From: <French.Chuck@epamail.epa.gov>

To: <Rleiby@dekabatteries.com>

CC: Donna Lazzari <Donna.Lazzari@erg.com>, <michael.burr@erg.com>, 

<Topham.Nathan@epamail.epa.gov>, Russell Kemp <rkemp@environcorp.com>

Date: 2/1/2011 5:20 PM

Subject: Re: Secondary Lead Smelters - RTR - Fugitive lead emissions and ICR responses

Dear Mr. Richard Leiby.

 There was an error in the previous emails that I sent you earlier

today. Please ignore/delete those emails and refer to this one instead,

as follows:

 Thank you for the information and data that you submitted to us in

response to the information collection request letters that we sent you

in June and July of 2010. The data and information are very helpful for

our risk and technology review of the Secondary Lead Smelting source

category. We have been using much of the data and information in our

analyses as you reported.

 However, with regard to the estimates of fugitive lead emissions,

because of complexities of estimating these emissions, the data gaps and

incomplete information, and various uncertainties, we determined that it

was appropriate to gather additional information and conduct

supplemental analyses to calculate revised estimates of fugitive

emissions for some of the facilities.

 As you know, in the section 114 survey, we requested information

for stack and fugitive emissions from the Secondary Lead Smelting

facilities. We are now in the process of conducting dispersion modeling

of the emission estimates. In some instances, we have found a

discrepancy between the results of the dispersion model and the values

recorded at local ambient monitors which cannot be accounted for by the

stack and fugitive emissions reported. EPA assumes the stack emissions

are reliable as they are based on actual test data, and the primary

cause of the discrepancy is due to releases of fugitive emissions. In

your survey, you did not provide an estimate for fugitive emissions

(e.g., roadway fugitives, fugitives from storage piles or slag handling

or fugitives which escape from buildings).

 Therefore, we have derived an estimate of fugitive emissions for

your facility based upon a review of the ICR responses and industry

practices and calculation methodologies. We have taken into account the

size of the facility, the degree to which facilities are contained

within enclosures, and the reported work practices described in your

survey. Moreover, we analyzed available ambient monitoring data near

the facility in relation to initial modeling estimates.

 The draft estimates we have calculated for your facility and the

original estimate you provided in the survey are provided as follows:
East Penn, PA:

1. The estimate of fugitive lead emissions provided in your survey

response = No estimate provided in survey.

2. The EPA draft estimate of total fugitive emissions of lead for this

facility = 0.33 tons per year.

 With this email we are providing you an opportunity to comment on

our revised draft estimates, provide calculations and documentation to

support your original estimates, or provide alternative estimates that

you believe are more accurate. If you suggest alternative estimates,

please provide complete documentation and explanation of the basis of

such alternatives. If you would like to comment or provide additional

information or alternative estimates, please send a response to this

email by February 8th, 2011.

 Thank You.

 Chuck French, Environmental Scientist,

 U.S. EPA, Office of Air Quality Planning and Standards,

Sector Policies and Program Division

 Phone: 919-541-7912