## 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(this page intentionally left blank)i TABLE OF CONTENTS

Page

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

INTRODUCT ION ......................................................................................................... 1

LOS ANGELES COUNTY LEAD SIP .......................................................................... 2
Introduc tion ............................................................................................................ 2 Air Qua lity .............................................................................................................. 2
Emissi ons .............................................................................................................. 3
Attainment De monstrat ion ..................................................................................... 3 New Source Review ............................................................................................... 4 Reasonably Available Control Technology and Reasonably Availabl e Control M easure ............................................................ 5
Enhanced Moni toring ............................................................................................. 6
Reasonable Furt her Progr ess ................................................................................ 6 Contingency Measures .......................................................................................... 7

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

APPENDIX A: FINAL – 2012 LEAD STATE IMPLEMENTATION PLAN
LOS ANGELES COUNTYii (this page intentionally left blank)-1- Proposed State Implementation Plan Revision

for the Federal Lead Standard

OVERVIEW

The purpose of this report is to summari ze a proposed revision to the California State Implementation Plan (SIP ) that provides for attaining the National Ambient Air Quality Standard for lead (federal l ead standard) in Los Angeles County. The revision is required under the federal Clean Air Act (CAA). The South Coast Air Quality Management District (South Coas t 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 info rmation 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 firs t set a federal lead standard in 1978, at a level of 1.5 μg/m 3 . Since then, the scientific ev idence related to the health and environmental impacts of lead has ex panded dramatically and shows that adverse impacts occur at much lower levels. Based on this new evidence, U.S. EPA revised the federal lead standar d on October 15, 2008, lowering it to a level of 0.15 μg/m 3 (a 90 percent reduction). The standard is violated when lead concentrations, averaged over a rolling three-month period, exceed 0.15 μg/m 3

.

When U.S. EPA revises a federal standard, the agen cy designates areas with
ambient concentrations that violate the standard as nonattainment. The Los Angeles County portion of the S outh Coast Air Basin, excluding San Clemente and Santa Catalina islands (h ereafter referred to as Los Angeles County), is the only area in California t hat violates the feder al lead standard, and U.S. EPA designated this area as nonattain ment on December 31, 2010. Under the CAA, a lead nonattainment area must de velop 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 Ca lifornia, including concentrations throughout most of Los Angeles County, ar e far below the level of the federal standard. However, violati ons of the federal lead standard occasionally occur in the area immediately surroundi ng two large lead-acid batt ery recycling facilities, based on near-source monitoring. The S outh 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 SI P that demonstrates attainment of
the federal lead standard around these fac ilities by December 31, 2015. While the attainment strategy is focused on the fa cilities that contribut e 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 Go verning Board adopted the Lead SIP at a public hearing on May 4, 2012. The S outh 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 nu mber of specific require ments, as set forth in CAA section 172(c). These requirem ents include the development of an emissions inventory, completion of an a ttainment 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 implementi ng contingency measures. The following sections provide a brief summary of t he various elements of the Lead SIP, as they relate to the requirements establishe d 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 bec ause of State and federal re gulations that phased-out the use of lead as an anti-knock agent in gasoline for motor vehicles. Although lead has been virtually eliminated from mo tor vehicle fuel, it is still used as an additive in general aviation gasoline, whic h is used in general aviation aircraft with piston engines. The South Coast Dis trict has collected ambient lead data in Los Angeles County since 1975 via its r egional monitoring network. The South
Coast District has also monitored am bient lead concentrations near general aviation airports – specifically, near Van Nuys Airport, which is California’s largest airport in terms of lead emissi ons. Monthly average lead concentrations
at all of these sites show dramatic r eductions – from concentrations as high as-3- 7.49 μg/m 3 in 1976, to the current levels of 0.04 μg/m 3 or less, far below the level
of the revised standard.

In contrast to these monitors, a netw ork 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, concent rations decrease rapidly with distance
from the source. The cu rrent violations of th e 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 im plementing rules to address these violations. As a result, lead conc entrations have decreased and have been
below the level of the federal lead standard since December 2011.

Emissions

Similar to the rest of the nation, l ead emissions in Los Angeles County have declined dramatically over t he last four decades. This reduction in emissions is
reflected in the decrease in ambient l ead concentrations at population-oriented monitors. As discussed in the previous section, the current lead violations In Los Angeles County are the result of emi ssions from two large lead-acid battery recycling facilities. These two facilitie s have been identified as the only sources contributing to violat ions in the area.

These large lead-acid battery recycli ng facilities are broadly categorized as secondary lead smelters. U.S. E PA has determined that secondary lead smelters are some of the largest stati onary source lead emitters in the United States. Overall, ther e are 15 facilities in the nation, including the two facilities in Los Angeles County. The re cycling 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 t hat 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 inv entory 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 proj ected emissions based on growth factors and compliance requi rements between 2010 and 2015.

Attainment Demonstration

The main purpose of the Lead SIP is to demonstrate attainment of the federal lead standard by the Decem ber 31, 2015, statutory deadl ine. To address lead-4- emissions from the large lead-acid batte ry recycling facilities in Los Angeles County, the South Coast District a dopted Rule 1420.1– Emissions Standard for Lead from Large Lead-Acid Battery Recyclin g Facilities in November 2010.
Rule 1420.1 limits lead emissions from st acks, requires total enclosures of dust, and contains stringent housekeeping requirem ents. In combi nation 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 effe ctive in attaining the federal lead standard than the traditional approach based on emission reductions, alone.

