_____________________________________________________________________________________

Draft Technical Support Document 

_____________________________________________________________________________________

Proposed Rulemaking Action on the 2012 Los Angeles County Lead SIP

November 2013

For questions 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 LeadNAAQS

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 Resultsfor 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 Emissions
3

Figure II.D.3. Exide – 2015 Lead Concentrations (ug/m3) - Using Rule 1420.1 Emission 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. THE LEAD 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 the 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 considered 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 leadcontaminated 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 

to 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/m3(quarterly average).1Based on 

new health and scientific data, EPA revised the federal lead standard to 0.15 ug/m3and 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. Designations 

for the 2008 lead NAAQS were promulgated effective December 31, 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.2Figure 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 NAAQS. 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 leadNAAQS. 

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

available control measures (RACM), and the measures must be implemented expeditiously and 

ensure attainment no later 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 nonattainment 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 November 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 from 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 applicable 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 sections 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 Quality 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

 Implementation 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 lead 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 measures. 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 

(μg/m3). 

In the South Coast lead nonattainment area, the SCAQMD is the agency responsible for 

assuring that the area meets air quality monitoring requirements including its submittal of

annual monitoring network plans to EPA. The SCAQMD 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 required 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 forlead 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 reviews

these annual plans for compliance with the applicable reporting requirements in 40 CFR part 

58. 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.5SCAQMD annually 

certifies that the data it submits to AQS are complete 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 2008-2013. 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 NAAQS of 0.15 μg/m3. Levels decreased considerably in 2008, and the 3-

month mean concentrations fell below 0.50 μg/m3starting in 2009. 2010 and 2011 show 

higher concentrations in spring and summer, with 2010’s maximum 3-month mean 

concentration being measured at 0.39 μg/m3in April-May-June, while 2011 saw higher 3-month 

mean concentrations and a maximum of 0.45 μg/m3in 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, South 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 Administrator, U.S. EPA Region 9, 

certifying calendar year 2012 ambient air quality data and quality assurance data for PM2.5, PM10, and Pb, May 1, 

2013.
9

from January 2012 through June 2013 are at or below the 0.15 μg/m3standard. 

An area attains the lead standard if it has three calendar years’ worth of 3-month site 

means that are less than or equal to 0.15 μg/m3. 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 Basin7

 

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, 2008-2013, South Coast Air Basin Lead 

Monitoring Data

Table I.D.1. 3-Month Mean Concentrations, 2008-2013, 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 demonstration.

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 172, 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 , 2012, 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 

inventory 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 Table 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-road 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 facilities --

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/m3, 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 2010 Lead Emissionsa (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 13.96
13

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 SCAQMD through the Annual Emissions 

Reporting Program (AER).9The 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 that reported lead emissions of at least one pound per year. In 2010, 

no facility reported lead emissions 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 SCAQMD 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 

facilities.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 RTR11 Emissions Dataset for the Secondary Lead Smelting Source 

Category", used for development of Secondary Lead Smelting National Emission Standard for 

Hazardous Air Pollutants, was used by SCAQMD 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.

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

Los Angeles County

Facility Name

2010 Lead 

Emissions 

(pounds/year)

EXIDE TECHNOLOGIES13 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

TROJAN 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 From 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=EPAHQOAR-2011-0344-0163). The lead fugitive emissions for each facility were calculated as follows:

Fugitive lead emissions (Lbs/Yr) = (0.71 tons/yr * size factor * enclosure factor * Housekeeping factor) * 2000

Exide fugitive emissions = (0.71 * 1.84 * 0.25 * 0.2) * 2000 = 130 lbs/yr

Quemetco fugitive emissions = (0.71 * 1.19 * 0.25 * 0.2) * 2000 = 85 lbs/yr

14 Ibid.
15

Facility Name

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” and 0.0124 

percent for “Paved Road Dust.” The source of lead in the PM emissions from these source 

categories are likely from the historical lead content in materials, such as paint and gasoline. 

Although the total lead inventory is dominated by these sources, the lead from area sources is 

emitted over a wide geographical area and the ambient lead concentrations (illustrated in 

Chapter 2 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.htm
16

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.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.” 

The paved road dust lead emissions in the 2012 Los Angeles County Lead SIP were 

estimated using EPA’s 2006 AP-42 calculation, 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, the SCAQMD staff submitted a 

technical clarification 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 Vehicle Miles Traveled 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 2010 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 values (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 published supplements and updates to the 

chapters in Volume I, Stationary Point and Area Sources at the following web site:

http://www.epa.gov/ttnchie1/ap42/. 

