# State Implementation Plan Revision for the Implementation, Maintenance, and Enforcement of the 

# 2008 Lead National Ambient Air Quality Standard



# Attainment Demonstration

Our Vision

– Healthy Kansans living in safe and sustainable environments



## Department of Health and Environment

Division of Environment

Bureau of Air (785) 296

- 6024



# July 2014This page intentionally left blank

### TABLE OF CONTENTS

INTRODUCTION

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

EMISSIONS INVENTORY

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

MONITORING AND AMBIENT AIR QUALITY DATA

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

Source

- oriented Monitoring

.......................................................... 7 Lead Monitoring Network

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

INTERSTATE TRANSPORT

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

ATTAINMENT DEMONSTRATION MODELING

................................. ..... 9 AERMOD Modeling System

......................................................... 9 Modeling Analysis

..................................................................... 10 Background Lead Concentrations

.................................................... 10 Modeling Results

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

CONTROL STRATEGY

..................................................................... .. 12

RACM/RACT

.......................................................................... 12

Point Sources Control Activities

..................................................... 13

BALLFUG Source

..................................................................... 15 Roadways

............................................................... ................ 16 Current Projects Completion Summary

............................................. 17

REASONABLE FURTHER PROGRESS (RFP)

....................................... ... 17 Emission Reduction Projects

...................................................... ... 18 RFP Project Completion Timeline

.................................................. 19

CONTINGENCY MEASURES

............................................................. . 20 Contingency Triggers and Corrective Actions

.................................... 20

OUTREACH

.............................. ...................................................... 21 Public Participation

.................................................................. .. 22

CONCLUSION

................................................................................. 23FIGURES

Figure 1 Saline County Lead Nonattainment Area Boundary .........................

.. 4 Figure 2 Salina Reported Facility Stac k Emissions 2007

– 2013

...................... . 6 Figure 3 Salina , Kansas Lead Source Monitoring Site ..................................

. 7 Figure 4 Salina Lead Monitor Average Values ......

............... ...................... 8 Figure 5 Contour Map of Lea d Concentration ...........................................

. 11 Figure 6 Decline of Annual Average L ead Monitor Values ............................ 12

TABLES

Table 1 Applicable Clean Air Act Requirements for Lead Nonattainment

.......... 3

Table 2 Summary of Predicted Impacts at Maximum and Sensitive Receptors

..... 10

Table 3 Oxide Mill Replacemen t Completion ............................................ 13

Table 4 Facility Baghouse Proj ect Completion .......................................... 13

Table 5 Point Source Control Stack Tests

................................................ 14

Table 6 Point Source Control Emission Rates

........................................... 14

Table 7 Ball Mill Total Enclosure Standards .............................

................. 16

Table 8 Current Improvement Projects Completion .................

.................... 17

Table 9 Emission Reduction Projects .....................................................

. 18

Table 10 Reasonable Further Progress Project Completion ............................

.. 19

Table 11 Contingency Measures Completion ...

........................................... 20

APPENDICES

Appendix A Environ Air Dispersion Modeling Report for SIP Attainment Demonstration Appendix B RACM/RAC T Improvement Projects (Control S trategy and RFP) Appendix C Federally E nforceable Construction Permit (RFP) Appendix D Federally Required Public Participation Documents Append ix E ISO Certification Document Appendix F Exide Technologies’ Continge n cy Measures Compliance Plan Report

Hi

- Volume Air Inspection Form1 INTRODU C TION

Lead is one of the six criteria air pollutants identified as particularly harmful to hu m ans and the

e nviron m ent. Nati o nal A m bient Air Quality Standards (NAAQS) were developed for these six pollut a nts

to use as m easure m ents of air qu a lity. The federal Clean Air Act (CAA) requires the United States

Environ m ent a l Protection Agency (U.S. EPA) t o set pri m ary standards at a level judged to be “ r equisite to
protect the public health with an adequate m argin of safety,” and to establish secondary standards requisite

to protect public welfare from “any known or anticipated effects associated with the pollutant in the

a m bient air,” including effects on crops, vegetation, wildlife, buildings a nd national m onu m en t s, and visibility. Therefore, National Ambient Air Quality Standards (NAAQS) were established to measure air quality in regard to Ozone (O3), Nitrogen Dioxide (NO2), Sulfur Dioxide (SO2), Lead (Pb), Particulate Matter (PM), and Carbon Monoxide (CO). Both primary and secondary standards are updated as

necessary.

On October 15, 2008, the U.S. EPA promulgated a revision to the 2008 National Ambient Air Qu ality Standard (NAAQS) for lead then publ ished a final rule in the Federal Register on November 12,

2008

. ( 73 FR 66964 ) This revision establishes 0.15 micrograms per cubic meter (μg/m3)

, measured as a rolling three

- month average for the primary and secondary lead standard ; an order of magnitude lower than the previous standard of 1.5 μg/m3 set in 1978.

In accordance with the federal Clean Air Act (CAA), the governor of Kansas submit ted a recommendation to EPA on June 6, 2011 that a portion of Saline County surr ounding the Exide Technologies (Exide) lead acid battery manufa cturing plant in Salina, Kansas be designated as a

nonattainment area for lead . This r ecommendation was based on 2008 t hrough 2010 monitoring data, air dispersion modeling, and analysis of additional factors as prescribed by the EPA regulations and guidance. On November 8, 2011, the EPA designated part of the city of S alina and Saline County, Kansas

as nonattainment for the 2008 Lead NAAQS. (76 FR 72097 )

The main purpose of this SIP revision is to address requirements described in the Clean Air Act,

Section 172(c) that pertain to the Saline County, Kansas nonattainment area

. This SIP revision

establishes reasonably available control technology (RACT ), reasonably available control measures ( RACM), reasonable further progress (RFP)

, and emission limitations as required to reduce impacts of

lead emissions in the air. Historic and current air quality data included in this report illustrate progress made since the national lead standard revision went into effect in January 2009

.

Kansas respectfully submits this information with described authority to enforce the compliance

measures that Exide Technologies agrees to incorporate

. And f inally, KDH E takes this action in accordance with the Clean Air Act (CAA or Act) and EPA’s guidance related to lead standard attainment planning.