To assess the effectiveness of the cont rol strategy, the South Coast District completed an attainment demonstrat ion 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 concentrati ons for a 2010 base year and the 2015 attainment year. The mode ling runs included both stac k 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 s how future year (2015) ambient lead
concentrations below the level of the f ederal standard for both facilities. Thus, the modeling analysis demonstrates attain ment 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 ar e rules that apply to newly constructed stationary sources and to major modifica tions 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 m odified stationary sources do not slow progress toward attainment.

For the federal lead standard, NSR requi rements 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-relate d facilities, it is unlikely that the lead NSR requirements would ever be triggered. The comb ined lead emissions from all stationary sources in Los Angeles C ounty 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 Coas t District has all of the required NSR provisions in place.-5- In addition to the NSR provisions, Sout h 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 ar eas 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 Technolog y (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 hav e the potential to cause violations of
the federal lead standard. The South Coast District has conducted the required RACT/RACM analysis on existing lead source s and therefore, fully meets this requirement.

In general, the RACT/RACM review in cludes analysis of emission controls adopted in other nonattainment areas, as we ll as controls identified by U.S. EPA in guidelines or other doc uments. To satisfy the RACT/RACM requirement, the
South Coast District identified and eval uated 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 Califor nia, as well as with the available U.S. EPA guidelines.

Based on this evaluation, the South C oast 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 guidance 1 . 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 provis ions specified in Rule 1420.1 will ensure
attainment of the federal lead st andard by the stat utory 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-ori ented monitoring. Therefore, the
attainment demonstration must address those specific facilities that contribute to
violations of the national standard. T he attainment strategy for Los Angeles County is based on a combination of lead emissions reductions, in tandem with an ambient monitoring progr am that is more stri ngent than current federal monitoring requirements.

In addition to rules that limit emissions from lead sources, the South Coast District requires source-oriented lead m onitors around large lead-acid battery recycling facilities, the only sources with t he potential to cause violations of the
federal lead standard. Under South Coas t District Rule 1420.1, large lead-acid battery recycling facilities must mainta in 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 expe cted ground-level concentration. As of January 1, 2012, a source must implement additional lead emissions controls
when concentrations at a source-o riented monitor exceeds 0.15 μg/m 3 , averaged over a 30-day period. The Rule 1 420.1 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 ti me. Reasonable Further Progress (RFP) requirements are designed to track progre ss, thereby ensuring the nonattainment
area will attain the federal standard by the statutory deadline. In Los Angeles County, lead violations ar e 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 implem enting all required
control measures and emissions limits and a compliance deadline of January 1, 2012, for meeting the ambi ent monitoring limit of 0.15 μg/m 3

.

Because the deadline for compliance with Rule 1420.1 has already passed, both large lead-acid battery recycling facilit ies 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 establis hed in Rule 1420.1. Based on growth factors, lead emissions at this fac ility could increase between now and 2015, but
would still remain well below the allowabl e limit established in Rule 1420.1.

The effectiveness of Rule 1420.1 has been demonstrated thr ough the substantial
reductions in ambient concentrations that have already occurred. Since December 2011, no source-oriented monito r 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 ru les 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 dem onstrate sufficient progress. The South Coast District has several contingency m easures in place for lead that are already fully adopted as part of Rule 14 20.1. Furthermore, these measures apply to the facilities that contribute to vi olations of the feder al lead standard in Los Angeles County:

- Compliance Plan: If a source-oriented monitor measures a 30-day rolling average lead c oncentration of 0.12 μg/m 3 or more, the facility must submit a Compliance Plan identifying
measures that will be automatically implem ented if ambient concentrations exceed 0.15 μg/m 3 , 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 concentra tion exceeding 0.12 μg/m 3

, 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/m 3 , calculated as a 30-day rolling average, as measured by any source-oriented monitor;
ambient concentrations exceed ing this level trigger the implementation of daily monitoring, a Compliance Plan, and a Feasibility Study.-8- Given that the 30-day rolling average spec ified in Rule 1420.1 is more stringent than the rolling three-month average spec ified in the federal lead standard, provisions of the Rule wil l 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/m 3 , calculated as a 30-day rolling av erage. 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 t he CAA requirements. Thus, ARB staff recommends the Board approve the Lead SIP as a revision to the st atewide SIP.

The cornerstone of the Lead SIP is Sout h Coast District Rule 1420.1, which specifically addresses emissions from t he two large lead-acid battery recycling
facilities that contribute to violations of the federal lead st andard in Los Angeles County. The requirements of Rule 1420. 1, which was adopted in 2010, are more stringent than federal requirements and hav e been effective in reducing ambient
lead concentrations. Ambient lead conc entrations have been below the level of
the federal lead standard since Dece mber 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

## S o u t h C o a s t A i r Q u a l i t y M a n a g e m e n t D i s t r i c t

FINAL 2012 L EAD 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 Rule s Philip Fine, Ph.D.

