From: Rick Leiby <rleiby@dekabatteries.com>

To: "'French.Chuck@epamail.epa.gov'" <French.Chuck@epamail.epa.gov>

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

<michael.burr@erg.com>, "'Topham.Nathan@epamail.epa.gov'" <Topham.Nathan@epamail.epa.gov>

Date: 2/11/2011 2:15 PM 

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

Attachments: comments on fugitive emission estimate.final.doc 

Dear Mr. French: 

Attached please find East Penn Mfg's comments regarding the estimate of fugitive emissions from its 

secondary lead smelter. 

We trust this meets with your request of February 7, 2011. 

If you have any questions regarding these comments please contact me directly. 

Sincerely, 

R. A. Leiby, Jr. 

Vice President, Metals Operations 

East Penn mfg. co., inc. 

610-682-6361
Page 1 of 4

EAST PENN manufacturing co., inc. 

Metals Division

P.O.BOX 147, DEKA ROAD ● LYON STATION, PA 19536-0147

PHONE: 610-682-6361 ● FAX 610-682-1038

EMAIL: RLeiby@DekaBatteries.com

February 11, 2011

Chuck French, Environmental Scientist

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

Sector Policies and Program Division

French.Chuck@epamail.epa.gov

Reference: Secondary Lead Smelters – RTR

Fugitive lead emissions and ICR responses

Received via Email Mon 2/7/2011 4:24 PM

Dear Sir:

Thank you for forwarding the information regarding the fugitive emissions calculations for 

the secondary lead smelter at East Penn’s Lyon Station manufacturing complex and the 

opportunity for East Penn Mfg to comment on those emission calculations and estimations. 

It is East Penn’s understanding that the EPA is attempting to relate emission data 

submitted as part of the ICR response with available ambient air monitoring data. Accounting for 

fugitive emissions from the smelter is important in the process of validating this approach. EPA 

has taken the approach that the 2009 TRI data as supplied from East Penn Mfg is an estimate of 

the fugitive emissions to be applied for this project. That approach has resulted in EPA estimating 

fugitive emissions from East Penn’s smelter to be 0.272 tons per year. We have concerns related 

to the accurate representation of the EPA using this approach, as there is insufficient data 

available for either EPA or East Penn Mfg to formulate a detailed estimation. With this in mind, 

we provide the following comments:

1. Ambient monitoring data at East Penn Mfg cannot be directly correlated to stack and 

fugitive emissions from East Penn Mfg’s secondary lead smelter due to the confounding 

influence of the other stack and fugitive emissions from the manufacturing complex.

East Penn has for a number of years conducted ambient sampling for compliance with the 

NAAQS for the entire Lyon Station manufacturing complex. This manufacturing complex 

includes not only a secondary lead smelter, but six (6) battery manufacturing operations, a 

Lead Oxide production facility that includes 28 Barton type reactors, two (2) injection molding 

facilities, two (2) water treatment facilities, fleet repair and maintenance facilities along with 

technical engineering facilities, and other support operations. The results obtained from the 

NAAQS sampling are influenced from the entire complex, including lead oxide production and 

lead acid battery manufacturing, not solely from the secondary lead smelter. Thus, if EPA is 

attempting to match the ICR response information, which is solely smelter information, to the 

published ambient monitoring data, the result would certainly be a misapplication or 

misrepresentation of the data. This misapplication is not only due to fugitive emissions, but 

due to emissions from the associated battery manufacturing stacks, and the fugitive 
RTR Fugitive lead emissions 2/11/2011

Page 2 of 4

emissions from the entire complex. EPA admits that estimation of the impacts from fugitive 

emissions are challenging since they cannot be easily captured or directly measured. This 

challenge is magnified by the additional and varied operations taking place at Lyon Station. 

2. East Penn Mfg’s 2009 TRI data is not representative of fugitive emissions from the 

secondary lead smelter.

The TRI data supplied by East Penn Mfg is representative of the emissions from the 

manufacturing complex at Lyon Station, PA. As previously stated, the manufacturing complex 

includes not only a secondary lead smelter, but six (6) battery manufacturing operations, a 

Lead Oxide production facility that includes 28 Barton type reactors, two (2) injection molding 

facilities, two (2) water treatment facilities, fleet repair and maintenance facilities along with 

technical engineering facilities, and other support operations. The entire complex 

encompasses 400 acres of which the smelter is located on 10 acres within that complex. The 

use of the 2009 TRI information significantly overestimates the levels of fugitive emissions for 

the operations regulated under Subpart X since East Penn Mfg reports TRI (and Form R) 

information for the entire manufacturing complex, not solely the secondary lead smelter. 

Separate information regarding the smelter and the battery plant operations are only 

submitted for the AIMS program of the State of Pennsylvania as this directly relates to the 

two separate Title V permits issued by the PA DEP.

3. East Penn Mfg’s smelter fugitive emissions can be estimated from the facility TRI data if

the applicable smelter portion is derived from a ratio to the total complex emissions.