Clean Air Act Requirements

Section 191(a) of the federal CAA requires states with lead nonattainment areas to submit a state implementation plan (SIP) revision to EPA that demon strates attainment strategies within five years following nonattainment designation. Kansas was i dentified in the second round of nonattainment design ations, effective December 2011

, and provides this SIP revision to demonstrate Saline County lead

attainment to EPA

. This plan addresses background lead concentration in the air, the impact of emissions from Exide operations, and the impact of other lead emitting facilities within t he designated nonattainment

area.2 Control strategies and contingency measures identified for this proposed revision are federally enforceable through permit s issued by the KDHE Bureau of Air (BOA)

. Scheduled i ssuance of

C onstruction P ermit C

- 12206 (Appendix C) follow ing the required 30

- day public notice period for this

SIP revision supports attainment of the 2008 L ead NAAQS by December 31, 2016

.

Kansas h as a long standing and fully i mpl e m e n ted New Source Review (NSR) p er m itting progra m

. CAA Section 172(c)(5 ) provisions are addressed in K.A.R. 28

- 19

- 300 et seq. K.A.R. 28

- 19

- 301(d) Construction permits and approvals; application and issuance specifically addresses attainment provision as: “No construction pe rmit or approval shall be issued if the department determines that the

air contaminant emissions from the source will interfere with the attainment or maintenance of any ambient air quality standard that has been established under the provisions of the federal clean air act, as amended, or under the provisions of state law.”

Transportation conformity is required under CAA Section 176(c) (42 U.S.C. 7506(c)) to ens ure that federally supported highway and transit project activities are consistent with th e purpose of the SIP. In light of lead additive elimination from gasoline in the United States (1 980s )

, transportation conformity does not apply to the 2008 L ead NAA QS

.

State Implementation Plan Approval

Section 110 of the CAA defines general SIP require m ents and Part D contains requirements appli c able to Subpart 1, nonattai n ment a r eas. S ection 110 requirements were add r essed under Kansas’

2008 Lead NAAQS Infrastructure SI P , dated October 2011

. 1

This attainment demonstration do c ument addresses Part D requirements set forth in section 172

of the CAA for the partial Saline Co u nty nonattain m ent area

. 2 The following sections of this document

address CAA Sec t ion 172(c) requiremen t s as well as portions of Sections 110 as referenced in Table 1

, below

. 3

1 The 2008 Lead NAAQS SIP Revision (Infrastructure SIP) is available on KDHE’s website: http://www.kdheks.gov/bar/air

monitor/lead/lead.html

2 Additional specific plan requirements for lead nonattainment areas are outlined in 40 CFR 51.117.

3 The requirements o f Section 172(c)(7) (compliance with Section 110(a)(2)) were addressed as part of Kansas’ 2008 Lea d

NAAQS Infrastructure SIP submittal, some of which are addressed, again, in this atta inment demonstration submittal.3 Table 1: Applicable CAA Requirements for Lead Nonattainment

Applicable CAA Requirements for Lead Nonattainment Page (s)

 Nonattainment areas
(Nonattainment plan provisions in general) § 172(c) 1

- 3

 Transportation Conformity § 176(c) 2

 Emissions Inventory § 172(c)(3) 5

- 6

 Monitoring and ambient air quality data § 110(a)(2)(B) 7

- 8

 Interstate Transport § 172(c)(7) § 110(a)(2)(D) 9

 Reasonably Available Control Measures (RACM)

 Reasonably Available Control Technology (RACT) § 172(c)(1) 1, 1 2

- 13

 Enforceable emission limitations

 Control measures

 Compliance schedules and timetables § 172(c)(6) and § 110(a)(2)(A) 1 3

- 17

 Reasonable further progress requirement (RFP) § 172(c)(2) 1, 17

- 19

 Contingency Measures § 172(c)(9) 2, 2 0

- 21 Appendix F

 Federally Enforceable Construction Permit C# 12206 Appendix C

 Public Participation/Outreach § 110(a)(2)

40 CFR 51.102 21

- 23 Appendix D4 Background

Lead is a naturally occurring

, toxic metal found in rocks and soil

. Lead particles are sometimes

e m itted from industrial p r o cesses and may be present in m anufactured p rod u cts. The m ajor sources of

lead e m issions have historically been m otor vehicles and industrial sources. Since the phase

- out of leaded gasoline, EPA ' s lead air quality m onitoring strat e gy generally focuses on areas surroun d ing industrial sources that process metals, particularly primary and secondary lead smelters.

Health Effects

People can be exposed to lead by breathing air, drinking water, eating foods, or swallowing dust or dirt that contain s lead. Lead affects children more seriously than adults. Some of the more common health effects of lead exposure in children include: irritability, anemia, loss of appetite, hyperactivity and learning

disabilities. Common health effe cts of lead exposure in adults include: fatigue, nausea, anemia, reproductive problems and impaired concentration. The Centers for Disease Control and Prevention recommends that protective actions take place when a child’s blood lead level is greater tha n or equal to

5 μg/dL or a blood lead level of 25μg/dL or greater is found in an adult.

Site Description

Exide owns and operates a lead

- acid battery and lead oxide manufacturing facility at 413 East Berg Street in Salina, Kansas (Saline County) wher e lead acid batteries were historically manufactured for automobile, truck, and marine applications. Current production includes lead battery manufacturing for a wide variety of applications . Figure 1 defines the lead nonattainment area boundary surrounding Exide

propert y with the initial monitor site.

Figure 1: Saline County Lead Nonattainment Area Boundary

The Exide facility properties occupy approximately 46 acres centered within the total nonattainment

area that spans 475 acres of Saline County, situated 1.6 kil o meters north to south and 1 .2 kilome t ers east to

west

.5 Exide ’s personnel utilize an environmental management system (EMS) to assess how their organization interacts with the environment, then minimize [harmful impacts of] those interactions

. International Organization for Standardization © (ISO) 14001 is the internationally approved standard for environmental management systems

, with a driving force of continual improvement. Any organization th at subscribes to the principles of ISO 14001 must be able to provide evidence that it continually strives to reduce its environmental impact. Effects of this standard also provide opportunity for external stakeholders

to become involved in the organizatio n's continual improvement process. 4 For more detail, refer to:

http://www.iso.org/iso/home/standards/management

- standards/iso14000.htm

Exide demonstrated conformance and achieved certification for October 2012

– October 2015 under
ISO 14001, the most important standard within the ISO 1400 0 series for small to large organizations. The
design of this standard flows in the procedural cycles listed below.

Plan: C ul tivates the beginning stages of becoming ISO 14001 compliant.

Check: C hecking and correcting errors.

Do: I mplements and operates the ISO 14001 standard within an organization.

Review: R eview of the entire process by the organization’s top management.
Improve: C ycle that never ends as an organization continually finds ways to improve their E MS.