Authors: Victoria Moaveni Senior Air Quality Engineer

Jillian Baker, P h.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 SpecialistSOUTH COAST AIR QUAL ITY MANAGEMENT DISTR ICT
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 Representati ve, Los Angeles County, Eastern Region

JOSIE GONZALES Supervisor, Fifth District San Bernardino County Representative

R ONALD 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 Councilme mber, 9 th District Cities Representative, Los Angeles County

MIGUEL A. PULIDO Mayor, City of Santa Ana Cities Representative, Orange County

EXECUTIVE OFFICER:

B ARRY 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 SurveyDraft 201 2 Lead SIP Table of Contents

TOC

– i April 2012 TABLE OF CONTENTS

TABLE OF CONTENTS

................................ ................................ ................................ .. i
LIST OF TABLES

................................ ................................ ................................ ........... i ii
LIST OF FIGURES

................................ ................................ ................................ ......... i v

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

- 1 1 Summary

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

- 1 7

CHAPTER 3

– LEAD INVENTORY

Introduction

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

- 1
Emission Inventories

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

- 1

Base and Future Year Emissions

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

- 2 Uncertainty in the Inventory

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

- 1 2

CHAPTER 4

– LEAD CONTROL STRATEGY

Introduction

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

- 1 Overall Attainment Strategy

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

- 1Draft 201 2 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 COMMENTSDraft 201 2 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 T echnologies (Vernon Facility) 2

- 12

Table 2

- 4 Name and location of all fence

- line monitoring stations

operated by Quemetco Inc. 2

- 1 5

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

- 1 1

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

- 20Draft 201 2 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

T echnologies (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

- 1 5

Figure 2

- 8 Fence

- line 30

- day rolling average lead concentrations at the

Quemetco recycling battery facility 2

- 1 6

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 SIPExecutive Summary

E S

- 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 S tate Implementation Plan (SIP) for Los Angeles County

- (2012 Lead SIP);

 Questions and answers concerning this 2012 lead SIP



### LEAD AIR QUALITY AND REGULATORY BACKGROUN D

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

se t 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 PM 10 and PM 2.5 , nitrogen dioxide , carbon monoxide, a nd 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 crit eria 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/m 3 ) in
1978 . On October 15, 2008 (73 FR 66964; November 12, 2008), EPA tightened the standard by reducing it to 0.15 μg/m 3 , and changing the form of the standard to a rolling 3

- month average rather than the previous quarterly average. Once EPA establishes or revise s 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, ex cluding 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

- aci d 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 c ontaining 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 t o 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 noExecutive Summary

E S

- 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 o f 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 w ell 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,” pr esents 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 s pecific federal requirements and how they are satisfied by this 2012 Lead SIP.Executive Summary

E S

- 3 

### QUESTIONS AND ANSWER S 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?

Ye s. 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

am bient 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 on

road vehicles. Substantial emission reductions have also been achieved due to en hanced 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 concentr ations 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/m 3 in 1976 to an urban background level of about 0.01 μg/m 3 ). Although past controls have resulted in subs tantial lead emission reductions, the revised 2008 NAAQS for lead of 0.15 μg/m 3 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 ins tead 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 Indus try), 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 t o 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

E S

- 4 

### What are the major sources contributing to lead nonattainment ar eas 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 ha ve 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 1 420.1

– 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 quantify ing 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 ef fective 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

concentr ations, 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 RequirementsChapter 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 l aw 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/m 3 ) 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, t he EPA revised the lead NAAQS on October 15, 2008 (73 FR 66964; November 12, 2008) significantly strengthening
the standard from 1.5 μg/m 3 to 0.15 μg/m 3

. In conjunction with strengthening the lead NAAQS, EPA also established new criteria for the siting of ambient lead monitors. EPA
found that t he pre

- existing ambient lead monitoring networks w ere inadequate for determining whether many areas are meeting the revised lead NAAQS. Additional m onitors 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 200 7

- 200 9

, 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 planni ng 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 activ ities that demonstrate attainment
of the lead NAAQS as expeditiously as p racticable, 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).



### S ETTING /PO PULATION

The AQMD jurisdiction c over s 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 B asin, 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 C ounty 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 federal lyChapter 1: Introduction

1

- 2 designated nonattainment area for lead consists on ly 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 whic h 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 unlikel y, 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 porti on 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 region al air quality cont rol program s . 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 200 7

- 200 9 . CARB’s reco mmendation 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 measu rements using a rolling 3

- month averaging form of the standard
to be evaluated over a 3

- year period. Ambient m easurement data are to be produced by

EPA

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

- oriented
and population mon itors.



### 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 PM 10 and PM 2.5 )

, 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 impa irment, 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 o r 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/m 3 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/m 3 based on a quarterly average (maximum arithmetic mea n averaged over a calendar quarter).

