_____________________________________________________________________________________



## Draft Technical Support Document

_____________________________________________________________________________________



## Proposed Rulemaking Action on the 2012 Los Angeles County Lead SIP

November 2013

For q uestions about this document

, please contact Wienke Tax, EPA Region 9, 415

- 947

- 4192, or John Ungvarsky, 415

- 972

- 3963.2 

### Table of Contents

I. Background

A. The Lead NAAQS

B. Lead NAAQS Designations

C. Lead Planning Requirements

D. Monitoring Network

II. Review of SIP Submittal

A. Base Year Emissions Inventory

B. RACM/RACT Demonstration and Control Strategy

C. Attainment Demonstration and Modeling

III. List of Tables

Table I.D.1. South Coast Air Basin Lead Monitoring Data, 2007

- 2013

Table II.B.1. Category

- Specific Los Angeles County Nonattainment Area 2010 Emission Inventory for Lead

Table II.B.2. 2010 Lead Emissions by Facility Emitting Over One Pound per Year in Los Angeles County

Table II.B.3. Piston

- Engine Aircraft Emissions in Los Angeles County

Table II.D.1. 2008 Lead NAAQS Attainment Demonstration Modeling Results for Exide and Quemetco Lead

- Acid Battery Acid Recycling Facilities

VI. List of Figures

Figure I.B.1. Los Angeles County Lead Nonattainment Area

Figure I.D.1. Ambient Lead Monitoring Locations in the South Coast Air Basin

Figure I.D.2. 3

- Month Mean Concentrations, 2008

- 2013, South Coast Air Basin Lead Monitoring
Data

Figure II.D.1: Quemetco

– Location of Modeled Sources

– 2015 Emissions

Figure II.D.2: Exide

– Location of Modeled Sources

– 2015 Emissions3

Figure II.D.3. Exide

– 2015 Lead Concentrations (ug/m3)

- Using Rule 1420.1 Emiss ion Limits (Total Emissions

– Stack and Fugitive Emissions)

Figure II.D.4. Quemetco

– 2015 Lead Concentrations (ug/m3) Using Rule 1420.1 Emission Limits (Total Emissions

– Stack and Fugitive Emissions)

Figure II.D.5. Exide

– 2015 Lead Concentrations (ug/ m3) Using Rule 1420.1 Emission Limits (Stack Emissions Only)

Figure II.D.6. Quemetco

– 2015 Lead Concentrations (ug/m3)

- Using Rule 1420.1 Emission Limits (Stack Emissions Only)4



### I. Background

A. T HE L EAD NAAQS

The Clean Air Act (CAA or Act), which was last amended in 1990, requires the United States Environmental Protection Agency (EPA) to set National Ambient Air Quality Standards (NAAQS or standards ) for wide

- spread pollutants from numerous and diverse sources considered harmful to public health and t he environment. The CAA also requires EPA to periodically review the standards to ensure that they provide adequate health and environmental protection, and to update those standards as necessary. EPA sets NAAQS for
lead and five other pollutants conside red harmful to public health and the environment (the other pollutants are ozone, nitrogen oxides, carbon monoxide, sulfur dioxide and particulate

matter ). These six pollutants are known as “criteria pollutants

. ”

Lead is generally emitted in the form of particles, which end up being deposited in water, soil, and dust. People may be exposed to lead by inhaling it, or by ingesting lead

contaminated food, water, soil, or dust. Once in the body, lead is quickly absorbed into the
bloodstream and can result in a broad range of adverse health effects. These include damage to the central nervous system, cardiovascular function, kidneys, immune system, and red blood cells. Children are particularly vulnerable to lead exposure, in part because they are more likely

t o ingest lead and in part because their still

- developing bodies are more sensitive to the effects of lead. Urban children are also of particular risk if the mother is exposed to lead. The harmful effects to children’s developing nervous systems (including their brains) arising from lead exposure may include IQ loss, poor academic achievement, long

- term learning disabilities, and an increased risk of delinquent behavior.

EPA first established a lead standard in 1978 at 1.5 ug/m 3 (quarterly average). 1 Based on new health and scientific data, EPA revised the federal lead standard to 0.15 ug/m 3 and the averaging time for the standard (to a 3

- month rolling average) on October 15, 2008 (see 73 FR 66964, November 12, 2008).

B. Lead NAAQS Designations

The process for designating areas following promulgation of a new or revised NAAQS is contained in section 107(d) of the CAA. The CAA requires EPA to complete the initial areas designations process within two years of promulgating a new or revised NAAQS. D esignations for the 2008 lead NAAQS were promulgated effective December 3 1, 2010 (see 75 FR 71033). Based on ambient air quality data for the years 2007

- 2009, a portion of Los Angeles County (excluding the high desert areas, San Clemente and Santa Catalina Islands) was identified as an

1 See 43 FR 46246, October 5, 1978.5

area that did not meet the 2008 Pb NAAQS. 2 Figure I

- B

- 1 illustrates the Los Angeles County lead

nonattainment area.

Figure I.B.1. Los Angeles County Lead Nonattainment Area (Source: 2012 Los Angeles County Lead SIP, p.1

- 3).

C. Lead Planning Requirements

The 1990 CAA Amendments established new planning requirements that states must
use to demonstrate attainment of the N AAQS. The most fundamental of these nonattainment area provisions applicable to the South Coast Air Basin is the requirement that the State submit

a state implementation plan (“ SIP ” or “Plan”) demonstrating attainment of the lead NAAQS. This demonstration must be based upon enforceable measures to achieve emission reductions leading to emissions at or below the level predicted to result in attainment of the NAAQS throughout the nonattainment area. The measures must meet the standard for reasonably

2 For an exact description of the Los Angeles County lead nonattainment area, see 40 CFR part 81.305.6

a vailable c ontrol m easures ( R ACM), and the measures must be implemented expeditiously and
ensure attainment no la ter than the applicable CAA deadline

. 3

Areas are required to attain the revised lead standard as expeditiously as practicable,
but no later than five years from the date the nonattainment designation became effective. For the Los Angeles County lead nonat tainment area, this date is December 31, 2015.

Attainment demonstration SIPs are due eighteen months after the effective date of an area’s designation. For the Los Angeles County nonattainment area, the SIP was due June 30,
2012. These SIPs should include emissions inventories, a reasonable further progress
demonstration (RFP) , reasonably available control measures, an attainment demonstration, and contingency measures. Control measures for the 2008 NAAQS need to be in place as expeditiously as practicable. In order for control measures to result in three years of monitored clean data by the attainment date, lead nonattainment areas required to demonstrate attainment by December 31, 2015 would need to have all necessary controls in place no later
than Novemb er 1, 2012.

EPA Regulations and Guidance

EPA is implementing the lead NAAQS under Title 1, Part D, subparts 1 and 5 of the CAA, which includes section 172, “Nonattainment plan provisions,” and sections 191 and 192, “Plan
Submission Deadlines” and “Attainment Dates,” respectively.

Section 192(a) establishes the attainment date for lead nonattainment areas "as expeditiously as practicable" but no later than five years from the date of the nonattainment designation for the area. EPA designated most of Los Angeles County except for San Clemente and Catalina islands as a nonattainment area effective December 31, 2010, and thus the applicable attainment date is no later than December 31, 2015. Under section 172(a)(2)(D), the Administrator is precluded fro m granting an extension of this attainment date where the statute separately establishes a specific attainment date, such as the five

- year deadline established in section 192(a).

Section 172(c) contains the general statutory planning requirements applicabl e to all nonattainment areas, including the requirements for emissions inventories, reasonably available control measures/reasonably available control technology (RACM/RACT), attainment demonstrations, RFP demonstrations, and contingency measures.

When EPA issued the NAAQS for lead on November 12, 2008 (“lead NAAQS rule”), it included some implementation guidelines for the lead NAAQS regarding planning requirements.

3 See CAA s ection s 172(c)(1) and 192(a)

.7

See 73 FR 66964. EPA also issued several guidance documents related to planning requirements for the lead NAAQS. These include:

 Memorandum from Scott Mathias, Interim Director, Air Quality Policy Division, USEPA Office of Air Quality Planning and Standards, to Regional Air Division Directors, Regions I

- X, “2008 Lead (Pb) National Ambient Air Qual ity Standards (NAAQS) Implementation Questions and Answers

, ” July 8, 2011 , (“Lead Q&A”) ;

 “Addendum to the 2008 Lead NAAQS Implementation Questions and Answers Signed on July 11, 2011, by Scott Mathias,” dated August 10, 2012. (“Lead Q&A Addendum”); and

 Imp lementation of the 2008 Lead National Ambient Air Quality Standards

– Guide to Developing Reasonably Available Control Measures (RACM) for Controlling Lead Emissions , USEPA Office of Air Quality Planning and Standards,

EPA

- 457/R

- 12

- 001, March 2012.

The lea d NAAQS rule and its preamble and the two guidance documents address the statutory planning requirements for emissions inventories, RACM/RACT, attainment demonstrations including air quality modeling requirements, RFP demonstrations, and contingency measur es. The lead NAAQS rule also addresses other topics such as monitoring

, designations, lead infrastructure SIPs and exceptional events.8

D. South Coast Lead Monitoring Network and Ambient Data

The lead standard is attained when an area’s maximum arithmetic 3

- month mean concentration for a 3

- year period is less than or equal to 0.15 micrograms per cubic meter ( μ g/m 3 ).