The ISO 14001 standard is the only ISO 1400 0 series standard that allows an organization to be
registered or “certified.” A copy of Exide’s certification is attached as Appendix E.

EMISSIONS INVENTORY

Point Sources

T h e F e d e r a l C lea n A ir A c t

, § 17 2 ( c ) ( 3), r eq ui r e s t h e d e v el op m en t o f e mi s s i o ns i n v en t o r i e s f o r

n o na tt a i n m en t a r ea s

. T h e KDHE Bureau of Air m a i n t a i n s a po i n t s o u r ce emissions inventory wi th

u p

- t o

- d a t e i n f o r m a t i o n o n lea d and other pollutant s

. KDHE uses this data to identify sources and

emission levels, determine compliance with regulations, develop control and maintenance strategies, and analyze p rogress in attaining the NAAQS. Kansas requires Class I and Class II sources to report any emissions of lead or lead compounds. 5 KDHE maintains a database with emissions inventory data for more than 900 stationary source facilities in Kansas. KDHE posts a summary report of annual emissions

from major and minor stationary sources for the National Emissions Inventory (NEI) on its w ebsite at ( http://www.kdheks.gov/emission/data.html ). This data is also reported to the EPA every year

.

4 © Copyright International Organization for Standardization (ISO). All rights reserved. This material is reproduced from ISO 14001:1996 with permission of the American National Standards Institute (ANSI) on behalf of ISO

.

5 K.A.R. 28

- 19

- 517 Class I operating permits; annual emiss ion inventory, K.A.R. 28

- 19

- 546 Class II operating permits; annual

emission inventor y6 Source Classification

This facility is classified as a synthetic minor source and operates under a Class II Operating

Permit

- by

- Rule and subsequent construction approvals. 6

Em i ss i on s I n v e n t o ry De v el o p m e nt

To m ee t th e r ep o r t i n g r eq ui r e m en t s o f Kansas Administrative Regulation (K.A.R.) 28

- 19

- 564,

Exide submits their annual lead e mi ss i o n s d a t a to KDHE where they are reviewed for quality assurance and stored electronically in Kansas’ air facility management database (i

- Steps). One of the requirements of the federally enforceable construction permit is that Exide submit a full Class I emi ssions inventory beginning with calendar year 2014 (to be submitted in 2015). The Class I emissions in ventory form provides greater

detail regarding emission points within the plant than the Class II form.

U p da t e d Em i s s ion s I n v e n t o ry

E x ide submitted emission s inventories for al l lea d

- e mi tt i n g units lo c a t e d a t th e c o m p any ’ s manufacturing p lan t in Salina, Kansas as d epicted in Figure 2, below. E missions reported from 2007

to 2013 reveal consistent emission reductions between 2007 and 2008 followed by another significant

downturn from 2010 to 2013

.

Figure 2: Salina Reported

Facility Stack Emissions 2007

– 2013

6 January 15, 2004 permit issued by KDHE to Source ID 1690035 pursuant to K.A.R. 28

- 19

- 564 Class II Operating Permits;

Permit

- by

- Rule; Sources with Actual Emissions Less than 50 Percent of Major Source Thresholds

. 0.00 0.50 1.00 1.50 2.00 2.50 3.00 3.50

2007 2008 2009 2010 2011 2012 2013 Exide Technologies

- Salina reported facility stack emissions of lead (tons)7 MONITORING AND AMBIENT AIR QUALITY DATA

Source

- oriented Monitoring

According to 40 CFR Part 58, Appendix D, paragraph 4.5(a), source

- oriented monitors are to be located at the predicted maximum ambient air lead concentration in excess of the NAAQS, while considering the potential for population exposure and logistics.

KDHE performed dispersion modeling in Saline County to determine the area of maximum

conc entration for sampler placement. A high v ol ume (HiVol) total suspended particulate ( TSP ) sampler, installed on February 2, 2010, operates under AQS site ID 020

- 169

- 00 04 on a 1

- in

- 6 day schedule. The monitoring site (as displayed in Figure 3 ) is located north of the Exide manufacturing facility at the following legal description.

SOUTH INDUSTRIAL AREA, S1, T15, R3, BLOCK 2, ACRES 13.4, LTS 21

- 30 EXC E 32 LT 30

Figure 3 : Salina, Kansas Lead Source Monitoring Site(s)

In 2013 , KDHE installed a second HiVol TSP sampler at the Exide monitoring site for collocation purposes. Installed next to the existing monitor, the second monitor operates on the same 1

- in

- 6 day sampling schedule as the initial lead monitor. The Salina Exide plant is the only Kansas source that exceeds the 0.5 ton per year point source threshold for the mandatory 2008 Lead NAAQS Nonattainment SIP inventory.8 Lead (Pb) Monitoring Network

The KDHE Bureau of Air and local air quality agencies operate the Kans as Air Quality M onitoring

Network which provides real

- time monitoring and data analysis from 22 sites. EPA uses this data to

calculate the air quality i ndex

, to determine criteria pollutant compliance wi th federal standards 7 , and

to evaluate air quality trends. This quality

- assured data is compiled and reported to the EPA.

Each year, in accordance with 40 C.F.R. Part 58, KDHE submits an annual monitoring network plan to EPA after completing public notice and comment request requirements. The 2010

- 2011 Kansas Ambient Air Monitoring Network Plan , which included lead monitoring requirements, was approved by EPA in April 2011. All s ubsequent annual monitoring network p lans were approved by EPA including

the most recent 2013

- 2014 plan in December 2013. 8 Monthly and 3

- month rolling average designed lead monitoring data f rom 2010

- 2013 may be viewed at:

http://www.kdheks.gov/bar/air

- monitor/lead/Updated_Lead_Monitoring_Results.pdf

.

Figure 4 visually represents Saline County air monitoring results for 2010

– 2013 in annual tracks

of 3

- month rolling averages. As charted, below, s even out of nine values fell within or below the required

lead standard in 2013.

Figure 4 : Salina Lead M onitor 3

- month Rolling Average Values

KDHE also operates lead monitoring in Kansas City at the JFK multi

- pollutant air monitoring

station. A non

- source oriented HiVol TSP sampler was installed at this site on December 27, 2011 and

sa mpling began on January 4, 2012.

