equivalent Method (FEM) monitors located in the state. The 2008 

lead NAAQS requires full attainment no later than December 31, 2015. Demonstration of 

attainment is based on measurements using a rolling 3-month averaging form of the standard 

to be evaluated over a 3-year period. Ambient measurement data are to be produced by

EPA-required monitoring networks within each state which consist of both source-oriented 

and population monitors. 

HISTORY OF LEAD NAAQS

The CAA requires EPA to set national air quality standards for lead and five other pollutants 

considered harmful to public health and the environment [(the other pollutants are ozone, 

particulate matter (including PM10 and PM2.5), nitrogen dioxide, carbon monoxide, and sulfur 

dioxide)]. The law also requires EPA to periodically review the existing standards to ensure 

that they provide adequate health and environmental protection, and to update those 

standards as necessary.

The CAA established two types of NAAQS for lead and other criteria pollutants. Primary 

standards set limits to protect public health, including the health of “sensitive” populations 

such as asthmatics, children, and the elderly. Secondary standards set limits to protect public 

welfare, including protection against visibility impairment, damage to animals, crops, 

vegetation, and buildings. To provide increased protection against lead-related welfare 

effects, EPA revised the secondary standard to be identical in all respects to the revised 

primary standards. Once EPA establishes or revises a primary and/or secondary NAAQS, 

pursuant to section 107(d) of the CAA, EPA must designate as “nonattainment” those areas 

that violate the NAAQS and those nearby areas that contribute to violations. In addition, 
Chapter 1: Introduction

1 - 5

CARB is authorized to establish state ambient air quality standards which may be more 

stringent than the federal standards.

The following provides a brief summary of the lead NAAQS history:

 In 1970, CARB set the state ambient air quality standard for lead at 1.5 μg/m3 based on a 

30-day average.

 On October 1978, EPA promulgated primary and secondary NAAQS for lead under 

section 109 of the Act (43 FR 46246). Both primary and secondary standards were set at 

a level of 1.5 μg/m3based on a quarterly average (maximum arithmetic mean averaged 

over a calendar quarter).

 On October 2008, EPA amended the NAAQS for lead from 1.5 μg/m3 to 0.15 μg/m3 

requiring attainment by December 31, 2015 using a rolling 3-month averaged evaluated 

over 3 year period.

 On May 2010, CARB recommended to the EPA that the South Coast portion of Los 

Angeles County be designated as nonattainment for the 2008 federal lead standard. 

 On December 31, 2010, EPA designated the Los Angeles County portion of the South 

Coast Air Basin, excluding San Clemente and Santa Catalina Islands (Southern Los 

Angeles County), as nonattainment for the 2008 lead NAAQS requiring attainment no 

later than December 31, 2015. 

EMISSION SOURCES

Lead is a metal found naturally in the environment and present in some manufactured 

products. There are a variety of activities that can contribute to lead emissions, which are 

grouped into two general categories, stationary and mobile sources. Stationary sources can 

be further grouped into “point” and “area” sources. Point sources have one or more 

identified and fixed pieces of equipment and emission points at a permitted facility. Area 

sources consist of widespread and numerous smaller emission sources, such as smaller 

facilities, households, or other land uses. Mobile sources can also be grouped into two major 

categories, “on-road” and “other” mobile sources. On-road mobile sources include light-duty 

automobiles; light-, medium-, and heavy-duty trucks; and motorcycles. Examples of “other” 

mobile sources include aircraft, locomotives, construction equipment, mobile equipment, and 

off-road recreational vehicles. 

Emissions of lead have dropped substantially over the past forty years. The reduction before 

1990 is largely due to the phase-out of lead as an anti-knock agent in gasoline for on-road 

automobiles. Substantial emission reductions have also been achieved due to enhanced 

controls in the metals processing industry. However, with the recent strengthening of the 

NAAQS for lead, additional reductions may be needed to maintain attainment of the federal 

lead air quality standards.

Historically, the major source of lead air emissions has been gasoline-powered motor 

vehicles. Motor vehicle emissions of lead have been dramatically reduced due to the phase-
Chapter 1: Introduction

1 - 6

out of leaded gasoline, but lead is still used as an additive in general aviation gasoline (avgas) 

and remains as a trace contaminant in other fuels. Avgas is only utilized in general aviation 

aircraft with piston engines, which are generally used for instructional flying, air taxi 

activities, and personal transportation. Emissions of lead from piston-engine aircraft using 

leaded avgas comprise approximately half of the national inventory of lead emitted to the air.

Sources of lead from stationary sources are mainly from larger industrial sources including 

but not limited to, metals processing, particularly primary and secondary lead smelters. Lead 

can also be emitted from sources, such as iron and steel foundries; primary and secondary 

copper smelters; industrial, commercial, and institutional boilers; waste incinerators; glass 

manufacturing; refineries, and cement manufacturing. The lead-acid battery recycling 

industry has been determined by AQMD staff to be the highest stationary source emitters of 

lead in Los Angeles County. Staff’s analysis has shown this industry to be the only known 

stationary source category that has the potential to cause violations of the new lead NAAQS. 

The lead emission sources in the nonattainment area are described in Chapter 3.

LEAD HEALTH EFFECTS

Lead is generally emitted in the form of particles, which can end up being deposited in the 

human lung as well as in water, soil, and dust. Human exposure to lead occurs in a variety of 

ways with common routes being that of inhalation and ingestion. Once in the body, lead is 

quickly absorbed into the bloodstream and can result in a broad range of adverse health 

effects. The most widely used indicator of lead exposure in many studies is the amount of 

lead measured in whole blood because of the direct relationship between blood lead (PbB) 

levels and health effects. Clinical effects resulting from high-level lead exposure include 

nervous and reproductive system disorders, neurological and physical developmental effects, 

cognitive and behavioral changes, and hypertension. Young children are especially 

susceptible to the effects of environmental lead because they are more vulnerable to certain 

biological effects of lead including learning disabilities, deficits in IQ, and behavioral 

problems.1 Based on studies reviewed by the EPA’s Clean Air Scientific Advisory 

Committee (CASAC), it was concluded that a “population loss of 1-2 IQ points” resulting 

from exposure to ambient air lead concentrations “is highly significant from a public health 

perspective.” 

Under the federal CAA, lead is classified as a “criteria pollutant.” Lead has observed health 

effects at ambient concentrations. The EPA has thoroughly reviewed the lead exposure and 

health effects research which indicates that PbB concentrations in a range of 5-10 μg/dL, or 

possibly lower, could likely result in neurocognitive effects in children. The report further 

states that “there is no level of lead exposure that can yet be identified with confidence, as 

clearly not being associated with some risk of deleterious health effects.” 2

 

1

 Environmental Protection Agency, “Lead in Air,” (http://www.epa.gov/air/lead/health.html), June 12, 2009.

2 Environmental Protection Agency, Office of Research and Development, “Air Quality Criteria Document for Lead, Volumes 

I-II,” October 2006.
Chapter 1: Introduction

1 - 7

The EPA has determined that a primary and secondary standard of 0.15 μg/m3is requisite to 

provide an adequate margin of safety that would ensure the protection of public health from 

the health effects associated with lead exposure. 3

HISTORY OF CONTROL EFFORTS

The CAA requires EPA to set national air quality standards for lead and five other pollutants 

considered harmful to public health and the environment (the other pollutants are ozone, 

particulate matter, nitrogen oxides, carbon monoxide, and sulfur dioxide). Federal, state and 

regional control efforts are designed to meet those standards by CAA-mandated deadlines. 

Below is a chronology of federal, state and regional lead control efforts relevant to the Basin, 

including the nonattainment area in Los Angeles County:

 In November 1970, CARB set the state ambient air quality standard for lead at 1.5 μg/m3

averaged over 30 days.

 In October 1978, EPA promulgated primary and secondary NAAQS for lead under 

section 109 of the Act (43 FR 46246). Both primary and secondary standards were set at 

a level of 1.5 μg/m3averaged over a calendar quarter.

 In 1987, the California legislature adopted the Air Toxics “Hot Spots” Information and 

Assessment Act (AB 2588). The goals of the Act are to collect emissions data of toxic 

air contaminants (TACs), identify facilities having localized impacts, to determine health 

risks, and to notify affected individuals. Facilities with high health risks must reduce 

their risks to the community by incorporating risk reduction plans.

 In December 1990, AQMD adopted Rule 1401 – New Source Review of Toxic Air 

Contaminants. The rule applies to new, relocated, and modified permit units with TAC 

emissions. Lead was added to the Rule 1401 list of TACs in 1992.

 In September 1992, AQMD adopted Rule 1420 – Emissions Standard for Lead. The rule 

incorporated the state ambient air quality standard and required control devices on lead 

emission points, control efficiency requirements for lead control devices, housekeeping, 

and monitoring or modeling of ambient air quality.

 In October 1992, Office of Environmental Health Hazard Assessment (OEHHA)

classified lead as a carcinogenic TAC. 

 In January 1993, CARB adopted the Airborne Toxic Control Measure (ATCM) for 

Emissions of TAC Metals from Non-Ferrous Metal Melting. 

 In April 1994, AQMD adopted Rule 1402 – Control of Toxic Air Contaminants from 

Existing Sources. The purpose of this rule is to reduce the health risk associated with 

emissions of TACs from existing sources by specifying health limits for cancer and noncancer compounds applicable to total facility emissions and by requiring facilities to 

implement risk reduction plans to achieve specified risk limits, as required by the AB

2588 “Hot Spots” and this rule. 

 

3 Environmental Protection Agency, “National Ambient Air Quality Standards for Lead; Final Rule,” 40 CFR Parts 50, 51, 53, 

and 58, November 2008.
Chapter 1: Introduction

1 - 8

 In April 1997, CARB identified lead compounds (including inorganic lead) as a TAC due 

to the health impacts associated with neurodevelopmental impairment in children, 

increased blood pressure in adults and cancer.

 In June 1997, EPA adopted the National Emissions Standards for Hazardous Air 

Pollutants (NESHAP) from Secondary Lead Smelting. The federal regulation required 

lead emission concentration limits of lead control devices, control of process fugitive 

emissions, monitoring, recordkeeping, and reporting.

 In September 1998, CARB established a cancer potency value of 1.2 x 10-5per μg/m3for 

inorganic lead exposure. 

 In March 2001, CARB developed “Risk Management Guidelines for New, Modified and 

Existing Sources of Lead”.

 In October 2008, EPA amended the NAAQS for lead from 1.5 μg/m3 to 0.15 μg/m3 

requiring attainment by December 31, 2015, using a rolling 3-month average evaluated 

over 3-year period. 

 In November 2010, AQMD adopted Rule 1420.1 – Emissions Standard for Lead from 

Large Lead-Acid Battery Recycling Facilities. The purpose of this rule is to protect 

public health while ensuring attainment with the 2008 lead NAAQS.

IMPACT OF CONTROL EFFORTS

The ambient air quality standards for lead were set at 1.5 μg/m3 by both CARB and EPA in 

1970, and 1978, respectively. Air pollution controls have had a positive impact on the 

Basin’s air quality relative to lead. There have been no violations of the federal and state 

standards at the AQMD’s regular air monitoring stations since 1982. The major reductions

were due to removal of lead from gasoline, in addition to adoption of AQMD Rule 1420 -

Emissions Standard for Lead. Although past controls have resulted in substantial lead 

emission reductions, the 2008 NAAQS for lead of 0.15 μg/m3 may require additional controls 

to ensure continued attainment of the federal lead air quality standards. 

Air quality summaries for ambient lead in the nonattainment areas of the Basin as well as the 

health effects of lead are briefly discussed in Chapter 2.

CAA PLANNING REQUIREMENTS ADDRESSED BY THIS SIP

In November 1990, Congress enacted a series of amendments to the CAA intended to 

intensify air pollution control efforts across the nation. One of the primary goals of the 1990 

CAA Amendments was an overhaul of the planning provisions for those areas not currently 

meeting NAAQS. The CAA identifies specific emission reduction goals, requires both a 

demonstration of reasonable further progress and an attainment demonstration, and 

incorporates more stringent sanctions for failure to attain or to meet interim milestones.

In October 2008, the EPA strengthened the NAAQS for lead from 1.5 μg/m3 to 0.15 μg/m3 

requiring attainment by December 31, 2015, using a rolling 3-month average evaluated over

a 3-year period. The Los Angeles County portion of the South Coast Air Basin, excluding 
Chapter 1: Introduction

1 - 9

San Clemente and Santa Catalina Islands (Southern Los Angeles County), was designated as 

nonattainment for the 2008 lead NAAQS based on air quality data from 2007-2009. 

There are several sets of general planning requirements, both for nonattainment areas 

[Section 172(c) and 191 of the CAA] and for implementation plans in general [Section 

110(a) (2)]. These requirements are listed and very briefly described in Tables 1-2 and 1-3, 

respectively. The general provisions apply to all applicable pollutants unless superseded by 

pollutant-specific requirements.
Chapter 1: Introduction

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TABLE 1-2

Nonattainment Plan Provisions 

[CAA Section 172(c)]

Requirement Description 

Reasonably Available 

Control Measures (RACM)

Implementation of all reasonably available control measures as 

well as Reasonably Available Control Technology (RACT) as 

expeditiously as practicable.

Reasonable Further 

Progress (RFP)

Provision for reasonable further progress which is defined as “such

annual incremental reductions in emissions of the relevant air 

pollutant as are required for the purpose of ensuring attainment of 

the applicable national ambient air quality standard by the 

applicable date.”

Emission Inventory Development and periodic revision of a comprehensive, accurate, 

current inventory of actual emissions from all sources.

Allowable emission levels Identification and quantification of allowable emission levels for 

major, new, or modified stationary sources.

Permits for new and 

modified stationary sources

Permit requirements for the construction and operation of major new 

or modified stationary sources.

Other measures Inclusion of all enforceable emission limitations and control 

measures as may be necessary to attain the standard by the 

applicable attainment deadline.

Contingency measures Implementation of contingency measures to be undertaken in the 

event of failure to make reasonable further progress or to attain the 

NAAQS.
Chapter 1: Introduction

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TABLE 1-3

General CAA Requirements for Implementation Plans 

Requirement Description 

Ambient monitoring An ambient air quality monitoring program. [Section 110(a)(2)(B)]

Enforceable emission 

limitations

Enforceable emission limitations or other control measures as 

needed to meet the requirements of the CAA [Section 110(a)(2)(A)]

Enforcement and 

regulation

A program for the enforcement of adopted control measures and 

emission limitations and regulation of the modification and 

construction of any stationary source to assure that the NAAQS are 

achieved. [Section 110(a)(2)(C)]

Interstate transport Adequate provisions to inhibit emissions that will contribute to 

nonattainment or interfere with maintenance of NAAQS or interfere 

with measures required to prevent significant deterioration of air 

quality or to protect visibility in any other state. [Section 

110(a)(2)(D)]

Adequate resources Assurances that adequate personnel, funding, and authority are 

available to carry out the plan. [Section 110(a)(2)(E)]

Source testing and 

monitoring

Requirements for emission monitoring and reporting by the source 

operators. [Section 110(a)(2)(F)]

Emergency Authority Ability to bring suit to enforce against source presenting imminent 

and substantial endangerment to public health or environment 

[Section (a)(2)(G)]

Plan revisions Provisions for revising the air quality plan to incorporate changes in 

the standards or in the availability of improved control methods. 

[Section 110(a)(2)(H)]

Other CAA requirements Adequate provisions to meet applicable requirements relating to new 

source review, consultation, notification, and prevention of 

significant deterioration and visibility protection contained in other 

sections of the CAA. [Section 110(a)(2)(I),(J)]

Impact assessment Appropriate air quality modeling to predict the effect of new source 

emissions on ambient air quality. [Section 110(a)(2)(K)]

Permit fees Provisions requiring major stationary sources to pay fees to cover 

reasonable costs for reviewing and acting on permit applications and 

for implementing and enforcing the permit conditions. [Section 

110(a)(2)(L)]

Local government 

participation

Equivalent techniques

Provisions for consultation and participation by local political 

subdivisions affected by the plan. [Section 110(a)(2)(M) & 121]

Provisions allowing usage of equivalent modeling, emission 

inventory, and planning procedures, unless determined by the 
Chapter 1: Introduction

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Requirement Description 

administrator that the techniques are, in the aggregate, less effective 

than the methods specified by the administrator. [Section 172(c)(8)]

EPA requires a public hearing on many of the required elements in SIP submittals before 

considering them officially submitted. The AQMD’s SIP submittal process includes a public 

workshop, 30 days public notice, and a public hearing before the AQMD Governing Board 

prior to submittal.

The CAA requires SIPs for most nonattainment areas to demonstrate reasonable further 

progress (RFP) toward attainment through emission reductions phased in from the time of the 

SIP submission until the projected attainment date. The RFP requirements in the CAA are 

intended to ensure that the lead nonattainment area provide for sufficient emission reductions 

to attain the lead NAAQS. Chapter 6 provides an estimation of the emission levels at each 

of the milestone years compared to the CAA target levels, and how this SIP will demonstrate 

attainment.

The South Coast Air Basin portion of Los Angeles County, where the major lead emissions 

sources are located, is surrounded by mountains which act as barriers to airflow. Although 

there are a limited number of gaps in these mountains where transport has been documented, 

transport of lead emissions is highly unlikely, given the weight of lead particles and the rapid 

decrease in concentration with distance from a source. As a result, emissions sources in the 

South Coast portion of Los Angeles are not expected to have an impact on lead 

concentrations in other parts of the South Coast and as such will not be addressed in this SIP 

submittal.

STATE LAW REQUIREMENTS

The Health and Safety Code (H&SC) section 39607(e) requires CARB to establish and 

periodically review area designation criteria. Once CARB establishes health-based State 

ambient air quality standards to identify outdoor pollutant levels considered safe for the 

public, State law requires them to designate each area as attainment, nonattainment, 

nonattainment-transitional, or unclassified. In addition, H&SC section 39608 requires the 

CARB to use the designation criteria to designate areas of California and to annually review 

those area designations. 

CARB made the first area designations for State ambient air quality standards (State 

standards) in 1989. Since then, CARB has reviewed the designations each year, making 

changes as needed. The California ambient air quality standard (CAAQS) for lead has 

remained the same at 1.5 μg/m3. However, the lead designation for the South Coast Air Basin 

(Los Angeles County portion only) was changed from attainment to nonattainment, based on 

data for the period 2006 to 2008, effective on September 25, 2010. 
CHAPTER 2

LEAD AIR QUALITY IN LOS ANGELES COUNTY

Introduction

Ambient Measurements

Measurements at Source-Oriented Sites

Fence-line Measurements

Summary
Chapter 2: Lead Air Quality in Los Angeles

2 - 1

INTRODUCTION

On October 15, 2008, EPA revised the National Ambient Air Quality Standard (NAAQS) for 

Total Suspended Particulate (TSP) lead, lowering it from 1.5 micrograms per cubic meter 

(μg/m3) (calculated as a quarterly average) to a more stringent 0.15 μg/m3(rolling three-month 

average “not to be exceeded” over a three-year period) for both the primary and the secondary 

standard. The final rule was published in the Federal Register on November 12, 2008. The new 

rule and a revision on November 22, 2010 also established minimum requirements for lead 

monitoring, including monitoring adjacent to major lead emission sources (“source-oriented” 

monitors) emitting over 0.5 tons of lead per year. AQMD has been collecting TSP lead 

monitoring data in the Los Angeles County portion of the South Coast Air Basin since 1975 

throughout its routine monitoring network. As described below, AQMD has also maintained 

source-oriented monitors at various industrial facilities over the past several years. For the most 

part, the AQMD’s existing lead monitoring network meets the new federal monitoring 

requirements for lead. The only exception was a new monitoring requirement leading to 

sampling at Van Nuys Airport, implemented in 2010 as described below.

In 1990, EPA requested that AQMD collect ambient air particulate samples near large lead 

handling facilities. As a result, long-term monitoring at sites located near several of these 

facilities (i.e. source-oriented sites) began in 1991. Also, additional lead sampling has been 

conducted by AQMD since the adoption of Rule 1420 (Emissions Standard for Lead) on 

September 11, 1992. The purpose of Rule 1420 is to reduce lead emissions from non-vehicular 

sources. It applies to all facilities that use or process materials containing lead, including primary 

or secondary lead smelters, foundries, and lead-acid battery manufacturers or recyclers, as well 

as facilities that produce lead-oxide, brass, and bronze. Under Rule 1420, facilities shall not 

discharge lead emissions into the atmosphere which cause ambient concentrations beyond the 

property line to exceed 1.5 μg/m3averaged over 30 consecutive days (30-day rolling average). 

This concentration reflects the current California Ambient Air Quality standard (CAAQS) for 

lead (also a “not to be exceeded” standard), which has a level that is consistent with, and a form 

that is more stringent than, the previous federal standard (1.5 μg/m3averaged over a calendar 

quarter).