18See 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 Clarification 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 impact 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 model21 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 information 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-engine aircraft operating at airports, airfields, or airparks in the Los Angeles 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 Federal 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 (EMission FACtor) is California’s model for estimating emissions from on-road vehicles operating in 

California. EPA approved EMFAC2007 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 County 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 tpy of lead emitted from VNY, SCAQMD 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 ton 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 Inventory

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 < 0.01 < 0.01 < 0.01

Totals 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 

technology), 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 

nonattainment 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 application 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 lead.

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 characteristics (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 

PM2.5 or ozone situation in that attainment must be demonstrated at source-oriented 

monitors, and thus the 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 facilities (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 from 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/m3), which is 

80% of the rule limit.

EPA describes RACM/RACT nationally 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 revisions 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) under 

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 

evaluation of RACM/RACT. A summary of the MACT requirements and how they are 

addressed by Rule 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 staff 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/m3averaged 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 

ambient air quality lead concentration standard of Rule 1420.1. The rule requires a 

minimum of four monitors at facility locations approved by SCAQMD. 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/m3

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 

conducted 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 SIP, 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 which must be in publicly accessible areas. Along with the shorter 

averaging time described previously, all of the ambient air monitoring and sampling 

requirements of Rule 1420.1 are more stringent than the federal requirements, such 

that potential rule violations 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 required 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. Rule 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 vented 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 any 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/m3.

 Housekeeping 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 structural integrity inspections; storage and transport of leadcontaining 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 control device 

inspection and maintenance, and unplanned shutdowns of any smelting furnaces 
23

must be maintained. Facilities are required to submit reports for monthly ambient air 

monitoring results for lead and wind data measured at each sampling location on a 

monthly basis. 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 compliance 

plan is triggered if the facility exceeds 0.12 μg/m3as 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/m3 

as 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/m3

NAAQS (which is measured on a 90-day rolling average) and are ready for fast 

implementation if 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/m3, Exide must submit to 

SCAQMD for approval, within 15 days of any such occurrence, the mitigation measures it will 

implement. Such mitigation measures may include installation of second stage high efficient 

particulate air (HEPA) filters at specified locations. 

Expeditious Implementation of RACM/RACT

Expeditious implementation of RACM/RACT at affected sources within the 

nonattainment area is an appropriate approach 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 sources to: (1) submit a 

complete permit application 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 was earlier; and (3) 

install, maintain, 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/m3

on a rolling 30-day average. The 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 Requirements 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 media 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 H2O). Each total enclosure must be vented 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 control 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 primary 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 arithmetic 3-

month mean concentration for a 3-year period is less than or equal to 0.15 micrograms per 

cubic meter (μg/m3). 

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. These are the only two lead sources in the Los Angeles County with the potential to 

cause exceedances of the lead NAAQS.

34

 Modeling 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 emission 

levels were then modeled to determine the resulting air quality concentrations from each of 

the facilities. The modeled impact was added to a background concentration level of lead, and 

compared to the standard to demonstrate that the area will attain 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 Guidance

 Memorandum from Scott Mathias, Interim Director, Air Quality Policy Division, USEPA 

Office of Air Quality Planning and Standards, to Regional Air Division Directors, Regions IX, “2008 Lead (Pb) National Ambient Air Quality Standards (NAAQS) Implementation 

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 Planning 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/scram001/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 Report, 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 rollback philosophy 
27

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 options. 

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 complex terrain is 

unnecessary with AERMOD. In complex terrain, AERMOD employs the well-known dividingstreamline concept in a simplified simulation of the effects of plume-terrain interactions. 

c. If aerodynamic building downwash is important for the modeling 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 observations. 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 SYSTEM36

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 incorporated air dispersion based on planetary boundary layer turbulence 

structure and scaling concepts, including treatment of both surface and elevated sources, and 

both simple and complex terrain. As of December 9, 2006, the EPA promulgated the AERMOD 

modeling system as a replacement for the Industrial Source Complex (ISC) Model as the 

recommended dispersion model for regulatory applications, including attainment 

demonstration modeling. The AERMOD modeling system consists of the following components 

which were used: AERMET, a meteorological data preprocessor that incorporates air dispersion 

based on planetary boundary layer turbulence structure and scaling concepts; AERMAP, a 

terrain data preprocessor that incorporates complex terrain using U.S. Geologic Survey (USGS) 

Digital Elevation Data; AERSURFACE, a surface characteristics preprocessor; and BPIPPRIME, a 

multi-building dimensions program incorporating the good engineering practice technical 

procedures for downwash applications.