7 CAA Section 110(a)(2)(B) Ambient air quality monitoring/data system

(B) provide for establishment and operation of appropriate devices, methods, systems, and procedures necessary to

— (i) monitor, compile, and analyze data on ambient air quality, and (ii) upon request, make such data available to the Administ rator;” [42 U.S. C. 7410(a)(2)(B)]

8 Refer to http://www.epa.gov/region07/air/quality/quality.htm#amnp to review annual monitoring network plans. 0.000 0.050 0.100 0.150 0.200 0.250 0.300 0.350 0.400 0.450ug/m3 Salina Lead

2010 2011 2012 20139 INTERSTATE TRANSPORT

Section 172(c)(7) of the CAA requires nonattainment SIPs to meet the applicable provisions of Section 110(a)(2). The KDHE reports that prior rule submittals, along with this attainment demonstration, address the requirements associated with rule developm ent and maintain the necessary infrastructure and resources to comply with Section 110(a)(1) and (2) of the CAA for lead standards

attainment.

Lead is a pollutant that does not undergo atmospheric transformation. Due to its physical properties, lead does not transport over significant distances. Lead particles settle out quickly with localized impacts. Lead emissions do not have a transport impact unless the source is in close proximity

to state or international boundaries. Transport is not an issue for Kansas since its only recommended nonattainment area, consisting of a portion of Saline County, is more than 80 miles from the nearest

state or international border. The technical documen t supporting the nonattainment designation for Salina

Saline County includes air quality dispersion modeling and can be found on EPA’s lead designations

website at:

http: //www.epa.gov/leaddesignations/2008standards/rec/region7R.html

ATTAINMENT DEMONSTRATION MODELING

Exide contracted with ENVIRON to perform dispersion modeling to estimate the ambient air lead concentrations within the nonattainment area. This modeling successfully demonstrates attainment of the 2008 Lead NAAQS based on the implementation of specific control measures. ENVIRON’s Air Qual ity Dispersion Modeling Report f or SIP Attainment Demonstration is attached as Appendix A. Emission

reductions are ex pected to result in a maximum impact value of 0.137 μ g/m 3 or less following completion of all emission control projects and paving of roadways and parking areas on the northwest section of the plant site.

AERMOD Modeling System

Air dispersion modeling for the Salina Exide facility was performed using the most recent version of AERMOD (version 12345), the EPA

- recommended dispersion model. The AERMOD modeling system consists of the following components, which were used for this mo deling exercise:

AERMAP

– a terrain data preprocessor for elevations and features that could influence dispersion.

AERMET

– a meteorological data preprocessor that incorporates air dispersion based on planetary boundary layer turbulence structure and s caling concepts.

AERSURFACE

– a surface characteristics preprocessor.

BPIPPRM

– a multi

- building dimensions program used to determine the direction

- specific building downwash parameters.

LEADPOST

– a postprocessor used to calculate three

- month average l ead concentrations for each receptor and the maximum impact concentration using AERMOD monthly outputs.10 Modeling Analysis

For the attainment demonstration, there were ten lead

- emitting point sources within the Exide facility and three volume sources rep resenting fugitive emissions. The point sources included recent improvements to four general purpose (facility) baghouses (BH2, BH3, BH4, and BH5), planned replacement and increased stack height for a fifth general purpose baghouse (BH1), planned increase d stack heights for five ball mill baghouses (BH11, BH12, BH13, BH14 and BH15), and an oxide mill source (OM) representing the planned discharging of all ten oxide mills from a raised combined stack. Volume sources used in the modeling represented fugit ive emissions from the ball mill process (BALLFUG), from a neighboring facility (Met lcast), and from plant roadways

.

Background Lead Concentrations

EPA’s final Integrated Science Assessment for Lead (ISA), issued in June 2013, indicates that the

nationa l non

- source oriented monthly average ambient lead concentration is 0.01 μ g/m 3 . Tables 2

- 13 and

2

- 15 of the ISA provide detailed statistics based upon the national monitoring network. This average background concentration is further supported by data fro m a temporary non

- source oriented lead monitor

located north of the nonattainment area (average 0.005 μ g/m 3 ) and data from a lead monitor formerly located in Wichita, Kansas (average 0.0076 μ g/m 3 ). Since other lead

- emitting sources in the area surrounding the Exide facility have been included in the model, the ISA reported national monthly averaged value of 0.01 μ g/m 3 was used as the background concentration in the attainment demonstration modeling. EPA’s final Integrated Science Assessment for Lead (ISA) can be found using the following

link: http://www.epa.gov/ncea/isa/lead.htm

Modeling Results

Cumulative impact was determined using the LEADPOST output file of modeled maximum three

month average lead concentrations for all source groups plus the background value of 0.01 μ g/m 3 . The table below and a contour map of the three

- month average lead concentrations demonstrate attainment of the 2008 Lead NAAQS.

Table 2 : Summary of Predicted Impacts at Maximum and Sensitive Receptors

Receptor Maximum Impact (including 0.01

μ g/m 3 background concentration) 2008 Lead NAAQS 0.15 μ g/m 3

Maximum Impact 0.137 μ g/m 3

KDHE Ambient Lead Monitor 0.127 μ g/m 3

S c hilling Elementary School 0.018 μ g/m 3

Coronado Elementary School 0.028 μ g/m 311 Figure 5 : Contour Map of Lead Concentration

An analysis of the averages of monthly and averages for years 2010 through 2013 furthe r supports
this demonstration. As seen in Figure 6, average monitor values have decreased over this time perio d with the average of the 2013 averages being 0.118 μ g/m 3

. See ENVIRON’s Air Quality Dispersion Modeling Report For SIP

Attainment Demonstration

in Appendix A for further

det ails. The contour m ap12 Figure 6: Decline of Annual Average Lead Monitor Values

CONTROL STRATEGY

The Clean Air Act (CAA) requires any state containing a designated nonattainment area to submit a state implementation plan (SIP) in accordance with the provisions of Section 172(c). Section 172(c) specifies, among other things, t hat nonattainment SIPs i nclude R easonably Available Control M easures (RACM), R easonably Available Control Technology ( RACT), Reasonable Further Progress (RFP), and contain contingency measures.

Reasonably Available Control Measures & Reasonably Available Control Technology (RACM /RACT)

Section 172(c)(1) of the CAA requires that nonattainment SIPs “shall provide for the implementation of all reasonably available control measures as expeditiously as practicable (including such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, of reasonably available control technology) and shall provide for attainment of the national primary ambient air quality standards.” In March 2012, EPA issued a RACM guidance document, Implementation of the 2008 Lead National Ambient Air Quality Standards: Guide to Developing Reasonably Available Control Measures (RACM) for Controlling Lead Emissions

. 9 This document replaced prior RACM gu idance for identifying potential measures for controlling lead emissions from

lead sources in nonattainment areas.