 On October 2008, EPA amended the NAAQS for lead from 1.5 μg/m 3 to 0.15 μg/m 3
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 Ca talina 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 mo re identified and fixed pieces of equipment and emission points at a permitted facility. Area
sources consist of widespread and numerous small er emission sources

, such as smaller
facilities , households, or other land uses . Mobile sources can also be grou ped 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, constru ction 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

- r oad
automobiles. S ubstantial emission reductions ha ve 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 a s a trace contaminant in other fuels. Av gas is only utilized in general aviation aircraft with piston engines, which are generally used for instructional flying, air taxi
activit ies, 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 sour ces , such as iron and steel found ries ; p rimary 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 h ighest stationary source emitters of
lead in Los Angeles County . Staff’s analysis has shown this industry to be the only known

stati onary source category that has the potential to c ause violations of the new lead NAAQS.

T he lead emission sources in the n onattainment 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 r eproductive 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
b iological 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 i s classified as a “criteria pollutant.” L ead 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 possibl y 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/m 3 is 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 C ONTR OL E FFORTS

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 sulf ur 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 L os Angeles County :

 In November 1970, CARB set the state ambient air quality standard for lead at 1.5 μg/m 3
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/m 3 averaged over a calendar quarter.

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

Assessment Act (A B 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

Co ntaminants. 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 Ha zard 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 A ir 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 non

cancer 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, 5 1, 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 Emi ssions 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 reportin g.

 In September 1998, CARB established a cancer potency value of 1.2 x 10 - 5 per μg/m 3 for 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/m 3 to 0.15 μg/m 3
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 Recy cling Facilities

. The purpose of th is rule is to protect public health while ensur ing attainment with the 2008 lead NAAQS.



### IMPACT OF CONTROL EF FORTS

The a mbient air quality standard s for lead w ere set at 1.5 μg/m 3 by both C ARB 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 . T he major reduction s

w ere 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/m 3 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 REQUIRE MENTS ADDRESSED BY T HIS 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 overhau l 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 s anctions for failure to attain or to meet interim milestones.

In October 2008, the EPA strengthened the NAAQS for lead from 1.5 μg/m 3 to 0.15 μg/m 3
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, excludingChapter 1: Introduction

1

- 9 San Clemente and Santa Catalina Islands (Southern Los Angeles County), was designated as
nonattainment for the 2008 l ead NAAQS based on air quality data from 2007

- 2009.

There are sever al 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

, respec tively. The general provisions apply to all applicable pollutants unless superseded by pollutant

- specific requirements.Chapter 1: Introduction

1

- 10 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

m easures 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

1

- 11 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 signif icant 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 Appropria te 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 theChapter 1: Introduction

1

- 12 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 offi cially 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 th e CAA are
intended to ensure that the lead nonattainment area provide for sufficient emission r eductions
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 , a nd 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 . A lthough there are a limited number of g aps 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 p arts of the South Coast and as such will not be addressed in this SIP
submittal.



### STATE LAW REQUIREMEN TS

The Health and Safety Code (H&SC) section 39607(e) req uires CARB to establish and periodically review area designation criteria. Once CARB establishe s health

- based State ambient air quality standards to identify outdoor pollutant levels considered safe for the public

, State law require s them to designate eac h 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, C ARB has reviewed the designations each year, maki ng changes as needed. The California ambient air quality standard (CAAQS) for lead has
remained the same at 1.5 μg/m 3

. However, the lead designation for the South Coast Air Basin (Los Angeles County portion only) was changed from attainment to nonattainm ent, based on data for the period 2006 to 2008, effective on September 25, 2010.

## CHAPTER 2

LEAD AIR QUALITY IN LOS A NGELES COUNTY

Introduction

Ambient Measurements

Measurements at Source

- Oriented Sites

Fence

- line Measurements
SummaryChapter 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/m 3 ) (calculated as a quarterly average) to a more stringent 0.15 μg/m 3 (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 ne twork me e t s 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 parti culate 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 l ead 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 concentratio ns beyond the property line to exceed 1.5 μg/m 3 averaged 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/m 3 averaged over a calendar quarter).

Furthermore, on November 5, 2010, AQMD adopted Rule 1420.1 to establish additional requirements for large le ad

- 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 Ai r 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 14 20.1 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/m 3 averaged 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/m 3 must submit a Compliance Plan identifying additional lead emission reduction measures, thereby helping to av oid potenti a l 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 Cou nty 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 NAAQ S 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

- lin e 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 sched ule , 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 (Nort h 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/m 3 in 1976 to an urban background lev el of about 0.01 μg/m 3 ), 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 i n gasoline fuels.

Monthly average lead concentrations at all AQMD’s network sites have been at or below 0.05 μg/m 3 since 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 Ta ble 2

- 1, none of the design values for the 2008

- 2010 or 2009

- 2011 time period s ( 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/m 3 ). All monthly

- average lead data presented here have beenChapter 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

- 201 1 timeframeChapter 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 201 1 . The dotted line in the magnified portion of the graph represents the current 2008 NAAQS for lead (0.15 μg/m 3 )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 batter ies and other lead bearing material. Since February 1991, AQMD has operated source

- oriented lead monitors a t four locations at different distances from the facility’s perimeter (Figure 2

- 3a). Sampling at three of these

source

- oriented sites is still ongoin g (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 f acility 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 operatin g 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 ton s 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 19 90s (from values as high as 3.66 μg/m 3 in 1991 to concentrations that are close to or below 0.15 μg/m 3 in 201 1 ). This improvement reflects the reduction in lead emissions from large battery recyclin g 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/m 3