Furthermore, on November 5, 2010, AQMD adopted Rule 1420.1 to establish additional 

requirements for large lead-acid battery recycling facilities (those that process or have ever 

processed 50,000 tons or more of lead per year), to protect public health, and to ensure

attainment of the new 2008 NAAQS for lead in the Los Angeles County portion of the South 

Coast Air Basin. Rule 1420.1 requires total enclosures for any process associated with the 

preparation, recovery, refining, and storage of lead-containing material and requires pollution 

control devices on the enclosures and on lead emission point sources. Rule 1420.1 also includes 

housekeeping, monitoring potential lead emissions around the facility’s perimeter (i.e. fence-line 

monitoring), and recordkeeping requirements. The trigger level specified in Rule 1420.1 is 0.15 

μg/m3averaged over any consecutive 30-day period (30-day rolling average). As of July 1, 2011, 

any battery recycling facility exceeding an ambient lead concentration of 0.12 μg/m3 must 

submit a Compliance Plan identifying additional lead emission reduction measures, thereby 

helping to avoid potential subsequent violations of the federal standard. 
Chapter 2: Lead Air Quality in Los Angeles

2 - 2

The results of these sampling programs are summarized and discussed in this chapter. All 

information reported below refers to TSP lead measurements taken between 1975 and 2010 in 

the Los Angeles County portion of the South Coast Air Basin only. The discussion is divided 

into:

 Ambient measurements (non-source-oriented sites at permanent AQMD regional network 

monitoring stations that are not near local emissions sources)

 Source-oriented measurements (sites adjacent to lead-emitting facilities, beyond the 

property line, eligible for NAAQS comparison)

 Fence-line measurements (sites operated by the lead-emitting facility as required by 

AQMD rules 1420 or 1420.1, generally located just inside the fence-line on facility 

property or in non-public areas, and thus not eligible for NAAQS comparison) 

AMBIENT MEASUREMENTS

Since 1975, AQMD has been measuring ambient lead concentrations at multiple locations 

(Figure 2-1), typically using a 1-in-6 day sampling schedule, but in some cases sampling more 

frequently. All sites shown in Figure 2-1 are part of AQMD’s current or past monitoring network 

in the Los Angeles County portion of the South Coast Air Basin. The monitoring stations in 

Azusa, Burbank, Long Beach (North Long Beach Blvd.), Lynwood, and Los Angeles (North 

Main St.) have the longest continuous periods of record (Table 2-1). 
Chapter 2: Lead Air Quality in Los Angeles

2 - 3

FIGURE 2-1

Location of all AQMD’s network lead monitoring sites in the Los Angeles County portion of 

the Basin since 1975

Trends in monthly average TSP lead concentrations for all available network sites are shown in 

Figure 2-2. Noticeably, lead levels have been reduced by two orders of magnitude since 1975 

(from values as high as 7.49 μg/m3in 1976 to an urban background level of about 0.01 μg/m3), 

following the phase-out of lead in gasoline fuels that began during the 1970s. When the EPA

first adopted a lead standard in 1978, it was estimated that over 90% of ambient lead 

concentrations were attributable to the use of lead in gasoline fuels. 

Monthly average lead concentrations at all AQMD’s network sites have been at or below 0.05 

μg/m3since 2004. Note that lead concentrations in Figure 2-2 are not directly comparable to the 

form of the federal standard (monthly vs. a three-month average), but are provided to better 

illustrate long-term trends and the substantial reduction in the atmospheric levels of lead that has 

occurred in the Los Angeles County portion of the South Coast Air Basin in the past two 

decades. As shown in Table 2-1, none of the design values for the 2008-2010 or 2009-2011 time 

periods (i.e. highest valid 3-month site-level mean over a three year period) is close to the current 

2008 NAAQS for lead (0.15 μg/m3). All monthly-average lead data presented here have been 
Chapter 2: Lead Air Quality in Los Angeles

2 - 4

calculated from daily (24-hour) average values downloaded from EPA’s Air Quality System 

(AQS) database. A list of all available daily, one-month, and three-month average lead 

concentrations measured at all network sites since 1975 can be found in the supplemental CD 

provided with this document in Appendix I.

TABLE 2-1

AQMD’s monitoring network sites in the Los Angeles County portion of the Basin measuring 

Total Suspended Particulate (TSP) lead since 1975 with available design values for the

2008-2011 timeframe

Lead Design Value (μg/m3) Lead Design Value (μg/m3)

Start End (2008-2010)* (2009-2011)^

Azusa 803 N. Loren Ave., Azusa 01/04/80 12/27/09 NA NA

Burbank 228 W. Palm Ave., Burbank 02/23/75 12/27/09 NA NA

Compton 700 North Bullis Rd., Compton 11/02/08 Ongoing NA 0.02

El Monte 915 Flair Dr., El Monte 01/13/85 06/09/89 NA NA

Glendale 145 N. Howard St., Glendale 03/19/75 12/20/75 NA NA

Glendora 840 Laurel, Glendora 12/05/80 03/31/84 NA NA

Hawthorne 5234 W. 120th Street, Hawthorne 01/08/86 03/28/04 NA NA

Lancaster 45547 N. Beech St., Lancaster 01/04/80 12/28/86 NA NA

Lennox 11408 La Cienega Blvd., Los Angeles 01/04/80 10/28/85 NA NA

Long Beach-Pine Ave. 2655 Pine Ave., Long Beach 02/11/75 03/27/78 NA NA

Long Beach-N. LB Blvd. 3648 N. Long Beach Blvd., Long Beach 05/03/80 Ongoing 0.01 0.01

S. Long Beach 1305 E. Pacific Coast Hwy., Long Beach 08/07/03 Ongoing 0.01 0.01

Los Angeles-Selby Ave. 2050 Selby Ave, Los Angeles 02/23/75 10/18/80 NA NA

Los Angeles-N. Main St. 1630 N. Main St., Los Angeles 01/04/80 Ongoing 0.02 0.02

LAX Hastings 7201 W. Westchester Pkwy., Los Angeles 04/15/04 Ongoing 0.01 0.01

Lynwood 11220 Long Beach Blvd., Lynwood 01/04/80 10/27/08 NA NA

Pasadena-Cal. Tech. Cal. Tech. (Keck Lab.), Pasadena 02/11/75 03/27/78 NA NA

Pasadena-Walnut St. 1196 E. Walnut St., Pasadena 01/04/80 08/28/83 NA NA

Pasadena-Wilson Ave. 752 S. Wilson Ave., Pasadena 04/11/82 12/28/86 NA NA

Pico Rivera-SG River-a 3713 San Gabriel River Pkwy., Pico Rivera 01/04/80 04/22/05 NA NA

Pico Rivera-SG River-b 4144 San Gabriel River Pkwy., Pico Rivera 09/19/05 Ongoing 0.02 0.02

Reseda 18330 Gault St., Reseda 01/04/80 04/26/86 NA NA

Torrance 2300 Carson St., Torrance 02/11/75 09/23/78 NA NA

West Los Angeles-Rovertson 1535 Robertson Blvd., West Los Angeles 01/04/80 02/18/85 NA NA

West Los Angeles-Wilshire 11301 Wilshire Blvd., Los Angeles 06/05/84 12/28/86 NA NA

*Highest valid 3-month site-level mean over the most recent 38-month period (November 2007-December 2010)

^Preliminary value calculated as the highest valid 3-month site-level mean over the most recent 35-month period (November 2008-September 2011)

Lead data from October 2011 to December 2011 will be available soon

Sampling Site Name Site Address
Chapter 2: Lead Air Quality in Los Angeles

2 - 5

FIGURE 2-2

Monthly average Total Suspended Particulate (TSP) lead concentrations at all network sites in 

the Los Angeles County portion of the Basin from 1975 to 2011. The dotted line in the 

magnified portion of the graph represents the current 2008 NAAQS for lead (0.15 μg/m3)
Chapter 2: Lead Air Quality in Los Angeles

2 - 6

MEASUREMENTS AT SOURCE-ORIENTED SITES

TSP lead concentration data have been collected by AQMD during the past two decades in the 

vicinity of the following facilities, generally using the typical 1-in-6 day sampling schedule, but 

in some cases sampling more frequently:

 Exide Technologies 

 Vernon Facility (2700 South Indiana Street, Vernon): this secondary lead smelter 

plant recycles lead batteries and other lead bearing material. Since February 1991, 

AQMD has operated source-oriented lead monitors at four locations at different 

distances from the facility’s perimeter (Figure 2-3a). Sampling at three of these 

source-oriented sites is still ongoing (Table 2-2).

 Commerce Facility (5909 E Randolph St, Commerce): this is a lead oxide production 

facility. From January 1999 to May 2006, AQMD operated one lead monitoring site 

about 300 m north-west of the facility’s perimeter (Table 2-2; Figure 2-3b).

 Quemetco Inc. (720 South 7th Avenue, City of Industry)

 This secondary lead smelter plant recycles lead bearing scrap, primarily in the form of 

spent lead-acid batteries, and produces lead and lead alloy. AQMD has operated 

source-oriented sites around the facility at three locations since February 1991 

(Figure 2-3c). Sampling at one of these sites is still ongoing (Table 2-2).

 Trojan Battery (9440 Ann Street, Santa Fe Springs)

 This company designs and manufactures deep cycle batteries. AQMD has been 

operating a source-oriented site less than 100 m south-west of this facility since 

January 2001 (Table 2-2; Figure 2-3d). 

It should be noted that current EPA monitoring requirements for lead include a requirement to 

monitor at all facilities emitting over 0.5 tons of lead per year, excluding airports for which a 

pilot program for measuring lead at specified airports was required. However, monitoring at all 

facilities emitting over 1.0 tons per year, including airports, is also required. Therefore, in 2010,

a lead monitor was deployed at Van Nuys Airport (16461 Sherman Way, Van Nuys), about 80 

meters east of the main runway blast fence and downwind of the majority of the main runway

(Table 2-2; Figure 2-3e). This is a general aviation airport where aircraft with piston-driven 

engines still use leaded avgas. 

Trends in monthly-average TSP lead concentrations for all of AQMD’s source-oriented sites are 

shown in Figure 2-4. Overall, lead levels have been reduced substantially since the early 1990s 

(from values as high as 3.66 μg/m3in 1991 to concentrations that are close to or below 0.15 

μg/m3in 2011). This improvement reflects the reduction in lead emissions from large battery 

recycling facilities following the adoption of rules 1420 and 1420.1. However, as shown in Table 

2-2, the 2008-2010 design value for lead calculated at the Exide-Rehrig station (about 15 m east 

of Exide Technologies in Vernon) was 2.49 μg/m3, which was well above the current 2008 

NAAQS. The 2008-2010 design value for lead calculated for the Exide-AT&SF site (150 m 

north-east of the same facility) was substantially lower (0.22 μg/m3), but still above the current 

federal standard. 
Chapter 2: Lead Air Quality in Los Angeles

2 - 7

The preliminary 2009-2011 design values in Table 2-2 show considerable improvement. The 

only site above the new 2008 NAAQS for lead is the Rehrig site at Exide Technologies with a 

three-year design value of 0.66 μg/m3. Furthermore, as shown in Figure 2-4, the most recent 

month of data (December 2011) at the Rehrig site is actually below the 0.15 μg/m3level. Since 

lead is typically found in larger particles (those with an aerodynamic diameter larger than 2.5 

μm) its atmospheric concentration decreases rapidly from the point of release and, as a result, 

lead impacts are localized. With the exceptions listed above, monthly average lead 

concentrations at all AQMD’s source-oriented sites have been below 0.15 μg/m3since 

November 2008 and suggest a decreasing trend (Figure 2-4). Monthly average values at Van 

Nuys Airport have never exceeded 0.04 μg/m3.

The monthly average data shown in Figure 2-4 are not directly comparable to the three-month 

average form of the federal standard specified by EPA, but are provided to better illustrate longterm trends and the substantial reduction in the atmospheric concentration of lead that has 

occurred in the Los Angeles County portion of the South Coast Air Basin since the mid 70s. All 

lead measurements presented in this section have been calculated from daily (24-hour) average 

values measured by AQMD staff. Some of this special monitoring data is not available in AQS,

but it has been included in the supplemental CD provided with this document, which also 

includes all available daily, one-month, and three-month average lead concentrations for all 

source-oriented sites. This data is public and can be requested through the Public Information 

Records Act request process. 
Chapter 2: Lead Air Quality in Los Angeles

2 - 8

FIGURE 2-3

Location of all source-oriented sites 

operated by AQMD near:

a) Exide technology (Vernon facility), 

b) Exide Technology (Commerce facility),

c) Quemetco Inc., 

d) Trojan Battery, and 

e) Van Nuys airport.
Chapter 2: Lead Air Quality in Los Angeles

2 - 9

TABLE 2-2

AQMD’s source oriented sites measuring Total Suspended Particulate (TSP) lead since 1991 with available design values 

for the 2008-2011 timeframe

Lead Design Value (μg/m3) Lead Design Value (μg/m3)

Start End (2008-2010)* (2009-2011)*

Exide-Ayers 1

2249 Ayers Ave., Commerce

Exide-Ayers 2

EXIDE TECH (VERNON) Ayers and Washington Intersection, Vernon

2700 South Indiana Street, Vernon Exide-AT&SF

AT&SF Railroad Yard, Washington Blvd., Vernon

Exide-Rehrig

4010 East 26th Street, Vernon, CA

EXIDE TECH (COMMERCE) Exide-61st Street

5909 E Randolph St, Commerce 61st St., Commerce

Industry-7th Ave

500 S. 7th Ave, Industry^*

QUEMETCO INC. Industry-Lake Ave

720 S 7th Ave, Industry 14755 E. Salt Lake Ave., Industry

Industry-Post office

500 S. 7th Ave, Industry^*

TROJAN BATTERY Santa Fe Springs

9440 Ann Street, Santa Fe Springs 9440 Santa Fe Springs Rd, Santa Fe Springs^^

VAN NUYS AIRPORT Van Nuys Airport

16461 Sherman Way, Van Nuys 16461 Sherman Way, Van Nuys

*Highest valid 3-month site-level mean over the most recent 38-month period (November 2007-December 2010)

#Preliminary value calculated as the highest valid 3-month site-level mean over the most recent 35-month period (November 2008-September 2011)

Lead data from October 2011 to December 2011 will be available soon

^Sampling was interrupted on October 1992 and resumed on January 2001

**Sampling was interrupted on December 2006 and resumed on October 2008

^*On 10/06/2003 sampler was moved move to a nearby location (same address)

^^On 01/01/2001 sampler was moved from 9440 Santa Fe Springs Rd to 9331 Santa Fe Springs Rd

0.11#

NA

NA

0.12#

NA

01/06/99 05/31/06 NA

NA

0.03

0.08

0.66

NA

Ongoing

Ongoing 0.22

NA

NA

2.49

01/06/99 12/26/00 NA

2/17/1991^ Ongoing NA**

03/13/91 09/15/91 NA

01/02/10 12/22/10 NA

01/01/01 Ongoing 0.12

Facility Name and Address

11/14/2007

Source-oriented Site Name and Address Sampling

04/19/91

02/05/91 10/27/92

6/23/2008 Ongoing
Chapter 2: Lead Air Quality in Los Angeles

2 - 10

FIGURE 2-4

Monthly average Total Suspended Particulate (TSP) lead concentrations at all source-oriented 

sites from 1991 to 2011. The dotted line in the magnified portion of the graph represents the 

current 2008 NAAQS for lead (0.15 μg/m3)
Chapter 2: Lead Air Quality in Los Angeles

2 - 11

FENCE-LINE MEASUREMENTS

Monitoring of TSP lead in close proximity to Exide Technologies (Vernon facility) and 

Quemetco Inc. (the two largest lead-acid battery recycling facilities in Los Angeles County) has 

been conducted by the facilities in accordance with AQMD Rules 1420 and 1420.1 for several 

years. Fence-line monitors are located at or inside the facility property line at the points of 

maximum expected ground level lead concentrations. They allow AQMD to identify specific 

areas of the recycling facility where lead emissions are particularly high. Since monitoring 

locations are generally sited on facility property in non-public areas the measurements are not 

considered ambient air by EPA’s definition for NAAQS comparison purposes. The data from 

these sites is included here to show trends in ambient levels at additional monitoring locations to 

those operated by AQMD, and to show the effectiveness of AQMD rule requirements for 

monitoring and reducing lead emissions from these facilities. 

Exide Technologies – Vernon Facility 

Since January 2006, this plant has been operating between three and six fence-line lead monitors 

(AT&SF, SE, SW, New NE, New N, and MID) near the property line (Figure 2-5). An additional 

monitor (New NW) was added in May 2008 but ceased sampling in June 2008 (Table 2-3). Lead 

samples are collected on a 1-in-3 day schedule, although higher sampling frequency is required 

by Rule 1420.1 at sites where measured concentrations are repeatedly high.

Average lead concentrations (expressed as 30-day rolling averages) recorded at the fence-line 

monitors installed near the Exide facility have continuously exceeded the 0.15 μg/m3over the 

majority of the sampling period (Figure 2-6). However, the most recent 30-day rolling averages 

from December 2011 have dropped below the limit established by Rule 1420.1, which became 

effective on January 1, 2012. The highest 30-day average TSP lead level (2.41 μg/m3) was 

measured at the New N site in July 2009. Fugitive lead emissions from this battery recycling 

plant have been decreasing substantially since the initial measurements at Rehrig in 2009 and the 

adoption of Rule 1420.1 in 2010. As mentioned earlier, fugitive lead particles are relatively 

large, and tend to settle out quickly after they are emitted. As a result, the highest concentrations 

occur only in the immediate vicinity of an emission source, with concentrations dropping off 

rapidly with distance. In a recent guidance, EPA defined the critical transport distance for TSP 

lead as 2 miles.
Chapter 2: Lead Air Quality in Los Angeles

2 - 12

FIGURE 2-5

Location of all fence-line monitoring sites (SW, MID, New N, New, NE, New NW, SE and 

AT&SF) operated near Exide Technologies (Vernon facility). The faded yellow area represents 

the perimeter of the facility

TABLE 2-3

Name and location of all fence-line and off-site monitoring stations operated by Exide 

Technologies (Vernon facility). Sampling at these locations has been conducted since 2006. 

Monitoring

Conducted by

AT & SF Exide 01/03/06 Ongoing

SE Exide 01/03/06 Ongoing

SW Exide 01/03/06 Ongoing

New NW Exide 05/24/08 06/20/08

New NE Exide 01/22/09 Ongoing

New N Exide 01/22/09 Ongoing

MID Exide 11/18/09 Ongoing

Site Sampling

Name Start End
Chapter 2: Lead Air Quality in Los Angeles

2 - 13

FIGURE 2-6

Fence-line 30-day rolling average lead concentrations at the Exide recycling battery facility. 

The dotted line in the lower portion of the Figure represents the current rule 1420.1 rule limit 

adopted by AQMD (0.15 μg/m3)

Quemetco Inc. 

This facility has been operating three fence-line lead monitors (Sites 1, 2 and 3) since May 2001 

(Figure 2-7). An additional monitor (Site 4) was added in May 2003 and Site 3 was moved to the 

north-west corner of the plant and renamed as Site 5 on September 2007 (Table 2-4). Also in this 

case, lead samples are currently collected on a 1-in-3 day schedule per Rule 1420.1. 

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

4.0 January-06 January-07 January-08 January-09 January-10 January-11 January-12 TSP Lead (30-day rolling ave; μg/m3

)

AT & SF SE SW New NW New NE New N MID

0.0

0.1

0.2

0.3

0.4 January-11 February-11 March-11 April-11 May-11 June-11 July-11 August-11 September-11 October-11 November-11 December-11 January-12 TSP Lead (30-day rolling ave; μg/m3

)

Rule 

1420.1
Chapter 2: Lead Air Quality in Los Angeles

2 - 14

Figure 2-8 shows 30-day rolling average lead concentrations for all five fence-line monitors 

surrounding Quemetco Inc. The average levels have been decreasing in the past few years, and 

have been mostly below the Rule 1420.1 limit for the most recent six months of data. (Table 2-

4) Quemetco. The highest 30-day average TSP lead concentration was 1.37 μg/m3and was 

measured at Site 1 in January 2006. Generally, fence-line monitors #1 and #5 (closely located to 

the part of the plant where the recycling process occurs) have exhibited the highest average 

values. Fugitive lead emissions from this and other lead-acid battery recycling facilities have 

been decreasing substantially since the adoption of Rule 1420.1 in 2010.
Chapter 2: Lead Air Quality in Los Angeles

2 - 15

FIGURE 2-7

Location of all fence-line monitoring stations (Sites 1, 2, 3, 4 and 5) operated near Quemetco 

Inc. The faded yellow area represents the perimeter of the facility.

TABLE 2-4

Name and location of all fence-line monitoring stations operated by Quemetco Inc. Sampling at 

these locations has been conducted since 2001. 

Monitoring 

Conducted by

Site 1 Quemetco 05/09/01 Ongoing

Site 2 Quemetco 05/01/01 Ongoing

Site 3 Quemetco 05/01/01 18-Sep-07

Site 4 Quemetco 05/01/03 Ongoing

Site 5 Quemetco 09/21/07 Ongoing

Site Sampling

Name Start End
Chapter 2: Lead Air Quality in Los Angeles

2 - 16

FIGURE 2-8

Fence-line 30-day rolling average lead concentrations at the Quemetco recycling battery 

facility. The dotted line in the lower portion of the Figure represents the current rule 

1420.1 rule limit adopted by AQMD (0.15 μg/m3)

Note that since Trojan Batteries is not a lead-acid battery recycler and their throughput is below 

Rule 1420 criteria, no facility-operated fence-line monitor is required around or near its property 

line.

0.0

0.5

1.0

1.5

2.0

2.5

3.0 January-01 January-02 January-03 January-04 January-05 January-06 January-07 January-08 January-09 January-10 January-11 January-12 TSP Lead (30-day rolling ave; μg/m3

)

Site 1 Site 2 Site 3 Site 4 Site 5

0.0

0.1

0.2

0.3

0.4 January-11 February-11 March-11 April-11 May-11 June-11 July-11 August-11 September-11 October-11 November-11 December-11 January-12 TSP Lead (30-day rolling ave; μg/m3

)

Rule 

1420.1
Chapter 2: Lead Air Quality in Los Angeles

2 - 17

SUMMARY

The Los Angeles County portion of the South Coast Air Basin is the only area in California 

designated as non-attainment for the 2008 federal lead NAAQS (0.15 μg/m3; measured as a 

rolling three-month average “not to be exceeded” over a three-year period). This nonattainment 

status is due to lead emissions from two large battery recycling facilities, Exide Technologies 

(located in the City of Vernon) and Quemetco Inc. (City of Industry). AQMD has jurisdiction 

over stationary sources in Los Angeles County and has been proactive in mitigating their impact 

on ambient lead concentrations through Rule 1420 (Emissions Standard for Lead) and Rule 

1420.1, which applies specifically to large lead-acid battery recycling facilities. Although 

emissions from Exide and Quemetco are only recently below Rule 1420.1 limits, and are still 

causing a violation of the federal standard over the last three-year period, lead concentrations at 

all ambient network sites in the Los Angeles County portion of the Basin are well below the new 

2008 NAAQS for lead, with typical levels of about 0.01 μg/m3. Therefore, based on the 

historical lead measurements in the Los Angeles County, it is clear that the only potential 

locations for NAAQS exceedances are in the vicinity of these two battery-recycling facilities that 

are subject to AQMD Rule 1420.1. 
CHAPTER 3

LEAD INVENTORY

Introduction

Emission Inventories

Base and Future Year Emissions

Uncertainty in the Inventory
Chapter 3: Current Lead Inventory

3 - 1

INTRODUCTION

This chapter summarizes emissions that occurred in the Los Angeles County portion of the 

South Coast Air Basin, excluding San Clemente and Santa Catalina Islands (Southern Los 

Angeles County), during the base year 2010, and projected emissions for 2015.