In the South Coast lead nonattainment area, the SCAQMD is the agency responsible for assuring that the area meets air quality monitoring requi rements including its submit tal of annual mon itoring network plans to EPA. The SC AQMD network plans describe the monitoring network operated by SCAQMD in the South Coast nonattainment area. These plans discuss the status of the air monitoring network, as r equired under 40 CFR 58.10. As shown in Figure I.D.1, SCAQMD operates a combination of neighborhood and source

- oriented air quality monitoring stations for lead in the South Coast Air Basin. As required by 40 CFR part 58, the SCAQMD annually produces a plan which provides for the establishment and maintenance of their air quality monitoring network, and forwards the plan to EPA. Since 2007, EPA regularly review s these annual plans for compliance with the applicable reporting requirements in 40 CFR part
5 8. EPA has found that the areas’ network plans submitted by SCAQMD meet the applicable requirements under 40 CFR part 58

. 4

EPA also concluded from its Technical System Audit of the SCAQMD Primary Quality Assurance Organization (PQAO)

, conducted during the spring of 2010, that the ambient air monitoring network operated by SCAQMD currently exceeds the requirements for the minimum number of SLAMS for lead in the South Coast nonattainment area. 5 SCAQMD annually certifies that the data it submits to AQS are com plete and quality

- assured. 6

Since comprehensive monitoring began for lead in the South Coast in 1975 , the area has seen a significant decline in ambient levels. Figure I.D.2 displays lead data for the South Coast area for the years 200 8

- 201 3

. Certification of 2013 data by SCAQMD is anticipated in May 2014

. As shown in Figure I.D.2, at the beginning of 2008 the 3

- month mean (or average) concentrations measured in the South Coast nonattainment area were more than 15 times higher than the lead NAA QS of 0.15 μ g/m 3 . Levels decreased considerably in 2008, and the 3

- month mean concentrations fell below 0.50 μ g/m 3 starting in 2009. 2010 and 2011 show higher concentrations in spring and summer, with 2010’s maximum 3

- month mean concentration being measu red at 0.39 μ g/m 3 in April

- May

- June, while 2011 saw higher 3

- month mean concentrations and a maximum of 0.45 μ g/m 3 in May

- June

- July 2011. All 3

- month means

4 See Letter from Matthew Lakin , Manager, Air Quality Analysis Office, U.S. EPA Region IX, to Dr. Matt Miyasato

, Deputy Executive Officer, Science and Technology Advancement, SCAQMD, dated April 18, 2013.

5 Technical System Audit Report, Sout h Coast Air Quality Management District , April 13

– April 16, 2010, Conducted by Air Quality Analysis Office and Quality Assurance Office, US EPA Region 9, 75 Hawthorne Street

, San Francisco, California 94105, March 2011.

6 See, e.g., Letter, Dr. Matt M. Miyasato , Deputy Executive Officer

, Science and Technology Advancement, South Coast Air Quality Management District, to Mr. Jared Blumenfeld, Regional A dministrator, U.S. EPA Region 9, certifying calendar year 2012 ambient air quality data and qua lity assurance data for PM 2.5 , PM 10 , and Pb, May 1,
2013

.9

from January 2012 through June 2013 are at or below the 0.15 μ g/m 3 standard.

An area attains th e lead standard if it has three calendar years’ worth of 3

- month site means that are less than or equal to 0.15 μ g/m 3 . The South Coast nonattainment area currently has one complete calendar year’s worth of data meeting the standard (calendar year 2012). Should it collect valid and complete data that meet the standard through 2013 and 2014, it would be considered to be attaining the lead NAAQS.

Figure I.D.1. Ambient Lead Monitoring Locations in the South Coast Air Basin 7

7 Source: 2013 South Coast AQMD Annual Air Quality Monitoring Network Plan, Appendix A, p. 6.10

Figure I.D

. 2

. 3

- Month Mean Concentrations, 2008

- 201 3 , South Coast Air Basin Lead Monitoring Data

Table I.D .1. 3

- Month Mean Concentrations, 2008

- 201 3 , South Coast Air Basin Lead Monitoring Data

2008 2009 2010 2011 2012 2013*
Nov

- Dec

- Jan

- 0.66 0.25 0.24 0.15 0.07
Dec

- Jan

- Feb 2.45 0.54 0.24 0.25 0.10 0.07
Jan

- Feb

- Mar 2.49 0.42 0.25 0.29 0.09 0.08
Feb

- Mar

- Apr 2.29 0.48 0.32 0.36 0.08 0.10
Mar

- Apr

- May 1.76 0.48 0.37 0.42 0.07 0.09 Apr

- May

- Jun 1.26 0.38 0.39 0.44 0.07 0.08 May

- Jun

- Jul 0.71 0.47 0.35 0.45 0.08

- Jun

- Jul

- Aug 0.67 0.48 0.31 0.43 0.09

- Jul

- Aug

- Sep 0.79 0.49 0.32 0.44 0.10

- Aug

- Sep

- Oct 0.83 0.33 0.27 0.35 0.11

- Sep

- Oct

- Nov 0.80 0.31 0.27 0.30 0.10

- Oct

- Nov

- Dec 0.79 0.28 0.21 0.20 0.08

- *2013 data is not yet certified. Chart reflects data available in EPA's Air Quality System (AQS) as of September 18, 2013. Values in red are over the federal lead NAAQS.11



### II. Review of the South Coast Submittal

A. Selected Attainment Plan Requirements

The requirements for attainment plans for the lead NAAQS were described in Section I of this document. Following is a review of the planning requirements as they pertain to the emissions inventories, RACM/RACT demonstration and control strategy, and modeling and attainment dem onstration.

B. Base Year Inventory

Section 172(c)(3) of the CAA requires plan submittals to include a comprehensive, accurate, and current inventory for the base year from all sources in the nonattainment area. In demonstrating attainment in accordance with CAA section 17 2, the State should provide an attainment emissions inventory to identify the level of emissions in the area sufficient to attain the NAAQS. The attainment inventory should generally contain actual emissions at the time the area attained the standard. The inventory should also include all sources of lead emissions, and all stationary, area and mobile sources of emissions.

In evaluating the State’s inventory, EPA reviewed the following documents:

 South Coast Air Quality Management District

, Final 2012 Lead State Implementation Plan, Los Angeles County, May , 20 12, Chapter 3: Current Lead Inventory, and

 California Environmental Protection Agency, Air Resources Board, Staff Report, Proposed State Implementation Plan Revision for the Federal Lead Standard, Release Date May 11,
2012.
The inventory provides the basis for the control measure analysis and the RFP and attainment demonstrations in the Final 2012 Lead State Implementation Plan, Los Angeles County (“ 2012 Los Angeles County Lead SIP”). Table II.B.1 depicts the 2010 base year emissions
inventor y for lead in tons per year (tpy) as presented in Table 3

- 1 of the 2012 Los Angeles County Lead SIP. The point source emissions in Tab le II.B. 1 are grown and controlled from a 2002 baseline , and the 2010 inventory reflects adopted air regulations with current compliance dates as of 2010. The emissions inventory is divided into four major classifications: point, area, off

- road, and on

- roa d sources. Stationary sources can be further divided into “point” and “area” sources. As indicated in the Chapter 3, page 3

- 3 of the Los Angeles County Lead SIP, Los Angeles County’s lead nonattainment status is linked to two large battery

- recycling facili ties

-- Exide Technologies in Vernon (“Exide”) and Quemetco Inc. in City of Industry (“Quemetco”). These two sources fall within the Metal Processes subcategory

. 8

8 Lead concentrations at all non

- source oriented monitoring network sites in the Los Angeles County portion of the Basin are well below the new 2008 standard for lead, with typical levels of about 0.01 μg/m 3 , and have been since prior to January 2012

.12

Based on our review of the 2012 Los Angeles County Lead SIP , we find that the emissions inventories in the plan are comprehensive

, in that they include estimates of lead from all of the relevant source categories.

Table II.B. 1. Category

- Specific Los Angeles County Nonattainment Area 2010 Emissions Inventory for Lead

Source Category 2 010 Lead Emissions a (tpy)
Stationary and Area Sources

Fuel Combustion

Electric Utilities 0.02

Cogeneration 0.01
Petroleum Refining (Combustion) 0.05
Manufacturing and Industrial 0.08

Service and Commercial 0.04
Waste Disposal

Incinerators 0.01
Petroleum Production & Marketing
Petroleum Refining 0.03

Industrial Processes

Mineral Processes 0.06

Metal Processes 0.42

Glass and Related Products 0.02

Miscellaneous Processes

Residential Fuel Combustion 0.02

Construction and Demolition 5.80

Paved Road Dust 6.83
Unpaved Road Dust 0.47
Fugitive Windblown Dust 0.06

Fires 0.01
Waste Burning and Disposal 0.03
Total Stationary and Area Sources 13.9613

Mobile Sources

On

- Road Vehicles
Light

- Duty Passenger 0.09
Light & Medium Duty Trucks 0.06

Heavy

- Duty Gas Trucks 0.0

Heavy

- Duty Diesel Trucks 0.07

Total On

- Road Vehicles 0.22
Off

- road Mobile

Aircraft 3.95

Trains 0.01
Ships & Commercial Boats 0.0

Off

- Road Equipment 0.06

Total Off

- Road Mobile 4.02

Total All Sources 18.20

a Source: 2012 Los Angeles County Lead SIP, Table 3

- 1.

Point 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 SC AQMD through the Annual Emissions Reporting Program (AER). 9 The 2010 point source emissions are based principally on reported data from facilities. 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 II.B.2 provides Los Angeles County 2010 lead emissions for all facilities tha t reported lead emissions of at least one pound per year. In 2010, no facility reported lead emissi ons greater than 0.5 TPY, the threshold for monitoring under EPA regulations to evaluate compliance with the lead NAAQS. Inventories in previous years showed Exide emitting over 0.5 TPY, and SC AQMD continues to monitor at Exide.

Los Angeles County’s nonattainment status is based on lead emissions from Exide and Quemetco, and fugitive lead emissions are believed to be a major source of lead at these two facili ties. 10 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

9 See SCAQMD’s website at: http://www.aqmd.gov/aer/aer.html . The AER site includes links to various guidelines (e.g., Guidelines for Fugitive Emissions Calculations ) for sources to use for calculating and reporting their
emissions.

10 2012 Los Angeles County Lead SIP , p. 3

- 3.14

titled: "Development of the RTR 11 Emissions Dataset for the Secondary Lead Smelting Source Category", used for development of Secondary Lead Smelting National Emission Standard for Hazardous Air Pollutant s, was used by SC AQMD staff to estimate fugitive emissions from these two facilities. 12 For additional details on how fugitive lead emissions were calculated, please see pages 3

- 3 and 3

- 4 of the 2012 Los Angeles County Lead SIP

.