, 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/m 3 )

, but still above the current
federal standard.Chapter 2: Lead Air Quality in Los Angeles

2

- 7 The preliminary 2009

- 2011 design va lues 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/m 3

. Furthermore, a s shown in Figure 2

- 4, the most recent month of data (Dece mber 2011) at the Rehrig site is actually below the 0.15 μg/m 3 level. S ince lead is typically found in large r 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/m 3 since November 2008 and suggest a decreasing trend (Figure 2

- 4). M o nthly average v alues at Van Nuys A irport have never exceeded 0.04 μg/m 3

.
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 long

term tre nds 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 d ata is not available i n 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 a verage 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 F IGURE 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 T ABLE 2

- 2

AQMD’s source oriented sites measuring Total Suspended Particulate (TSP) lead since 1991 with available design values
for the 2008

- 201 1 timeframeChapter 2: Lead Air Quality in Los Angeles

2

- 10 F IGURE 2

- 4

Monthly average Total Suspended Particulate (TSP) lead concentrations at all source

- oriented
sites from 1991 to 201 1 . The dotted line in the magnified portion of the graph represents the

current 2008 NAAQS for lead (0.15 μg/m 3 )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 Qu e metco Inc. (the two largest lead

- acid battery recycling facilities in Los Angeles County) has been conducted by the facilit ies in accordance with AQMD Rules 1420 and 1420.1 for s everal

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 emission s are particul arly 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 faciliti es.
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 a dded 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 R ule 1420.1 at sites where measured concentrations are repeatedly high.

Average lead conce ntrations (expressed as 30

- day rolling averages) recorded at the fence

- line monitors installed near the Exide facility have continuously exceeded the 0.15 μg/m 3 over the majority of the samp ling 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 Janua r y 1, 2012 . The highest 30

- day average TSP lead level (2.41 μg/m 3 ) was
measured at the New N site in July 2009. F ugitive lead emissions fro m this battery recycling plant have been decreasing substantially since the initial measurements at Rehrig in 2009 and the adoption of R ule 1420.1 in 20 10 . As mentioned earlier, fugitive lead particles are relatively large, and tend to settle out quickly a fter 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
lea d 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 T echnologies (Vernon facility). The faded yellow area represents the perimeter of the facility

T ABLE 2

- 3

Name and location of all fence

- line and off

- site monitoring stations operated by Exide

T echnologies (Vernon facility). Sampling at these locations has been conducted since 2006.Chapter 2: Lead Air Quality in Los Angeles

2

- 13 FIGURE 2

- 6

Fence

- line 30

- day rolling average lead concentrations at the E xide 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/m 3 )

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 i n 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

.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. T he 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/m 3 and was
measured at Site 1 in January 2006. Generally, fence

- line monitors #1 a nd #5 (closely located to the part of the plant where the recycling process occurs) have exhibit ed the highest average values. Fugitive lead emissions from this and other lead

- acid battery recycling facilities have been decreasing substantially since the a doption of R ule 1420.1 in 20 10

.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

.

T ABLE 2

- 4

Name and location of all fence

- line monitoring stations operated by Quemetco Inc. Sampling at
these locations has been conducted since 2001.Chapter 2: Lead Air Quality in Los Angeles

2

- 16 FIGURE 2

- 8

Fence

- line 30

- day rolling average lead concentrations at the Qu e metco 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/m 3 )

Note that since Trojan B atteries is not a lead

- acid battery recycler and their throughput is below
Rule 1420 criteria

, no fac ility

- operated fence

- line monitor is required around or near its property
line.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/m 3 ; 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 specifi cally 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 level s of about 0.01 μg/m 3

. 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 R ule 1420.1.

## CHAPTER 3

LEAD INVENTORY

Introduction

Emission Inventories

Base and Future Year Emissions
Uncertainty in the InventoryChapter 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 pro vided 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 off

road emissions are also calculated based on 2007 AQMP inventories and projections. These

e missions 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 ut ilized in the 2007 AQMP. It should be
noted that the draft 2012 RTP forecasts and EMFAC 2011 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 conservativ e 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 Emission s 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 m obile 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.htmlChapter 3: Current Lead Inventory

3

- 2 Emissi ons 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 phase

out of leaded gasoline, b ut 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 ta xi activities, recreational flying, 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 ar e 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 ; indus trial, 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 Lo s 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 lea d 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 acc ounts 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 additiv e in general av iation fuel (av gas ) 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 2 010, 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 ExideChapter 3: Current Lead Inventory

3

- 3 Technologies emitting over 0.50 TPY, and the AQMD con tinues 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 fugiti ve 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 site

specific baseline emissions estimates for each of the facilities. The fugitive emission estimation methodology evaluated the estimates of fugitive lea d 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/y r) 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 othe r 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 cat egorize 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 c omplete 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 implemente d 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

- 0163Chapter 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 t o 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 pro file 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 profi le #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 percen t 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 fro m 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.htmChapter 3: Current Lead Inventory