9 The EPA March 2012 RACM guidance for controlling lead emissions is available on EPA’s website: http://www.epa.gov/airquality/lead/pdfs/2012ImplementationGuide.pdf

.13 Using EPA’s 2012 RACM guidance, KDHE determined that Exide’s ongoing point source improvement activities and fugitive emissions control measures are sufficient for RACM/RACT purposes for the Salina nonattainment area at this time. The Salina area is projected to attain the 2008 Lead NAAQS by the 2016 attainment date as a result of these measures, which are discussed below and in Appendix B

– Exide’s 2011 and 2013 Project Update Documents

.

Point Sources

- Control Activities

In April 2006, Exide commenced a five

- year project to replace all ten oxide mills. The project included replacement of oxide mills, associated baghouses, and the add ition of HEPA filters for each oxide mill source. This project was completed as follows in Table 3.

Table 3: Oxide Mill Replacement Completion

Source Completed

Oxide Mills #1 and #2 September 2006

Oxide Mills #3 and #4 July 2009

Oxide Mills #5 and #6 October 2010

Oxide Mill #7 January 2011

Oxide Mill #8 February 2011

Oxide Mills #9 and #10 March 2011

Exide also made improvements with the replacement of four general purpose (facility) baghouses (BH2, BH3, BH4, and BH5). In May 2013, KDHE received notification of Exide’s intent to replace the fifth general purpose baghouse (BH1). The current status of the baghouse replacement project follows in

Table 4.

Table 4: Facility Baghouse Project Comp letion

Source Status Baghouse #1 (BH1) Installation Completed by February 19, 2014 Baghouse #2 (BH2) Completed November 2010 Baghouse #3 (BH3) Completed September 2009 Baghouse #4 (BH4) Completed July 2011 Baghouse #5 (BH5) Completed May 2012

Stack compliance tests were conducted for each point source after installation and commissioning. For attainment demonstration modeling, point source emission rates were determined using information from the average of three runs from stack tests for each sour ce. The stack test dates are listed below in

Table 5 . The emission rates were estimated based on the highest measured average emission rate since 2007 or the most recent infrastructure update for the source.14 Table 5: Point Source Control Stack Tests

Source Stack Test Date Facility BH1 08/21/2008

BH2 11/17/2010

BH3 09/29/2009

BH4 08/02/2011

BH5 06/27/2012

Ball Mill BH11 10/24/2007

BH12 10/24/2007

BH13 10/24/2007

BH14 10/24/2007

BH15 08/21/2008

Oxide

Mill OM1 08/22/2008

OM2 08/21/2008

OM3 08/27/2009

OM4 08/25/2009

OM5 08/04/2010

OM6 07/15/2010

OM7 03/17/2011

OM8 05/05/2011

OM9 05/06/2011

OM10 05/05/2011

- 05/06/2011

In demonstrating ambient impacts less than the 2008 Lead NAAQS, and in alignment with the applicable federal New Source Performance Standard (NSPS) 10 and National Emission Standards for Hazardous Air Pollutants (NESHAP) 11 , the stacks for BH1 through BH5 and the oxide mills were modeled

at about 3.5 times measured emissi on rates. The ball mill baghouses, BH11 through BH15, were modeled

each at an emission rate of 8.82 x 10 - 4 grams per second (about 3.3 times the highest measured emission rate of all five ball mill baghouses). The emission rates in T able 6

, below, and in Table 1

- 1a of the

a ttainment demonstration modeling report (Appendix A to this report) , represent the permitted allowable limits for each point source. 12 These limits have been incorporated into a federally enforceable

construction permit , a ttached as Appendix C

.

Table 6: Point Source Control Emission Rates

Source ID Source Description Lead Emission Rate, grams/second (g/s) Lead Emission Rate, pounds/hour (lb/hr)

BH1 Baghouse 1 3.71 E

- 03 2.94E

- 02

BH2 Baghouse 2 1.73 E

- 03 1.37E

- 02

BH3 Baghouse 3 5.63 E

- 03 4.47E

- 02

BH4 Baghouse 4 1.85 E

- 02 1.47E

- 01

BH5 Baghouse 5 1.63 E

- 03 1.29E

- 02

BH11 Baghouse for Ball Mill 11 8.82 E

- 04 7.00E

- 03

BH12 Baghouse for Ball Mill 12 8.82 E

- 04 7.00E

- 03

10 40 C.F.R. Part 60 Subpart KK, Standards of Performance for Lead

- Acid Battery Manufacturing Plants.

11 40 C.F.R. Part 63 Subpart P PPPPP, National Emission Standards for Hazardous Air Pollutants for Lead Acid Battery Manufacturing Area Sources.

12 See Appendix A for a copy of the attainment demonstration report to this document15 BH13 Baghouse for Ball Mill 13 8.82 E

- 04 7.00E

- 03

BH14 Baghouse for Ball Mill 14 8.82 E

- 04 7.00E

- 03

BH15 Baghouse for Ball Mill 15 8.82 E

- 04 7.00E

- 03

OM Oxide Mills 1

- 10 (combined) 8.47 E

- 03 6.72E

- 02

BALLFUG Source

The BALLFUG source in the 2013 attainment demonstration modeling represents fugitive emissions from the Exide facility’s ball mill processes. In 2011, the emission rate for BALLFUG was estimated by Exide to be 28.16 pounds per month for the nonattainment designation recommendation modeling. Exide since has installed additional ventilation and closed prior building openings associated with this source. The Exide facility’s lead processing operations are located within a negative pressure

total enclosure a nd are fitted with local exhaust ventilation (LEV).

The negative pressure total enclosure with maintained LEV can be credited with 99 percent effectiveness in reducing fugitive emissions in accordance with a September 2012 letter from EPA Region 7 to Missouri DNR. 13 The EPA letter references a secondary lead smelter; however, it can apply similarly to the Exide lead acid battery manufacturing facility. The emission rate from the BALLFUG source has been decreased by 99 percent to a continuous emission of 4.86 x 10 - 5 grams per second (3.86 x 10 - 4 pounds per hour). The following requirement s have been incorporated into a federally enforceable permit:

Ball Mill Process Fugitive Emissions Control Requirements

– Ball Mill process emissions shall be contained in a negative pressure total enclosure with maintained local exhaust ventilation at

p rocess points, reducing the Ball Mill process fugitive emissions by 99 percent from 338 pounds of lead per year to 3.38 pounds of lead per year. Total enclosure means that the building is completely enclosed with a floor, walls, and a roof to prevent expo sure to the elements and to assure containment of lead bearing material with limited openings to allow access and egress for people and vehicles. The total enclosure must provide an effective barrier against fugitive dust emissions

with the direction of a ir flow being inward through any openings and with the enclosure being maintained under constant negative pressure. Ball Mill process fugitive emissions of lead shall be less than or equal to 4.86 x 10 - 5 grams per second (3.86 x 10 - 4 pounds per hour; 3.38 pounds per year), as modeled for the attainment of the 2008 Lead NAAQS. Negative pressure shall be

maintained in the total enclosure at all times. The Ball Mill total enclosure standards are identified

below in Table 7

.