These inventory years are selected to comply with federal and state Clean Air Act 

requirements. The 2010 base year emissions inventory reflects adopted air regulations with 

current compliance dates as of 2010; whereas 2015 emissions inventory shows projected 

emissions based on growth factors and compliance requirements between 2010 and 2015.

The emissions inventory is divided into four major classifications: point, area, off-road, and 

on-road sources. The 2010 base year point source emissions are based principally on 

reported data from facilities. The 2010 on-road emissions are calculated using the CARB 

EMFAC2007 V2.3 emission factor and the transportation activity data provided by the 

Southern California Association of Governments (SCAG) from their modified 2004 Regional 

Transportation Plan (2004 RTP) as used in the 2007 AQMP.

1

 The 2010 area source and offroad emissions are also calculated based on 2007 AQMP inventories and projections. These 

emissions were developed primarily based on estimated activity levels and emission factors. 

The future projections rely upon the 2004 RTP, and the planning assumptions and the best 

available information from CARB’s EMFAC for the on-road mobile source emissions 

inventory, CARB’s off-road model for the off-road mobile source emission inventory, the 

latest point source inventories, emission limits in adopted rules, air quality modeling 

analysis, and SCAG’s growth forecast assumptions utilized in the 2007 AQMP. It should be 

noted that the draft 2012 RTP forecasts and EMFAC2011 are not used in this analysis since 

they were not finalized as of the preparation of the Draft Lead SIP, and the 2004 RTP and 

EMFAC2007 represent more conservative estimates. 

EMISSION INVENTORIES

There are a variety of activities that can contribute to lead emissions, which are grouped into 

two general categories, stationary sources and mobile sources. Stationary sources can be 

further divided into “point” and “area” sources. Point sources have one or more identified 

and fixed pieces of equipment and emission points at a permitted facility which are reported 

to the AQMD through the Annual Emissions Reporting Program (AER).

2

 Area sources 

consist of widespread and numerous smaller emission sources such as smaller permitted 

facilities, households, or other land uses. Mobile sources can also be grouped into two major 

categories, “on-road” and “other” mobile sources. On-road mobile sources include light-duty 

automobiles, light-, medium-, and heavy-duty trucks; and motorcycles. Examples of “other” 

mobile sources include aircraft, locomotives, construction equipment, mobile equipment, and 

off-road recreational vehicles. 

 

1

South Coast Air Quality Management District, “Final 2007 Air Quality Management Plan,” June 2007.

2

From AQMD’s website, available at: http://www.aqmd.gov/aer/aer.html
Chapter 3: Current Lead Inventory

3 - 2

Emissions of lead have dropped substantially over the past forty years. The reduction before 

1990 is largely due to the phase-out of lead as an anti-knock agent in gasoline for on-road 

automobiles. Substantial emission reductions have also been achieved due to enhanced 

controls in the metals processing industry.

Historically, the major source of lead air emissions has been gasoline-powered motor 

vehicles. Motor vehicle emissions of lead have been dramatically reduced due to the phaseout of leaded gasoline, but lead is still used as an additive in general aviation gasoline (avgas) 

and remains as a trace contaminant in other fuels. Avgas is only utilized in general aviation 

aircraft with piston engines, which are generally used for instructional flying, air taxi 

activities, recreational flying, and personal transportation. Emissions of lead from pistonengine aircraft using leaded avgas comprise approximately half of the national inventory of 

lead emitted to the air.

Sources of lead from stationary sources are mainly from larger industrial sources including 

but not limited to, metals processing, particularly primary and secondary lead smelters. Lead 

can also be emitted from sources such as iron and steel foundries; primary and secondary 

copper smelters; industrial, commercial, and institutional boilers; waste incinerators; mineral 

processes & glass manufacturing; and refineries. The lead-acid battery recycling industry has 

been determined by AQMD staff to be the highest stationary source emitters of lead in Los 

Angeles County. Staff’s analysis has shown this industry to be the only known stationary 

source category that has the potential to cause violations of the new lead NAAQS. 

BASE AND FUTURE YEAR EMISSIONS

For the purpose of this SIP, the baseline for lead emissions was set at 2010. Table 3-1 shows 

the 2010 lead emissions inventory and projected 2015 lead emissions inventory by major 

source category. Overall, about 4.25 tons per year (TPY) of primary lead emissions are 

emitted by mobile sources which accounts for 23 percent of the total lead inventory for the 

Los Angeles County. Within the mobile source category, emissions from aircraft make up 

about 93 percent of all mobile source emissions. This is due to the fact that lead is still used 

as an additive in general aviation fuel (avgas) for aircraft with piston engines. Seventy seven 

percent of total lead inventory is attributed to stationary sources with a 90 percent 

contribution from construction and demolition and paved road dust. 

Stationary Sources

The 2010 base year stationary source emissions presented in this chapter are based on the 

emissions data reported by each facility in the AQMD’s 2010 AER program. Facilities 

calculate and report their emissions primarily based on their throughput data (e.g. fuel usage, 

material usage), appropriate emissions factors or source tests, and control efficiency (if 

applicable). Table 3-2 provides Los Angeles County 2010 lead emissions for all facilities 

with reported lead emissions over one pound per year. In 2010, no facility reported lead 

emissions greater than 0.50 TPY, the threshold for monitoring under EPA regulations to 

evaluate compliance with the lead NAAQS. Inventories in previous years showed Exide 
Chapter 3: Current Lead Inventory

3 - 3

Technologies emitting over 0.50 TPY, and the AQMD continues to monitor at Exide even 

though the recent lower emissions inventory does not require it under the federal regulation. 

The nonattainment status in the Los Angeles County is based on lead emissions from two 

large lead battery recycling facilities, Exide Technologies and Quemetco Inc., and fugitive 

lead emissions are believed to be a major source of lead at these two facilities. Given the fact 

that fugitive emissions cannot be readily captured or directly measured, they are challenging 

to estimate. As such, the methodology in the EPA document titled: "Development of the 

RTR Emissions Dataset for the Secondary Lead Smelting Source Category", used for 

development of Secondary Lead Smelting NESHAP was used by AQMD staff to estimate 

fugitive emissions from these two facilities.3 The document uses data collected by EPA on 

June of 2010 as part of an information collection request (ICR) pursuant to section 114 of the 

CAA to six companies who own 14 secondary lead smelting facilities operating in the United 

States. The emissions and process data collected under the ICR were used to develop sitespecific baseline emissions estimates for each of the facilities. The fugitive emission 

estimation methodology evaluated the estimates of fugitive lead emissions that were 

submitted by each facility under the 2010 ICR program, and selected the ones that seemed 

reasonable and relatively complete. Due to the lack of reasonable estimates at nine facilities 

and the large amount of variability in emissions estimates and methodologies between the 

other facilities, the emissions provided by one facility were selected as a model for 

estimating fugitive emissions at all other facilities. Each facility was compared to the model 

facility and an estimate of total lead fugitives was calculated based on a number of factors 

that described the activity level at the facility. The lead emission estimates for each facility 

were calculated by multiplying the fugitive lead emissions rate for the model facility (0.71 

tons/yr) by a site-specific size factor, enclosure factor, and housekeeping factor. 

The size factors were developed based on the activity level of each facility based on several 

factors (e.g. vehicle traffic, facility footprint and arrangement, as well as other factors) 

supplied in the ICR. The size factors developed for Exide (Vernon) and Quemetco were 1.84 

and 1.19, respectively. 

The information provided by each facility regarding the degree of containment of secondary 

lead smelting processes was used to categorize the facilities as having Level 1 enclosure, 

Level 2 enclosure, or Level 3 enclosure. Level 3 enclosure is consistent with the enclosure 

requirements identified in Rule 1420.1. The facilities categorized as having Level 3 

enclosure generally have complete enclosures with negative pressure for all their process 

activities. A factor of 0.25 was assigned to facilities with total enclosures for all processes 

(level 3) which reflects 75% reduction from total enclosure. Total enclosures can provide up 

to 99% control of fugitive emissions from the source inside a building, however, this factor 

was chosen for our facilities as a reasonable conservative estimate. 

A housekeeping factor was also developed to characterize the level of work practices 

implemented by each facility to control fugitive emissions. Factors ranging from 1.0 (work 

practices consistent with the NESHAP) to 0.2 (work practices far beyond the NESHAP) were 

 

3

From EPA’s website, available at http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2011-0344-

0163
Chapter 3: Current Lead Inventory

3 - 4

applied to the fugitive lead estimates in order to reflect reductions that are likely to occur due 

to the work practices in place at each facility. A housekeeping factor of 0.2 is consistent with 

practices specified in Rule 1420.1. However, in the EPA document, a housekeeping factor of 

0.5 was used for Exide since at the time, Exide had not yet incorporated all of the enhanced 

housekeeping measures. In consultation with EPA, it is appropriate to use the housekeeping 

factor of 0.2 in the calculation, since both facilities are now required to implement the 

measures in Rule 1420.1.4

Using the EPA formula, estimated fugitive lead emissions for Exide (Vernon) and Quemetco 

are 130 lbs/yr and 85 lbs/yr, respectively. 

The future emissions forecasts for stationary sources were derived using emissions from the 

2010 base year, and emissions growth in various source categories between the base and 

future year. Demographic growth forecasts for various socioeconomic categories (e.g., 

population, housing, employment by industry), as well as industry growth factors utilized in 

the 2007 AQMP were used to estimate future emissions. It should be noted that 2015 

inventories are based on growing the level of lead emissions estimated for 2010 using growth 

factors developed before the 2008 economic downturn. This results in a conservatively high 

estimate of future emissions for 2015.

Future emissions for the individual facilities that have the potential to cause NAAQS 

exceedances are discussed as part of the control strategy in Chapter 5. 

Area sources include source categories associated with human activity causing emissions that 

take place over a wide geographic area. Construction and demolition, and unpaved road dust 

are examples of area sources. CARB maintains and updates estimates of the chemical 

composition and particle size fractions for each source profile which are then used in 

emission inventory and air quality models. Area source lead emissions are calculated by 

applying the latest CARB speciation profiles for lead to the total particulate matter 

emissions.5 CARB particulate matter speciation profile #420 was used for estimating 

emissions from “Construction and Demolition” and profile #471 was used for estimating 

emissions from “Paved Road Dust.” The lead fraction of PM emissions is 0.0557 percent for 

“Construction and Demolition” and 0.0124 percent for “Paved Road Dust.” The source of 

lead in the PM emissions from these source categories are likely from the historical lead 

content in materials, such as paint and gasoline. Although the total lead inventory is 

dominated by these sources, the lead from area sources is emitted over a wide geographical 

area and the ambient lead concentrations (illustrated in Chapter 2) show that they currently 

do not lead to high ambient levels or NAAQS exceedances. 

Mobile Sources

The 2010 base year emissions inventory for all mobile sources categories are developed 

using the same methodology as described below, with the exception of aircraft emissions. 

 

4 Nathan Topham, EPA, conversation with AQMD staff, 3/8/2012.

5

CARB speciation profiles can be viewed or downloaded from the following CARB link: 

http://www.arb.ca.gov/ei/speciate/interopt01.htm
Chapter 3: Current Lead Inventory

3 - 5

The mobile source emissions summaries were developed using emissions that occurred in 

Los Angeles County during the base year 2002 as identified in the “Final 2007 Air Quality 

Management Plan” for AQMD, and projected emissions for the years 2010, and 2015. Onroad vehicle emissions are calculated using socioeconomic data and transportation models 

provided by SCAG, spatial distribution data from Caltrans’ Direct Travel Impact Model 

(DTIM4), and EMFAC2007 V2.3 inventories obtained from CARB. The EMFAC2007 V2.3 

reflects SCAG’s revised baseline activity data from the modified 2004 RTP. The 2000 

Census data, combined with SCAG’s 2001 origin and destination survey data, are used in 

SCAG’s modified 2004 RTP and in this SIP. Lead emissions from off-road vehicle 

categories (e.g., trains, ships, construction equipment, ports and rail cargo handling 

equipment) were developed primarily based on estimated activity levels, emission factors, 

and latest CARB speciation profiles for the particulate matter emissions. The forecasts for 

emissions were derived using: 1) emissions from the 2002 base year; 2) expected controls 

after implementation of District rules adopted by June 30, 2006, and most CARB rules 

adopted as of June 2005; and 3) emissions growth in various source categories between the 

base and 2015. Demographic growth forecasts for various socioeconomic categories (e.g., 

population, housing, employment by industry), developed by SCAG, were used in the 

modified 2004 RTP to estimate future emissions. Industry growth factors for 2002, 2010, 

and 2015 were provided by SCAG.

The aircraft lead emissions for 2010 were developed using historical airport specific 

operations data reported for 2008 and forecast operations data for 2010 and 2015 in the 

Terminal Area Forecast (TAF) system in the Federal Aviation Administration (FAA 

database) when available.6The TAF system is the official forecast of aviation activity at 

FAA facilities. Emissions from general aviation aircraft with piston engines were estimated 

using the methodology outlined in the 2008 National Emissions Inventory (NEI) developed 

by EPA, and scaling it to 2010 and 2015 using TAF forecast data.7 The 2008 NEI utilizes 

Appendix B of the updated Technical Support Document (TSD) titled “'Calculating PistonEngine Aircraft Airport Inventories for Lead for the 2008 National Emissions Inventory”.8

 

The methodology employed here uses the January 15, 2009 version of the Federal Aviation 

Administration (FAA) 5010 airport data report.9 Table 3-3 provides the lead emission 

inventory for piston engine aircrafts for Los Angeles County airports. 

The piston aircraft activity is reported to the FAA as general aviation (GA) or Air Taxi (AT) 

activity. Airport-specific inventories require information regarding landing and takeoff 

(LTO) activity by aircraft type. An aircraft operation is defined as any landing or takeoff 

event; therefore, to calculate LTOs, operations are divided by two. Most data sources from 

 

6

From FAA’s website, “Terminal Area Forecast”, available at: http://aspm.faa.gov/main/taf.asp.

7 Environmental Protection Agency, “2008 National Emissions Inventory, Version 1,”

(http://www.epa.gov/ttn/chief/net/2008inventory.html), January 27, 2011.

8 Environmental Protection Agency, “Documentation for Aircraft Component of the National Emissions Inventory 

Methodology,” January 27, 2011

9

From FAA’s website, available at: http://www.faa.gov/airports_airtraffic/airports/airport_safety/airportdata_5010/
Chapter 3: Current Lead Inventory

3 - 6

FAA report aircraft activity in numbers of operations, which, for the purposes of calculating 

lead emissions were converted to LTO events. To calculate LTOs for piston engine aircrafts, 

operations of GA and AT aircrafts were summed and then divided by two. The 

methodology and equations identified in Appendix B of the updated TSD were utilized to 

calculate lead emissions for piston engine aircrafts, as follows:

Lead Emissions (TPY) = (piston-engine LTO) * ( 7.7 X 10 -6)

Where piston-engine LTO = (GA LTO x 0.725) + (AT LTO x 0.231)

This methodology assumes certain fractions of GA and AT operations are piston-driven 

aircraft. 

Several smaller airports did not have TAF forecast data, and those airports are indicated with 

an asterisk (*) in Table 3-3. For those facilities, 2010 and 2015 LTO estimates were 

developed using the average growth of the other Los Angeles County airports that are 

included in the TAF forecasts, applied to the actual reported 2008 LTOs. The growth ratios 

were developed as follows:

Growth Ratio = 2010 LTO * 7.7 X 10 -6

 2008 LTO * 7.7 X 10 -6

2010 Emissions = 2008 Emissions * Growth Ratio

Current EPA regulations require NAAQS monitoring at airports emitting over 1.0 ton per 

year of lead. Based on an earlier version of the EPA’s 2008 NEI inventory that is not 

reflected in Table 3-3, Van Nuys Airport (VNY) exceeded this threshold and, based on that 

inventory, AQMD established a monitor near this source. Although a subsequent revision to 

the NEI, reflected in Table 3-3, showed less than one ton per year of lead emitted from VNY, 

AQMD continues to monitor there to demonstrate compliance with the NAAQS. Chapter 2 

presents data from this site showing levels much lower than the national ambient lead 

standard.

As also shown in Table 3-3, the revised 2008 NEI calculates more than one ton per year of 

lead emissions from Long Beach/Daugherty Field (LGB). Although this would trigger the 

federal monitoring requirements if this level of emissions persisted, the 2010 and future year 

inventories show less than one ton per year. Thus, no lead monitoring is currently required. 
Chapter 3: Current Lead Inventory

3 - 7

TABLE 3-1

2010 & 2015 Lead Emission Inventory by Major Source Category

Los Angeles County (TPY)

SOURCE CATEGORY 2010 2015

STATIONARY SOURCES

Fuel Combustion

Electric Utilities 0.02 0.02

Cogeneration 0.01 0.01

Petroleum Refining (Combustion) 0.05 0.05

Manufacturing and Industrial 0.08 0.08

Service and Commercial 0.04 0.04

Total Fuel Combustion 0.20 0.20

Waste Disposal

Incinerators 0.01 0.01

Total Waste Disposal 0.01 0.01

Petroleum Production & Marketing

Petroleum Refining 0.03 0.03

Petroleum Production & Marketing 0.03 0.03

Industrial Processes

Mineral Processes 0.06 0.06

Metal Processes 0.42 0.38

Glass and Related Products 0.02 0.02

Total Industrial Processes 0. 50 0.46

Miscellaneous Processes

Residential Fuel Combustion 0.02 0.02

Construction and Demolition 5.80 6.05

Paved Road Dust 6.83 6.91

Unpaved Road Dust 0.47 0.47

Fugitive Windblown Dust 0.06 0.06

Fires 0.01 0.01

Waste Burning and Disposal 0.03 0.03

Total Miscellaneous Processes 13.22 13.56

TOTAL STATIONARY SOURCES 13.96 14.26
Chapter 3: Current Lead Inventory

3 - 8

TABLE 3-1 (Continued)

2010 & 2015 Lead Emission Inventory by Major Source Category

Los Angeles County (TPY)

SOURCE CATEGORY 2010 2015

MOBILE SOURCES

On-Road Vehicles

 Light-Duty Passenger 0.09 0.09

 Light & Medium Duty Trucks 0.06 0.07

 Heavy-Duty Gas Trucks 0.00 0.00

 Heavy-Duty Diesel Trucks 0.07 0.06

 Total On-Road Vehicles 0.23 0.22

Other Mobile

 Aircraft 3.95 3.98

 Trains 0.01 0.01

 Ships & Commercial Boats 0.00 0.00

 Off-Road Equipment 0.06 0.03

 Total Other Mobile 4.02 4.02

 Total On-Road Vehicles 0.23 0.22

 Total Other Mobile 4.02 4.02

 Total Mobile Sources 4.25 4.24

TOTAL ALL SOURCES 18.21 18.50
Chapter 3: Current Lead Inventory

3 - 9

TABLE 3-2

2010 Lead Emissions by Facility Emitting Over One Pound per Year

Los Angeles County 

Facility ID Facility Name

2010 Lead 

Emissions 

(lbs/yr)

2010 Lead 

Emissions 

TPY

124838 EXIDE TECHNOLOGIES * 655.54 3.28E-01

17325 ACE CLEARWATER ENTERPRISES 117.81 5.89E-02

800089 EXXONMOBIL OIL CORPORATION 99.44 4.97E-02

8547 QUEMETCO INC. * 96.21 4.81E-02

131249 BP WEST COAST PRODUCTS LLC,BP WILMINGTON 78.76 3.94E-02

13854 EAST LOS ANGELES COLLEGE 68.04 3.40E-02

7427 OWENS-BROCKWAY GLASS CONTAINER INC 48.22 2.41E-02

800030 CHEVRON PRODUCTS CO. 29.60 1.48E-02

124805 EXIDE TECHNOLOGIES 27.72 1.39E-02

800363 CONOCOPHILLIPS COMPANY 24.75 1.24E-02

140878 LIBERTY MFG INC 22.50 1.12E-02

800327 GLENDALE CITY, GLENDALE WATER & POWER 20.80 1.04E-02

4477 SO CAL EDISON CO 18.44 9.22E-03

44577 LONG BEACH CITY, SERRF PROJECT 18.07 9.04E-03

131003 BP WEST COAST PROD.LLC BP CARSON REF. 16.24 8.12E-03

21872 TROJAN BATTERY CO 12.66 6.33E-03

800026 ULTRAMAR INC (NSR USE ONLY) 9.20 4.60E-03

16338 KAISER ALUMINUM FABRICATED PRODUCTS, LLC 8.79 4.39E-03

800335 LA CITY, DEPT OF AIRPORTS 6.48 3.24E-03

123774 HERAEUS METAL PROCESSING, LLC 6.44 3.22E-03

800236 LA CO. SANITATION DIST 6.28 3.14E-03

37507 TROJAN BATTERY CO 6.05 3.02E-03

800362 CONOCOPHILLIPS COMPANY 5.60 2.80E-03

93399 BARRY CONTROLS 5.56 2.78E-03

800409 NORTHROP GRUMMAN SYSTEMS CORPORATION 5.19 2.60E-03

148236 AIR LIQUIDE LARGE INDUSTRIES U.S., LP 4.35 2.17E-03

83102 LIGHT METALS INC 2.62 1.31E-03

8927 GLOBE IRON FOUNDRY INC 1.87 9.35E-04

20604 RALPHS GROCERY CO 1.79 8.96E-04

7796 TECHNI-CAST CORP 1.78 8.89E-04

91868 THE STRELITZ CO INC 1.73 8.64E-04

152952 SA RECYCLING LLC DBA SA RECYCLING OF LA 1.67 8.33E-04
Chapter 3: Current Lead Inventory

3 - 10

Facility ID Facility Name

2010 Lead 

Emissions 

(lbs/yr)