3

- 5 The mobile source emissions summaries were developed using emissions that occurred in Los Angeles County during the ba se year 2002 as identified in the “Final 2007 Air Quality Management Plan” for AQMD, and projected emissions for the years 2010, and 2015. On

road vehicle emissions are calculated using socioeconomic data and transportation models provided by SCAG, spatia l 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 SC AG’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 prima rily 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 implement ation 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., populat ion, 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 hi storical 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. 6 The 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, an d 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 Piston

Engine 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 pis ton 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 landi ng 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 calculat e 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
inv entory, 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). Altho ugh 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 14.26Chapter 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 18.50Chapter 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

- 04Chapter 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

- HQ

OAR

- 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/yrChapter 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 I NVENTORY

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 faciliti es 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 fug itive 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 STRATEG Y

Introduction
Overall Attainment Strategy
Existing Lead Emissions Control Regulations
AQMD’s Existing Rules
AQMD’s Proposed Lead Control Measure
Implementing AgencyChapter 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 m ade 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 S TRATEGY

Historically, the major source of lead air emissions has been motor vehicles such as cars and
trucks. Motor vehicle emission s 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. S ubstantial 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 f rom 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 seco ndary 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 air craft 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 n ational 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 thatChapter 4: Lead Control Strategy

4

- 2 are non

- source

- oriented, and those that are facility

- based referred to as “source

- oriented.” CARB’s lead design ation 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 a re 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

- sourc e

- 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 attainm ent strategy is exclusively focused on directly

- emitted lead from stationary sources. Further controls on mobile sources are not needed.



### EXISTING LEAD EMISSI ONS CONTROL REGULATI ONS

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/m 3
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 stan dards were set at a level of 1.5 μg/m 3 averaged over a calendar quarter.

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

Assessment Act

. The goal s 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 b y 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 TACChapter 4: Lead Control Strategy

4

- 3 emissions. Lead was added to the Rule 1401 list of TACs i n 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 co nstructed 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 q uality standard 1.5 μg/m 3 averaged 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 a dopted 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 b y specifying health limits for cancer and non

cancer 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 rul e.

 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
emiss ions, monitoring, recordkeeping, and reporting.

 In October 2008, EPA amended the NAAQS for lead from 1.5 μg/m 3 to 0.15 μg/m 3
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 th is rule is to protect public health and to help ensure attainment with the amended lead NAAQS.



### AQMD ’ S EXISTING RUL ES

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 An geles 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) cor e 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 bee n 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, additiona l 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 promulga tion 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 t o 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 materia ls 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 ent ities. 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. P oint 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 n ot 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 a ccumulates 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 spe cifying adequate frequencies and locations for all cleaning actions to be performed are also critical in the effectiveness to control fugitive lead

dust emissions.

Currently, emissions of lead from stationary sources, including lead

- acid battery recyclin g 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 sta tionary 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/m 3

.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 a dopted 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/m 3

.



### 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 limite d to, primary or secondary lead smelters, foundries, lead

- acid battery manufacturers or recyclers, and lead

oxide, brass and bronze producers. Rule 1420 is based on the state ambient air quality standard for lead of 1.5 μg/m 3 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 m aintain and operate two fence line monitors to collect samples to demonstrate compliance with the Rule 1420 ambient lead standard of 1.5 μg/m 3 . Each facility currently operates an ambient fence

- line air monitoring and sampling network. The fence

- line moni tors 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

- o riented monitors have shown that these two facilities have the potential to exceed the new federal lead ambient air quality standard of 0.15 μg/m 3 , 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 Recyc ling 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/m 3 standard. 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 An geles County will achieve the 2008 NAAQS for lead. The rule establishes facility

- wide and individual point sourceChapter 4: Lead Control Strategy

4

- 6 maximum allowable emission rates, and requires secondary lead control devices on dryers. Fugitive lead emissions are addressed through house keeping 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 concentrati ons 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 inclu ded 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/m 3 ) of the rule limit. The following provides a detailed
and d escription 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 a ir concentrations of lead that exceed 0.15 μg/m 3 averaged 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 o f 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 lea d

- 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 monitor ing 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 emi ssion 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 achi eve the ambient standard of 0.15  g/m 3

.

 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 ofChapter 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 faci lity 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 loc ations 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/m 3 averaged over any 30 consecutive days, measured at any fence line monitor, will be in viol ation 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 ex ceedance 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 f

ence 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 sh orter 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 l ead 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 facili ty. 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 P lan: 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 facilit ies of the key required controls coreChapter 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/m 3 . The Compliance Plan would be implemented if t he facility exceeded the Rule 1420.1 ambient lead standard of 0.15 ug/m 3 . The Compliance Plan provision serves as a contingency to ensure that measures can be identified prior to exceeding the 0.15 ug/m 3 standard and are ready for fast implementation if t he 0.15 ug/m 3 standard 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 imp ortance 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. The Compliance Plan allows for rapid deployment of addit ional 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/m 3 averaged 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/m 3 is not exceeded. An
exceedance of the Rule 1 420.1 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 Sta ndard 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/m 3 , averaged over 30 days. The amendment will lower the ambient limit in Rule 1420 to 0.15 μg/m 3 to correspond to the revised NAAQS for lead of 0.15 μg/m 3 . The more stringent, shorter averaging time of a 30 day rolling average will be retained. In add ition, 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 4 th 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 theChapter 4: Lead Control Strategy