Dispersion modeling for each facility was performed using AERMOD (version 12060) to 

determine the monthly lead concentrations for the attainment year 2015. All facility boundary 

 

36 2012 Los Angeles County Lead SIP, p 5-1.
28

information, source parameters, and building information were obtained from the most 

recently submitted health risk assessment (HRA) for each facility. 

Both facilities are located 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 the Census Bureau) is input under the URBANOPT keyword and 

urban surface roughness length is unspecified. By not specifying the urban surface roughness 

length, AERMOD assumes the regulatory default value of one meter. The latest version of EPA’s 

recommended building downwash program, BPIPPRM, is used to identify structures causing 

building downwash effects and to provide the source specific and direction specific building 

downwash parameters required by AERMOD (i.e., BUILDHGT, BUILDWID, BUILDLEN, XBADJ, and 

YBADJ).

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 Answers, 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 

receptors (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 be 

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 placed 

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 

expanding 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. 

Another 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 situation 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 air, 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 facility’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 and 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 concentrations from that facility, leaving 

 

38Ibid, 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 

11103). Terrain data, available from the United States Geological Survey (USGS), is used by 

AERMAP to produce terrain base elevations for each receptor and source and a hill height scale 

value for each receptor.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 

concentrations 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 National Weather Service (NWS)

station. 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 Angeles County Lead SIP

A set of meteorological data were developed for AERMOD applications in the Basin by 

EnviroComp Consulting Inc. under contract to the SCAQMD. 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 SCAQMD network, given the spatial coverage, locations, and sensor height 

of the measurements. Solar radiation measurements from the CIMIS stations were primarily 

used due to its temporal completeness and spatial coverage, while SCAQMD 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 

SCAQMD 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 used to determine the surface albedo and surface roughness. A Bowen ratio 

of 1.0 was used, instead of the AERSURFACE output value. This was done because the National 

Land Cover Data (NLCD) 92 dataset does not include the recent land development projects that 

occurred within Southern California, which would result in a lower Bowen ratio. AERMET 

(version 11059) was used to develop the necessary 5-year meteorological data set42 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 Los Angeles air quality and meteorology monitoring station was used. 

However, only 4 years of meteorological data is available for this station (2006 to 2009). For 

Quemetco, the La Habra monitoring station was used and all 5 years (2005 to 2009) of 

meteorological data is available. 

Discussion

EPA finds that the five years of meteorological data (2005 through 2009) from the La Habra 

monitoring 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/ttn/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 lead 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 allowable 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 level 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 during 

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 proposed 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 polygonal). 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 the 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. 2012a). 

 

44 Lead Q&A, p. 6.

45Lead 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 considered 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 Pollutants from 

Secondary Lead Smelting, 77 FR 555 (which includes requirements 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 should 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 roads (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 set 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_Workgroup-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 CHARACTERIZATION49

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 further reduce emissions, Exide constructed an enclosure for 

their baghouse 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 lead sources. 

For Quemetco, there were a total of 13 point sources, one volume source representing 

the fugitive emissions from the battery wrecking activities, and the roadway fugitive emissions 

were modeled as line sources (i.e. separate volume sources along the roadway where the 

trucks would travel). For Quemetco, different roadway configurations were used for the 2015 

modeling. This is based on information from the facility that the existing gate will be moved in 

order to move the on-site truck 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 RATES52

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), 2012 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 source lead mass emission limit of 0.045 

lb/hr, and the maximum individual stack lead emission rate standard of 0.01 lb/hr. Using the 

most recent source tests for each facility, the facility total emission limit of 0.045 lb/hr was 

distributed among the stacks based on the ratio of the measured emissions, ensuring that no 

individual stack exceeded the 0.01 lb/hr per stack limit.

FUGITIVE EMISSIONS: As stated in Chapter 3, fugitive lead emissions are believed to be a major 

source of lead to the atmosphere at these two facilities. However, estimating and modeling 

fugitive dust emissions accurately is challenging, given the uncertainties in magnitude, location, 

timing, and lead content of the dust. Therefore, the fugitive emissions estimated in the EPA 

document entitled “Development of the RTR Emissions Dataset for the Secondary Lead 

Smelting Source Category”, were used in the modeling analysis.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 

SCAQMD’s AER program. Exide reported fugitive lead emissions from two sources: 13.49 

lbs/year from the raw materials processing system (RMPS) and 69.03 lbs/year from roadway 

fugitives. Although these amounts were not used in the modeling, this relative ratio (16.35% 

from the raw materials processing and 83.65% from roadway fugitives) was used to apportion 

the total fugitive lead emissions listed in the EPA document.