2010 Lead 

Emissions 

TPY

144010 L-3 COMMUNICATIONS ELECTRON TECH INC 1.35 6.73E-04

800037 DEMENNO/KERDOON 1.26 6.28E-04

82613 ANCON MARINE INC 1.12 5.60E-04

37336 COMMERCE REFUSE TO ENERGY FACILITY 1.06 5.31E-04

154540 ARROWHEAD BRASS PRODUCTS 1.02 5.10E-04

* For these facilities, fugitive emissions estimated by EPA for lead-acid battery recyclers were added to the point 

source emissions to obtain total facility emissions (http://www.regulations.gov/#!documentDetail;D=EPA-HQOAR-2011-0344-0163). The lead fugitive emissions for each facility were calculated as follows:

Fugitive lead emissions (Lbs/Yr) = (0.71 tons/yr * size factor * enclosure factor * Housekeeping factor) * 2000

 Exide fugitive emissions = (0.71 * 1.84 * 0.25 * 0.2) * 2000 = 130 lbs/yr

 Quemetco fugitive emissions = (0.71 * 1.19 * 0.25 * 0.2) * 2000 = 85 lbs/yr
Chapter 3: Current Lead Inventory

3 - 11

TABLE 3-3

2008, 2010 & 2015 Lead Emission Inventory for Piston Engine Aircrafts

Los Angeles County (TPY)

Facility 

Identifier Facility Site Name

2008 Lead 

Emissions 

TPY

2010 Lead 

Emissions 

TPY

2015 Lead 

Emissions 

TPY

VNY Van Nuys 0.766 0.888 0.856

LGB Long Beach / Daugherty Field 1.025 0.758 0.807

POC Brackett Field 0.332 0.324 0.300

TOA Torrance / Zamperini Field 0.580 0.300 0.302

SMO Santa Monica Muni 0.326 0.290 0.294

EMT El Monte 0.236 0.245 0.244

WHP Whiteman 0.201 0.238 0.245

CPM Compton / Woodley 0.165 0.184 0.184

HHR

Hawthorne / Jack Northrop 

Field 0.158 0.160 0.163

WJF General Wm J Fox Airfield 0.160 0.157 0.153

LAX Los Angeles International 0.110 0.141 0.162

BUR

Burbank-Glendale-Pasadena 

Airport 0.116 0.126 0.125

AVX Catalina * 0.056 0.058 0.059

PMD Palmdale Prodn Flt/Test 0.032 0.027 0.030

L11 Pebbly Beach * 0.012 0.012 0.012

L70 Agua Dulce Airpark * 0.007 0.007 0.007

0CL6 Bohunk's Airpark * 0.007 0.006 0.007

1CL1 Little Buttes Antique Airfield * 0.006 0.006 0.006

CL46 Quail Lake Sky Park * 0.006 0.006 0.006

64CL Goodyear Blimp Base * 0.005 0.005 0.005

8CL0 Nichols Farms * 0.005 0.005 0.005

46CN Crystal * 0.002 0.003 0.003

Total Piston Engine Aircraft Emissions 4.31 3.95 3.98

 * Avg. 2010 Growth Ratio = 0.98636948 

 * Avg. 2015 Growth Ratio = 1.006049

 * 2010 Emissions = 2008 Emissions * Avg. 2010 Growth Ratio

 * 2015 Emissions = 2008 Emissions * Avg. 2015 Growth Ratio

 For facilities with actual piston engine LTOs:

 Emissions = (piston-engine LTO) * (7.7 X 10 -6) 
Chapter 3: Current Lead Inventory

3 - 12

UNCERTAINTY IN THE INVENTORY

Over the years, significant improvements have been made to quantify emission sources upon 

which control measures are developed. Increased use of source tests has contributed to the 

improvement in point source inventories. Technical assistance to facilities and auditing of 

reported emissions by the AQMD also have improved the accuracy of the emissions 

inventory. However, fugitive emissions are believed to be a significant source of ambient 

lead concentrations in the Los Angeles County, and quantifying fugitive emissions is 

problematic, given the large uncertainties in quantifying fugitive emissions under either 

controlled or uncontrolled scenarios. 

Mobile source inventories also remain a challenge due to the high number and types of 

equipment and engines involved, in-use performance variables, and complex emission 

characteristics. The latest approved models and planning assumptions were used in 

compiling the emissions inventory in this Chapter. 
CHAPTER 4

LEAD CONTROL STRATEGY

Introduction

Overall Attainment Strategy

Existing Lead Emissions Control Regulations

AQMD’s Existing Rules

AQMD’s Proposed Lead Control Measure

Implementing Agency
Chapter 4: Lead Control Strategy

4 - 1

INTRODUCTION

This chapter provides the overall control strategy in achieving emission reductions necessary 

for the attainment of the revised NAAQS for lead in the Los Angeles County portion of the 

Basin. Great strides have been made in lead control technologies and emission reduction 

programs, and attainment of the new lead NAAQS is achievable with the implementation of 

currently adopted AQMD rules. However, an additional control measure is proposed as part 

of this SIP to further ensure future attainment as demonstrated in Chapter 5. 

This chapter presents the control measures for the lead NAAQS and associated emission 

reductions, where currently quantifiable. For additional information regarding baseline 

emission projections and air quality modeling, please refer to Chapter 3 as well as Chapter 5 

and Appendix III, respectively. 

OVERALL ATTAINMENT STRATEGY

Historically, the major source of lead air emissions has been motor vehicles such as cars and 

trucks. Motor vehicle emissions of lead have been dramatically reduced over the past forty 

years due to the phase-out of leaded gasoline, but lead is still used as an additive in general 

aviation gasoline used in piston-engine aircraft and remains a trace contaminant in other 

fuels. Substantial emission reductions have also been achieved due to enhanced controls in 

the metals processing industry. To achieve the revised lead ambient air quality standards 

and ensure continued attainment in Los Angeles County, implementation of current rules and 

a new rule amendment are necessary. 

Sources of lead from stationary sources are mainly from larger industrial sources including 

but not limited to metals processing, particularly primary and secondary lead smelters. 

Emissions consist of those from lead point sources as well as fugitive lead dust emissions. 

Lead point source emissions are generally from the main exhaust of the battery breaking 

process, smelting furnaces, and refining kettles vented through a stack. Fugitive lead dust 

emissions are from facility roadways subject to wind, vehicular, or foot traffic, materials 

handling and storage areas, battery breaking areas, and smelting and refining areas. Lead can 

also be emitted from sources such as iron and steel foundries; primary and secondary copper 

smelters; industrial, commercial, and institutional boilers; waste incinerators; glass 

manufacturing; refineries, and cement manufacturing. Sources of lead from mobile sources 

are mainly from aviation gasoline utilized in general aviation aircraft with piston engines. 

These engines are generally used for instructional and recreational flying, air taxi activities, 

and personal transportation. Emissions of lead from piston-engine aircraft using leaded 

avgas comprise approximately half of the national inventory of lead emitted to air. 

In May 2010, CARB recommended that the Los Angeles County portion of the South Coast 

Air Basin, excluding San Clemente and Santa Catalina Islands (Southern Los Angeles 

County), be designated as nonattainment for the 2008 lead NAAQS based on air quality data 

from 2007-2009. CARB’s recommendation was based on data from Federal Reference 

Method (FRM) or Federal Equivalent Method (FEM) monitors. The 2008 NAAQS for lead 

requires that each state install and operate a network of ambient air lead monitors in order to 

determine attainment status with the standard. Two types of monitors are required; those that 
Chapter 4: Lead Control Strategy

4 - 2

are non-source-oriented, and those that are facility-based referred to as “source-oriented.” 

CARB’s lead designation recommendation was based on data from both sets of monitoring 

networks. Data values from measurements made at non-source-oriented monitors in the 

Basin were reviewed for years 2007 through 2009 and showed concentrations well below the 

new lead NAAQS. Ambient levels at non-source-oriented sites have consistently been an 

order of magnitude less than the new NAAQS for at least six years. Furthermore, the recent 

data at the source-oriented site at Van Nuys Airport also shows no potential to exceed the 

NAAQS. However, the source-oriented monitors near lead-acid battery recyclers showed 

exceedances of the new standard in 2005 at monitors for one facility, and from February 

2008 through January 2010 at monitors for another facility. 

The lead-acid battery recycling industry is the highest stationary source emitter of lead in 

Los Angeles County. Ambient measurements have shown that this industry is the only 

stationary source category that has the potential to cause nonattainment with the new lead 

NAAQS. There are currently two large lead-acid battery recyclers within Los Angeles 

County (the only two in the Western United States: Exide Technologies and Quemetco, Inc.) 

These facilities receive spent (used) lead-acid batteries and other lead-bearing material and 

recycle them, recovering the lead. Lead is recycled because of its value and the reduction of 

toxic waste, and is primarily used to manufacture new batteries. Approximately 98 percent of 

lead acid batteries in the United States are recycled, and all components of the batteries, 

primarily lead, plastic, and acid, are recycled. Through the recycling process, approximately 

95 percent of the lead in the batteries is recovered. 

Given that the ambient lead concentrations at non-source-oriented sites and at the Van Nuys 

Airport site show very low levels relative to the new lead NAAQS, and that the only ambient 

levels exceeding or even approaching the new lead NAAQS are at the sites near the lead-acid 

battery recyclers, the lead attainment strategy is exclusively focused on directly-emitted lead 

from stationary sources. Further controls on mobile sources are not needed.

EXISTING LEAD EMISSIONS CONTROL REGULATIONS

The following provides a chronology of existing lead control regulations:

 In November 1970, CARB set the state ambient air quality standard for lead at 1.5 μg/m3

averaged over 30 days.

 In October 1978, EPA promulgated primary and secondary NAAQS for lead under 

section 109 of the Act (43 FR 46246). Both primary and secondary standards were set at 

a level of 1.5 μg/m3averaged over a calendar quarter.

 In 1987, the California legislature adopted the Air Toxics “Hot Spots” Information and 

Assessment Act. The goals of the Act are to collect emissions data of toxic air 

contaminants, identify facilities having localized impacts, to determine health risks, and 

to notify affected individuals. Facilities with high health risks must reduce their risks to 

the community by incorporating risk reduction plans.

 In December 1990, AQMD adopted Rule 1401 – New Source Review of Toxic Air 

Contaminants. The rule applies to new, relocated, and modified permit units with TAC 
Chapter 4: Lead Control Strategy

4 - 3

emissions. Lead was added to the Rule 1401 list of TACs in 1992. The rule denies 

granting permits to construct a new, relocated or modified permit unit if emissions of any 

TACs create a maximum individual cancer risk (MICR) of greater than one in one 

million at any receptor location unless the permit unit is constructed with Best Available 

Control Technology for Toxics (T-BACT). If the unit has T-BACT, MICR of ten in one 

million is allowed. 

 In September 1992, AQMD adopted Rule 1420 – Emissions Standard for Lead. The rule 

incorporated the state ambient air quality standard 1.5 μg/m3averaged over a 30-day 

period and required control devices on lead emission points, control efficiency 

requirements for lead control devices, housekeeping, and monitoring or modeling of 

ambient air quality.

 In January 1993, CARB adopted the Airborne Toxic Control Measure (ATCM) for 

Emissions of TAC Metals from Non-Ferrous Metal Melting. The state regulation 

required control devices for lead and other toxic metal emission points, control efficiency 

requirements for control devices, fugitive emission control, and recordkeeping.

 In April 1994, AQMD adopted Rule 1402 – Control of Toxic Air Contaminants from 

Existing Sources. The purpose of this rule is to reduce the health risk associated with 

emissions of TACs from existing sources by specifying health limits for cancer and noncancer compounds applicable to total facility emissions and by requiring facilities to 

implement risk reduction plans to achieve specified risk limits, as required by the 

AB2588 “Hot Spots” Program and this rule.

 In June 1997, EPA adopted the National Emissions Standards for Hazardous Air 

Pollutants (NESHAP) from Secondary Lead Smelting. The federal regulation required 

lead emission concentration limits of lead control devices, control of process fugitive 

emissions, monitoring, recordkeeping, and reporting.

 In October 2008, EPA amended the NAAQS for lead from 1.5 μg/m3 to 0.15 μg/m3 

requiring attainment by December 31, 2015, using a rolling 3-month average evaluated 

over three year period. 

 In November 2010, AQMD adopted Rule 1420.1 – Emissions Standard for Lead from 

Large Lead-Acid Battery Recycling Facilities. The purpose of this rule is to protect 

public health and to help ensure attainment with the amended lead NAAQS.

AQMD’S EXISTING RULES

The 2008 lead NAAQS requires full attainment of the revised federal lead standards no later 

than December 31, 2015. The lead-acid battery recycling industry has been determined by 

AQMD staff to be the highest stationary source emitter of lead in Los Angeles County, and 

the only known stationary source category that causes or has the potential to cause 

exceedances of the new lead NAAQS.

The AQMD’s control strategy for this source category is based on the following approaches: 

1) permit conditions; 2) core rule requirements with contingency compliance plans; 3) 
Chapter 4: Lead Control Strategy

4 - 4

process changes; 4) good management practices and housekeeping requirements; and 5) 

more stringent monitoring requirements.

Over the past several years, both facilities (Exide and Quemetco) have been the subject of 

several actions resulting from violations of AQMD rules, including exceeding ambient lead 

limits at fence-line monitors. Violations have led to modifications of facility compliance 

plans, new permit conditions, and in some cases, additional conditions under orders of 

abatement. Many of the conditions have included additional housekeeping requirements, 

process changes, and more frequent monitoring at more locations. The exceedances of Rule 

1420 ambient lead limits, along with the promulgation of the more stringent lead NAAQS by 

EPA, also led to the adoption of AQMD Rule 1420.1 in 2010, applicable specifically to the 

two large lead-acid battery recycling facilities. In addition to air quality regulations, these 

two facilities are subject to other toxics requirements under the California Department of 

Toxic Substances Control (DTSC).

Lead-acid battery recycling facilities are secondary lead smelting operations where spent 

lead-acid batteries, mostly automotive, and other lead-bearing materials are received from 

various sources and processed to recover lead, plastics, and acids. The process mainly 

involves the sorting, crushing, melting, and refining of lead-acid batteries, which ultimately 

produces lead ingots that are then sold to other entities. Several types of controls for lead 

emissions are currently used at the lead-acid battery recycling facilities in the Basin. Lead 

emissions at lead-acid battery recycling facilities are generally categorized as point and 

fugitive lead emissions. Point source emissions are those emissions that are vented to a stack 

where the stack can be from a specific piece of equipment such as a furnace, building, or air 

pollution control device. Fugitive emissions are particulate matter that contain lead, are not 

vented through a stack or control device that can become airborne from anywhere in the 

facility, including dust. Fugitive lead-dust at lead-acid battery recycling facilities can be a 

major source of lead emissions. Fugitive lead-dust deposits and accumulates in and around 

process areas, from lead point sources, on roof tops, in and around a facility, and during 

maintenance operations. There are a variety of housekeeping and management practices that 

can be implemented to minimize fugitive lead dust. Housekeeping activities must be 

implemented frequently and properly to ensure they are effective. The concept behind many 

of these strategies is to either stabilize, contain, or remove lead dust so it cannot become 

airborne. Housekeeping practices specifying adequate frequencies and locations for all 

cleaning actions to be performed are also critical in the effectiveness to control fugitive leaddust emissions. 

Currently, emissions of lead from stationary sources, including lead-acid battery recycling 

facilities, are regulated by AQMD Rule 1420 – Emissions Standard for Lead, and AQMD 

Rule 1420.1 – Emissions Standard for Lead from Large Lead-Acid Battery Recycling 

Facilities. 

Rule 1420 was adopted in August 1992 and controls emissions of lead from stationary 

sources which use or process lead-containing materials. The rule was adopted to help ensure 

that facilities would not discharge emissions which would cause ambient air concentrations 

of lead to exceed the 1978 federal and state ambient air quality standards for lead of 1.5 

μg/m3. 
Chapter 4: Lead Control Strategy

4 - 5

Rule 1420.1 was adopted on November 5, 2010 and controls emissions of lead from large 

lead-acid battery recycling facilities which are the highest stationary source emitter of lead in 

Los Angeles County. The rule was adopted to address the amended NAAQS for lead to 

ensure the Los Angeles County can achieve the revised lead ambient air quality standard of 

0.15 μg/m3. 

Rule 1420 – Emissions Standards for Lead

AQMD Rule 1420 was adopted in September 1992 and has not been amended since its 

adoption. The full text of the Rule is included in Appendix II. The rule applies to facilities 

that process or use lead-containing materials which includes, but is not limited to, primary or 

secondary lead smelters, foundries, lead-acid battery manufacturers or recyclers, and leadoxide, brass and bronze producers. Rule 1420 is based on the state ambient air quality 

standard for lead of 1.5 μg/m3 averaged over a 30-day period, and it ensures that the standard 

is met through requirements for emission control systems, monitoring, sampling, 

recordkeeping, reporting, and good housekeeping practices.

Rule 1420 requires facilities that process more than two tons of lead per year to submit a 

Compliance Plan. Historically, Rule 1420 Compliance Plans have included requirements for 

monitoring, air dispersion modeling, and installation and implementation of point source 

controls.

Under Rule 1420, both Exide and Quemetco are required to maintain and operate two fence 

line monitors to collect samples to demonstrate compliance with the Rule 1420 ambient lead 

standard of 1.5 μg/m3. Each facility currently operates an ambient fence-line air monitoring 

and sampling network. The fence-line monitors are installed at locations that are based on the 

maximum expected ground-level concentrations of lead at or beyond the facility’s property 

line. (See Chapter 2 for the location of Exide’s and Quemetco’s fence-line monitors.)

Since the AQMD’s source-oriented monitors have shown that these two facilities have the 

potential to exceed the new federal lead ambient air quality standard of 0.15 μg/m3, the 

AQMD Governing Board adopted Rule 1420.1 in November 2010. This Rule applies to 

large lead-acid battery recycling facilities that process more than 50,000 tons of lead a year. 

The provisions of Rule 1420.1 are more stringent and are in addition to the requirements of 

Rule 1420. 

Rule 1420.1 – Emissions Standards for Lead from Large Lead-Acid Battery 

Recycling Facilities

Rule 1420.1 was adopted in November 2010 and is designed to address lead emissions from 

large lead-acid battery recycling facilities in order to help achieve attainment with the 0.15 

μg/m3standard. The full text of the Rule is included in Appendix II. 

Rule 1420.1 incorporated in regulation many of the provisions and requirements that were 

being implemented via compliance plans and orders of abatement at Exide Technologies, and 

included additional safeguards to help ensure that the Los Angeles County will achieve the 

2008 NAAQS for lead. The rule establishes facility-wide and individual point source 
Chapter 4: Lead Control Strategy

4 - 6

maximum allowable emission rates, and requires secondary lead control devices on dryers. 

Fugitive lead emissions are addressed through housekeeping and maintenance activity 

requirements, and total enclosures, vented to control devices, of all areas where lead is being 

processed and where maintenance activities are occurring. The rule also sets ambient 

standards for airborne lead concentrations at monitors around the facility, and requires more 

facility-operated monitors (a minimum of four) that collect samples on a more frequent 

schedule (once every three days). Additional, source testing, recordkeeping, and reporting 

requirements are included to ensure continuous compliance. The rule also includes provision 

for the submittal of new compliance plans and emission reduction feasibility studies if 

ambient levels reach 80% (0.12 g/m3) of the rule limit. The following provides a detailed 

and description of Rule 1420.1 requirements.

 Ambient Air Lead Concentrations: Beginning January 1, 2012, large lead-acid battery 

recycling facilities subject to Rule 1420.1 are not allowed to discharge into the 

atmosphere emissions which contribute to ambient air concentrations of lead that exceed 

0.15 μg/m3averaged over any 30 consecutive days. The averaging time for Rule 1420.1 

is shorter than that of the lead NAAQS (rolling three-month average of monthly 

averages) with a more frequent sampling requirement of one sample in three days versus 

the NAAQS which requires one sample in six days. In addition, the compliance date of 

Rule 1420.1 is January 1, 2012 vs. December 31, 2015 for the lead NAAQS.

 Total Enclosures: Under Rule 1420.1, all areas used in the lead-acid battery recycling 

operation for processing or storage of lead-containing material, and all areas where 

maintenance is being performed, are required to install total enclosures vented to a lead 

control device. The areas may be enclosed individually or in groups. This requirement 

provides maximum containment and will minimize fugitive lead-dust emissions 

generated in areas where processing, handling and storage of lead-containing materials 

occur. Rule 1420.1 also establishes requirements for monitoring and maintaining 

negative pressure and in-draft velocity at the openings of these enclosed areas. Facilities 

are required to complete construction of all necessary equipment for total enclosures by 

July 1, 2011. 

 Lead Point Source Emission Controls: All lead emissions from lead point sources are 

required to be vented to an emissions collection system that ducts the entire gas stream to 

a lead control device. The effective date for lead point source emission control 

requirements is July 1, 2011. The total facility mass lead emission rate for all lead point 

sources shall not exceed 0.045 pounds of lead per hour, with a maximum emission rate 

for any single lead point source not to exceed 0.010 pounds of lead per hour. The total 

facility and maximum emission rates shall be determined using the most recent source 

tests conducted by the facility or the AQMD. The maximum emission rates of 0.045 and 

0.010 lb/hr were established to adequately provide a protective limit for exposure to lead 

emissions and achieve the ambient standard of 0.15 g/m3. 

 Housekeeping Requirements: More stringent housekeeping practices must be 

conducted to minimize fugitive lead-dust emissions. The housekeeping requirements 

include prescribed requirements for cleaning frequencies of specific areas; maintenance 

activity; encapsulation of all facility grounds, removal of weather caps on any lead 

emissions source stacks; building structural integrity inspections; storage and transport of 
Chapter 4: Lead Control Strategy

4 - 7

lead-containing materials; onsite mobile vacuum sweeping; and surface impoundment 

pond or reservoir cleanings.

 Annual Source Testing: Rule 1420.1 requires annual source tests for all lead control 

devices in order to demonstrate compliance with the facility total lead mass emission rate 

standard of 0.045 lb/hr, and the maximum individual stack lead emission rate standard of 

0.01 lb/hr. If the most recent source test for a lead point source demonstrates emissions 

of 0.0025 lb/hr or less, the facility may alternatively elect to conduct the next source test 

for that device within 24 months.