13 Missouri DNR’s lead SIP documents can be found here: http://www.dnr.mo.gov/env/apcp/sips.htm#lead

. See Section 6.2 Capture Efficiency Discussion and Appendix K in the Missouri SIP for the Buick/Viburnum Trend Lead Nonattainment Area, http://www.dnr.mo.gov/env/apcp/docs/buick

- complete

- submittal

- pkg.pdf , for supporting documentation on capture efficiency for total enclosures with negative pressure and loca l exhaust ventilation.16 Table 7: Ball Mill Total Enclosure Standards

Ball Mill Total

Enclosure Standards 1. The total enclosure must be free of significant cracks, gaps, corrosion, or other deterioration that could cause lead bearing material to be released

fro m the primary barrier.

2. Measures must be in place to prevent the tracking of lead bearing material out of the enclosure by personnel or equipment.

3. The total enclosure must be ventilated to ensure negative pressure values of

at least 0.013 mm of mercury (0.007 inches of water).

4. An inward flow of air must be maintained through all natural draft openings.

5. The total enclosure must be inspected at least once every 30 days . Any gaps, breaks, separations, leak points, or other poss ible routes for emissions of lead to the atmosphere must be repaired within 30 days of identification unless an approval for an extension is obtained from KDHE before the repair period is exceeded. Inspection and repair records shall be kept on site for a minimum of two ye ars and shall be made available to KDHE upon request.

Roadways

Air dispersion modeling demonstrated that lead

- in

- roadway silt content would need to decrease in order to achieve attainment. Exide shall pave all plant roadways and parking lots subject to vehicular

traffic on the no rthwest section by July 31 , 2014

. 14 This project is aimed at reducing the silt load and lead content to the levels similar to the dust loading and lead content on other paved roadways on the property

and r educing the fugitive dust impact on ambient air monitors, as modeled for the attainment of the 2008 Lead NAAQS. All internal roadways and parking lots subject to vehicular traffic on the northwest section, a total area of 15,200 square yards, shall be pav ed to achieve the necessary results per the attainment demonstration modeling, which demonstrates a roadway fugitive lead emission reduction of 0.04 tons (80 pounds) per year, from 0.056 tons of lead per year to 0.016 tons of lead per year. This proje ct has been incorporated into a federally enforceable permit. 15

Summary of Recent Projec ts to be Completed

Table 8 below lists improvement projects with assigned and actual completion dates.

14 A map of the area to be paved is included in the permit as Attachment 2.

15 See Appendix C for a copy of the permit.17 Table 8: Recent Improvement Projects Completion

Project Action Completion Date

Baghouses 11

- 15 (BH11

- BH15),

Ball Mill Stacks Increase stack heights by 3 7 feet as demonstrated in attainment modeling. July 19, 2013

Stack test completed on November 22, 2013

Oxide Mill (OM1

- OM10),

Oxide Mill Stacks Manifold to new stack, 65 feet from ground level per attainment demonstration. October 1, 2013

Stack test completed on November 22, 2013

Baghouse 1 (BH1) Replace baghouse and increase stack height to 80 feet per attainment demonstration modeling. Installation completed February 19, 2014

Paving Plant Roadways Pave all internal roadways and parking lots subject to vehicular traffic on the northwest section per attainmen t demonstration modeling. Total area to be paved is 15,220 square yards. July 31 , 2014

All completed improvement projects and those yet to be completed, as well as any associated provisions, are included in the federally enforceable comprehensive per mit issued by KDHE to the Salina Exide facility.

REASONABLE FURTHER PROGRESS (RFP)

Nonattainment SIPs must provide for reasonable further progress (RFP), in accordance with Section 172(c)( 2) of the CAA. Section 171 of the CAA defines RFP as “such annual incremental reductions in emissions of the relevant air pollutant as are required by this part or may reasonably be required by the Administrator for the purpose of ensuring attainment of t he applicable national ambient air quality standard by the applicable date.” According to the EPA, RFP for lead nonattainment areas should be met by the strict adherence to an ambitious compliance schedule that is expected to periodically yield significan t emission reductions, and to the extent appropriate, linear progress. The EPA recommends that nonattainment SIPs provide a detailed schedule for compliance of RACM (including RACT) and accurately indicate the corresponding annual emission reductions to be achieved. 16

Since 2006, Exide has been working on projects to reduce lead emissions. The majority of the improvement activities have occurred since 2009, after the Lead NAAQS was revised from 1.5 μg/m3 to
0.15 μg/m3 in November 2008. (See Appendix B for Exide’s 2011 and 2013 project update documents.) Table 9, below, demonstrates emission reductions through 2013 as met by “adherence to an ambitious compliance schedule.” With the completion of the Baghouse 1 (BH1) replacement and the roadways

16 Federal Register Volume 73, Wednesday, November 12, 2008, 73 FR 66964 , “National Ambient Air Quality Standards for Lead” Final Rule. See pages 67038

- 67039.18 paving project in 2014, all emissions reductions will have been achieved well before the December 31, 2016, attainment date and there is no need to further demonstrate annual incremental reductions or linear progress for RFP. Exide’s permit conditions, including emissions limits and the requirement to maintain less than or equal to 0.15 μg/m3 at KDHE ambient air monitors, will ensure compliance with the NAAQS.