For Quemetco, the fugitive emissions of 85 lbs/year contained in Table 5-2 of EPA’s document 

were used. In the SCAQMD’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, 

 The same lead fugitive emissions were applied to the raw materials processing and 

battery wrecker areas for Exide and Quemetco, respectively. No further reductions were 

applied since the EPA document had assumed that both of those areas were fully 

enclosed in their fugitive emissions calculations. 

 As part of housekeeping requirements identified in Rule 1420.1, each large lead battery 

recycling facility shall maintain and use an onsite mobile vacuum sweeper or vacuum 

that is in compliance with SCAQMD 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=EPA-HQ-OAR-2011-0344-

0163.
36

pick-up efficiency, as identified in SCAQMD’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 roadway 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 Emissions54

The buildings are shown as bright blue polygons. The line sources (made up 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 occurred in 2012. The point 

sources are shown as red dots; the 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 Emissions55

The buildings are shown as bright blue polygons; this configuration includes the new baghouse row which 

was completed in March 2012. The line sources (made up of multiple volume sources) are shown as a red 

line source. This configuration reflects the addition of the truck wash area in the western 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; the volume source (raw materials processing 

fugitives) is shown 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 agrees with the state that the 80% reduction applied to the 

roadway fugitive emissions for 2015 was 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 Air 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, 2005). 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 concentrations. 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 sources 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 Section 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 man-made sources. 

2012 Los Angeles County Lead SIP

A background concentration of 0.01 μg/m3for 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/m3for lead, obtained from the 

SCAQMD 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 Angeles County Lead SIP

MODEL RESULTS BY FACILITY59

To illustrate how Rule 1420.1 ambient monitoring requirements provide the assurance 

that fugitive emissions will not cause a NAAQS exceedance, modeling results for total emissions

as well as stack-only emissions are provided for both facilities.

EXIDE

Total Emissions – Stack and Fugitive Emissions

By applying Rule 1420.1 emission limits for 2015 (emission rates for the stacks were

apportioned based on the most recent source test for the facility), applying an 80% 

reduction to the roadway fugitives, and keeping the RMPS emissions the same, the 

modeled maximum 3-month rolling average lead concentration is 0.135 μg/m3. The 

results are given in Table II.D.1.

Stack Emissions Only

Using the Rule 1420.1 emission limits for 2015, the 0.045 lb/hr stack emission limit was

evenly distributed throughout the stacks, ensuring that no individual stack exceeded the 

0.01 lb/hr per stack limit in Rule 1420.1, the modeled maximum 3-month rolling average 

lead concentration is 0.115 μg/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% 

reduction to the roadway fugitives, and keeping the battery wrecker emissions the 

same, the modeled maximum 3-month rolling average lead concentration is 0.140 

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

Stack Emissions Only

Using the Rule 1420.1 emission limits for 2015, the 0.045 lb/hr stack emission limit was

evenly distributed throughout the stacks, ensuring that no individual stack exceeded the 

0.01 lb/hr per stack limit in Rule 1420.1, the modeled maximum 3-month rolling average 

lead concentration is 0.083 μg/m3. It is important to note that the 2015 modeled lead

concentrations are very conservative estimates 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 modeled 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 Resultsfor 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 

micrograms per cubic meter (μg/m3). 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 Resultsfor Exide and 

Quemetco Lead-Acid Battery Acid Recycling Facilities60

Facility Lead Concentration (Maximum 3-month Rolling Average)61 for 

Stack and Fugitive Emissions

Exide 

0.135 μg/m3

Quemetco 0.140 μg/m3

 

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. Modeling results for 

total emissions (stack and fugitive emission) as well as stack 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 facilities, 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

 

622012 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, Appendix 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 Resultsfor Exide and Quemetco Lead-Acid Battery Acid Recycling Facilities, above, 

show the modeled ambient lead 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-year period is less than or equal to 0.15 micrograms per cubic meter (μg/m3). 

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 most 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 attainment demonstration 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 provides an adequate basis for the 

lead attainment demonstration in the 2012 Los Angeles County Lead SIP.

 

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