T able II.B.2. 2010 Lead Emissions by Facility Emitting Over One Pound per Year in Los Angeles County

Facility Na me 2010 Lead Emissions (pounds/year)

EXIDE TECHNOLOGIES 13 655.5
ACE CLEARWATER ENTERPRISES 117.8
EXXONMOBIL OIL CORPORATION 99.4 QUEMETCO INC. 14 96.2 BP WEST COAST PRODUCTS LLC,BP WILMINGTON 78. 8
EAST LOS ANGELES COLLEGE 68.0
OWENS

- BROCKWAY GLASS CONTAINER INC 48.2
CHEVRON PRODUCTS CO. 29.6
EXIDE TECHNOLOGIES 27.7
CONOCOPHILLIPS COMPANY 24. 8
LIBERTY MFG INC 22.5 GLENDALE CITY, GLENDALE WATER & POWER 20.8
SO CAL EDISON CO 18.4 LONG BEACH CITY, SERRF PROJECT 18. 1
BP WEST COAST PROD.LLC BP CARSON REF. 16.2

T ROJAN BATTERY CO 12. 7 ULTRAMAR INC (NSR USE ONLY) 9.2 KAISER ALUMINUM FABRICATED PRODUCTS, LLC 8.8 LA CITY, DEPT OF AIRPORTS 6.4 HERAEUS METAL PROCESSING, LLC 6.4
LA CO. SANITATION DIST 6.3
TROJAN BATTERY CO 6.0

11 RTR = Risk and Technology Review.

12 F rom EPA’s website, available at http://www.regulations.gov/#!documentDetail;D=EPA

- HQ

- OAR

- 2011

- 0344

- 0163

. 13 For Exide and Quemetco , fugitive emissions estimated by EPA for lead

- acid battery recyclers were added to the point source emissions to obtain total facility emissions ( http://www.regulations.gov/#!documentDetail;D=EPA

HQOAR

- 2011

- 0344

- 0163 ). The lead fugitive emissions for each facility were calculated as follows: Fugitive lead emissions (Lbs/Yr) = (0.71 tons/yr * size factor * enclosure factor * Hous ekeeping factor) * 2000 Exide fugitive emissions = (0.71 * 1.84 * 0.25 * 0.2) * 2000 = 130 lbs/yr Quemetco fugitive emissions = (0.71 * 1.19 * 0.25 * 0.2) * 2000 = 85 lbs/yr

14 Ibid.15

Facility Na me 2010 Lead Emissions (pounds/year)

CONOCOPHILLIPS COMPANY 5.6
BARRY CONTROLS 5.6
NORTHROP GRUMMAN SYSTEMS CORPORATION 5.2 AIR LIQUIDE LARGE INDUSTRIES U.S., LP 4.4
LIGHT METALS INC 2.6
GLOBE IRON FOUNDRY INC 1.9
RALPHS GROCERY CO 1.8
TECHNI

- CAST CORP 1.8
THE STRELITZ CO INC 1.7
SA RECYCLING LLC DBA SA RECYCLING OF LA 1.8

L

- 3 COMMUNICATIONS ELECTRON TECH INC 1.4 DEMENNO/KERDOON 1.3
ANCON MARINE INC 1.1
COMMERCE REFUSE TO ENERGY FACILITY 1.1
ARROWHEAD BRASS PRODUCTS 1.0

Source: 2012 Los Angeles County Lead SIP, Table 3

- 2.

Area Sources

Area sources consist of widespread and numerous smaller emission sources such as smaller permitted facilities, households, or other land uses. Area sources include source categories associated with human activity causing emissions that take place over a wide geographic area. Construction and demolition, and paved and unpaved road dust are examples of area sources. CARB maintains and updates estimates of the chemical composition and particle size fractions for each source profile which are then used in emission inventory and air quality models. Area source lead emissions are calculated by applying the latest CARB speciation profiles for lead to the total particulate matter emissions. 15 CARB particulate matter (PM) speciation profile #420 was used for estimating emissions from “Construction and Demolition” and profile #471 was used for estimating emissions from “Paved Road Dust.” The lead fraction of PM emissions is 0.0557 percent for “Construction and Demolition” an d 0.0124 percent for “Paved Road Dust.” The source of lead in the PM emissions from these source categories are likely from the historical lead content in materials, such as paint and gasoline. Although the total lead inventory is dominated by these source s, the lead from area sources is emitted over a wide geographical area and the ambient lead c oncentrations (illustrated in Chapter 2 of the 2012 Los Angeles County Lead SIP ) show that they currently do not lead to high ambient levels or NAAQS exceedances.

15 CARB speciation profiles can be viewed or downloaded from the following CARB link: http://www.arb.ca.gov/ei/speciate/interopt01.htm16

CARB maintains and updates estimates of the chemical composition and particle size fractions for each source profile

, which are then used in emission inventory and air quality models. Area source lead emissions are calculated by applying the latest CARB s peciation profiles for lead to the total particulate matter emissions. 16 CARB particulate matter (PM) speciation profile #420 was used for estimating emissions from “Construction and Demolition” and profile #471 was used for estimating emissions from “Paved Road Dust.” The lead fraction of PM emissions is 0.0557 percent for “Construction and Demolition” and 0.0124 percent for “Paved Road Dust.”

T he paved road dust lead emissions in the 2012 Los Angeles County L ead SIP were estimated using EPA ’s 2006 AP

- 42 c alculation, EMFAC 2007 mobile source brake, tire wear and exhaust emissions, and CARB’s “California” silt loading profiles as well as centerline mileage planning assumptions

. 17

, 18 EPA released an update to AP

- 42 in January 2011 which revised the equation for estimating paved road dust lead emissions based on an updated regression that included new emission tests results. 19 In November 2013, t he SCAQMD staff submitted a technical c larification of the paved road lead emission projections using the updated AP

- 42 equation and the latest planning assumptions to ensure that the emissions inventories are consistent with currently approved modeling tools and data. 20 V ehicle M iles T raveled estimates were extracted from the CARB’s EMFAC2011 for 2015. The technical clarification showed that the updated paved road dust lead emissions were less than the attainment inventory emissions for the two years for which emissions were estimated in 2012 Los Angeles County Lead SIP. For example, in the November 2013 technical clarification , emissions of paved road dust in 2010 and 2015 (calculated with the latest AP

- 42 version and the updated VMT data) were estimated to be 56% lower, namely 3.02 tpy for 2 010 and 3.07 tpy for 2015 vs. 6.83 tpy for 2010 and 6.91 tpy for 2015 in the 2012 Los Angeles County Lead SIP . The 2012 Los Angeles County Lead SIP demonstrates that the lead NAAQS can be maintained with lead emissions from paved road dust at the higher va lues (see November 2013 technical clarification ). Therefore, the revised future year emissions estimates resulting from the technical analysis are much lower (e.g. 56%) than the levels that were shown as needed to attain and maintain the lead NAAQS in the original analysis submitted by the SCAQMD. In addition, the November 2013 technical clarification of the paved road dust emissions does not affect the source

- specific emissions

16 CARB speciation profiles can be viewed or downloaded from the following CARB link: http://www.arb.ca.gov/ei/speciate/interopt01.htm

17 AP

- 42, Compilation of Air Pollutant Emission Factors

, is a document published by EPA as the primary collection of EPA approved emission factor information. The emission factors have been developed and compiled from source test data, material balance studies, and engineering estimates. EPA has publishe d suppl ements and updates to the chapters in Volume I, Stationary Point and Area Sources at the following web site: http://www.epa.gov/ttnchie1/ap42/

. 18 See 2012 Los Angeles County Lead SIP, as adopted by the SCAQMD on May 4, 2012 and submitted to EPA on June 20, 2012.

19 See 76 FR 6328, February 4, 2011, in the docket for today’s action.

20 See Letter from Elaine Chang, Deputy Executive Officer, SCAQMD to Deborah Jordan, Director Air Division, EPA, Region 9, and accompanying technical analysis (“Technical Clarifica tion of Lead Paved Road Dust Emissions for the 2012 Lead SIP for the South Coast Air Basin”), dated November 8, 2013.17

inventories at the Exide and Quemetco facilities, and therefore, does not impac t the attainment strategy in the 2012 Los Angeles County Lead SIP.

On

- Road and Off

- Road Mobile Sources

The 2010 on

- road emissions were calculated using the CARB EMFAC2007 V2.3 emission factor model 21 and transportation activity data provided by the Southern California Association of Governments (SCAG) from their modified 2004 Regional Transportation Plan (2004 RTP) as used in the 2007 AQMP. 22 The 2010 area source and off

- road emissions are also calculated based on 2007 AQMP inventories and projections. These emissions were developed primarily based on estimated activity levels and emission factors.

The future projections rely upon the 2004 RTP, and the planning assumptions and the best available informati on from CARB’s EMFAC model for the on

- road mobile source emissions inventory, CARB’s off

- road model for the off

- road mobile source emission inventory, the latest point source inventories, emission limits in adopted rules, air quality modeling analysis, and SCAG’s growth forecast assumptions utilized in the 2007 AQMP. It should be noted that the draft 2012 RTP forecasts and EMFAC2011 are not used in this analysis since they were not finalized at the time Draft Lead SIP was developed , and the 2004 RTP and EMFAC2007 represent more conservative estimates.

Piston Engine Aircraft Emissions

Table II.B. 3 is the lead emission inventory in the 2012 Los Angeles County Lead SIP for piston

- e ngine aircraft operating at airports, airfields, or airparks in the Los An geles County
nonattainment area

. The aircraft lead emissions for 2010 were developed using historical airport specific operations data reported for 2008 and forecast operations data for 2010 and 2015 in the Terminal Area Forecast (TAF) system in the Federa l Aviation Administration (FAA database) when available. 23 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, and scaling it to 2010 and 2015 using TAF forecast data. 24 The 2008 NEI utilizes Appendix B of the updated Technical Support Document (TSD) titled “'Calculating Piston

- Engine Aircraft Airport

21 EMFAC ( EM ission FAC tor) is California’s model for estimating emissions from on

- road vehicles operating in California. EPA approved EMFA C2007 for use in SIPs and conformity purposes on January 18, 2008 (73 FR 3464). CARB’s latest release is EMFAC 2011

, which EPA approved on March 6, 2013 (78 FR 14533) . EMFAC2011 was not approved for use in SIPs and conformity when the 2012 Los Angeles Coun ty Lead SIP was developed.

22 South Coast Air Quality Management District, “Final 2007 Air Quality Management Plan,” Chapter 3 and Appendix III, June 2007.