4

- 9 following. The only new proposed control measure in the 2012 Lead SIP would amend R ule 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 av erage 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 mea sure 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 whethe r 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 t o 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 the re 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 FacilityChapter 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 modeli ng 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 concent ration 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 Improveme nt Committee (AERMIC) was formed to introduce state

- of

- the

- art modeling concepts into the EPA's air quality models. 2 Through AERMIC, a modeling system, AERMOD, was introduced that incorporated air dispersion based on planetary boundary layer turbulence str ucture 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) Mode l as the recommended dispersion model. 3 The 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 inc orporating 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#aermodChapter 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 Infor mation 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 net works

– 28 AQMD, 22 NWS, and 17 CIMIS
stations

– were integrated into AQMD measurements to construct a complete set of missing

value 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 projec ts 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. 4 T herefore, 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 so urces 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 bag

house row had to be raised above th e roof line. Therefore, in the modeling for 2015, the stack

4 From EPA’s websi te, available at http://www.epa.gov/ttn/scram/guidance/guide/appw_05.pdfChapter 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 ea st 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

t o 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 cent ered 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 con centration of 0.01  g/m 3
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.htmChapter 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/m 3
averaged over any 30 consecutive days. Rule 1420.1 requires annual source tests for all lead
control devices in order to demo nstrate 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 l imit 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, th e 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 amo unts 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 o f 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 materia ls 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 housekeepi ng 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://w ww.regulations.gov/#!documentDetail;D=EPA

- HQ

- OAR

- 2011

- 0344

- 0163Chapter 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 FAC ILITY

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 li mits 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 l ead concentration is 0.135  g/m 3 . 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/m 3 . 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/m 3 . 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/m 3 . 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 a t 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/m 3 0.115  g/m 3

Quemetco 0.140  g/m 3 0.083  g/m 3

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 si ngle 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 of f 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 da y 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 AQMD

operated, 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 high est 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/m 3 at anyChapter 5: Future Ambient Lead Concentrations

5

- 7 site ne ar 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)

## CHAPTER 6
CLEAN AIR ACT REQUIR MENTS

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) RequirementsChapter 6: Clean Air Act Requirements

6

- 1 

### INTRODUCTION

The purpose of this chapter is to demo nstrate 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 a llow 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 i s 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 combinatio n 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 AC T 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 Amendm ents 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 incorporat es 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

req uirements 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 PLANNI NG REQUIREMENTS

The EPA promulgated the initial lead standard of 1.5 μg/m 3 in 1978, and revised it on October 15, 2008 to a level of 0.15 μg/m 3

. 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 c ase 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 SO URCE REVIEW (NSR) PR OGRAM

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 nonattainme nt 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 maj or 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 cre ditable 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 propose d 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 ove r 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 mix ed 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 i ncluded 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 mea sures 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 a dopted 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 d ate. 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 me asures (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/m 3 as 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/m 3 standard and are ready for fast and automatic implementation if the 0.15 ug/m 3 ambient 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/m 3 . Note that the Rule 1420.1 ambient standard is a 30

- day rolling average, which would show an exceedan ce of the 0.15 ug/m 3 limit 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 t o 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/m 3 30

- day rolling average limit in Rule 1420.1.

According to the language in AQMD Rule 1420.1, the C ompliance 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.pdfChapter 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/m 3 averaged over any 30 consec utive 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;

 Installati on 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 contri bute to ambient air concentrations for lead that exceed 0.15 ug/m 3 averaged 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 prio r 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/m 3 averaged 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 w ill 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 ad dress 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;

 Re surface 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 pr essure 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 fug itive 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
fun ction 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/m 3

. 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/m 3

, 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 af ter exceeding 0.12 μg/m 3 , 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/m 3 averaged over a ny 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 requiredChapter 6: Clean Air Act Requirements

6

- 6 rather than the single monitor per facility required in the federal regulations. T hese 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, an d 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 req uirements. 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 requi red 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 equ ivalent 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 u sed 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 exceedan ce 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/m 3 ) Date Lead (μg/m 3 )

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

r equired 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 cor respond 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 requir ement 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 requ irements 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 n eeded 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 pr ovide 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 gener ally 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 re quirement 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/m 3 . 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 31 s t of 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 rep orting, 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 (m aximum 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 f ailure 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 requirementsChapter 6: Clean Air Act Requirements

6

- 10 for emission levels, controls, housekeeping, and monitoring. In addition, sour ces must comply with an ambient air quality lead standard of 1.5 μg/m 3 , averaged over 30 days. The proposed amendment seeks to lower the ambient limit in Rule 1420 to 0.15 μg/m 3 to correspond to the revised NAAQS for lead of 0.15 μg/m 3 . The more stringe nt, 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 clari fy 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 4 th 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 NAAQ S final rule (73 FR 67040), specifies t hat 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 appr oved 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/m 3 on 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 specif ic 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 suf ficient 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 furn ace 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 baghou se (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/m 3 on a three

- month average). Rule 1420 .1 ambient lead concentration limit of 0.15 μg/m 3 based on rolling 30 day average, will occur before a three

month 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 implem ented 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

meas ure. 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 monito r 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 shal l 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 ra te, 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, inChapter 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 vol tage 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 emi ssions 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 Que metco 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 rem oved 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 effectivenes s 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, reve rberatory 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 low er 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 contr ol, 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 exchang er 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 proc esses 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 th e 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 ofChapter 6: Clean Air Act Requirements

6

- 13 condensable compounds such as arseni c 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 part icles 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 m ist eliminator for water droplet removal prior to discharge through a stack.