Table 9: Emission Reduction Projects

Year Emissions Inventory Lead (Pb),

Tons Improvement Activities C omments Monitor, 3

- month Avg Pb, 17 μ g/m 3

2007 3.31 OM1 & OM2 (2006)

2008 2.25

2009 2.15 OM3 & OM4; BH3

2010 2.17 OM5 & OM6; BH2 0.421

2011 1.45 OM7, OM8, OM9, OM10; BH4; Ball Mill Process Fugitive Control; Ball Mill Ventilation Upgrade Lead NAAQS designation

effective 12/31/2011

– base year for reductions 0.206

2012 0.67 BH5; Relocation of OM Diverter

Valves 54% EI reduction 0.207

2013 0.53 BH11

- 15, Ball Mill Stacks; OM

Stacks 63% EI reduction 0.144 18

2014 BH1; Plant NW Section Roadway Paving Start of compliance period for 3 years clean data

determination shows 33

- 47% reduction in

monitored values for Nov

2013

- Feb 2014 over Nov

2012

- Feb 2013. 19 0.140 20

2015 Continuous Improvement (CI); Best Management Practices (BMP) 21 0.140 2 0

2016 CI; BMP 0.140 20

0.137 22

0.127 23

17 Highest 3

- month average during calendar year unless otherwise noted. Ambient air monitoring for lead implemented in 2010.

18 3

- mont h rolling average monitor value for July

- September 2013.

19 3

- month rolling average for Nov 2012

- Jan 2013 was 0.151 μ g/m 3 versus 0.080 μ g/m 3 for Nov 2013

- Jan 2014; Dec 2012

- Feb

2013 was 0.095 μ g/m 3 versus 0.064 μ g/m 3 for Dec 2013

- Feb 2014.

20 Projection for decline of annual highest 3

- month rolling average monitor value towards the maximum impact value of 0.137

μ g/m 3 identified in the attainment demonstration modeling (Appendix A) to occur after the completion of emission reduction projects.

21 The Exide Salina facility is certified to ISO 14001. See certificate in Appendix E.

22 Maximum impact value of 0.137 μ g/m 3 by the attainment date of December 31, 2016, identified in the attainment demonstration modeling (Appendix A).

23 Monitor 3

- month average value of 0.127 μ g/m 3 by the attainment date of December 31, 2016, identified in the attainment demonstration modeling (Appendix A).19 As indicated in Table 9, Exide’s improvement projects schedule, to

- date and ongoing, has resulted in significant reduction in lead emissions from the facility and in modeled attainment of the 2008 Lead NAAQS before the December 31, 2016 attainment date. Reasonable further progress for Exide, as the primary contributor to lead emissions in the Salina nonattainment area, will be monitored and evaluated by

KDHE and will be based on the following.

1. Achieving a highest 3

- mon th rolling average KDHE ambient air monitor value less than or equal to 0.15 μ g/m 3 for any 3

- month period beginning after July 31, 2014 (i.e., beginning with the average for Aug

- Oct 2014).

2. On

- schedule completion of projects, which include those listed bel ow in Table 10.

Table 10: Reasonable Further Progress Project Completion

Project Action Completion Date

Baghouses 11

- 15 (BH11

- BH15),

Ball Mill Stacks Increase stack heights by

37 feet as demonstrated in attainment modeling. Completed July 19, 2013 Stack test November 22, 2013

Oxide Mill (OM1

- OM10),

Oxide Mill Stacks Manifold to new stack, 65 feet from ground level per attainment demon

stration. Completed October 1, 2013 Stack test November 22, 2013

Baghouse 1 (BH1) Replace baghouse and increase height to 80 feet per attainment demon

stration modeling. Completed February 19, 2014 Stack test March 20, 2014

Paving Plant Roadways Pave all internal roadways and parking lots subject to

vehicular traffic on the northwest section per

a ttainment demonstration modeling. Total area to be paved is 15,220 square yards. (See map

- Attachment 1) Completed July 31, 2014

Section 172(c)(9) of the federal Clean Air Act requires the implementation of specific measures if

the nonattainment area fails to maintain reasonable further progress. Upon failure to achieve and maintain reasonable further progress (RFP), root cause analysis and corrective and preventive action provisions shall be implemented in accordance with Table 11 below. The ab ove RFP measures have been incorporated into a federally enforceable perm it as exhibited in Appendix C.20 CONTINGENCY MEASURES

Section 172(c)(9) of the federal Clean Air Act requires the implementation of specific measures if

the nonattainment area fails to maintain reasonable further progress (see above) or to attain the NAAQS by the applicable attainment date.

Contingency measures shall be triggered upon the following determination made by KDHE:

KDHE ambient air monitoring shows that the nonattainment area fails to meet the 0.15 μ g/m 3 based

on a 3

- month rolling average for any 3

- month period beginning after July 31, 2014 (i.e., beginning

with the 3

- month rolling average for Aug

- Oct 2014).

Table 11. Contingency Measures to be Implemented and Allotted Time Frames for Completion.

Measures Completion Time

• For each NAAQS violation on the KDHE ambient air monitor (i.e., average greater than 0.15 μ g/m 3 ) or for failure to maintain reasonable further progress , Exide shall develop and submit to KDHE a root cause analysis, which shall include but not be limited to: the investigation of production/operations performance, including startup, shutdown, malfunction and maintenance periods and the resulting data and discussion; meteorological data for the site and surrounding area; Exide’s fence line site monitoring data; and any other conditions or events that may be relevant to lead emissions and/or that may influence or impact KDHE ambient air

monitor results. Exi de shall develop and submit to KDHE

documentation of corrective actions taken for each occurrence for which there is found to be a controllable or preventable contributing

factor or root cause.

• In addition to the above

- mentioned root cause analysis and corrective/preventive action process, Exide shall implement selected and approved contingency measures as outlined in the compliance plans developed by Exide per Section XI (Contingency Measures) of the permit. 24 Exide shall submit to KDHE

documentation of implemented measures, including identification of measures and timeline for implementation and effect. 30 days after KDHE notifies Exide of Lead NAAQS violation

To be implemented in accordance

with KDHE

- approved schedule as part of compliance plans developed per Section XI Contingency Measures

24 Refer to federally enforceable Permit # C

- 12206 attached as Appendix C21 • Exide shall compile analyses and results from the contingency measures described above in addition to performing the following:

o Exide shall implement further compliance plan measures

for controls on sources and areas of lead emissions on site that were identified pursuant to Section XI of the permit or as a result of Exide’s root cause analysis and corrective/preventive action process or other analyses.