The 2009 TRI data included stack and fugitive emissions for the entire complex. Within that 

estimation, total stack emissions for the complex were 3,860 pounds per year and fugitive 

emissions were conservatively estimated at 544 pounds per year. Stack emissions related to 

the smelter operations totaled 400 pounds per year. Using a simple ratio to compare the two 

and estimate that portion of fugitive emissions resulting from the smelter calculates to 56 

pounds per year.

Calculation of the smelter fugitive portion would be as follows:

544 lbs complex fugitive emissions _X_lbs smelter fugitive emissions 

3860 lbs complex stack emissions = 400 lbs smelter stack emissions

56.37 lbs per year = lbs smelter fugitive emissions

This equates to 0.0282 tons per year of fugitive emissions per year, which is significantly 

different and, in fact, an order of magnitude less than the calculation utilizing East Penn Mfg’s 

2009 TRI data.

4. EPA’s own model for estimating the facility emissions supports the results obtained from 

the ratio. 

The attachment to the email received included the following methodology for the estimation of 

the fugitive emission from each facility: 

“The total estimated emissions for the facility were 1.03 tons per year of fugitive emissions of 

lead compounds, which we designated as the emissions factor for the model plant. The 
RTR Fugitive lead emissions 2/11/2011

Page 3 of 4

estimates for the other facilities were calculated by multiplying the emissions factor (1.03 

tons/yr) by a size factor, an enclosure factor, and a housekeeping factor.”

Applying that methodology the estimation of emissions from East Penn Mfg’s secondary lead 

smelter would calculate as follows:

1.03 tons/ year X 1.0 size factor X 0.25 enclosure factor X 0.2 work practice factor =

0.0515 tons per year.

5. East Penn Mfg employs housekeeping and emission control techniques that go beyond 

the current NESHAP standards.

East Penn Mfg has employed at its secondary lead smelter a greater level of control for stack 

emissions than the NESHAP requirements. The secondary smelter employs HEPA filtration 

after the fabric filtration to further reduce emissions and to prevent atmospheric deposition 

onto the roadways and other areas of the facility, thereby reducing re-entrainment and 

reducing fugitive emissions. 

In addition, the facility employs both dry sweeping and wet scrubbing of the roadway surfaces 

in and throughout the smelter as well as other parts of the manufacturing complex. This 

program involves both dedicated equipment and dedicated employees to accomplishing this 

task.

The smelter is a totally enclosed facility and utilizes enclosure and localized ventilation on 

process points to ensure that fugitive emissions are controlled at the point of generation.

6. Current ambient air quality monitoring results support and corroborate East Penn Mfg’s 

position that the fugitive emissions from the secondary smelter are overestimated.

The ambient monitoring stations for the determination of compliance with the NAAQS for lead 

have resulted in measurements yielding three month rolling averages of < 0.05 μg/M3. These 

measurements are an order of magnitude less than the impacts projected from the PA DEP 

modeling of the emissions for the complex. While modeling results are a conservative 

estimation of actual impacts, the relationship between the two indicates that the facility is not 

subject to significant impact from fugitive emissions either from the smelter or from the other 

operations on site. They indicate that the current EPA fugitive estimate is an over 

representation and does not represent what is occurring at the facility.

In conclusion, it is East Penn Mfg’s opinion that the EPA should reconsider the fugitive emission 

values assigned to the East Penn smelter. The use of Lyon Station data, both ambient air results 

and the TRI data are not an accurate representation of the smelter operation. This is due to the 

confounding influences of the other manufacturing operations besides the smelter and the lack of 

necessary information to properly account for the impact of these operations. Additionally, the 

EPA’s use of the TRI data to estimate fugitive emissions from the secondary lead smelter is 

inappropriate. The TRI data represents the emissions from the entire manufacturing complex at 

Lyon Station rather than the emissions solely from the secondary lead smelter. The potential 

exists for EPA to estimate the fugitive emissions from the secondary lead smelter by applying a 

ratio of the smelter portion compared to the total. This estimation results in a reduction of the 
RTR Fugitive lead emissions 2/11/2011

Page 4 of 4

estimate by an order of magnitude. When the EPA’s proposed model for estimating emissions is 

applied to the smelter the result is also an order of magnitude less than the current EPA estimate 

from TRI data. East Penn Mfg believes that the best estimate for fugitive emissions from its 

secondary lead smelter to be in the range of 0.03 to 0.05 tons per year.

Again, thank you for the opportunity to comment on these estimations and the 

methodology. Please be advised that due to the limited time allowed us to prepare a response, 

this information is preliminary and we would reserve the right to supplement these comments with 

additional information in the future. We look forward to continued dialog in the development of 

these standards for our industry. Please feel free to contact me at the above addresses or phone 

number should you require additional information or wish to discuss this further.

Sincerely,

R. A. Leiby, Jr.

Vice President, Metals Operations

East Penn Manufacturing Co., Inc.