23 From FAA’s website, “Terminal Area Forecast”, available at: http://aspm.faa.gov/main/taf.asp.

24 Environmental Protection Agency, “2008 National Emissions Inventory, Version 1,” (http://www.epa.gov/ttn/chief/net/2008inventory.html), January 27, 2011.18

Inventories for Lead for the 2008 National Emissions Inventory”. 25 The methodology employed here uses the January 15, 2009 version of the Federal Aviation Administration 5010 airport data report. 26

Federal regulations require monitoring at airports that are estimated to emit 1.0 or more tons per year based on either the most recent NEI or other scientifically justifiable methods and data (such as improved emissions factors or site

- specific data). Based on an earlier version of the EPA’s 2008 NEI inventory that is not reflected in Table II.B. 3, Van Nuys Airport (VNY) exceeded this threshold and, based on that inventory, AQMD established a monitor near this source. Although a subsequent revision to the NEI, reflected in Table II.B.3

, showed less than one t py of lead emit ted from VNY, SC AQMD states in its July 2013 Annual Air Quality Monitoring Network Plan that it continues to monitor at that location to demonstrate compliance with the NAAQS

. 27 As also shown in Table II.B.3, the revised 2008 NEI calculates more than one to n per year of lead emissions from Long Beach/Daugherty Field. However,

more recent inventories for Long Beach/Daugherty Field (as shown in Table II.B.3) indicate that
emissions are currently less than 1.0 tpy and are expected to remain less than 1.0 tpy in future

years. As such, EPA’s regulations do not require lead monitoring at Long Beach/Daugherty Field.

Table II.B.3. Piston

- Engine Aircraft Emissions in Los Angeles County

Facility Identifier Facility Name Tons per year

2008 2010 2015

VNY Van Nuys 0.77 0.89 0.86

LGB Long Beach / Daugherty Field 1.03 0.76 0.81

POC Brackett Field 0.33 0.32 0.30

TOA Torrance / Zamperini Field 0.58 0.30 0.30

SMO Santa Monica Muni 0.33 0.29 0.29

EMT El Monte 0.24 0.25 0.24

WHP Whiteman 0.201 0.238 0.245 0.20 0.24 0.25

CPM Compton / Woodley 0.17 0.18 0.18

HHR Hawthorne / Jack Northrop Field 0.16 0.16 0.16

WJF General Wm J Fox Airfield 0.16 0.16 0.15

LAX Los Angeles International 0.11 0.14 0.16

BUR Burbank

- Glendale

- Pasadena Airport 0.12 0.13 0.13

AVX Catalina 0.06 0.06 0.06

PMD Palmdale Prodn Flt/Test 0.03 0.03 0.03

L11 Pebbly Beach 0.01 0.01 0.01

25 Environmental Protection Agency, “Documentation for Aircraft Component of the National Emissions Inv entory Methodology,” January 27, 2011

. 26 From FAA’s website, available at: http://www.faa.gov/airports/airport_safety/airportdata_5010/

27 2013 South Coast AQMD Annual Air Quality Monitoring Network Plan, pg 11.19 L70 Agua Dulce Airpark 0.01 0.01 0.01

0CL6 Bohunk's Airpark 0.01 0.01 0.01

1CL1 Little Buttes Antique Airfield 0.01 0.01 0.01

CL46 Quail Lake Sky Park 0.01 0.01 0.01

64CL Goodyear Blimp Base 0.01 0.01 0.01

8CL0 Nichols Farms 0.01 0.01 0.01

46CN Crystal < 0.0 1 < 0.0 1 < 0.0 1
Total s 4.3 4.0 4.0

Source: 2012 Los Angeles County Lead SIP, Table 3

- 3.
NOTES: For Catalina and all facilities in table with emissions less than 0.01 tpy, the following applies: 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)

Totals may not equal cumulative facility values due to rounding conventions.

C. Reasonably Available Control Measures (RACM)/Reasonably Available Control Technology (RACT) Demonstration and Adopted Control Strategy

1. Requirements for RACM/RACT Demonstrations

CAA section 172(c)(1) requires that each attainment plan “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

te chnology), and shall provide for attainment of the national primary ambient air quality standards.” EPA defines RACM as measures that a State finds are both reasonably available and contribute to attainment as expeditiously as practicable in its
nonattainm ent area. Lead nonattainment plans must contain RACM (including RACT) that address sources of ambient lead concentrations. The EPA’s historic definition of RACT is the lowest emissions limitation that a particular source is capable of meeting by the applic ation of control technology that is reasonably available considering technological and economic feasibility. 28 EPA recommends that, at a minimum, all stationary sources emitting 0.5 tpy or more should undergo a RACT review. See 73 FR 67038. Based on annual emissions reporting for 2010, no point sources in the Los Angeles nonattainment area emit over 0.5 tpy of lea d.

2. RACM/RACT Demonstration in the 2012 Los Angeles County Lead SIP

CARB and the District have rulemaking processes for development, adoption and implementation of RACM/RACT that have been in place for decades.

28 See for example, 44 FR 53762 (September 17, 1979) and footnote 3 of that notice.20 Because of lead’s dispersion characteristi cs (e.g., lack of transport over a large geographic area) , the highest ambient concentrations of lead are expected to be near lead sources (e.g., Exide and Quemetco). The 2008 lead NAAQS is unlike the typical
PM 2.5 or ozone situation in that attainment mus t be demonstrated at source

- oriented monitors, and thus th e RACM/RACT demonstration addresses specific facilities that may cause NAAQS exceedances. Thus, the RACM/RACT analysis for the 2012 Los Angeles County Lead SIP does not involve or require a typical RACM evaluation as is done for other criteria pollutants (e.g., ozone or fine particulate matter) , which involves looking at a broader set of source categories.

Based on lead monitoring data, SCAQMD identified two large lead

- acid battery recycling facili ties (i.e., Exide and Quemetco) as the only sources of lead in the Los Angeles nonattainment area that have the potential to cause exceedances of the 2008 lead NAAQS. 29 The overall control strategy in the Los Angeles County Lead SIP relies on Rule 1420.1

– Emissions Standard for Lead f rom Large Lead

- Acid Battery Recycling Facilities, adopted by SCAQMD in November 2010. Thus

, EPA’s evaluation of RACM/RACT relies on an evaluation of Rule 1420.1. SCAQMD’s RACM/RACT evaluation is found in Section 6, pages 17

- 21 of the 2012 Los Angeles County Lead SIP. A discussion of the Rule 1420.1 is provided below.

Control measure

On January 25, 2013, EPA approved SCAQMD Rule 1420.1 into the California SIP. See 78 FR 5305. Rule 1420.1 establishes facility

- wide and individual point source maximum allowable emission rates, and requires secondary lead control devices on dryers. Fugitive lead emissions are addressed through housekeeping and maintenance activity requirements, and total enclosures, vented to control devices, of all areas where lead is being processed and where maintenance activities are occurring. The rule also sets ambient standards for airborne lead concentrations at monitors around the facility, and requires more facility

- operated monitors (a minimum of four) that collect samples

on a once every

- three

- days schedule. Additional monitoring , source testing, recordkeeping, and reporting requirements are included to ensure continuous compliance. The rule also requires the submittal of a new compliance plan and emission reduction feasibility study when a source’s monitoring indicates ambient levels over a 30

- day rolling average have reached 0.12 micrograms per meter cubed ( μg/m 3 ) , which is 80% of the rule limit.

EPA describes RACM/RACT nat ionally for secondary lead smelters in a document published in March 2012. 30 Rule 1420.1 includes extensive and comprehensive provisions for the control of lead point source and fugitive emissions and contains all

29 As previously stated, EPA recommends that, at a minimum, all stationary sources emitting 0.5 tpy (1000 pounds) or more should undergo a RACT review (See 73 FR 67038). Based on annual emissions reporting for 2010, no point sources in the Los Angeles Lead nonattainment area emit over 0.5 tpy of Lead.

30 Implementation of the 2008 Lead National Ambient Air Quality Standards, Guide to Developing Reasonably Available Control Measures (RACM) for Controlling Lead Emissions, EPA

- 457/R

- 12

- 001. March 2012.21

the necessary RACM/RACT elements described in EPA guidance. A summary of these minimum elements and how they are addressed in Rule 1420.1 is provided in the Technical Support Document (TSD) for EPA’s approval of Rule 1420.1. 31

EPA also published the final residual risk and technology review revisio ns to the National Emission Standard for Hazardous Air Pollutants from Secondary Lead Smelting on January 5, 2012 (NESHAP from Secondary Lead Smelting ). See 77 FR 556. The revised NESHAP requirements represent maximum achievable control technology (MACT) u nder CAA Section 112. MACT requirements apply nationwide, regardless of whether an area attains the lead NAAQS. EPA considered the MACT requirements as part of our evaluat ion of RACM/RACT. A summary of the MACT requirements and how they are addressed by Ru le 1420.1 is also in the TSD for EPA’s approval of Rule 1420.1.

In its January 25, 2013 approval of Rule 1420.1, EPA determined that, based on comparison of Rule 1420.1 to the national RACM guidance and MACT, and additional analysis provided in SCAQMD’s s taff report, 32 that Rule 1420.1 adequately fulfills CAA RACM/RACT requirements.

The following provides a detailed description of Rule 1420.1 requirements.

 Ambient Air Lead Concentrations: Facilities 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. The averaging time is shorter than that of the lead NAAQS (rolling three

- month average of monthly averages) with a more frequent sampling requirement of one sample in three days versus the NAAQS which requires one sample in six days.

 Ambient Air Monitoring and Sampling Requirements: Each facility is required to collect and analyze ambient air lead samples to determine compliance with the

am bient air quality lead concentration standard of Rule 1420.1. The rule requires a minimum of four monitors at facility locations approved by SC AQMD. Federal regulations require a minimum of one source

- oriented monitor at each facility emitting more than 0.5 tons of lead per year. Facilities are required to collect samples at least once every three days, more frequent than the federal requirement of once every six days. 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 violation of the rule and be required to increase ambient air monitoring and sampling to a daily frequency. Daily monitoring and sampling will be required to be condu cted for a period of at least 60 consecutive days at each sampling site that measured an exceedance until no 30

- day rolling average exceedances are recorded. Sampling sites at the property line may be located just inside the fence line on facility

31 TSD for EPA’s Proposed Rulemaking for the California S IP, SCAQMD Rule 1420.1, Emissions Standard for Lead from Large Lead

- acid Battery Recycling Facilities. June 2012. The TSD is included in the docket for today’s action.