Exide shall submit to KDHE document ation of implemented measures, including identification of measures and timeline for implementation and effect.

o Exide shall implement measures from the fugitive dust control plan for the site as developed by Exide per Section XI of the permit. Exide shall submit to KDHE documentation of implemented measures, including identification of measures and timeline for implementation

and effect. To be implemented in accordance

with KDHE

- approved schedule as part of compliance plans developed per Section XI

Conti ngency Measures

• Exide shall conduct stack testing on an increased frequency as determined by KDHE. The scope and frequency of the increased stack tests will be based on an evaluation by KDHE of the information submitted in the root cause analysis triggered by a

violation of the lead standard. The supplemental stack tests required by KDHE will be limited to those stacks that the root cause analysis shows have the potential to contribute to the increase in monitored lead concentrations. KDHE will reduce the required freq uency to the frequencies outlined in Table 1 of the permit once the additional stack tests demonstrate that the stacks in questions do not show a significant increase above their baseline stack test rates. Upon notification by KDHE to

Exide

• Exide shall re

- model with proposed changes to emission rates and/or work practices, improvements to the remainder of roadways and parking lots within plant boundaries, and any proposed changes to other parameters or conditions (which may include throughput ). Exide shall submit to KDHE for approval a revised demonstration for the timely attainment and maintenance of the 2008 Lead NAAQS, which shall include the implemented changes and a timeline for implementation and effect. 60 days after KDHE notifies

Exide

OUTREACH

KDHE promoted efforts to communicate information to the public during early phases of 2008 Lead NAAQS nonattainment area findings in and around Salina and ensuing designation activities. The agency

distributed a Press Release in June 2011 summarizing the new (2008) Lead N AAQS threshold and its

effects including new air pollution controls, equipment upgrades, and other actions necessary to achieve

airborne lead standard compliance. KDHE and Salina’s Exide manufacturing plant establishe d extensive

corrective measures to reduce lead emissions and their detrimental effects

.22 On February 23, 2011: KDHE facilitated a meeting that included a Lead Air Quality Issues presentation in Salina for Exide, City of Salina, Saline County, and Salina

- Saline County Health Department staff followed by discussion.

On June 28, 2011: KDHE held a public meeting in Salina to provide a Salina Air Quality Public Meeting overview of the new air quality standard for lead emissions monitoring, nonattainment designation and SIP requirements.

For additional public participation activities , r efer to:

http://www.kdheks.gov/bar/air

- monitor/lead/Salina_Air_Quality_Public_Meeting_June_28_2011_Presentation.pdf

On November 10, 2011: Kan sas published a public hea r ing notice inviting comment s concerning the proposed 2008 Lead NAAQS Infrastructure SIP (i

- SIP) in the Kansas Register, on the KDHE BOA public notice website

, the Salina, Topeka, Hays, Wichita, Dodge City and Chanute newspaper s
, and

KDHE District Offices in the same locations

. No requests for a hearing or comments were received by December 13th so the public hearing was cancelled via KDHE BOA website announcement , along with public comment period closure on December 13, 2011.

KDHE and Saline County l ocal health officials provide d education and outreach to the Saline County community , including blood lead testing which indicated elevated levels in both children and

adults. Case management efforts were provided through KDHE Healthy Homes programs and the Salina Local Health agency. Kansa s Statutes Annotated (K

. S

. A

. ) 65

- 1 200 throu gh 65

- 1 214 authorize the Secretary of KDHE to investigate the extent of childhood lead poisoning in Kansas and to develop a data management system designed to collect and analyze information on childhood blood lead poisoning. The

KDHE Bureau of Epidemiolog y and Pu blic Health Informatics (BEPHI) maintains a database of blood lead

test results for tests administered on children and adults living in Kansas. Kansas Administrative Regulation (KAR) 28

- 1

- 18 specifies that laboratories must report the results of all blood lead test results to

KDHE. Analysis of the blood lead test results within the database helps to improve knowledge about the environmental factors contributing to lead exposure among Kansans.

Public Participation Requirements

In accordance with Section 110(a)(2) of the CAA, Kansas is required to hold a public hearing prior to adopt ion of this SIP revision and subsequent submittal to EPA. KDHE notified the public and other stakeholders of an upcoming public hearing and required 30

- day comment period prior to the tentatively scheduled hearing for this proposed 2008 Lead NAAQS SIP Revision f or Attainment Demonstration, as

follows.

Specific to 40 CFR 51.102 (Public Participation Requirements ), KDHE complies with public notice requirements for this SIP revision. The opportunity to submit written comments, request a public hearing

a nd/or participate in a public hearing, was advertised in the Kansas Regi ster, the Salina, Wichita, Hays, Dodge City, Chanute, and Topeka newspaper s, the KDHE District Office s , and on the KDHE BOA website

at www.kdheks.gov/bar/planning/pnplanning.html

, at least thirty days prior to the tentatively scheduled date for the hearing. Information regarding the date, place, and time of the public hearing was included in the notice along with information on how to request the hearing or ascertain whether the hearing would be

cancelled.23 No hearing was requested and none was held. One comment was received and addressed in the Responsiveness Summary (see Appendix D). Notice of cancellation of the hearing was provided as set forth in the public notice of the proposed SIP revision

A statement verifying public participation compliance was included in the certification letter t o EPA and copy of the required public notice and tentatively

- scheduled public hearing cancellation documents included with this report

, as Appendix D.

In addition to the public notice for this State Implementation Plan, a separate 60

- day public comment period was opened for the issuance of the federally enforceable permit. That comment period ran from June 12, 2014 to July 16 , 2014 . No comments were received and a hearing was not requested.

CONCLUSION

The control measures that Sa lina Exide Technologies and KDHE have established and enforced since 2008 reveal improvement in lead emission reductions, overall. A dditional control measures will

be implemented if ongoing monitoring results warrant them for the nonat tainment area in Saline County.

Exide’s continual point source improvements and existing fugitive emission control measures already in place include :

 Ball Mill total enclosure with negative pressure

 Roadway paving

 Facility baghouse replacements

 Oxide mill replacements

 Oxide mill process and structural improvements

S pecifically identified contingency measures are incorporated into a federally enforceable

construction permit [KDHE C

- 12206] for Exide to implement upon evidence of air monitoring exceedance triggers determined by Exide and KDHE monitoring

. The permit serves to supplement all construction and operating permits previously issued to Exide

. Based on recent and ongoing improvements and control measures, KDHE projects the Salina area will reach attain ment of the 2008 Lead NAAQS by the required

December 31, 2016 attainment date.

The Kansas Department of Health and Environment pos its the State meets its CAA Section 191(a) obligation to sub m it a plan for the Salina/Saline County (Exide) Lead Nonattain m ent Area under the 2008 lead NAAQS via this SIP for Attainment Demonstration

. This docu m ent de m onstrates attain m ent of the

2008 lead NAAQS th r ough air dispersion modeling of an effective c ontrol strategy and co m pliance with all

req u ire m ents of Section 172(c) regarding this stan d ard f or the Exide Technologies l ead n onattain m ent a r ea.