 Ambient Air Monitoring and Sampling Requirements: Under Rule 1420.1, each facility 

will be required to collect and analyze ambient air lead samples to determine compliance 

with the ambient air quality lead concentration standard of Rule 1420.1. The rule 

requires a minimum of four monitors at facility locations approved by AQMD. Federal 

regulations require only one source-oriented monitor at all facilities emitting more than 

0.5 tons of lead per year. Rule 1420.1 requires facilities to collect samples at least once 

every three days, more frequent than the federal requirement of once every six days. 

Under Rule 1420.1, on and after January 1, 2012, facilities that exceed an ambient air 

lead concentration of 0.15 μg/m3averaged over any 30 consecutive days, measured at 

any fence line monitor, will be in violation of the rule and be required to increase ambient 

air monitoring and sampling to a daily frequency. Daily monitoring and sampling will 

be required to be conducted for a period of at least 60 consecutive days at each sampling 

site that measured an exceedance until no 30-day average exceedances are recorded. In 

addition, according to Rule 1420.1, sampling sites at the property line may be located just 

inside the fence line on facility property if logistical constraints preclude placement 

outside the fence line. As a result, monitors required under Rule 1420.1 will be located 

closer to fugitive lead sources, in most cases, when compared to monitors required by 

federal monitoring requirements which must be in publicly accessible areas. Along with 

the shorter averaging time described previously, all of the ambient air monitoring and 

sampling requirements of Rule 1420.1 are more stringent than the federal requirements, 

such that potential Rule 1420.1 violations will likely occur before exceedances of the lead 

NAAQS. 

 Recordkeeping and Reporting Requirements: Rule 1420.1 requires recordkeeping and 

reporting, including public notifications, for specific maintenance activity, turnarounds 

and shutdowns for all lead-containing materials processed at the facility. Records for all 

housekeeping, maintenance activity, ambient air lead monitoring, lead control device 

inspection and maintenance, and unplanned shutdowns of any smelting furnaces must be 

maintained. Facilities are required to submit reports for monthly ambient air monitoring 

results for lead and wind data measured at each sampling location on a monthly basis. 

Rule 1420.1 also requires notifications of planned and unplanned shutdowns, and 

turnarounds.

 Core Requirements with a “Contingency” Compliance Plan: Rule 1420.1 establishes 

the core requirements for lead emissions sources described above, with the additional 

provision of a “Contingency” Compliance Plan. Establishing core requirements in the 

rule provides regulatory certainty for affected facilities of the key required controls core 
Chapter 4: Lead Control Strategy

4 - 8

requirements for lead point sources that are based on both facility-wide and individual 

emission rates for the facility’s lead point sources, as well as source testing requirements. 

Core requirements for fugitive lead sources include total enclosures, comprehensive 

housekeeping and maintenance activities, and ambient monitoring and limits that capture 

fugitive as well as point source emissions. As an additional safeguard against the 

facilities exceeding ambient NAAQS or Rule 1420.1 limits, the preparation and submittal 

of a “Contingency” Compliance Plan is triggered if the facility approaches the lead 

ambient air quality standard with a 30-day rolling average of 0.12 ug/m3. The 

Compliance Plan would be implemented if the facility exceeded the Rule 1420.1 ambient 

lead standard of 0.15 ug/m3. The Compliance Plan provision serves as a contingency to 

ensure that measures can be identified prior to exceeding the 0.15 ug/m3standard and are 

ready for fast implementation if the 0.15 ug/m3standard is exceeded. 

 Compliance Plan: The most important provision of Rule 1420.1 is the limit on ambient 

concentrations of lead at fence line monitors. Given the challenges in quantifying 

fugitive lead emissions, and given the known importance of fugitive emissions at leadacid battery recycling facilities, the ambient monitors provide the most effective means of 

ensuring compliance with the NAAQS since they capture all emissions. The Compliance 

Plan allows for rapid deployment of additional controls on fugitive or other sources if a 

facility approaches the ambient lead standard even after all core requirements of Rule 

1420.1 have been implemented. As of July 1, 2011, any facility that exceeds an ambient 

air lead concentration of 0.12 μg/m3averaged over any 30 consecutive days is required to 

submit a Compliance Plan that identifies additional lead emission reduction measures to 

ensure that the ambient air quality concentration of 0.15 μg/m3is not exceeded. An 

exceedance of the Rule 1420.1 lead standard averaged over any 30 consecutive days will 

constitute a violation, as well as triggering implementation of the Compliance Plan. 

AQMD’S PROPOSED LEAD CONTROL MEASURE

A proposed control measure is to amend AQMD Rule 1420 – Emissions Standard for Lead. 

Rule 1420 applies to all non-vehicular sources of lead emissions and contains requirements 

for emission levels, controls, housekeeping, and monitoring. In addition, sources must 

comply with an ambient air quality lead standard of 1.5 μg/m3, averaged over 30 days. The 

amendment will lower the ambient limit in Rule 1420 to 0.15 μg/m3to correspond to the 

revised NAAQS for lead of 0.15 μg/m3. The more stringent, shorter averaging time of a 30 

day rolling average will be retained. In addition, language will be added to Rule 1420 to 

clarify New Source Review (NSR) requirements for stationary lead sources, consistent with 

AQMD’s current NSR regulation (Regulation XIII) and federal NSR requirements. 

Amendments to Rule 1420 are scheduled for the 4th quarter of 2012.

California Environmental Quality Act (CEQA) Analysis

Staff has reviewed the proposed 2012 Lead State Implementation Plan (SIP) for Los Angeles 

County, pursuant to CEQA Guidelines §15002(k) - Three Step Process. If the project is not 

exempt, the lead agency takes the second step and prepares an Initial Study (IS) (CEQA 

Guidelines §15002(k)(2)). AQMD staff has prepared an IS, which demonstrates the 
Chapter 4: Lead Control Strategy

4 - 9

following. The only new proposed control measure in the 2012 Lead SIP would amend Rule 

1420 to lower the ambient lead standard from 1.5 to 0.15 ug/m3, consistent with Rule 1420.1. 

Since the most current monthly lead monitoring data in the Los Angeles County at facilities 

subject to Rule 1420, but not subject to Rule 1420.1, show that average lead concentrations 

are less than 0.15 ug/m3, the proposed control measure is not expected to result in any 

changes at existing affected facilities. In the event that monitoring near or at a lead facility 

exceeds 0.15 ug/m3, the proposed control measure may require implementing lead control 

requirements similar to those in Rule 1420.1, resulting in environmental impacts that are 

essentially the same as those identified in the October 2010 Final Environmental Assessment 

(EA) for Rule 1420.1 (AQMD No. 100331JK, SCH No. 2010041086). In addition, based on 

the IS, AQMD has determined that the 2010 Rule 1420.1 Final EA adequately describes the 

three requisite criteria specified in CEQA Guidelines Section 15153(b)(1)(A-C) As a result, 

staff intends to use the previously approved October 2010 Final EA as the CEQA document 

for the 2012 Lead SIP pursuant to CEQA Guidelines §15153. 

Staff has provided the notice required by Guidelines Section 15153(b)(2). As required by 

that section, the key issues are whether this EIR should be used for this project and whether 

there are any additional, reasonable alternatives or mitigation measures that should be 

considered as ways of avoiding or reducing any significant impacts of the project. Pursuant 

to CEQA Guidelines §15153(b)(2), the October 2010 Final EA for Rule 1420.1 was available 

to the public for a 30-day public comment period. 

Socioeconomic Impacts & Cost Effectiveness Analysis

Since no existing sources are expected to be affected by the proposed amendments to Rule 

1420, no cost assumptions were made and no socioeconomic impact analysis was made. 

AQMD staff assesses socioeconomic impacts of proposed rule amendments or proposed 

rules pursuant to the Board resolutions and state legislative requirements, but there is no 

specific requirement for this SIP submittal.

As additional information on control requirements becomes more well-defined during the 

rulemaking process, a detailed assessment of their socioeconomic and environmental impacts 

will be conducted.

IMPLEMENTING AGENCY

The AQMD has the authority to adopt and enforce rules and regulations to achieve and 

maintain the NAAQS under H&SC Section 40460 and 40440(a). For lead NAAQS, the 

AQMD is responsible for implementing stationary source control measures.
CHAPTER 5

FUTURE AMBIENT LEAD CONCENTRATIONS

Introduction

Modeling Approach

Model Results by Facility
Chapter 5: Future Ambient Lead Concentrations

5 - 1

INTRODUCTION

This chapter provides a description of the atmospheric dispersion modeling performed to 

predict future ambient lead concentrations and demonstrate attainment of the NAAQS in the 

vicinity of the two major lead sources in the Los Angeles County.

For additional information regarding the actual input and output files, please refer to 

Appendix III. 

MODELING APPROACH

The new federal lead NAAQS regulation requires states to employ atmospheric dispersion 

modeling to demonstrate attainment in the vicinity of major point sources of lead: primary 

lead smelters, secondary lead smelters, primary copper smelters, lead gasoline additive 

plants, lead-acid storage battery manufacturing plants that produce 2,000 or more batteries 

per day. Dispersion modeling was performed following the procedures outlined in EPA’s 

latest guidance document entitled “Guideline on Air Quality Models”.1 

The two large lead-acid battery recycling facilities (Exide and Quemetco) were modeled to 

determine the monthly lead concentration for for the attainment year 2015. As shown in 

Chapter 2, these are the only two lead sources in the Los Angeles County with the potential 

to cause exceedances of the new lead NAAQS. All facility boundary information, source 

parameters, and emission rates were obtained from the most recently submitted health risk 

assessment (HRA) for each facility and recently conducted source tests. 

AERMOD MODELING SYSTEM

The American Meteorological Society/Environmental Protection Agency Regulatory Model 

Improvement Committee (AERMIC) was formed to introduce state-of-the-art modeling 

concepts into the EPA's air quality models.2Through AERMIC, a modeling system, 

AERMOD, was introduced that incorporated air dispersion based on planetary boundary 

layer turbulence structure and scaling concepts, including treatment of both surface and 

elevated sources, and both simple and complex terrain. As of December 9, 2006, the EPA 

promulgated the AERMOD modeling system as a replacement for the Industrial Source 

Complex (ISC) Model as the recommended dispersion model.3The AERMOD modeling 

system consists of the following components which were utilized: AERMET, a 

meteorological data preprocessor that incorporates air dispersion based on planetary 

boundary layer turbulence structure and scaling concepts; AERMAP, a terrain data 

preprocessor that incorporates complex terrain using U.S. Geologic Survey (USGS) Digital 

Elevation Data; AERSURFACE, a surface characteristics preprocessor; and BPIPPRIME, a 

multi-building dimensions program incorporating the good engineering practice technical 

procedures for PRIME applications. 

 

1

From EPA’s website, available at http://www.epa.gov/ttn/scram/guidance/guide/appw_05.pdf

2

From EPA’s website, available at http://www.epa.gov/ttn/scram/dispersion_prefrec.htm

3

From EPA’s website, available at http://www.epa.gov/ttn/scram/dispersion_prefrec.htm#aermod
Chapter 5: Future Ambient Lead Concentrations

5 - 2

METEOROLOGICAL DATA

A set of meteorological data were developed for AERMOD applications in the Basin by 

EnviroComp Consulting Inc. under contract to the AQMD. The reports documenting the 

effort can be found at http://www.aqmd.gov/smog/metdata/AERMOD.html. Meteorological 

data from three independent monitoring networks were employed: AQMD, National Weather 

Service (NWS) and California Irrigation Management Information System (CIMIS). Among 

them, wind speed and direction were taken from the AQMD network given the spatial 

coverage, locations, sensor height of the measurements. Solar radiation measured from the 

CIMIS stations were primarily used due to its temporal completeness and spatial coverage, 

while AQMD radiation measurements were employed as supplementary data to fill missing 

data in the CIMIS data. Fractional cloud coverage was available only from the NWS. As for 

temperature, all the data from the three networks – 28 AQMD, 22 NWS, and 17 CIMIS 

stations – were integrated into AQMD measurements to construct a complete set of missingvalue free data. Upper air profiles were obtained from the NWS San Diego Miramar Naval 

Air Station rawinsonde data. 

AERSURFACE was used to determine the surface albedo and surface roughness. A Bowen 

ratio of 1.0 was used, instead of the AERSURFACE output value. This was done because the 

National Land Cover Data (NLCD) 92 dataset does not include the recent land development 

projects that occurred within Southern California, which would result in a lower Bowen ratio. 

According to Section 8.3.1.2 of Appendix W, five years of representative meteorological data 

should be used when estimating concentrations with an air quality model.4Therefore, 

AERMET (version 11059) was used to develop the necessary 5-year meteorological data set 

for each facility using the meteorological data from the appropriate monitoring station and 

upper air sounding data collected at the Miramar Naval Air Station, as described above. For 

Exide, the Central LA monitoring station was used. However, only 4 years of meteorological 

data is available for this station (2006 to 2009). For Quemetco, the La Habra monitoring 

station was used and all 5 years (2005 to 2009) of meteorological data is available. 

AERMOD MODEL INPUTS

Dispersion modeling for each facility was performed using AERMOD (version 12060) to 

determine the monthly lead concentrations for the attainment year 2015. 

All facility boundary information, source parameters, and building information were obtained 

from the most recently submitted health risk assessment (HRA) for each facility. All stacks 

were modeled as point sources while the fugitive emission sources were modeled as volume 

sources. 

For Exide, there were a total of 10 point sources, one volume source representing the fugitive 

emissions from the raw materials processing, and the roadway fugitive emissions were 

modeled as line sources (i.e. separate volume sources along the roadway where the trucks 

would travel). In 2012, in an effort to further reduce emissions, Exide constructed an 

enclosure for their bag-house row. As a result, the stacks which are located within the baghouse row had to be raised above the roof line. Therefore, in the modeling for 2015, the stack 

 

4

From EPA’s website, available at http://www.epa.gov/ttn/scram/guidance/guide/appw_05.pdf
Chapter 5: Future Ambient Lead Concentrations

5 - 3

heights were increased to reflect the new bag-house row enclosure based on the permit 

application filed by Exide. Furthermore, the Exide facility now includes a truck wash where 

all trucks dealing with lead deliveries will be required to have their wheels washed prior to 

leaving the facility. As such, for the 2015 modeling, the roadways were modeled to reflect 

the addition of this truck wash and the opening of two other gates along the north and east 

property lines which allow for other deliveries that do not include lead sources. 

For Quemetco, there were a total of 13 point sources, one volume source representing the 

fugitive emissions from the battery wrecking activities, and the roadway fugitive emissions 

were modeled as line sources (i.e. separate volume sources along the roadway where the 

trucks would travel). For Quemetco, different roadway configurations were used for the 2015 

modeling. This is based on information from the facility that the existing gate will be moved 

in order to move the on-site truck movement from areas where people are frequently walking 

and to allow for more efficient truck movement. Specific modeling information and source 

parameters are included in Appendix III. 

Both facilities are located in the densely populated areas of Los Angeles County. Thus, all 

lead sources modeled are identified as urban sources. The Los Angeles County population of 

9,862,049 (2008 estimate from the Census Bureau) is input under the URBANOPT keyword 

and urban surface roughness length is unspecified. By not specifying the urban surface 

roughness length, AERMOD assumes the regulatory default value of one meter.

The latest version of EPA’s recommended building downwash program, BPIPPRM, is used 

to identify structures causing building downwash effects and provide the source specific and 

direction specific building downwash parameters required by AERMOD (i.e., BUILDHGT, 

BUILDWID, BUILDLEN, XBADJ, and YBADJ).

A 50-meter by 50-meter receptor grid centered on the facility was used, as well as fence-line 

receptors placed using 25-meter intervals. Receptors within the facility’s property boundaries 

were removed. 

Receptor elevations and hill heights were assigned using AERMAP (Version 11103). Terrain 

data, available from the United States Geological Survey (USGS), is used by AERMAP to 

produce terrain base elevations for each receptor and source and a hill height scale value for 

each receptor. 

To comply with the EPA’s modeling requirement, a background concentration of 0.01 g/m3

for lead obtained from the latest AQMD network monitoring data was modeled in AERMOD 

using the BACKGRND keyword.5 

At this time, AERMOD does not have the capability to calculate design values for the lead 

NAAQS, therefore, the EPA’s post processor, LEADPOST, was used to calculate the rolling 

cumulative (all sources) 3-month average concentration at each modeled receptor with source 

group contributions and the maximum cumulative (all sources) rolling 3-month average 

concentration by receptor.

 

5

From AQMD’s website, available at: http://www.aqmd.gov/smog/historicaldata.htm
Chapter 5: Future Ambient Lead Concentrations

5 - 4

EMISSION RATES

STACK EMISSIONS: For 2015 modeling, the emission rates were calculated from the 

emissions limits specified in Rule 1420.1. As of January 1, 2012, large lead-acid battery 

recycling facilities subject to Rule 1420.1 are not allowed to discharge into the atmosphere 

emissions which contribute to ambient air concentrations of lead that exceed 0.15 μg/m3

averaged over any 30 consecutive days. Rule 1420.1 requires annual source tests for all lead 

control devices in order to demonstrate compliance with the facility total point source lead 

mass emission limit of 0.045 lb/hr, and the maximum individual stack lead emission rate 

standard of 0.01 lb/hr. Using the most recent source tests for each facility, the facility total 

emission limit of 0.045 lb/hr was distributed among the stacks based on the ratio of the 

measured emissions, ensuring that no individual stack exceeded the 0.01 lb/hr per stack limit.

FUGITIVE EMISSIONS: As stated in Chapter 3, fugitive lead emissions are believed to be 

a major source of lead to the atmosphere at these two facilities. However, estimating and 

modeling fugitive dust emissions accurately is challenging, given the uncertainties in 

magnitude, location, timing, and lead content of the dust. Therefore, the fugitive emissions 

estimated in the EPA document entitled “Development of the RTR Emissions Dataset for the 

Secondary Lead Smelting Source Category”, were used in the modeling analysis.6

In 2010, the adjusted fugitive lead emissions for Exide are 130.64 lbs/year compared to 82.52 

lbs/yr as reported in the AQMD’s AER program. Exide reported fugitive lead emissions 

from two sources: 13.49 lbs/year from the raw materials processing system (RMPS) and 

69.03 lbs/year from roadway fugitives. Although these amounts were not used in the 

modeling, this relative ratio (16.35% from the raw materials processing and 83.65% from 

roadway fugitives) was used to apportion the total fugitive lead emissions listed in the EPA 

document. 

For Quemetco, the fugitive emissions of 85 lbs/year contained in Table 5-2 of EPA’s 

document were used. In the AQMD’s AER program, Quemetco did not report fugitive lead 

emissions for 2010. Since the battery wrecking area is approximately equivalent to Exide’s 

raw materials processing area, the same ratio (16.35% from the raw materials processing and 

83.65% from roadway fugitives) was used to apportion the total fugitive lead emissions listed 

in the EPA document.

For 2015 modeling, the same lead fugitive emissions were applied to the raw materials 

processing and battery wrecker areas for Exide and Quemetco, respectively. No further 

reductions were applied since the EPA document had assumed that both of those areas were 

fully enclosed in their fugitive emissions calculations. As part of housekeeping requirements 

identified in Rule 1420.1, each large lead battery recycling facility shall maintain and use an 

onsite mobile vacuum sweeper or vacuum that is in compliance with AQMD Rule 1186, or a 

vacuum equipped with filter(s) rated by the manufacturer to achieve a 99.97% capture 

efficiency for 0.3 micron particles. The pick-up efficiency, as identified in AQMD’s test 

protocol for Rule 1186 specifies a pick-up efficiency of 80% or greater for certified street 

 

6

From EPA’s website, available at http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2011-0344-

0163
Chapter 5: Future Ambient Lead Concentrations

5 - 5

sweepers. An 80% reduction was applied to the roadway fugitive emissions for 2015 as a 

reasonable conservative estimate since the measure identified in Rule 1420.1 is already in 

place. 

MODEL RESULTS BY FACILITY

To illustrate how Rule 1420.1 ambient monitoring requirements provide the assurance that 

fugitive emissions will not cause a NAAQS exceedance, modeling results for total emissions 

as well as stack only emissions are provided for both facilities. 

EXIDE 

Total Emissions – Stack and Fugitive Emissions

By applying Rule 1420.1 emission limits for 2015 (emission rates for the stacks were 

apportioned based on the most recent source test for the facility), applying an 80% reduction 

to the roadway fugitives, and keeping the RMPS emissions the same, the modeled maximum 

3-month rolling average lead concentration is 0.135 g/m3. The results are given in Table 5-

1. 

Stack Emissions Only

Using the Rule 1420.1 emission limits for 2015, the 0.045 lb/hr stack emission limit was 

evenly distributed throughout the stacks, ensuring that no individual stack exceeded the 0.01 

lb/hr per stack limit in Rule 1420.1, the modeled maximum 3-month rolling average lead 

concentration is 0.115 g/m3. The results are given in Table 5-1. 

QUEMETCO 

Total Emissions – Stack and Fugitive Emissions

By applying the Rule 1420.1 emission limits for 2015 (emission rates for the stacks were 

apportioned based on the most recent source test for the facility), applying an 80% reduction 

to the roadway fugitives, and keeping the Battery Wrecker emissions the same, the modeled 

maximum 3-month rolling average lead concentration is 0.140 g/m3. The results are given 

in Table 5-1. 

Stack Emissions Only

Using the Rule 1420.1 emission limits for 2015, the 0.045 lb/hr stack emission limit was 

evenly distributed throughout the stacks, ensuring that no individual stack exceeded the 0.01 

lb/hr per stack limit in Rule 1420.1, the modeled maximum 3-month rolling average lead 

concentration is 0.083 g/m3. It is important to note that the 2015 modeled lead 

concentrations are a very conservative estimate since it assumes allowable limits set by Rule 

1420.1, which are significantly higher than the current emissions at the facility. No 

significant increases in actual emissions are expected beyond the modest growth factors used 

in the actual emission projection. The results are given in Table 5-1.
Chapter 5: Future Ambient Lead Concentrations

5 - 6

TABLE 5-1

Dispersion Model Results by Facility for Demonstrating NAAQS Attainment (2015) 

Maximum Concentration

Stack and Fugitives

Maximum Concentration

Stack Only

Exide 0.135 g/m3

0.115 g/m3

Quemetco 0.140 g/m3

0.083 g/m3

Figures showing modeled concentration isopleths for each facility are included in Appendix 

III.