32 Staff Report, Proposed Rule 1420.1

– Emissions Standard for Lead from Large Lead

- Acid Battery Recycling Facilities, November, 2010.22

property if logistical constraints preclude placement outside the fence line. As a result, monitors required under Rule 1420.1 will be located closer to fugitive lead sources, in most cases, when compared to monitors required by federal monitoring requirements whi ch must be in publicly accessible areas. Along with the shorter averaging time described previously, all of the ambient air monitoring and sampling requirements of Rule 1420.1 are more stringent than the federal requirements, such that potential rule viola tions will likely occur before exceedances of the lead NAAQS.

 Total Enclosures: All areas used in the lead

- acid battery recycling operation for processing or storage of lead

- containing material, and all areas where maintenance is being performed, are requ ired to install total enclosures vented to a lead control device. 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. Rul e 1420.1 also establishes requirements for monitoring and maintaining negative pressure and in

- draft velocity at the openings of these enclosed areas.

 Lead Point Source Emission Controls: All lead emissions from lead point sources are required to be vente d to an emissions collection system that ducts the entire gas stream to a lead control device. The total facility mass lead emission rate for all lead point sources shall not exceed 0.045 pounds of lead per hour ( lbs/hr ) , with a maximum emission rate for a ny single lead point source not to exceed 0.010 lbs/hr

. The maximum emission rates of 0.045 and 0.010 lb/hr were established to adequately provide a protective limit for exposure to lead emissions and achieve the ambient standard of 0.15 μg/m 3

.

 Housekeepin g Requirements: 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 str uctural integrity inspections; storage and transport of lead

containing materials; onsite mobile vacuum sweeping; and surface impoundment pond or reservoir cleanings.

 Annual Source Testing: Annual source tests are required for all lead control devices to demonstrate compliance with the facility total lead mass emission rate standard of 0.045 lb/hr, and the maximum individual stack lead emission rate standard of 0.01 lb/hr. If the most recent source test for a lead point source demonstrates emissions of 0.0025 lb/hr or less, the facility may alternatively elect to conduct the next source test for that device within 24 months.

 Recordkeeping and Reporting Requirements : Requires recordkeeping and reporting, including public notifications, for specific maintenance activity, turnarounds and shutdowns for all lead

- containing materials processed at the facility. Records for all housekeeping, maintenance activity, ambient air lead monitoring, lead contr ol device inspection and maintenance, and unplanned shutdowns of any smelting furnaces23

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

m onthly basis. Also requires notifications of planned and unplanned shutdowns, and turnarounds.

 Compliance Plan : As an additional safeguard against the facilities exceeding the lead NAAQS or Rule 1420.1 limits, the requirement to prepare and submit a compli ance plan is triggered if the facility exceeds 0.12 μg/m 3 as measured on a 30

- day rolling average. The compliance plan must be implemented if the facility’s lead emissions contribute to an exceedance of the Rule 1420.1 ambient lead standard of 0.15 μg/m 3

a s measured on a 30

- day rolling average. The compliance plan provision is intended to ensure that measures can be identified prior to exceedances of the 0.15 μg/m 3 NAAQS (which is measured on a 90

- day rolling average) and are ready for fast implementation i f the NAAQS is exceeded.

On January 27, 2012, SCAQMD approved a Compliance Plan for Exide. The approved Compliance Plan requires Exide to implement various measures and install various controls to reduce lead emissions. Condition 8 of the Compliance Plan states that if, after March 31, 2012, monitored ambient lead concentrations exceed 0.15 μg/m 3 , Exide must submit to SCAQMD for approval, within 15 days of any such occurrence, the mitigation measures it will implement. Such mitigation measures may in clude installation of second stage high efficient particulate air (HEPA) filters at specified locations.

Expeditious Implementation of RACM/RACT

E xpeditious implementation of RACM/RACT at affected sources within the nonattainment area is an appropriate a pproach to assure attainment of the lead NAAQS in an expeditious manner. 33 South Coast Rule 1420.1 establishes various deadlines for affected

sources

. Specifically

, South Coast Rule 1420.1 requires affected source s to : (1) s ubmit a complete permit applicati on for all construction and necessary equipment within 30 days of November 5, 2010; (2) complete all construction within 180 days of receiving permit to construct approvals from the District, or by July 1, 2011, whichever wa s earlier; and (3) install, main tain, and operate total enclosures and lead point source emission control devices) by July 1, 2011

. In addition, Rule 1420.1 requires expeditious installation of additional controls in the event monitored ambient lead concentrations exceed 0.15 ug/m 3

on a rolling 30

- day average. T he measures and schedule in Rule 1420.1 are both reasonably available and contribute to attainment as expeditiously as practicable in the Los Angeles County lead nonattainment area.

Comparison of Rule 1420.1 R equirements with EPA Guidance for Lead RACM

EPA has determined Rule 1420.1 contains all RACM/RACT elements described as necessary in applicable EPA guidance (i.e., Implementation of the 2008 NAAQS Guide to

33 See Lead NAAQS Rule, 73 FR 66964 (November 12, 2008) at 67038

- 67039.24

Developing RACM for Controlling Lead Emissions (EPA

- 457/R

- 12

- 001). A summary of these minimum elements and how they are fulfilled in Rule 1420.1 is provided below:

 RACM includes fabric filters controlling lead process emissions from stacks. By requiring 99.97% capture efficiency for 0.3 micron particles for the filter m edia in subsections (f)(4) and (i)(1)(B), and by requiring that filter bags be of polytetrafluoroethylene membrane type in subsection (f)(5), Rule 1420.1 essentially requires the replacement of old fabric filters.

 RACM also includes negative pressure total enclosures and partial enclosures with wet suppression for process units and storage areas to capture fugitive process emissions. Rule 1420.1(e) requires total enclosures for battery breaking areas, storage areas , dryer areas, melting furnace areas, agglomerating furnace areas and refining and casting areas. Section (e) also requires that total enclosures be maintained at a negative pressure of a minimum 0.02 mm Hg (0.11 inches H 2 O). Each total enclosure must be v ented to an emission collection system that ducts the entire stream to a lead control device that meets the requirements in subsection (f) for filters and baghouses. Wet suppression is recommended for maintenance in an enclosure under negative pressure in areas where fugitive lead dust generation is a potential, “barring safety issues” in subsection (i)(1)(B).

 RACM includes paving or chemical stabilization of unpaved roads, and vacuuming paved roads for fugitive dust sources. Rule 1420.1(h), Housekeeping Requirements, requires paving and cleaning of surfaces subject to vehicular traffic, cleaning of rooftop structures, monthly inspections of enclosures and other structures that contain fugitive dust and storage methods for fugitive dust.

The following are also considered RACM/RACT in EPA’s March 2012 guidance:

 Fabric filters with downstream add

- on control devices, such as HEPA filters, to control uncontrolled lead process emissions from stacks. Rule 1420.1(f)(3) specifically requires a secondary lead cont rol device on dryer emissions. In addition, Rule 1420.1(g)(2)(A)(iv) provides that compliance plans may include the installation of multi

- stage lead control devices as an additional emission reduction measures for the compliance plan.

 Replacement of old fabric filters. The requirements of Sections 1420.1(f)(4) and (5) will result in the replacement of any filter bags that do not meet those standards.

 Cleaning of vehicles and building exteriors. Requirements in Rule 1420.1(h) include regular cleaning of rooftops, lead

- containing waste storage or recovery areas, and requirements in section (i)(2) include general cleaning of lead

- contaminated equipment and materials used for any maintenance activity.25

Adopted Control Strategies

As described above, the pr imary control strategy in the 2012 Lead SIP relies on emission reductions achieved through the implementation of SCAQMD Rule 1420.1

– Emissions Standard for Lead from Large Lead

- Acid Battery Recycling Facilities. Full implementation of Rule 1420.1 began on January 1, 2012, and EPA approved the rule into the SIP on January 25, 2013. See 78 FR 5305.

3. Proposed Actions on RACM/RACT Demonstration and Adopted Control Strategy

We propose to find that there are, at this time, no additional RACM that individually or collectively would advance attainment of the lead NAAQS by one year or more in the Los Angeles lead nonattainment area. We also propose to find that the RACM/RACT measure (i.e., Rule 1420.1) is both reasonably available and contributes to attainment as expeditiously as practicable in Los Angeles County lead nonattainment area. This proposal is based on our review of 2012 Los Angeles County Lead SIP, the sources contributing to nonattainment of the lead NAAQS, the District's adopted control strategy, and EPA guidance. Therefore, we propose to find that the 2012 Los Angeles County Lead SIP provides for the implementation of RACM/RACT as required by CAA section 172(c)(1).

D. Attainment Demonstration and Modeling

Modeling is used to show that a nonattainment area will be in attainment of the lead NAAQS by the attainment date as a result of the control strategy in the plan

. Section 192(a) establishes the attainment date for lead nonattainment areas "as expeditiously as practicable" but no later than five years from the date of the nonattainment designation for the area

, thus the applicable attainment date for the Los Angeles County lead nonattainment area is no later than December 31, 2015. The lead standard is attained when an area’s maximum ar ithmetic 3

- month mean concentration for a 3

- year period is less than or equal to 0.15 micrograms per cubic meter (μg/m 3 ).
The two large lead

- acid battery recycling facilities in Los Angeles County (Exide and Quemetco) were modeled to predict the monthly lead concentration for the attainment year
2015. T hese are the only two lead sources in the Los Angeles County with the potential to cause exceedances of the lead NAAQS

. 34 M odeling is used to show the effectiveness of control measures on the sources. 35 The state first determined current lead emission levels at each of the facilities. The state then projected the emission levels in 2015 by calculating the reductions in emissions resulting from the control strategy and accounting for growth . The 2015 emi ssion levels were then modeled to determine the resulting air quality concentrations from each of the facilities. The model ed impact was added to a background concentration level of lead, and compared to the standard to demonstrate that the area will attai n the standard in 2015.

34 2012 Los Angeles County Lead SIP, p 5

- 1.