Satisfaction of Contingency Requirements: According to the preamble to the Lead NAAQ S final rule (73 FR 67040), the key requirements associated with contingency measures are:

 Con tingency 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 prov ide 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 alrea dy 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

- speci fic 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

f urther rulemaking actions by the state, or EPA, would be needed to implement theChapter 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 req uirements



### REASONABLE FURTHER P ROGRESS (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 b e 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 E xide, 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 meet ing 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 ma ndated 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 emi ssions 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

RFPChapter 6: Clean Air Act Requirements

6

- 16 

### FIGURE 6

- 3

Demonstration of RFP for Quemetco

CAA Section 171 also states that RFP for lead nonattainm ent 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 de tailed 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/m 3

. 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)

EmissionsChapter 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 (RA CM) AND
REASONABLY AVAILABLE CONTROL TECHNOLOGY ( RACT) REQUIREMENTS

The fe deral 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

nona ttainment 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 expeditiousl y 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 sta te. 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 am bient 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 em itters 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 Faci lities. 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 s tandards.

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 nonattain ment 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 constituteChapter 6: Clean Air Act Requirements

6

- 18 reasonably available control me asures (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 Manufa cturing, 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 r evise 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 t he 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 techno logical 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) Gui delines §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 requirement s 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 4 th quarter of 2012, which will ensure that sources of lead which are not subject to Rule 1420.1 will ne ver 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.htmlChapter 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 lead

containing materials All lead sources Secondary lead
smelters

Ambient Air Quality
Standard On and after January

1, 2012, meet 0.15 μg/m 3 averaged over 30 consecutive days 1.5 μg/m 3 averaged

over 30 days 0.15 μg/m 3 :

- 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 lead

containing materials

occur None 4 None 5 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

emiss ion 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/m 3 ; 30 consecutive day avg.;
Identifies additional
lead control measures beyond the rule; Begin implementation if facility exceeds 0.15 μg/m 3 ; 30 consecutive day avg. Specifies general

facility information 6 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/m 3 is
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

- source

oriented 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 lead

containing materials;
onsite mobile Requirements for

storage of dust

forming 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 exit ing
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
activities 7 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 COUNTYAppendix 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

RULESAppendix 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/r ules/reg/reg14/r1420

- 1.pdf

## APPENDIX III

MODELING AND ATTAINMENT DEMONSTRATIONAppendix 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

(m) X (m) Y (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 emissi on 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 t he 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 ra te 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

(m) X (m) Y (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 t o 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 squareAppendix III Page 4 

## Quemetco

– Location of Modeled Sources

– 2015 Emissions

The building s 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 relocati on of the main gate in
order to move the on

- site truck movement from areas where people are f requently 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 squareAppendix III Page 5 

## Exide

– 2015 Lead Concentrations (ug/m 3 

## ) Using Rule 1420.1 Emission Limits (Total Emissions

– Stack and Fugitive Emissions)Appendix III Page 6 

## Quemetco

– 2015 Lead Concentrations (ug/m 3 

## ) Using Rule 1420.1 Emission Limits (Total Emissions

– Stack and Fugitive Emissions)Appendix III Page 7 

## Exide

– 2015 Lead Concentrations (ug/m 3 

## ) Using Rule 1420.1 Emission Limits (Stack Emissions Only)Appendix III Page 8 

## Quemetco

– 2015 Lead Concentrations (ug/m 3 

## ) Using Rule 1420.1 Emission Limits (Stack Emissions Only)

## APPENDIX IV

SOCIOECONOMIC REPORT FOR RULE 1420.1Appendix IV Page 1 

### Socioeconomic report is available at: http://www.aqmd.gov/aqmp/Lead_SIP/homepage.htm

## APPENDIX V

RESPONSE TO COMMENTSAppendix V Page 1 Comment 1

Comment 2

Comment 3Appendix V Page 2Appendix 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
read ily 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 Sme lting 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 wi th 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

r equirements 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 cont ingency 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 4Appendix V Page 5 Comment 1

Comment 2Appendix V Page 6 Comment 2Appendix V Page 7 Comment 3

Comment 1Appendix V Page 8 Comment 1Appendix 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 i n 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 Q uemetco 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 sim ilar 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," d ated 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 mod eling 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 stan dard 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
develo ping 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.

Respon se: 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 analys is 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 Seco ndary 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 ba sed on criteria outlined in the report. There are three types of emissions from secondary lead smelting facilities: process emissions, process fugitive emissionsAppendix V Page 10

and fugitive dust emissions. For all three types of emissions, the document specifically
ref erences 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 1Appendix 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

- 20 09, 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 mon itoring 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 1Appendix 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).