Note that the results in Table 5-1 represent a series of very conservative estimates of 

emissions and ambient concentrations since they are based on the allowable, not projected 

actual emissions under Rule 1420.1. Actual stack emissions in 2015 will be lower to ensure 

compliance with Rule 1420.1 by both facilities.

ON-SITE MONITORING

The Rule 1420.1 monitoring provisions, which include the influence from fugitive as well as 

point sources, will ensure attainment of the NAAQS given that the Rule 1420.1 monitoring 

requirements and limits are more stringent than the federal NAAQS. The averaging time is a 

rolling 30-day average rather than a rolling three month average of monthly averages. At 

least four monitoring locations are required rather than the single monitor per facility 

required in the federal regulations. These monitors, placed to capture maximum impacts, are 

generally located closer to the facility since they are allowed to be just inside the fence-line. 

Federally required monitors must be off facility property to meet the definition of ambient 

air, and thus are farther from the facility and are often subject to logistical constraints that 

preclude locating at maximum impact locations. The minimum monitoring frequency in 

Rule 1420.1 is one day in three, more frequent than the federal one day in six requirements. 

Taken together, the monitoring provisions of Rule 1420.1 were designed such that a facility 

would be in violation of the Rule before causing an exceedance of the federal lead NAAQS. 

As a result, the facility will be required to take steps to avoid future violations of Rule 

1420.1, thus avoiding any violations of the lead NAAQS. This protection against NAAQS 

exceedances is illustrated in Figure 5-1 which depicts the relationship between the AQMDoperated, NAAQS comparable, source-oriented site near Exide at Rehrig, and the sites 

operated by Exide pursuant to Rule 1420.1. The monthly averages at Rehrig are generally 

lower than the highest monthly average measured at the Rule 1420.1 sites. Note that Figure 

5-1 shows monthly averages, while the federal NAAQS is in the form of a three month 

average. Also note that according to Rule 1420.1, a 30-day average above 0.15 g/m3at any
Chapter 5: Future Ambient Lead Concentrations

5 - 7

site near the facility would cause a violation of the rule. So a 30-day exceedance at the 

Rehrig site would lead to a violation of Rule 1420.1, and require measures to reduce lead 

emissions well before a three-month average exceedance of the federal NAAQS at the same 

location. 
Chapter 5: Future Ambient Lead Concentrations

5 - 8

FIGURE 5-1

Highest monthly average lead concentrations measured near the Exide facility in 

Vernon. The dashed red line represents average monthly lead levels recorded by 

AQMD at the Rehrig source-oriented site. The solid black line indicates the highest 

monthly average lead concentrations measured by the Exide facility pursuant to Rule 

1420.1 at their monitoring locations (i.e. AT&SF, SE, SW, New NW, New NE, New N, 

and MID)

0.0

0.5

1.0

1.5

2.0

2.5

Lead (μg/m3

)

Rehrig (monthly ave.) Exide (highest monthly ave.)
CHAPTER 6

CLEAN AIR ACT REQUIRMENTS

Introduction

Federal Clean Air Act Requirements

Specific Lead Planning Requirements

Nonattainment New Source Review (NSR) Program

Contingency Measures

Reasonable Further Progress (RFP)

Reasonably Available Control Measures (RACM) and Reasonably 

Available Control Technology (RACT) Requirements
Chapter 6: Clean Air Act Requirements

6 - 1

INTRODUCTION

The purpose of this chapter is to demonstrate this lead SIP meets all submittal requirements 

in the CAA as well as the new federal lead regulation (73 FR 66964). Note that CAA 

Section 172(c)(8) (42 U.S.C. §7502(c)(8)) provides as follows:

Upon application by any state, the Administrator may allow the use of equivalent modeling, 

emission inventory, and planning procedures, unless the Administrator determines that the 

proposed techniques are, in the aggregate, less effective than the methods specified by the 

Administrator. 

The new lead NAAQS is unique in that attainment must be demonstrated at source-oriented 

monitors, and thus the attainment demonstration must address specific facilities that may 

cause NAAQS exceedances. The attainment demonstration presented in Chapter 5 employs 

a combination of emissions reductions as well as an ambient monitoring program that is more 

stringent than the federal monitoring requirements. These techniques should be more 

effective at ensuring NAAQS lead attainment than traditional procedures that rely on future

emissions reductions alone. 

FEDERAL CLEAN AIR ACT REQUIREMENTS

In November 1990, Congress enacted a series of amendments to the CAA intended to 

intensify air pollution control efforts across the nation. One of the primary goals of the 1990 

CAA Amendments was an overhaul of the planning provisions for those areas not currently 

meeting NAAQS. The CAA identifies specific emission reduction goals, requires both a 

demonstration of reasonable further progress and an attainment demonstration, and 

incorporates more stringent sanctions for failure to attain or to meet interim milestones. 

There are several sets of general planning requirements, both for nonattainment areas 

[Section 172(c)] and for implementation plans in general [Section 110(a)(2)]. These 

requirements are listed and briefly described in Chapter 1 (Tables 1-2 and 1-3). The general 

provisions apply to all applicable pollutants unless superseded by pollutant-specific 

requirements. The following sections discuss the federal CAA requirements for lead.

SPECIFIC LEAD PLANNING REQUIREMENTS

The EPA promulgated the initial lead standard of 1.5 μg/m3in 1978, and revised it on 

October 15, 2008 to a level of 0.15 μg/m3. On December 31, 2010, the EPA designated the 

Los Angeles County portion of the Basin, excluding San Clemente and Santa Catalina 

Islands, as nonattainment for the 2008 lead NAAQS. The CAA requires areas classified as 

nonattainment to attain the lead standard as expeditiously as practicable and within the 

CAA’s deadlines, which in AQMD’s case is no later than December 31, 2015. The 

requirements specifically addressed for the lead SIP are:

 Nonattainment New Source Review (NSR) Program;

 Contingency Measures;
Chapter 6: Clean Air Act Requirements

6 - 2

 Reasonable Further Progress (RFP);

 Reasonably Available Control Measures (RACM); and

 Reasonably Available Control Technology (RACT)

NONATTAINMENT NEW SOURCE REVIEW (NSR) PROGRAM

The nonattainment New Source Review (NSR) program applies when a major source of a 

criteria pollutant that is located in an area that is designated as nonattainment for that 

pollutant is constructed or undergoes a major modification. The major source threshold for 

lead under the nonattainment NSR program is 100 TPY for all source categories.1

Accordingly, the nonattainment NSR program for lead applies when any major source of lead 

located in an area designated nonattainment for lead is constructed, or undergoes a major 

modification. A major modification is a project at a major stationary source that results in a 

significant emissions increase and a significant net emissions increase, where “significant” 

for lead emissions is defined as 0.6 TPY. Nonattainment NSR requirements include but are 

not limited to:

 Installation of Lowest Achievable Emissions Rate (LAER) control technology;

 Offsetting new emissions with creditable emissions reductions;

 A certification that all major sources owned and operated in the state by the same owner 

are in compliance with all applicable requirements under the CAA;

 An alternatives analysis demonstrating that the benefits of the proposed source 

significantly outweigh the environmental and social costs imposed as a result of its 

location, construction, or modification; and

 Public comment on a permit.

Due to the persistent nature of lead and the potential for lead particle accumulation over time, 

Rule 1420.1 has additional requirements for new large lead-acid recycling facilities. Under 

Rule 1420.1, any new battery recycling facility that begins construction or operations shall 

not be located in an area that is zoned for residential or mixed use, and shall not be located 

within 1,000 feet from the property line of a sensitive receptor, a school under construction, 

park, or any area that is zoned for residential or mixed use. A siting provision for new 

battery recycling facilities is also included to avoid the possibility of high lead exposure for 

nearby residences and sensitive receptors from any new lead-acid battery recycling facility. 

In addition, language will be added to the proposed amendments to AQMD Rule 1420 to

clarify lead NSR requirements for stationary sources, consistent with AQMD’s Regulation 

XIII and federal NSR requirements. 

 

1 Environmental Protection Agency, “National Ambient Air Quality Standards for Lead; Final Rule,” 40 CFR Part 51.166, 

November 2008.
Chapter 6: Clean Air Act Requirements

6 - 3

CONTINGENCY MEASURES

The federal CAA Section 172(c)(9) requires that state implementation plans include specific 

contingency measures to be implemented in the event of failure to meet milestone emission 

reduction targets or Reasonable Further Progress (RFP) and/or failure to attain the national 

primary ambient lead standard by the attainment date of 2015. As described later in the RFP 

section of this document, the RFP requirements for 2012 are already met via Rule 1420.1 

implementation. Therefore, contingency measures only need to address any possible failure 

to attain the lead NAAQS by 2015. 

Contingency measures must be fully adopted rules or control measures that are ready to be 

implemented without significant further action by the State or EPA, upon determination by 

EPA that the area has failed to achieve, or maintain RFP, or attain the lead NAAQS by the 

statutory attainment date. The EPA interprets this provision to allow states to meet this 

requirement with control measures that have already been implemented but are not needed 

for attainment, and to allow for “minimal action” to be necessary prior to implementation of 

the measures (73 FR 66964, at 67039). It should also contain trigger mechanisms with a 

specific schedule for implementation. The amount of reductions yielded by implementation 

of contingency measures should be quantified, and for a five-year plan, the measures should 

reduce emissions by 20 percent of the total amount needed for attainment. Under certain 

circumstances, this amount may be derived by reference to reductions in ambient air 

concentrations (2008 lead NAAQS Implementation Q&A, July 8, 2011, EPA).2 

The provisions included in adopted AQMD Rule 1420.1 as well as other approved 

compliance and permit provisions satisfy the CAA contingency requirements as described 

below:

Rule 1420.1 Compliance Plan: As of July 1, 2011, if a facility approaches the lead ambient 

air quality standard with a 30-day rolling average of 0.12 ug/m3as determined by monitors 

pursuant to Rule 1420.1, or at any District-installed monitor, it will trigger the preparation 

and submittal of a Compliance Plan by the facility, subject to AQMD approval. The 

Compliance Plan provision provides a means to identify the necessary measures which can 

be implemented prior to exceeding the 0.15 ug/m3standard and are ready for fast and 

automatic implementation if the 0.15 ug/m3ambient standard is exceeded. The Compliance 

Plan is required to be automatically implemented if the facility exceeds the Rule 1420.1 

ambient lead standard of 0.15 ug/m3. Note that the Rule 1420.1 ambient standard is a 30-

day rolling average, which would show an exceedance of the 0.15 ug/m3limit before an 

exceedance of three-month rolling average NAAQS was recorded. Therefore, the additional 

controls in the approved Compliance Plan would be triggered for implementation prior to a 

NAAQS exceedance and are thus designed to avoid a NAAQS exceedance. They take effect 

without any further action by EPA or the State, being automatically triggered by an 

exceedance of the 0.15 ug/m330-day rolling average limit in Rule 1420.1.

According to the language in AQMD Rule 1420.1, the Compliance Plan shall, at a minimum, 

include the following specific components and emission reduction measures:

 

2

From EPA’s website, available at: http://www.epa.gov/oaqps001/lead/pdfs/20110708QAguidance.pdf
Chapter 6: Clean Air Act Requirements

6 - 4

 A description of additional lead emission reduction measures to achieve the ambient lead 

concentrations of 0.15 ug/m3averaged over any 30 consecutive days as determined by 

any District-installed monitors, including, but not limited to, requirements for the 

following:

 Housekeeping, inspection, and maintenance activities;

 Additional total enclosures;

 Modifications to lead control devices;

 Installation of multi-stage lead control devices;

 Process changes including reduced throughput limits; and 

 Conditional curtailments including, at a minimum, information specifying the 

curtailed processes, process amounts, and length of curtailment.

 The locations within the facility and method(s) of implementation for each lead reduction 

measure identified above; 

 An implementation schedule for each lead emission reduction measure to be 

implemented if lead emissions discharged from the facility contribute to ambient air 

concentrations for lead that exceed 0.15 ug/m3averaged over any 30 consecutive days 

measures at any District-installed monitor. The schedule shall also include a list of lead 

reduction measures that can be implemented immediately prior to plan approval.

 The owner or operator shall implement the additional measures identified in the 

compliance plan based on the schedule in the compliance plan if lead emissions 

discharged from the facility contribute to ambient air concentrations of lead to exceed 

0.15 ug/m3averaged over any 30 consecutive days measured at any District-installed 

monitors.

The Compliance Plan approach provides the fastest and most efficient tool for both the 

AQMD and the facility to achieve and maintain the federal NAAQS by tailoring each 

Compliance Plan to address facility specific problems. The different operational parameters 

at different facilities will necessarily require different approaches for further reduction of 

lead emissions. A pre-specified control approach will likely not effectively address the 

specific problem that a specific facility may experience at a particular time. The 

requirements of Rule 1420.1 already include all feasible generic measures to reduce lead 

emissions from lead-acid battery recyclers. Additional specific measures to be used for 

contingency purposes must necessarily be targeted to the specific situation, which cannot be 

anticipated in a prior rulemaking. 

To illustrate examples of specific measures to be included in a Compliance Plan, the 

following site specific controls and measures were identified in a recent Compliance Plan 

submitted by a facility and approved by AQMD. Each of these measures may be 

implemented individually or in any combination based on the specific situation to address the 

suspected lead emission source: 

 Install doors between the shipping and enclosed processing buildings to enhance negative 

pressure in the building;
Chapter 6: Clean Air Act Requirements

6 - 5

 Install automated doors between processing areas to reduce the amount of time the door 

is open;

 Resurface the outside area of the facility to enhance the effectiveness of pavement 

cleaning activities;

 Upgrade ride-on yard sweeper to a combination hybrid dry sweeper /wet scrubbing unit 

to enhance pavement cleaning efforts;

 Install ventilated negative pressure enclosure on specific operations;

 Replace strip curtains with doors;

 More focused housekeeping on roofs and other horizontal surfaces in processing areas to 

minimize fugitive dust;

 Designating one or more forklifts to be used exclusively inside the total containment 

buildings to avoid tracking lead bearing materials outside of the containment building;

 Install additional room ventilation baghouse or dust collector, equipped with second stage 

high efficiency particulate air (HEPA) filter to reduce fugitive lead emissions;

 Install additional differential pressure monitoring system on the enclosures;

 Install second stage HEPA filters on specific control systems; and

 Conditional percent curtailment of specific activities generating the exceedance as a 

function of exceedance amount over the NAAQS limits. The curtailments shall remain in 

effect until the monitoring results at the affected monitoring station reflect a specified 

number of consecutive 30-calendar day averages of less than 0.15 μg/m3.

Rule 1420.1 Feasibility Study: As of July 1, 2011, if emission are discharged into the 

atmosphere which contribute to ambient air concentrations of lead that exceed 0.12 μg/m3, 

averaged over any 30 consecutive days, determined by monitors pursuant to Rule 1420.1 or 

at any District-installed monitor, the owner or operator of a large lead-acid battery recycling 

facility shall submit a study addressing the technical, economic and physical feasibility of 

achieving a total facility mass lead emission rate of 0.003 pounds per hour from all lead point 

sources (much lower than the current rule 1420.1 cap of 0.045 pounds per hour) . The study 

shall be submitted within 30 calendar days after exceeding 0.12 μg/m3, averaged over any 30 

consecutive days. The intent of this feasibility study is to provide information that could be 

incorporated into future facility-specific emission reduction efforts, such as Compliance Plan 

revisions, permit modifications, abatement orders, or rule amendments. 

Rule 1420.1 Ambient Monitoring: As of January 1, 2012, facilities are not allowed to 

discharge lead emissions which contribute to ambient air concentrations of lead exceeding 

0.15 μg/m3 averaged over any 30 consecutive days measured by fence-line ambient monitors 

(30-day rolling average). Given the inherent uncertainty in quantifying fugitive lead 

emissions, and given the known importance of fugitive emissions at lead-acid battery 

recycling facilities, the ambient monitors provide the most effective means of ensuring 

compliance with the NAAQS since they capture all emissions from a facility. The monitoring 

requirements and limit under Rule 1420.1 are more stringent than the federal NAAQS and 

monitoring requirements. The averaging time is a rolling 30-day average rather than a rolling 

three month average of monthly averages. At least four monitoring locations are required 
Chapter 6: Clean Air Act Requirements

6 - 6

rather than the single monitor per facility required in the federal regulations. These monitors, 

placed to capture maximum impacts, are generally located closer to the facility since they are 

allowed to be just inside the fence-line. Federally required monitors must be off facility 

property to meet the EPA definition of ambient air, and thus are farther from the facility and 

are often subject to logistical constraints that preclude locating at maximum impact locations. 

The minimum monitoring frequency in Rule 1420.1 is one day in three, more frequent than 

the federal one day in six requirements. Taken together, the monitoring provisions of Rule 

1420.1 were designed such that a facility would be in violation of the Rule before causing an 

exceedance of the federal lead NAAQS. An exceedance of the Rule 1420.1 lead standard 

averaged over any 30 consecutive days will constitute a violation of the Rule, as well as 

triggering automatic implementation of daily monitoring and the approved Compliance Plan.

These ambient monitoring provisions of Rule 1420.1 serve as a quantifiable contingency 

measure based on ambient air concentrations. Where a single source is responsible for 

nonattainment, EPA allows for the identification of the amount of reductions required by 

reference to reductions in ambient air concentrations (2008 Pb NAAQS Implementation 

Q&A, July 8, 2011, EPA). The extra stringency provided by the more stringent 30-day 

rolling average limit vs. federal three-month average NAAQS provides for the equivalent of 

lower facility emissions. This is illustrated by a comparison of maximum monthly 30-day 

rolling average TSP lead concentration for all Rule 1420.1 fence-line ambient monitoring 

sites at Exide vs. the AQMD operated Exide-Rehrig station that is used for NAAQs 

comparison (about 15 m east of Exide Technologies in Vernon) as shown in Figure 6-1. In 

almost all cases, the 30-day rolling average measured at the Rule 1420.1 locations 

significantly exceed the corresponding three-month average at Rehrig. Given the inherent 

lag time in the response of the three-month average, it may exceed the 30-day average only 

when concentrations are dropping, as seen in the last quarter of 2011. However, the more 

relevant question is whether a potential NAAQS exceedance would be preceded by a 

corresponding Rule 1420.1 ambient limit violation and associated Compliance Plan 

implementation trigger. 
Chapter 6: Clean Air Act Requirements

6 - 7

FIGURE 6-1

Comparison between Rehrig lead concentrations and the corresponding 

maximum lead levels at all Exide locations

This question is better addressed by Table 6-1 showing the three-month average at Rehrig 

corresponding to the maximum 30-day rolling average in the first month of that three month 

period. This comparison illustrates that historically at Exide, all potential 3-month 

exceedances were preceded two months earlier by a higher 30-day average at the Rule 

1420.1 sites. This extra stringency can be quantified as shown in the last column in Table 6-

1. Over the time period when the Rehrig site was operating, the average difference between 

the two monitoring approaches was 57%, with a minimum monthly difference of 22%.
Chapter 6: Clean Air Act Requirements

6 - 8

TABLE 6-1

Comparison between Rehrig lead concentrations and the corresponding 

maximum lead levels at all Exide locations

REHRIG ALL EXIDE SITES

Difference 

(%) 3-mo Average Max 30-day Rolling(2-months Prior)

Date Lead (μg/m3) Date Lead (μg/m3)

1-Mar-09 0.42 1-Jan-09 0.53 22%

1-Apr-09 0.48 1-Feb-09 1.45 67%

1-May-09 0.48 1-Mar-09 2.08 77%

1-Jun-09 0.38 1-Apr-09 2.41 84%

1-Jul-09 0.47 1-May-09 1.19 61%

1-Aug-09 0.48 1-Jun-09 0.95 50%

1-Sep-09 0.49 1-Jul-09 0.78 37%

1-Oct-09 0.33 1-Aug-09 0.91 64%

1-Nov-09 0.31 1-Sep-09 0.88 65%

1-Dec-09 0.28 1-Oct-09 0.79 64%

1-Jan-10 0.25 1-Nov-09 1.06 76%

1-Feb-10 0.24 1-Dec-09 1.07 78%

1-Mar-10 0.25 1-Jan-10 0.88 72%

1-Apr-10 0.32 1-Feb-10 0.99 68%

1-May-10 0.37 1-Mar-10 0.82 55%

1-Jun-10 0.39 1-Apr-10 1.31 71%

1-Jul-10 0.35 1-May-10 0.87 60%

1-Aug-10 0.31 1-Jun-10 0.98 68%

1-Sep-10 0.32 1-Jul-10 1.03 69%

1-Oct-10 0.27 1-Aug-10 0.76 64%

1-Nov-10 0.27 1-Sep-10 0.58 54%

1-Dec-10 0.21 1-Oct-10 0.55 61%

1-Jan-11 0.24 1-Nov-10 0.50 52%

1-Feb-11 0.25 1-Dec-10 0.50 50%

1-Mar-11 0.29 1-Jan-11 0.53 45%

1-Apr-11 0.36 1-Feb-11 0.50 27%

1-May-11 0.42 1-Mar-11 0.57 25%

1-Jun-11 0.44 1-Apr-11 0.93 53%

1-Jul-11 0.45 1-May-11 0.91 51%

1-Aug-11 0.43 1-Jun-11 0.98 56%

1-Sep-11 0.44 1-Jul-11 0.96 54%

1-Oct-11 0.35 1-Aug-11 0.98 64%

1-Nov-11 0.30 1-Sep-11 0.62 52%

1-Dec-11 0.20 1-Oct-11 0.28 28%

1-Jan-12 0.15 1-Nov-11 0.26 43%

1-Feb-12 0.10 1-Dec-11 0.26 62%

Average 57%

Minimum 22%
Chapter 6: Clean Air Act Requirements

6 - 9

This extra stringency in monitoring can be directly related to emissions reductions for 

contingency purposes. For lead SIPs, EPA believes it is reasonable for contingency 

measures to reduce emissions by 20% (one-year’s worth) of the amount of reductions 

required for attainment. Table 6-1 shows that a minimum of 22% of reduction in total

ambient concentrations is inherent in the more stringent monitoring requirements of Rule 

1420.1. The 20% of the lead reductions needed for attainment will necessarily correspond to 

less than 20% in ambient concentration reductions (given background levels of lead and the 

fact that emissions do not need to be reduced to zero for attainment). Thus, the minimum of 

22% in ambient reductions conservatively satisfies the requirement for the amount of 

contingency reductions according to the following EPA guidance. The EPA allows states to 

meet contingency requirements with control measures that have already been implemented 

but are not needed for attainment. The monitoring requirements in Rule 1420.1 have already 

been implemented, and, being more stringent than the NAAQS requirements, are not needed 

for attainment. Furthermore, EPA allows for the identification of the amount of reductions 

required by reference to reductions in ambient air concentrations. The extra stringency of 

Rule 1420.1 monitoring provides for quantifiable reductions in ambient air concentrations, 

and corresponding reductions in facility emissions, in excess of the 20% of total required 

emission reductions needed to satisfy contingency requirements. Although only data from 

Exide was used in this example, ambient data at Quemetco show the same relationship and 

also satisfy the contingency requirement.