35 ”Lead Q&A, July 8, 2011, p. 7.26

EPA evaluated the State’s air quality model selection and model inputs, such as meteorological data and emission data, to determine if the model application met EPA’s regulations and guidance, listed below:
EPA Regulations and Guid ance

 Memorandum from Scott Mathias, Interim Director, Air Quality Policy Division, USEPA Office of Air Quality Planning and Standards, to Regional Air Division Directors, Regions I

X, “2008 Lead (Pb) National Ambient Air Quality Standards (NAAQS) Implement ation Questions and Answers

, ” July 8, 2011, and http://www.epa.gov/airquality/lead/pdfs/20110708QAguidance.pdf

 Addendum to the July 11, 2011 Memorandum from Scott Mathias, Interim Director, Air Quality Policy Division, USEPA Office of Air Quality Plannin g and Standards, to Regional Air Division Directors, Regions I

- X, “2008 Lead (Pb) National Ambient Air Quality Standards (NAAQS) Implementation Questions and Answers

, ” August 10, 2012, and http://www.epa.gov/airquality/lead/pdfs/20120810qanda.pdf

 Guideline on Air Quality Models : http://www.epa.gov/scram00 1/guidance/guide/appw_05.pdf

In evaluating the State’s attainment demonstration, EPA reviewed the following documents:
2012 Los Angeles County Lead SIP

 South Coast Air Quality Management District , Final 2012 Lead State Implementation Plan, Los Angeles County, May , 2012, Chapter 5

– Future Ambient Lead Concentrations, Appendix III

– Modeling And Attainment Demonstration, and

 California Environmental Protection Agency, Air Resources Board, Staff Re port, Proposed State Implementation Plan Revision for the Federal Lead Standard, Release Date May 11,
2012.

1. Model Selection

EPA Regulations and Guidance

The Guideline on Air Quality Models provides guidance on modeling for lead as well as refined analytical techniques for modeling

. 5.2.5 Models for Lead

a. For major lead point sources, such as smelters, which contribute fugitive emissions and for which deposition is important, professional judgment should be used, and there should be coordination with the appropriate reviewing authority (paragraph 3.0(b)). To model an entire major urban area or to model areas without significant sources of lead emissions, as a minimum a proportional (rollback) model may be used for air quality analysis. The rollbac k philosophy27

assumes that measured pollutant concentrations are proportional to emissions. However, urban or other dispersion models are encouraged in these circumstances where the use of such models is feasible.
4.2.2 Refined Analytical Techniques

a. A brief description of each preferred model for refined applications is found in Appendix A. Also listed in that appendix are availability, the model input requirements, the standard options that should be selected when running the program, and output option s. b. For a wide range of regulatory applications in all types of terrain, the recommended model is AERMOD. This recommendation is based on extensive developmental and performance evaluation (Section A.1; subsection n). Differentiation of simple versus co mplex terrain is unnecessary with AERMOD. In complex terrain, AERMOD employs the well

- known dividing

streamline concept in a simplified simulation of the effects of plume

- terrain interactions.
c. If aerodynamic building downwash is important for the model ing analysis, e.g. , paragraph 6.2.2(b), then the recommended model is AERMOD. The state

- of

- the

- science for modeling atmospheric deposition is evolving and the best techniques are currently being assessed and their results are being compared with observatio ns. Consequently, while deposition treatment is available in AERMOD, the approach taken for any purpose should be coordinated with the appropriate reviewing authority.
2012 Los Angeles County Lead SIP

AERMOD MODELING SYSTEM 36

The American Meteorological Society/Environmental Protection Agency Regulatory Model Improvement Committee (AERMIC) was formed to introduce state

- of

- the

- art modeling concepts into the EPA's air quality models. Through AERMIC, a modeling system, AERMOD, was introduced that incorporate d air dispersion based on planetary boundary layer turbulence structure and scaling concepts, including treatment of both surface and elevated sources, and both simple and complex terrain. As of December 9, 2006, the EPA promulgated the AERMOD modeling sys tem as a replacement for the Industrial Source Complex (ISC) Model as the recommended dispersion model for regulatory applications, including attainment demonstration modeling. The AERMOD modeling system consists of the follow ing components which were us ed: 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 (U SGS) Digital Elevation Data; AERSURFACE, a surface characteristics preprocessor; and BPIPPRIME, a multi

- building dimensions program incorporating the good engineering practice technical procedures for downwash applications.

Dispersion modeling for each fa cility was performed using AERMOD (version 12060) to determine the monthly lead concentrations for the attainment year 2015. All facility boundary

36 2012 Los Angeles County Lead SIP, p 5

- 1.28

information, source parameters, and building information were obtained from the most recently submitted healt h risk assessment (HRA) for each facility.

Both facilities are locate d in 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 th e Census Bureau) is input under the URBANOPT keyword and urban surface roughness length is unspecified. By not specifying the urban surface roughness length, AERMOD assumes the regulatory default value of one meter. The latest version of EPA’s recommended building downwash program, BPIPPRM, is used to identify structures causing building downwash effects and to provide the source specific and direction specific building downwash parameters required by AERMOD (i.e., BUILDHGT, BUILDWID, BUILDLEN, XBADJ, and
Y BADJ).

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.

Discussion
EPA finds that the state’s selection of AERMOD is appropriate, based on the Guideline

on Air Quality Models guidance on modeling for lead as well as refined analytical techniques for modeling

. EPA finds the lead sources modeled are appropriately identified as urban sources

, based on facilities are located in the densely populated areas of Los Angeles County.

2 . Model Input

- Receptor Spacing

EPA Regulations and Guidance

The 2008 Lead (Pb) National Ambient Air Quality Standards (NAAQS) Implementation Questions and Answer s, August 10, 2012 discussed proper receptor spacing as well as how to model ambient air.

Q: What is the proper receptor spacing in modeling? 37

A: The model receptor grid is unique to the particular situation and depends on the size of the modeling domain, the number of modeled sources, and the complexity of the terrain. Emphasis should be placed on resolution and location, not the total number of

re ceptors (Section 7.2.2 (U.S. EPA, 2005)). Receptors should be placed in areas that are considered ambient air (see ambient air discussion above) with respect to the source(s) being modeled and placed out to a distance such that all areas of violation can b e detected from the model output. Receptor placement should be of sufficient density to

37 Lead Q&A Addendum

, August 10, 2012

.29

provide resolution needed to detect significant gradients in the concentrations with receptors placed closer together near the source(s) to detect local gradients and p laced farther apart away from the source(s). In addition, the user should place receptors at key locations such as around facility fence lines (which define the ambient air boundary for a particular source) or monitor locations (for comparison to monitored concentrations for model evaluation purposes). The receptor network should cover the modeling domain. If modeling indicates elevated levels of lead (close to the level of the standard) near the edge of the receptor grid, consideration should be given to

e xpanding the grid or conducting an additional modeling run centered on the area of concern. As noted above, terrain complexity should also be considered when setting up the receptor grid.

Q: What is the best way to model ambient air? 38

A: Ambient air is considered to be the air in those areas where the public generally has
access. Non

- ambient air generally includes property owned or controlled by the source to which access by the public is prohibited by a fence or other effective physical barrier. Anoth er issue with ambient air in modeling is the situation of multiple facilities in an area. As noted above, facility property is not ambient relative to its own emissions but is ambient relative to other sources’ emissions. For example, there may be a situat ion with two sources, Source A and Source B. In this situation, the impacts of Source A on the air over Source A are not considered to be impacts on ambient air, but the impacts of Source A on the air over Source B are considered to be impacts on ambient a ir, and vice versa. This situation is discussed in the March 1985 memorandum “Applicability Determinations for Columbian Chemical Company.” 39

In modeling these situations, there are two ways to handle ambient air over multiple facilities:

1. Divide the model runs into several modeling domains: A) a receptor network that is outside the property lines for all facilities for which all sources are modeled, and B) separate receptor networks and model runs over each facility for which that facili ty’s emissions are not included. For this case, design values can be calculated for each receptor network using LEADPOST. LEADPOST results from all receptor networks can be concatenated together.

2. Create a receptor network that covers all ambient air a nd facilities. Include all emissions in the model runs and generate monthly POSTFILES by source group, with each source group representing a separate facility. After the model runs are finished, for receptors over a specific facility

, zero out the concentr ations from that facility

, leaving

38 Ibid, p.3.

39 This memorandum can be found in the docket for today’s action.30

the other facilities’ contributions as they are. The new concentration files can be input into LEADPOST to calculate design values for cumulative concentrations.

2012 Los Angeles County Lead SIP

A 50

- meter by 50

- meter receptor grid centered on the facility was used, as well as fence

- line receptors placed using 25

- meter intervals. Receptors within the facility’s property boundaries were removed. Receptor elevations and hill heights were assigned using AERMAP (Version
111 03). 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. 40

Discussion

EPA finds that the 50

- by 50 meter receptor grid placement is of sufficient density to provide resolution needed to detect significant gradients in the concentrations . EPA also finds that the 25 meter interval receptor is appropriate.

3. Model Input

- Meteorological data

EPA Regulations and Guidance

The Guideline on Air Quality Models provides recommendations on the use of meteorological data, discussed below:

8.3.1.2 Recommendations

a. Five years of representative meteorological data should be used when estimating

concentra tions with an air quality model. Consecutive years from the most recent, readily available 5

- year period are preferred. The meteorological data should be adequately representative , and may be site specific or from a nearby N ational W eather S ervice (NWS)

st ation. Where professional judgment indicates NWS

- collected ASOS (automated surface observing stations) data are inadequate (for cloud cover observations) , the most recent 5 years of NWS data that are observer

- based may be considered for use.

2012 Los Ange les County Lead SIP

A set of meteorological data were developed for AERMOD applications in the Basin by EnviroComp Consulting Inc. under contract to the SC 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, NWS and California Irrigation Management Information System (CIMIS). Among them, wind speed and direction

40 2012 Los Angeles County Lead SIP, p. 5

- 3.31

were taken from the SC AQMD network

, given the spatial coverage, locations, and sensor height of the measurements. Solar rad iation measurements from the CIMIS stations were primarily used due to its temporal completeness and spatial coverage, while SC AQMD radiation measurements were employed as supplementary data to fill in missing data in the CIMIS data. Fractional cloud coverage was available only from the NWS. As for temperature, all the data from the three networks

– 28 AQMD, 22 NWS, and 17 CIMIS stations

– were integrated into
SC 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. 41

AERSURFACE was use d to determine the surface albedo and surface roughness. A Bowen ratio of 1.0 was used, instead of the AERSURFACE output value. This was done because the National Land Cover Data (NLCD) 92 dataset does not include the recent land development projects that occurred within Southern California, which would result in a lower Bowen ratio. A ERMET (version 11059) was used to develop the necessary 5

- year meteorological data set 42 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 L os A ngeles air quality and meteorology monitoring station was used. However, only 4 years of meteorological data is available for this sta tion (2006 to 2009). For Quemetco, the La Habra monitoring station was used and all 5 years (2005 to 2009) of meteorological data is available.