The Rule 1420.1 monitoring requirements are designed to provide advance warning to avoid 

an exceedance of the lead NAAQS with a quick response. Alternatively, the CAA 

contingency requirements are intended to provide quick implementation of control measures 

after an exceedance occurs or RFP is not met. EPA generally expects all actions needed to 

affect full implementation of the measures to occur within 60 days after EPA notifies the 

state of such failure. The state should ensure that the measures are fully implemented as 

expeditiously as practicable after the requirement takes effect (73 FR 67039). As noted 

above, there will be up to a two month period between a Rule 1420.1 violation and a 

potential NAAQS violation. There will likely have been a previous trigger for a Compliance 

Plan at the lower ambient limit of 0.12 g/m3. Ambient data are collected, validated, and 

reported to EPA on a quarterly basis with an associated three to six month lag time. Ambient 

data from a particular year are not required to be certified by state and local agencies until 

May 31stof the following year. Therefore, there will be a minimum of five months between 

an exceedance and a potential EPA notification to implement contingency measures, and 

then 60 more days to implement those measures. More likely, given the lag in data reporting, 

there will be much more than seven months to implement contingency measures. This time 

frame is much longer than needed under Rule 1420.1 to prepare (30 days), approve (usually 

60-90 days), get EPA approval under Title V permitting requirements (maximum 45 days), 

and if needed, implement a facility’s Compliance Plan. In practice, if there is a NAAQS 

exceedance, the measures in the Compliance Plan will already be implemented by the time 

EPA has the data to make a determination and notification of failure to attain.

A proposed control measure is to amend AQMD Rule 1420 – Emissions Standard for Lead. 

Rule 1420 applies to all non-vehicular sources of lead emissions and contains requirements 
Chapter 6: Clean Air Act Requirements

6 - 10

for emission levels, controls, housekeeping, and monitoring. In addition, sources must 

comply with an ambient air quality lead standard of 1.5 μg/m3, averaged over 30 days. The 

proposed amendment seeks to lower the ambient limit in Rule 1420 to 0.15 μg/m3to 

correspond to the revised NAAQS for lead of 0.15 μg/m3. The more stringent, shorter 

averaging time of a 30 day rolling average will be retained. This proposed amendment will 

ensure that the Los Angeles County can comply with the federal NAAQS. The 30-day 

average form of the proposed Rule 1420 limit, being more stringent than the three-month 

average federal NAAQS, will serve as a contingency measure in the same manner described 

above for Rule 1420.1 as it will be triggered before any actual violation of the lead NAAQS. 

In addition, language will be added to Rule 1420 to clarify New Source Review (NSR) 

requirements for stationary lead sources, consistent with AQMD’s current NSR regulation 

(Regulation XIII) and federal NSR requirements. Amendments to Rule 1420 are scheduled 

for the 4th quarter of 2012.

In response to U.S. EPA’s comments on a draft version of this Lead SIP, additional site 

specific contingency measures for each of the two large lead acid battery recycling facilities 

are described below. 

Exide:

The preamble to the Lead NAAQS final rule (73 FR 67040), specifies that the SIP should 

contain trigger mechanisms for the contingency measures, must be implemented without 

further action by the state or the Administrator, and specify a schedule for implementation.

A Compliance Plan submitted by Exide on 12/20/2011 and approved by AQMD on 

1/27/2012 under Rule 1420.1 provisions provides specific measures to be taken if Rule 

1420.1 ambient limits are exceeded. AQMD is submitting measures 8A and 8B specified in 

the compliance plan as contingency measures. These measures state that as of March 31, 

2012, if monitored ambient lead concentrations exceed 0.15 μg/m3on a rolling 30-day 

average at any AQMD or AQMD-approved ambient monitor, Exide shall implement 

mitigation measures individually or in any combination based on the specific situation and 

information available at the time. These specific mitigation measures are as follows: 

1. Install an additional room ventilation baghouse or dust collector, equipped with a second 

stage high efficiency particulate air (HEPA) filter, with sufficient blower capacity to 

move a minimum of 50,000 CFM of air from one or more of the following locations:

 The battery crusher room in the north end of the RMPS building.

 The truck loading and unloading dock on the south end of the RMPS building.

 The furnace room in the smelter building.

 The cupola feed room in the south end of the smelter building.

As an alternative to adding additional ventilation with individual baghouses or dust 

collectors, Exide may install a single larger air pollution control system with at least 

200,000 CFM of blower capacity to cover all four of these locations.

2. Install second stage HEPA filters on one or more of the following air pollution control 

systems:

 The hard lead refinery baghouse (device C47).
Chapter 6: Clean Air Act Requirements

6 - 11

 The soft lead refinery baghouse (device C46).

 The MAC baghouses venting the RMPS building (devices C156, C157).

 The cupola furnace feed room baghouse (device C48).

These measures identified in Exide’s Compliance Plan are now included in the Title V permit 

for the facility. These measures are in addition to measures identified in and required by 

Rule 1420.1. The trigger mechanism is a monitored ambient lead concentration exceeding 

NAAQS (i.e., 0.15 μg/m3on a three-month average). Rule 1420.1 ambient lead 

concentration limit of 0.15 μg/m3based on rolling 30 day average, will occur before a threemonth average NAAQS exceedance. The specific implementation will be no more than 

twelve months from the date of the NAAQS exceedance. Therefore, the contents of this 

approved, enforceable Compliance Plan meet all the requirements as a contingency measure 

for the Exide facility. 

Quemetco:

The EPA allows states to meet contingency requirements with control measures that have 

already been implemented but are not needed for attainment. The contingency measures 

should also consist of control measures that are not already included in the control strategy 

for the attainment demonstration of the SIP. The SIP must indicate that the measures will be 

implemented without further action (or only minimal action) by the state or by the 

Administrator.

Quemetco has designed, constructed, source tested, and now operates a wet electrostatic 

precipitator (WESP) to control particulate and metal emissions such as lead. The WESP 

technology serves as a secondary control device to capture low concentrations of specific 

contaminants present in the gas stream as condensable particulates. 

For Quemetco, proper design and operation of WESP would serve as the contingency 

measure. The operating conditions as specified in the Title V permit for the facility is as 

follow:

 The operator shall use this equipment in such a manner that the pH being monitored is 

not less than 6.5 of the pH scale. To comply with this condition, the operator shall install 

and maintain a(n) pH meter to accurately indicate the pH in the recirculation tank serving 

the scrubber. In addition, each pH meter shall be equipped with a chart recorder to 

continuously monitor and record the pH in the recirculation tank serving the scrubber.

 The operator shall use this equipment in such a manner that the flow rate being 

monitored, is not less than 1200 gallons per minute (gpm). To comply with this 

condition, the operator shall install and maintain a(n) flow meter to accurately indicate 

the flow rate in the liquid supply lines to the top of each scrubber compartment. Each 

flow meter shall be equipped with a chart recorder to continuously record the 

recirculating liquid flow rate, in gpm.

 The operator shall install and maintain a(n) flow meter to accurately indicate the flow rate 

in the water wash supply line in each WESP device. Each flow meter shall be equipped 

with a chart recorder with continuously records the flow rate, in gpm, and the duration, in 
Chapter 6: Clean Air Act Requirements

6 - 12

minutes, of each wash cycle. The flow rate to the WESP spray wash nozzles shall not be 

less than 144 gpm whenever a wash cycle is in progress.

 The operator shall install and maintain a(n) voltmeter to accurately indicate the voltage in 

the high voltage electric circuit serving each WESP device. The initial electric field 

voltage in each WESP device shall not be less than 15 kilovolts.

 The operator shall install and maintain a(n) flow meter to accurately indicate the flow rate 

in the exhaust outlet in each WESP device. A minimum of 4 WESP shall be in full 

operation at any one time.

The WESP is included in the Title V permit for the facility, and after more than three years 

of continuous operation, and several rounds of extensive testing, it has demonstrated a 

substantial reduction in emissions of lead. The control efficiency achieved by the WESP is 

not required by Rule 1420.1. It has already been implemented and is more stringent than 

Rule 1420.1 and RACM requirements. The emissions reductions provided by this device are 

not needed for or included in the control strategy to demonstrate attainment for this facility as 

presented in Chapter 5. Therefore, it meets all the requirements necessary as a contingency 

measure for the Quemetco facility.

WESPs are considered to be an excellent control technology for target compounds such as 

arsenic and lead. Arsenic is expected to be greatly reduced in the scrubber section of the 

WESP, while the other particulate metals compounds can be removed in the electrode 

collection section. Generally, WESPs are regarded as particulate removal devices. After 

construction of the WESP, a series of tests were performed in November 2008, March 2009, 

June 2009, and November 2009 to assess the effectiveness of the design. Comparison of 

before and after the installation and operation of the WESP indicates an overall control 

efficiency of up to 86% for lead.

At Quemetco, an “upflow” WESP design was selected. With upflow design, inlet gas from 

the kiln, reverberatory furnace, electric arc furnace, and refinery flows through the primary 

particulate control equipment (compliant with Rule 1420.1 requirements), and then into the 

bottom of the WESP. Initial treatment is performed in the scrubber section at the lower part 

of the WESP. The scrubber section contains a packed bed condenser/absorber. In this 

section, SO2 is removed from the gas stream through the use of a low-concentration sodium 

carbonate solution as the scrubber liquid. For particulate metals control, the main purpose of 

the scrubber section is to ensure that the flow of inlet gas is saturated and evenly distributed 

as it moves to the collection section above. A liquid cooling circuit consisting of a cooling 

tower and a plate-and-frame heat exchanger cools the gas and condenses the water vapor. A 

blowdown stream is taken from the scrubber section recirculation line to bleed sulfate 

reaction products and condensed water from the system. The blowdown is used as make-up 

water for other scrubbing processes in the plant.

Gas cooling in the scrubber section offers a number of advantages. Of these, the most 

important is water condensing on the sub-micron particulate metals. This results in increased 

particle size and higher collection efficiencies in the collection section. The gas volume is 

also reduced, allowing the collection section to be smaller than would otherwise be needed. 

Finally, gas cooling in the scrubber section ensures the greatest possible capture of 
Chapter 6: Clean Air Act Requirements

6 - 13

condensable compounds such as arsenic from the gas stream prior to entering the collection 

section.

After passing through the scrubber section, the gas enters the collection section, which is 

made up of an array of tubes with a high-voltage electrode running through the center of 

each. Particulate metals collection in this area involves three steps. Initially the particles are 

given a negative charge by an ionizing corona produced by the electrode. Next the electrical 

field between the electrode and the tube wall causes the charged particles to migrate to and 

accumulate on the tube walls. Finally, accumulated particulate is periodically washed from 

the tube walls into a discharge basin at the bottom of the WESP. As the treated exhaust exits 

the collection section, it passes through a mist eliminator for water droplet removal prior to 

discharge through a stack.

Satisfaction of Contingency Requirements: According to the preamble to the Lead NAAQS

final rule (73 FR 67040), the key requirements associated with contingency measures are:

 Contingency measures must be fully adopted rules or control measures that are ready to 

be implemented as expeditiously as practicable upon a determination by EPA that the 

area has failed to achieve, or maintain reasonable further progress, or attain the lead 

NAAQS by the applicable statutory attainment date.

 The SIP should contain trigger mechanisms for the contingency measures and specify a 

schedule for implementation.

 The SIP must indicate that the measures will be implemented without further action (or 

only minimal action) by the state or by the Administrator.

 The contingency measures should also consist of control measures for the area that are 

not already included in the control strategy for the attainment demonstration of the SIP.

 The measures should provide for emission reductions that are at least equivalent to one 

year’s worth of reductions needed for the area to meet the requirements of RFP, based on 

linear progress towards achieving the overall level of reductions needed to demonstrate 

attainment.

All of these key requirements are satisfied by the provisions of adopted AQMD Rule 1420.1 

and the other compliance and permit mechanisms listed above.

The rule is fully adopted, and the Compliance Plan provision serves as a contingency 

measure that will already be implemented before a determination of failure to meet RFP or 

the attainment date. Rule 1420.1 contains specific trigger mechanisms more stringent than 

the NAAQS, with specific contingency control measures to be included in a targeted, 

facility-specific Compliance Plan. Implementation of the contingency measures in the 

approved Compliance Plan is triggered automatically without further action by the state or 

the Administrator. The approval of the Compliance Plan will necessarily occur months 

before EPA can provide notification of the need to implement contingency measures. 

Therefore, the Compliance Plan approval process is not subject to the minimal action 

requirement, although it still meets the EPA interpretation of this requirement, i.e. that no 

further rulemaking actions by the state, or EPA, would be needed to implement the 
Chapter 6: Clean Air Act Requirements

6 - 14

contingency measures (73 FR 67039). The contingency measures in the Compliance Plan are 

not already included in the SIP or Rule 1420.1; they are additional, targeted measures to 

control lead emissions from unanticipated problems not already covered by the rule. The 

more stringent ambient monitoring requirements under rule 1420.1 are an additional 

contingency measure that leads to more than one year’s worth of reductions based on 

observed ambient air concentrations.

In addition, an approved and enforceable Compliance Plan with a trigger mechanism at 

Exide, and an existing additional control device at Quemetco, provide additional contingency 

measures that further satisfy CAA requirements 

REASONABLE FURTHER PROGRESS (RFP)

The CAA requires SIPs for most nonattainment areas to demonstrate RFP toward attainment 

through emission reductions phased in from the time of the SIP submission out to the 

attainment date. The revised lead NAAQS provides further detail on how RFP is to be 

addressed in lead SIP submittals (73 FR 67038). Per CAA section 171, RFP is defined as 

“such annual incremental reductions in emissions of lead as are required by this part or may 

reasonably be required by the Administrator for the purposes of ensuring attainment of the 

lead NAAQS by December 31, 2015”. To determine RFP for lead, at a minimum, controls 

must be implemented expeditiously and an accurate estimate of emissions reductions that 

will be achieved by control measures should be quantified.

For Exide, in 2010, the actual total emissions were 655.54 lbs/yr. Since Rule 1420.1 is 

already adopted and all provisions in the rule leading to emissions reduction are already in 

effect, the emissions from Exide for 2012 are anticipated to be 437.41 lbs/yr, which is the 

total allowable emissions limit established in Rule 1420.1. The amount represents minimium 

emission reductions necessary for Exide to ensure attainment, and show compliance with 

Rule 1420.1 requirements. Since the compliance deadline for meeting Rule 1420.1 ambient 

limits is January 1, 2012, Exide’s emissions after 2012 should either decrease or stay the 

same. Therefore, as shown in Figure 6-2, RFP for Exide is demonstrated through the early 

achievement of the required emissions reductions mandated under Rule 1420.1. 
Chapter 6: Clean Air Act Requirements

6 - 15

FIGURE 6-2

Demonstration of RFP for Exide

For the Quemetco facility, in 2010, the actual total emissions were 96.21 lbs/yr, which is well 

below the allowable emission limit of 422.32 lbs/yr established in Rule 1420.1. Since 

Quemetco has already taken major steps in reducing lead emissions, as shown by their 2010 

emissions, it is not anticipated that their emissions will increase to the total allowable limit. 

In order to estimate Quemetco’s actual future emissions for RFP demonstration, the emission 

growth factor contained in the 2007 AQMP was applied to the actual baseline emissions in 

2010, and as a result, 2012 and 2015 lead emissions are estimated to be 98.06 lbs/yr and 

107.73 lbs/yr, respectively. These total emissions continue to be much less than the 422.32 

lbs/yr allowable emission limit. Therefore, as shown in Figure 6-3, RFP has been met since 

2010. 

350

400

450

500

550

600

650

700

2010 2011 2012 2013 2014 2015

Total Lead Emissions (lb/year)

Exide

Actual 2010 

& Projected 

2012-2015 

(based on 

Rule 1420.1 

Allowable 

Emission 

Limits) 

Emissions

RFP
Chapter 6: Clean Air Act Requirements

6 - 16

FIGURE 6-3

Demonstration of RFP for Quemetco

CAA Section 171 also states that RFP for lead nonattainment areas should be met by 

“adherence to an ambitious compliance schedule” which is expected to periodically yield 

significant emission reductions, and as appropriate, linear progress. The EPA recommends 

that SIPs for lead nonattainment areas provide a detailed schedule for compliance of RACM 

(including RACT) in the affected areas and accurately indicate the corresponding annual 

emission reductions to be achieved.

The “ambitious compliance schedule” requirement for RFP is already met since adopted Rule 

1420.1 contains compliance deadlines of July 1, 2011 for implementation of all requisite 

control measures and emissions limits, and January 1, 2012 for the ambient monitoring limit 

of 0.15 μg/m3. Rule 1420.1 complies fully with RACM, and since Rule 1420.1 is already 

adopted, and all provisions in the rule leading to emissions reductions are already in effect, 

there is no need to further indicate annual incremental reductions or linear progress for RFP 

purposes. All emission reductions have already been achieved. The facilities are already 

subject to emission limits and ambient monitoring requirements that will ensure compliance 

with the NAAQS.

The CAA also requires early implementation of less technology intensive control measures 

(e.g. controlling fugitive dust emissions at the stationary source, as well as required controls 

on area sources), and phased in implementation of more technology intensive control 

50

100

150

200

250

300

350

400

450

500

2010 2011 2012 2013 2014 2015

Total Lead Emissions (lb/year)

Quemetco

Total 

Allowable 

Emissions 

Under rule 

1420.1

Actual 2010 

& Projected 

2012-2015 

(based on 

2007 AQMP 

growth 

factors) 

Emissions
Chapter 6: Clean Air Act Requirements

6 - 17

measures, such as those involving the installation of new hardware. Rule 1420.1 outlines 

requirements for total enclosures of all areas which process, handle and store lead-containing 

materials for the control of fugitive emissions, in addition to add-on controls such as the 

usage of filters or bags achieving 99.97% control efficiency on 0.3 micron particles, and 

secondary lead controls on dryers. Rule 1420.1 also includes additional provisions requiring 

detailed housekeeping, and periodic emissions testing of air pollution control devices. 

Failure to comply with these requirements will result in violations and associated further 

actions to bring the facility into compliance. 

REASONABLY AVAILABLE CONTROL MEASURES (RACM) AND 

REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) 

REQUIREMENTS

The federal Clean Air Act, Section 172(c)(1) and the new lead NAAQS regulation (73 FR 

66964), requires lead nonattainment area SIPs contain all reasonably available control 

measures (RACM), including reasonably available control technology (RACT). For each 

nonattainment area required to submit an attainment demonstration, Section 172(c)(1) and 

(c)(2) of the CAA requires the area to demonstrate that it has adopted all control measures 

necessary to show that it will attain the revised lead standard as expeditiously as practicable. 

In order to comply with this provision, the AQMD has identified and evaluated all measures 

it has implemented or plans to implement in the future and compare them with measures 

implemented by other agencies within and outside of the state. Once the process of 

determining RACM for an area is completed, the individual measures should then be 

converted into a legally enforceable vehicle (e.g. a regulation or permit program), as it was 

done for Rule 1420.1.

RACM should address sources of ambient lead concentration, but primarily limited to 

stationary sources emitting more than 0.5 tons per year (73 FR 67037). Based on monitoring 

data, the AQMD staff has identified large lead-acid battery recycling facilities as the only 

stationary source emitters of lead in the Los Angeles County, that cause or has the potential 

to cause exceedances of the new lead NAAQS. As a result, On November 5, 2010, the 

AQMD adopted Rule 1420.1 – Emissions Standard for Lead From Large Lead-Acid Battery 

Recycling Facilities. The purpose of the rule is to protect public health by reducing exposure 

and emissions of lead from large lead-acid battery recycling facilities, and to address the new 

NAAQS for lead to ensure the Los Angeles County can achieve the revised lead standards. 

RACM should identify potential control measures for sources of lead in the nonattainment 

area. The control measures should be evaluated for reasonableness, considering their 

technological feasibility and the cost of control within the nonattainment area. Rule 1420.1 

includes extensive and comprehensive provisions for the control of lead point source and 

fugitive emissions. 

In addition, EPA document titled "Implementation of the 2008 Lead National Ambient Air 

Quality Standards (NAAQS) - Guide to Developing Reasonably Available Control Measures 

(RACM) for Controlling Lead Emissions," dated March 2012, contains an analysis of lead 

emission control measures for the purpose of determining what controls may constitute 
Chapter 6: Clean Air Act Requirements

6 - 18

reasonably available control measures (RACM), including reasonably available control 

technologies (RACT) pursuant to Section 172(c)(1) of the Clean Air Act. The document 

identifies control measures for lead emissions from sources in the Secondary Lead Smelting, 

Lead Acid Battery Manufacturing, Iron and Steel Mills, and Iron and Steel Foundries source 

categories. For each identified control measure, the document contains an assessment of how 

likely the control measure is to constitute RACM based on criteria outlined in the report. 

There are three types of emissions from secondary lead smelting facilities: process 

emissions, process fugitive emissions and fugitive dust emissions. For all three types of 

emissions, the document specifically references the control measures included in AQMD

Rule 1420.1 as RACM in their analysis.