Discussion

EPA finds that the five years of meteorological data (200 5 through 2009) from the La Habra
monitori ng station for the Quemetco modeling application is appropriate . For Exide, the 4 years available meteorological data from the Central LA monitoring station (2006 to 2009 ) were used appropriately and the use of four years rather than five is preferable to using data from another station because the Central LA monitoring station is the most representative site for the Exide facility

. 4. Model Input

– Emissions Data

EPA Regulations and Guidance

The Guideline on Air Quality Models and EPA memoranda provide guidance on the appropriate emissions inputs for modeling lead, including appropriate emissions rate, characterization of fugitive emissions, characterization of haul roads, and control capture efficiency.

Q. What is the appropriate emissions rate (peak seasonal, monthly, or annual rate) to use for the three

- month rolling average? 43

41 2012 Los Angeles County Lead SIP, p. 5

- 2.

42 Guideline on Air Quality Models, Section 8.3.1.2.

43 Lead Q&A, p.5.32

A. Modeling analyses should conform with EPA’s guidelines on air quality models contained in Appendix W to 40 CFR part 51. http://www.epa.gov/t tn/scram/guidance/guide/appw_05.pdf.

Modeling input data, including emission rates, are addressed in Section 8.0 of Appendix W. The averaging period for the 2008 l ead NAAQS is a rolling 3

- month average evaluated over a 3

- year period. Accordingly, emissions limits should be based on concentration estimates for this same period (3

- month average) as described in Section 10.2.3 of Appendix W. The emissions rate to input into AERMOD for attainment demonstrations is based on the maximum allowable or permit limit emissions, often 1

- hour limits. Table 8

- 1 of Appendix W (see below) gives the calculation methodology to use to calculate the emissions rate to input into AERMOD. The input emissions rate for a source subject to SIP limits is a product of the maximum allow able or permit limit emissions, operating level (actual or design capacity, whichever is greater, or federally enforceable permit condition) and operating factor. This same calculation is also used for nearby sources. For “other” sources, the operating lev el is the annual level when actually operating averaged over the most recent two years. For definitions of nearby and other sources, see Section 8.2.3 of Appendix W.

In certain cases, longer

- term average emission rates or emissions representative of actual operating schedules may be approved for use in modeling demonstrations and corresponding permit limitations. Consistent with Appendix W, where a source is willing to accept an enforceable limitation on operating schedule, emissions need only be modeled du ring allowable periods of operation. Longer

- term average emission limits (e.g., monthly average, 3

- month average, or 3

- month total) may be approved for qualifying emissions units. To be approvable, such limitations must be enforceable as a practical matter . We emphasize that approval of model input data and proposed emissions limits must be granted by the reviewing authority on a case

- by

- case basis, taking into account source and emissions unit

- specific factors. Modeled emission rates, including any propose d limitations on emissions or source operation, should be documented in the modeling protocol, and any associated permit application materials submitted to the reviewing agency for approval. 44

Q. How should fugitives be modeled in attainment demonstrations ? 45

A: Fugitives can be characterized as volume sources or area type sources (rectangular, circular, or polygon al ). If the exact locations of fugitive emissions are unknown or are widespread over a particular area, such that their emissions can be combined into one representative source, the fugitives may be modeled as some type of area source. However, if the locations are known, it may be better to model them as volume sources, unless the placement of receptors would mean that receptors would be within th e volume source exclusion zone (2.15 x Sigma Y + 1 meter). In those cases, smaller area sources may be used. Also, volume sources allow for meander under light wind conditions, whereas area sources do not. For details regarding source input parameters for volume or area type sources in AERMOD, see 3.3 of the AERMOD User’s Guide (U.S. EPA, 2004a; U.S. EPA. 201 2 a).

44 Lead Q&A, p. 6.

45 Lead Q&A Addendum, p.3.33

If the reviewing authority has adequate technical data (i.e., soil samples) and additional information to support the inclusion of re

- entrainment of lead from the soil, this can be simulated as an area of volume source type in the model.

Q. What is the level of capture efficiency that should be used in modeling of total enclosure emissions? 46

A: For modeling of secondary lead smelters, capture efficiency is needed for modeling of total enclosure emissions. At this time, 100% capture efficiency is not con sidered technically achievable in common practice. At this time, states that impose total enclosure controls in a manner consistent with the National Emission Standard for Hazardous Air Pollutan ts from Secondary Lead Smelting

, 77 FR 555 (which includes req uirements for enclosures and housekeeping), can assume a capture efficiency for total enclosures of no greater than 95%. A greater level of capture efficiency (up to 99%) may be demonstrated on a case

- by

- case basis taking into account site

- specific factors and additional design or housekeeping provisions that go beyond what is assumed in the NESHAP. States should consult with their respective Regions for consideration of case

- specific demonstrations claiming greater than 95% capture efficiency.

Q. How sho uld haul roads for lead facilities be modeled? 47

A: Useful information regarding the modeling of haul roads in and around lead facilities can be found in the Final Report of the Haul Roads Workgroup, available on EPA’s SCRAM website at Haul Road Workgroup Final Report Submission to EPA

- OAQPS, March 12, 2012. 48 The report details the efforts of the Haul Roads Workgroup, which was a collaborative effort between the EPA and state/local modelers. The workgroup has recommended a methodology for modeling haul road s (pages 4

- 6 of the report). These recommendations are:

 Model all haul roads as adjacent volume sources, unless ambient air receptors are in the volume source exclusion zone (2.15 x Sigma Y + 1 meter)

 Top of plume height set to 1.7 x the vehicle height

 Release height of volume source set to half the plume height

 Width of the plume should be vehicle width + 6 m for single

- lane roads or road width + 6 m for 2

- lane roads

 The initial Sigma Z should be set to plume height/2.15

 Initial Sigma Y should be se t to plume width/2.15

 Emission rate in grams/second

46 Lead Q&A Addendum, p.3

. 47 Lead Q&A Addendum, p.5

. 48 See http://www.epa.gov/scram001/reports/Haul_Road_Workgr oup

- Final_Report_Package

- 20120302.pdf

.34

2012 Los Angeles County Lead SIP

All facility boundary information, source parameters, and building information were obtained from the most recently submitted health risk assessment (HRA) for each facility , at the time the sources were modeled for the 2012 Lead SIP. All stacks were modeled as point sources while the fugitive emission sources were modeled as volume sources.

SOURCE CHARACTERIZATION 49

For Exide, there were a total of 10 point sources, one volume source representing the fugitive emissions from the raw materials processing, and the roadway fugitive emissions were modeled as line sources (i.e. separate volume sources along the roadway where trucks would travel). In 2012, in an effort to f urther reduce emissions, Exide constructed an enclos ure for their bag house row. As a result, the stacks

, which are located within the baghouse row

, had to be raised above the roof line. Therefore, in the modeling for 2015, the stack 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 wheel wash area where all trucks dealing with lead deliveries will be required to have their wheels washed prior to leaving the facility. As such, for the 2015 modeling, the roadways were modeled to reflect the addition of this truck wash and the opening of two other gates along the north and east property lines which allow for other deliveries that do not include l ead 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 a long 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 traffic 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 of the 2012 Los Angeles County Lead SIP

. 50

, 51

The source configuration is shown in Figure II.D.1 : Quemetco

– Location of Modeled Sources

– 2015 Emissions and Figure II.D. 2: Exide

– Location of Modeled Sources

– 2015 Emissions , below.

EMISSION RATES 52

Base Year Emissions

- 2010

49 2012 Los Angeles County Lead SIP, p. 5

- 2

. 50 Exide

– AERMOD Source Parameters for 2015 (Total Emissions

– Stack and Fugitive Emissions ), 2012 Los Angeles County Lead SIP, Appendix III, p.1

. 51 Quemetco

– AERMOD Source Parameters for 2015 (Total Emissions

– Stack and Fugitive Emissions), 20 12 Los Angeles County Lead SIP , Appendix III, p.2.

52 2012 Los Angeles County Lead SIP, p. 5

- 4

.35

STACK EMISSIONS : For 2015 modeling, the emission rates were calculated from the emissions limits specified in Rule 1420.1. As of January 1, 2012, large lead

- acid battery recycling facilities subject to Rule 1420.1 are not allowed to discharge into the atmosphere emissions which contribute to ambient air concentrations of lead that exceed 0.15 μg/m3 averaged over any 30 consecutive days. Rule 1420.1 requires annual source tests for all lead control devices in order to demonstrate compliance with the facility total point sour ce lead mass emission limit of 0.045 lb/hr, and the maximum individual stack lead emission rate standard of 0.01 lb/hr. Using the most recent source tests for each facility, the facility total emission limit of 0.045 lb/hr was distributed among the stacks based on the ratio of the measured emissions, ensuring that no individual stack exceeded the 0.01 lb/hr per stack limit.

FUGITIVE EMISSIONS: As stated in Chapter 3, fugitive lead emissions are believed to be a major source of lead to the atmosphere at thes e two facilities. However, estimating and modeling fugitive dust emissions accurately is challenging, given the uncertainties in magnitude, location, timing, and lead content of the dust. Therefore, the fugitive emissions estimated in the EPA document enti tled “Development of the RTR Emissions Dataset for the Secondary Lead Smelting Source Category”, were used in the modeling analysis. 53 In 2010, the adjusted fugitive lead emissions for Exide are 130.64 lbs/year compared to 82.52 lbs/yr as reported in the
SC AQMD’s AER program. Exide reported fugitive lead emissions from two sources: 13.49 lbs/year from the raw materials processing system (RMPS) and 69.03 lbs/year from roadway fugitives. Although these amounts were not used in the modeling, this relative ratio (16.35% from the raw materials processing and 83.65% from roadway fugitives) was used to apportion the total fugitive lead emissions listed in the EPA document.

For Quemetco, the fugitive emissions of 85 lbs/year contained in Table 5

- 2 of EPA’s document

w ere used. In the SC 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.

Future Year Emissions

- 2015

For the attainment year 2015 modeling,

 T he same lead fugitive emissions were applied to the raw materials pr ocessing and battery wrecker areas for Exide and Quemetco, respectively. No further reductions were applied since the EPA document had assumed that both of those areas were fully enclosed in their fugitive emissions calculations.

 As part of housekeeping r equirements 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 SC AQMD Rule 1186, or a vacuum equipped with filter(s) rated by the manufacturer to achieve 99.97% capture efficiency for 0.3 micron particles. The

53 From EPA’s website, available at http://www.regulations.gov/#!documentDetail;D=E PA

- HQ

- OAR

- 2011

- 0344

- 0163

.36

pick

- up efficiency, as identified in SC AQMD’s test protocol for Rule 1186

, specifies a pick

- up efficiency of 80% or greater for certified sweepers. An 80% reduction was applied to the roadwa y fugitive emissions for 2015 as a reasonable conservative estimate since the measure identified in Rule 1420.1 is already in place.

Figure II.D.1: Quemetco

– Location of Modeled Sources

– 2015 Emissions 54

The buildings are shown as bright blue polygons. The line sources (made u p of multiple volume sources) are
shown as a red line source. This configuration reflects the relocation of the main gate in order to move the

on

- site truck movement from areas where people are frequently walking, which oc cur red in 2012. The point sources are shown as red dots; t he volume source (battery wrecker fugitives) is shown as a dark blue square.

54 2012 Los Angeles County Lead SIP, Appendix III, p. 4

.37

Figure II.D. 2 : Exide

– Location of Modeled Sources

– 2015 Emissions 55

The buildings are shown as bright blue polygons; t his configuration includes the new baghouse row which was completed in March 2012. The line sources (made u p of multiple volume sources) are shown as a red
line source. This configuration reflects the addition of the truck wash area in the w estern portion of the
site which all trucks with lead associated materials will have to use prior to leaving the facility, and the addition of 2 gates. The point sources are shown as red dots; t he volume source (raw materials processing fugitives) is sho wn as a dark blue square.

55 2012 Los Angeles County Lead SIP, Appendix III, p. 3

.38

Discussion

EPA believes that the state appropriately characterized the fugitive sources as volume sources. EPA also believes that the haul roads for lead facilities were appropriately modeled as multiple volume sources. EPA agree s with the state that the 80% reduction applied to the roadway fugitive em issions for 2015 w as a reasonably conservative estimate since the measure identified in Rule 1420.1 is already in place.

5. Model Input

- Background Data

EPA Regulations and Guidance

The Addendum to the July 11, 2011 Memorandum from Scott Mathias, Interim Director, Air Quality Policy Division, USEPA Office of Air Quality Planning and Standards, to Regional Air Division Directors, Regions I

- X, “2008 Lead (Pb) National Ambient A ir Quality Standards (NAAQS) Implementation Questions and Answers

, ” August 10, 2012, states:

Q. How should model concentrations and background concentrations be properly accounted for in attainment demonstrations? 56

A: In order to properly account for cumulative effects, background concentrations should be added to modeled concentrations to calculate a design value. Background concentrations should reflect contributions from natural sources, nearby sources other than the one(s) being explicitly modeled

, and unidentified sources. Beginning with version 11103, AERMOD can now include background concentrations in the model simulation. AERMOD can accept a variety of temporally varying background concentrations, from hourly background to an annual concentration. See Section 2.4 of the AERMOD User’s Guide addendum (U.S. EPA, 2011a) for more details.

General guidance on background concentrations can be found in Section 8.2 of the Guideline on Air Quality Models (U.S. EPA, 200 5). For isolated single sources, the Guideline discusses two options for determining background concentrations. The first, discussed in Section 8.2.2.b

, is the use of air quality data collected in the vicinity of the source to determine the background conc entrations. Background concentrations are determined by excluding observations when the source being modeled is impacting the monitor. The guideline offers guidance that monitors inside a 90

- degree sector downwind of the source may be used to determine the area of impact. Meteorological data used in the source contribution analysis should be representative of the monitored area. Because observed values often represent a 24

- hour sample, it may be difficult to separate hours within a sample when modeled sourc es are impacting the monitor. In these cases, it may be necessary to exclude many 24

- hour values entirely, such that the remaining observations are no longer robustly representative. This may necessitate the use of the second option, as discussed in Sectio n 8.2.2.c. This option is to use a “regional site” when there are no monitors located in the vicinity of the source. As defined in

56 Lead Q&A Addendum, p. 2.39

the Guideline , a regional site is one that is located away from the area of interest but is impacted by similar natural and m an

- made sources.

2012 Los Angeles County Lead SIP

A background concentration of 0.01 μg/m 3 for lead obtained from the latest AQMD network monitoring data was modeled in AERMOD using the BACKGRND keyword. 57

Discussion

EPA finds that the background concentration of 0.01 μg/m 3 for lead

, obtained from the
SC AQMD ambient air monitoring network , and based on the monitored lead concentrations presented in the plan to be appropriate. 58

6. Model Results and Attainment Demonstration

2012 Los Ange les County Lead SIP

MODEL RESULTS BY FACILITY 59

To illustrate how Rule 1420.1 ambient monitoring requirements provide the assurance that fugitive emission s will not cause a NAAQS exceedance, modeling results for total emissions as well as stack

- only emissions are provided for both facilities.

EXIDE

Total Emissions

– Stack and Fugitive Emissions

By applying Rule 1420.1 emission limits for 2015 (emission rates for the stacks were apportioned based on the most recent source test for the facility), applying an 80% reduction to the roadway fugitives, and keeping the RMPS emissions the same, the modeled maximum 3

- month rolling average lead concentration is 0.135 μ g/m3. The results are given in Table II.D.1.

Stack Emissions Only

Using the Rule 1420.1 em ission 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 concentrat ion is 0.115 μ g/m3..

57 2012 Los Angeles County Lead SIP, p. 5

- 3.

58 2012 Los Angeles County Lead SIP, p. 2

- 4, 2

- 5.

59 2012 Los Angeles County Lead SIP, p. 5

- 5.40

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% reduc tion to the road way fugitives, and keeping the battery w recker emissions the same, the modeled maximum 3

- month rolling average lead concentration is 0.140

μ g/m3. The results are given in Table II.D.1.

Stack Emissions Only

Using the Rule 1420.1 emission lim its 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 0.0 83 μ g/m3. It is important to note that the 2015 modeled lead
concentrations are very conservative estimate s since they assume allowable limits set by Rule 1420.1, which are significantly higher than the current emissions at the facility.
No significant increases in actual emissions are expected beyond the modest growth factors used in the actual emission projection.

The model results take a number of relevant factors into consideration, including emissions, receptor proximity, and wind direction. The mod eled maximum 3

- month rolling average lead concentration from all emissions (stack and fugitive emissions combined) is 0.135 μg/m3 for the Exide facility, and 0.140 μg/m3 for Quemetco. The model results are shown in Table II.D.1

, 2008 Lead NAAQS Attainment Demonstration Modeling Results for Exide and Quemetco Lead

- Acid Battery Acid Recycling Facilities , below. The lead standard is attained when an area’s maximum arithmetic 3

- month mean concentration for a 3

- year period is less than or equal to 0.15 microgra ms per cubic meter (μg/m 3 ). The modeled ambient lead concentrations are below the standard for each of the facilities, demonstrating the area will attain the 2008 lead standard in
2015. Table II.D.1. 2008 Lead NAAQS Attainment Demonstration Modeling Results for Exide and

Quemetco Lead

- Acid Battery Acid Recycling Facilities 60

Facility Lead Concentration ( Maximum 3

- month Rolling Average) 61 for Stack and Fugitive Emissions

Exide 0.135 μg/m 3

Quemetco 0.140 μg/m 3

60 Final results listed in Table II.D.1 are rounded according to 40 CFR part 50, Appendix R

, specifically

, subsection 4(a) which addresses comparison with the Lead NAAQS, as well as 5(a), (b), and (c) which addresses rounding
conventions.

61 The maximum modeled 3

- month rolling average across all years of meteorological data (Exide 2006

– 2009, and Quemetco 2005

- 2009)

.41

The modeled lead concentration gradients are shown in the figures below. M odeling results for total emissions (stack and fugitive emission) as well as s tack only emissions are shown for each facility, below

. Figures II.D.3 and II.D.4, below, show the modeled impact from total emissions (both stack and fugitive) for the Exide and Quemetco f acilities

, respectively. Figures II.D.5 and II.D.6, below, show the modeled impact for stack emissions (only) for the Exide and Quemetco facilities, respectively. All areas are below the lead standard

.

Figure II.D.3 . Exide

– 2015 Lead Concentrations (ug/m3)

- Using Rule 1420.1 Emission Limits

(Total Emissions

– Stack and Fugitive Emissions) 62

62 2012 Los Angeles County Lead SIP , Appendix III, p. 5

.42

Figure II.D.4 . Exide

– 2015 Lead Concentrations (ug/m3) Using Rule 1420.1 Emission Limits (Stack Emissions Only) 63

63 2012 Los Angeles County Lead SIP, Appe ndix III, p. 7

.43

Figure II.D.5 . Quemetco

– 2015 Lead Concentrations (ug/m3) Using Rule 1420.1 Emission

Limits (Total Emissions

– Stack and Fugitive Emissions) 64

64 2012 Los Angeles County Lead SIP, Appendix III, p. 6

.44

Figure II.D.6 . Quemetco

– 2015 Lead Concentrations (ug/m3)

- Using Rule 1420.1 Emission Limits (Stack Emissions Only) 65

Discussion

The model results, shown in Table II.D.1, 2008 Lead NAAQS Attainment Demonstration Modeling Results for Exide and Quemetco Lead

- Acid Battery Acid Recycling Facilities , above, show the modeled ambient l ead concentrations are below the standard for each of the facilities is below the standard, demonstrating the area will attain the 2008 lead standard in 2015. The lead standard is attained when an area’s maximum arithmetic 3

- month mean concentration for
a 3

- y ear period is less than or equal to 0.15 micrograms per cubic meter (μg/m 3 ).

7 . Evaluation and Conclusion The air quality modeling documentation in Chapter 5 and Appendix III of the 2012 Los Angeles County Lead SIP contain all the elements required by EPA’s modeling guidance. The modeling is based on the best and mos t current information available at the time the plan was developed

. Based on our evaluation, discussed above, we propose to find that the modeling analysis used for the attainm ent demonstr ation of the 2008 lead NAAQS meets the CAA section 172(c)(1) requirement that the plan “shall provide for attainment of the national primary ambient air quality standards” and that the modeling in the provi des an adequate basis for the lead attainment demo nstration in the 2012 Los Angeles County Lead SIP.

65 2012 Los Angeles County Lead SIP , Appendix III, p. 8

.