The EPA’s historic definition of RACT is the lowest emissions limitation that a particular 

source is capable of meeting by the application of control technology that is reasonably 

available considering technological and economic feasibility. RACT applies to the “existing 

sources” of lead in an area emitting 0.5 tons per year or more, including stack emissions, 

industrial process fugitive emissions, and industrial fugitive dust emission. The CAA 

requires the EPA to revise RACT, update existing Control Technique Guidelines (CTG) 

documents, or develop new documents, on a frequent basis to provide states and local 

agencies with most current technical information and assist them in determining RACT. 

AQMD staff compared the current requirements in the AQMD’s rules pertaining to lead 

emissions with the requirements in the revised CTGs as part of the Rule 1420.1 development 

process. Rule 1420.1 meets or exceeds the emissions controls provided in the CTGs. 

To address technological and economic feasibility, a socioeconomic assessment was 

conducted to analyze the costs associated with compliance under Rule 1420.1 as part of the 

rule development process. In addition, pursuant to California Environmental Quality Act 

(CEQA) Guidelines §15252 and AQMD Rule 110, the AQMD prepared an Environmental 

Assessment for Rule 1420.1.3 The socioeconomic assessment for Rule 1420.1 is provided in 

Appendix II.

 

The AQMD staff has concluded that Rule 1420.1 fulfills the RACM/RACT requirements for 

the revised lead NAAQS. In general, the AQMD’s current rules and regulations are 

equivalent to or more stringent than those developed by other air districts. Table 6-2 

provides a comparative analysis of Rule 1420.1 and Rule 1420 with the monitoring

requirements of the new lead NAAQS regulation and NESHAP requirements for secondary 

lead smelters. Moreover, AQMD proposes to revise Rule 1420 in the 4th quarter of 2012, 

which will ensure that sources of lead which are not subject to Rule 1420.1 will never exceed 

the 2008 NAAQS for lead. No such sources currently exceed the 2008 NAAQS for lead.

 

3

From AQMD’s website, available at: http://www.aqmd.gov/ceqa/aqmd.html
Chapter 6: Clean Air Act Requirements

6 - 19

TABLE 6-2

Comparison of AQMD Rule 1420.1 with AQMD Rule 1420, the 2008 Lead NAAQS, and 

the NESHAP for Secondary Lead Smelters

Rule Element AQMD Rule 1420.1 AQMD Rule 1420 2008 Lead NAAQS

NESHAP from 

Secondary Lead 

Smelting

Applicability Lead-acid battery 

recycling facilities 

that have processed 

more than 50,000 

lead-tons/year in the 

past 5 years or in any 

future year

Facilities that use or 

process leadcontaining materials

All lead sources Secondary lead 

smelters

Ambient Air 

Quality 

Standard

On and after January 

1, 2012, meet 0.15 

μg/m3averaged over 

30 consecutive days

1.5 μg/m3averaged 

over 30 days

0.15 μg/m3:

- 3-month average of 

monthly averages

- Demonstrated over a 3-

year period.

None

Total 

Enclosures

Total enclosures for 

main areas where 

processing, handling 

and storage of leadcontaining materials 

occur

None4 None5 Total or partial 

enclosures for:

- Smelting furnace 

and dryer charging 

hoppers, chutes, 

and skip hoists;

- Smelting furnace 

lead taps, and 

molds during 

tapping;

- Refining kettles;

- Dryer transition 

pieces; and

- Agglomerating 

furnace product 

taps

Emission 

Standard and 

Requirements 

for Lead 

Control Devices

- Total facility mass 

emission rate of 

0.045 lbs/hr of lead 

from all lead point 

sources; maximum 

emission rate of 

0.010 lb/hr of lead 

for any individual 

lead point source 

- Use of filters or 

bags that are rated 

99% control 

efficiency for 

particulate matter; 

98% control 

efficiency for lead

None Concentration of 2.0 

mg/dscm

 

4

Total enclosures have been required through Compliance Plans and legal actions.

5 Effective date for the NAAQS is five years after final attainment designation.
Chapter 6: Clean Air Act Requirements

6 - 20

Rule Element AQMD Rule 1420.1 AQMD Rule 1420 2008 Lead NAAQS

NESHAP from 

Secondary Lead 

Smelting

by the 

manufacturer to 

achieve 99.97 

percent control 

efficiency on 0.3 

micron particles or 

made of PTFE 

membrane material

- Secondary lead 

controls on dryer 

Compliance 

Plan

Only required if a 

facility exceeds 0.12 

μg/m3; 30 

consecutive day avg.; 

Identifies additional 

lead control 

measures beyond the 

rule; Begin 

implementation if 

facility exceeds 0.15 

μg/m3; 30 

consecutive day avg.

Specifies general 

facility information6

None None

Ambient Air 

Monitoring 

Requirements

- Minimum of four 

monitors at facility 

locations approved 

by the Executive 

Officer

- Samples collected 

at least once every 

three days

- Results reported 

monthly

- Daily sampling if 

0.15 μg/m3is 

exceeded after 

January 1, 2012

- Minimum of two 

monitors at facility 

locations approved 

by the Executive 

Officer

- Samples collected 

every six days

- Results reported 

quarterly

For states, a minimum 

of:

- One source-oriented 

monitor at all facilities 

emitting 0.5 tons of 

lead/year; and

- One non-sourceoriented monitor in 

urban areas with a 

population of at least 

500,000 people

- Samples collected 

every six days

None

Housekeeping 

Requirements

Prescribed 

requirements for 

cleaning frequencies 

of specific areas; 

maintenance activity; 

building integrity 

inspections; storage 

and transport of leadcontaining materials; 

onsite mobile 

Requirements for 

storage of dustforming material; 

weekly cleaning of 

surfaces subject to 

vehicular or foot 

traffic; and storage, 

disposal, recovery, 

and recycling of lead 

or lead-containing 

None Periodic wash down 

of plant roadways 

(lower frequency 

than Rule 1420.1); 

wet suppression of 

battery breaking 

area storage piles; 

vehicle wet washing 

of vehicles exiting 

the materials 

 

6 Additional facility requirements have been added through revised Compliance Plans.
Chapter 6: Clean Air Act Requirements

6 - 21

Rule Element AQMD Rule 1420.1 AQMD Rule 1420 2008 Lead NAAQS

NESHAP from 

Secondary Lead 

Smelting

sweeping; and 

surface 

impoundment 

cleanings

wastes generated 

from housekeeping 

activities7

handling and storage 

areas

Reporting 

Requirements

- Ambient air lead 

and wind 

monitoring;

- Shutdown, 

turnaround, and 

maintenance 

activity reports;

- Public notifications 

for specific 

shutdown and 

maintenance 

activity;

- Initial Facility 

Status Reports

- Ongoing Facility 

Status Reports

Ambient air lead and 

wind monitoring for 

any lead-processing 

facility that is 

required or elects to 

do ambient air 

monitoring

For states:

- SIP submittal;

- Emission reports; and

- Ambient air quality 

data

- Lead control 

alarm/failure 

reports including 

fugitive dust 

control measures 

performed during 

failures

 

7

Additional housekeeping measures have been required through revised Compliance Plans and legal actions.
APPENDIX I

LEAD AIR QUALITY IN LOS ANGELES COUNTY
Appendix I Page 1

The Appendix I includes:

 Monitoring data from fence-line sites 

 Exide daily and 30 day rolling averages

 Quemetco daily and 30 day rolling averages

 Monitoring data from network sites

 One- and three- month averages

 Daily average data - AQS

 Source-oriented sites

 One- and three- month averages

 Exide – Daily averages

 Quemetco – Daily averages

 Trojan – Daily averages

 Van Nuys Airport – Daily averages
APPENDIX II

RULES 
Appendix II Page 1

Rules can be found on our website at: 

Rule 1420 - https://www.aqmd.gov/rules/reg/reg14/r1420.pdf

Rule 1420.1 - https://www.aqmd.gov/rules/reg/reg14/r1420-1.pdf
APPENDIX III

MODELING AND ATTAINMENT DEMONSTRATION
Appendix III Page 1

Exide – AERMOD Source Parameters for 2015

(Total Emissions – Stack and Fugitive Emissions)

Source 

ID Source Description UTM Coordinates Emission Rate (g/s)

Release 

Ht (m) Temp (K) Velocity (m/s)

Diameter 

X (m) Y (m) (m)

S001 Raw Materials 

Processing Scrubber 389796 3763324 1.728E-04 19.360 296.48 8.702 1.09

S002 Material Handling 

Baghouse 389814 3763277 5.551E-04 34.146 295.93 12.995 2.13

S003 Soft Lead Baghouse 389841 3763343 4.108E-04 34.146 309.82 13.345 2.13

S004 Hard Lead Baghouse 389821 3763295 4.923E-04 34.146 310.37 15.860 2.13

S005 Feed Dryer Baghouse 389857 3763308 1.260E-03 36.600 375.37 10.927 0.91

S006 Neptune Scrubber 389843 3763316 8.447E-05 34.146 332.59 11.151 1.16

S007 North Torit Baghouse 389885 3763337 6.806E-04 36.600 312.04 13.340 2.101

S008 South Torit Baghouse 389883 3763334 1.738E-03 36.600 298.15 14.712 2.101

S017 Raw Materials 

Processing Fugitive 389820 3763358 3.072E-04 7.622 N/A N/A 46.0

S018 MAC Baghouse 389832 3763288 2.761E-04 36.600 296.48 19.187 1.799

L001 Roadway Fugitives 106 vol sources 2.966E-06 1.000 N/A N/A 6.0

Note:

1) The items which have been changed from the 2010 modeling (shown in previous table) are in bold and italics. 

2) S005, S007, S008, S018 stack heights were raised due to the construction of the baghouse row enclosure. 

3) The number and location of the volume sources for the roadways also changed due to the new roadway configuration. 

4) An 80% reduction was applied to the roadway fugitives to account for the good housekeeping measures required by Rule 

1420.1.

5) The stack emission rates were calculated using the Rule 1420.1 facility total emission limit of 0.045 lb/hr distributed 

among the stacks based on the ratio of the measured emissions, ensuring that no individual stack exceeded the 0.01 lb/hr 

per stack limit.

6) For 2015, in the Stacks only scenario, the point source parameters modeled were the same as listed in this table, but the 

Rule 1420.1 total facility point source limit of 0.045 lb/hr was evenly distributed throughout the stacks and each stack 

was assigned an emission rate of 6.300E-04 g/s. 
Appendix III Page 2

Quemetco – AERMOD Source Parameters for 2015 

(Total Emissions – Stack and Fugitive Emissions)

Source 

ID

Source 

Description

UTM Coordinates Emission 

Rate (g/s)

Release 

Ht (m) Temp (K) Velocity (m/s)

Diameter 

X (m) Y (m) (m)

S002 WESP 409269.08 3765291.357 5.841E-04 21.336 310.928 14.19850 2.034

S004 Busch FA 409168.74 3765360.937 4.181E-04 10.100 311.483 19.11614 1.180

S005 Busch FB 409172.69 3765357.767 5.021E-04 10.100 312.039 18.77568 1.180

S006 Busch FC 409176.63 3765353.927 8.400E-04 10.100 314.817 13.05550 1.180

S007 Busch FD 409180.57 3765350.427 4.210E-04 10.103 318.706 8.75294 1.180

S008 Busch DBE 409280.86 3765382.797 3.162E-04 10.100 299.261 16.29674 1.180

S009 Busch DCF 409284.27 3765386.947 6.855E-04 10.103 309.261 17.06880 1.180

S010 Busch DAG 409287.68 3765391.107 1.260E-03 10.103 307.594 15.92062 1.180

S011 Busch BEH 409291.10 3765395.097 2.650E-04 10.103 309.817 16.55064 1.180

S012 Busch BW 409294.53 3765399.267 3.780E-04 10.103 314.261 15.33144 1.180

S017 Battery Wrecker 

Fugitive 409260.27 3765352.270 1.999E-04 7.622 N/A N/A 46.0

L001 Roadway Fugitives 24 volume sources 8.523E-06 1.000 N/A N/A 6.0

Note:

1) The items which have been changed from the 2010 modeling (shown in previous table) are in bold and italics. 

2) The number and location of the volume sources for the roadways also changed due to the new roadway configuration. 

3) An 80% reduction was applied to the roadway fugitives to account for the good housekeeping measures required by Rule 

1420.1.

4) The stack emission rates were calculated using the Rule 1420.1 facility total emission limit of 0.045 lb/hr distributed 

among the stacks based on the ratio of the measured emissions, ensuring that no individual stack exceeded the 0.01 lb/hr 

per stack limit.

5) For 2015, in the Stacks only scenario, the point source parameters modeled were the same as listed in this table, but the 

Rule 1420.1 total facility point source limit of 0.045 lb/hr was evenly distributed throughout the stacks and each stack 

was assigned an emission rate of 5.670E-04 g/s.
Appendix III Page 3

Exide – Location of Modeled Sources – 2015 Emissions

Truck 

Wash

The buildings are shown as bright blue polygons; This configuration includes the new baghouse row which was completed in March 2012.

The line sources (made up of multiple volume sources) is shown as a red line source; This configuration reflects the addition of the truck wash area in 

the western portion of the site where all trucks with lead associated materials will have to use prior to leaving the facility, and the addition of 2 gates. 

The point sources are shown as red dots ; The volume source (raw materials processing fugitives) is shown as a dark blue square
Appendix III Page 4

Quemetco – Location of Modeled Sources – 2015 Emissions

The buildings are shown as bright blue polygons. 

The line sources (made up of multiple volume sources) is shown as a red line source; This configuration reflects the relocation of the main gate in 

order to move the on-site truck movement from areas where people are frequently walking , which will occur in 2012. 

The point sources are shown as red dots ; The volume source (battery wrecker fugitives) is shown as a dark blue square
Appendix III Page 5

Exide – 2015 Lead Concentrations (ug/m3)

Using Rule 1420.1 Emission Limits (Total Emissions – Stack and Fugitive Emissions)
Appendix III Page 6

Quemetco – 2015 Lead Concentrations (ug/m3)

Using Rule 1420.1 Emission Limits (Total Emissions – Stack and Fugitive Emissions)
Appendix III Page 7

Exide – 2015 Lead Concentrations (ug/m3)

Using Rule 1420.1 Emission Limits (Stack Emissions Only)
Appendix III Page 8

Quemetco – 2015 Lead Concentrations (ug/m3)

Using Rule 1420.1 Emission Limits (Stack Emissions Only)
APPENDIX IV

SOCIOECONOMIC REPORT FOR RULE 1420.1
Appendix IV Page 1

Socioeconomic report is available at:

http://www.aqmd.gov/aqmp/Lead_SIP/homepage.htm
APPENDIX V

RESPONSE TO COMMENTS
Appendix V Page 1

Comment 1

Comment 2

Comment 3
Appendix V Page 2
Appendix V Page 3

Comment 1: We understand that fugitive emissions are difficult to estimate. However, the 

modeled attainment demonstration needs to address fugitive emissions.

Response: To address this comment, the modeling in the Revised Draft 2012 Lead SIP 

document was revised to include the fugitive lead emissions for Exide Technologies and 

Quemetco Inc., in the Los Angeles County. Given the fact that fugitive emissions cannot be 

readily captured or directly measured, and they are challenging to estimate, the methodology in 

the EPA document titled as: “"Development of the RTR Emissions Dataset for the Secondary 

Lead Smelting Source Category", used for development of Secondary Lead Smelting NESHAP 

was used by AQMD staff to estimate fugitive emissions (for more details, please refer to Chapter 

3, Stationary Sources, Pg 3-3). With the inclusion of the fugitive emissions, modeling for both 

facilities continues to demonstrate attainment with the NAAQS for future years. 

Comment 2: Please provide adequate documentation for the modeling for EPA review, 

including an estimate of fugitive emissions and how the estimate was calculated.

Response: To address this comment, the modeling approach in Chapter 5 of the Revised Draft 

2012 Lead SIP document was revised to provide further documentation for the modeling and to 

address fugitive emissions.

Comment 3: Clean Air Act Section 172(c)(9) states that each SIP shall provide for the 

implementation of specific contingency measures to be taken if the area fails to make reasonable 

further progress, or to attain the NAAQS by the attainment date. Please provide further 

clarification on how AQMD Rule 1420.1 and its compliance plan section fulfills the 

requirements of a contingency measure.

Response: To provide further clarification on contingency measures and how AQMD Rule 

1420.1 and its compliance plan provision fulfills this requirement, more details were provided. In 

addition, facility specific contingency measures for Exide Technologies and Quemetco Inc. were 

included via reference to specific elements of approved Compliance Plan and permit conditions. 

As a result, the Contingency Measures chapter (Chapter 6, pages 6-3 to 6-14) in the Revised 

Draft 2012 Lead SIP document was expanded. In addition, language was added to clarify how 

the reasonable further progress requirements are met (Chapter 6, pages 6-15 to 6-18). 
Appendix V Page 4
Appendix V Page 5

Comment 1

Comment 2
Appendix V Page 6

Comment 2
Appendix V Page 7

Comment 3

Comment 1
Appendix V Page 8

Comment 1
Appendix V Page 9

Comment 1: It is imperative that AQMD’s lead SIP implement all reasonable measures and 

technologies to appropriately protect human health and the environment, as required by the 

Clean Air Act. In addition, the AQMD must include Wet Electrostatic Precipitator (WESP) as a 

Reasonably Available Control Measures (RACM) and perform an analysis of whether it qualifies 

as Reasonably Available Control Technologies (RACT) for lead recycling facilities in Los 

Angeles County. 

Response: Staff performed a feasibility analysis of all reasonable measure and technologies as 

part of Rule 1420.1 rule development. In addition, staff looked at the Wet Electrostatic 

Precipitator (WESP) since already installed by Quemetco and concluded that addition of WESP 

as a secondary control was not considered cost effective at this time. However, employing a 

control measure identified in Rule 1420.1, requiring 99.97% control efficiency for 0.3 micron 

particles would yield similar results. This analysis has been confirmed by the EPA document 

titled "Implementation of the 2008 Lead National Ambient Air Quality Standards (NAAQS) -

Guide to Developing Reasonably Available Control Measures (RACM) for Controlling Lead 

Emissions," dated March 2012. The document states that “installing an add-on control 

technology, such as, WESP, downstream of the primary control would double the control 

technology costs. Moreover, because fabric filters can achieve efficiencies of greater than 99%,

the amount of further lead emissions captured is relatively low compared to the amount captured 

with a fabric filter controlling uncontrolled emissions.

Comment 2: The Draft Lead SIP documents that the lead emissions from the Exide facility are 

well above the 2008 lead NAAQS, and therefore, the Exide facility may not meet the 2008 lead 

NAAQS and that additional measures must be considered.

Response: The revised modeling for attainment demonstration for Exide in the Revised Draft 

2012 Lead SIP document that includes the fugitive and stack lead emissions demonstrates 

attainment with the NAAQS prior to 2015. Monitoring demonstrates that Exide met the Rule 

1420.1 standard prior to January 2012. Furthermore, the existing Rule 1420.1 and the 2012 Lead 

SIP contingency measures would trigger additional controls if warranted. 

Comment 3: Given the significant health risks from lead pollution, and the importance of 

developing a lead SIP to fully address these risks, AQMD’s lead SIP must be revised to include a 

discussion of Reasonably Available Control Measures (RACM) and Reasonably Available 

Control Technologies (RACT) that complies with Clean Air Act requirements.

Response: A recent EPA document titled "Implementation of the 2008 Lead National Ambient 

Air Quality Standards (NAAQS) - Guide to Developing Reasonably Available Control Measures 

(RACM) for Controlling Lead Emissions," dated March 2012, contains detailed analysis of lead 

emission control measures for the purpose of determining what controls may constitute RACM, 

including RACT, pursuant to Section 172(c)(1) of the Clean Air Act. The document identifies 

control measures for lead emissions from sources in the Secondary Lead Smelting, Lead Acid 

Battery Manufacturing, Iron and Steel Mills, and Iron and Steel Foundries source categories. For 

each identified control measure, the document contains an assessment of how likely the control 

measure is to constitute RACM based on criteria outlined in the report. There are three types of 

emissions from secondary lead smelting facilities: process emissions, process fugitive emissions 
Appendix V Page 10

and fugitive dust emissions. For all three types of emissions, the document specifically 

references the control measures included in the adopted AQMD Rule 1420.1 as RACM, 

including RACT in their analysis. Therefore, the provisions of RACM and RACT have been 

fully addressed in Chapter 6 of the Revised Draft 2012 Lead SIP. 
Appendix V Page 11

 

Comment 1
Appendix V Page 12

Comment 1: When was the data identifying the Los Angeles County as “nonattainment” 

gathered? Is it possible that the data is now so outdated that the rule itself is obsolete?

Response: On December 31, 2010, the EPA designated the Los Angeles County portion of the 

Basin, excluding San Clemente and Santa Catalina Islands (Southern Los Angeles County), as 

nonattainment for the 2008 Lead NAAQS based on monitored air quality data from 2007-2009, 

indicating a violation of the NAAQS, pursuant to section 107 (d)(1) of the CAA. This 

nonattainment status is due to lead emissions from two large battery recycling facilities, Exide 

Technologies (located in the City of Vernon) and Quemetco Inc. (City of Industry). On 

November 5, 2010, AQMD adopted Rule 1420.1 to establish additional requirements for large 

lead-acid battery recycling facilities, to protect public health, and to ensure attainment of the new 

2008 NAAQS for lead. The preliminary 2011 monitoring results show considerable 

improvement, but still some violations of the NAAQS. The only site above the new 2008 

NAAQS for lead is the Rehrig site at Exide Technologies which has also shown compliance as of 

December 2011. For more specific details regarding air quality near these sources, please refer 

to Chapter 2, Lead Air Quality in Los Angeles. 
Appendix V Page 13

Comment 1
Appendix V Page 14

Comment 1: Page 1-12 of the Draft SIP states that there has been no change to the State lead air 

quality standard (which is true) and therefore, no recent changes to the State designation of the 

lead have been made. However, the lead designation for the AQMD Basin (Los Angeles County 

portion) changed from attainment to nonattainment, effective on September 25, 2010, based on 

data for the period of 2006 to 2008. 

Response: This comment is correct and the Final Draft Lead SIP has been revised to address 

this comment (page 1-12).