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

Implementation of the 2008 Lead National Ambient Air Quality Standards

Guide to Developing Reasonably Available Control Measures (RACM) for Controlling Lead 

Emissions

By: 

Doug McIntyre

EC/R Incorporated

Chapel Hill, North Carolina

Prepared for:

Ms. Mia South, Work Assignment Manager

Air Quality Policy Division

EPA Contract No. EP-D-07-001

Work Assignment #4-10

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Air Quality Policy Division

Research Triangle Park, NC 27711
i

List of Acronyms

BDT Best Demonstrated Technology

BOPF Basic Oxygen Process Furnace 

BOPH Basic Oxygen Process Heater

CAA Clean Air Act

CFR Code of Federal Regulations

EAF Electric Arc Furnace

EIF Electric Induction Furnace

EPA Environmental Protection Agency

FR Federal Register

GACT Generally Available Control Technology

HAP Hazardous Air Pollutant

HEPA High Efficiency Particulate Air

MACT Maximum Available Control Technology

NAAQS National Ambient Air Quality Standard

NAICS North American Industry Classification System

NEI National Emissions Inventory

NESHAP National Emission Standards for Hazardous Air Pollutants

NSPS New Source Performance Standard

PM Particulate Matter

RACM Reasonably Available Control Measure

RACT Reasonably Available Control Technology

SCAQMD South Coast Air Quality Management District

SIP State Implementation Plan

TPY Tons Per Year

WESPs Wet Electrostatic Precipitators
ii

-TABLE OF CONTENTS1.0. INTRODUCTION. ......................................................................................................................................................1

1.1. Purpose – Supporting the Implementation of the 2008 Lead NAAQS by Analyzing Relevant Control Measures 

for RACM Development................................................................................................................................................1

1.2. The 2008 Lead NAAQS and RACM Requirements. ..............................................................................................1

2.0. EPA CRITERIA AND PROCEDURES FOR RACM DEVELOPMENT..................................................................3

2.1. EPA Criteria for Determining whether a Control Measure is a RACM................................................................3

2.2. Using Particulate Matter Cost-Effectiveness Information as a Surrogate for Lead Cost- Effectiveness

Information....................................................................................................................................................................5

3.0. OVERVIEW OF RACM DEVELOPMENT FOR THE IMPLEMENTATION OF THE 2008 LEAD NAAQS. .....6

3.1. Overview of RACM Development. .........................................................................................................................6

3.2. Selecting the Source Categories for which RACM Development is Focused on in this Document........................6

3.3. Strategy for Developing RACM for Source Categories not Focused on in this Document..................................14

4.0. RACM DEVELOPMENT FOR THE SECONDARY LEAD SMELTING SOURCE CATEGORY......................16

4.1. Overview of Source Category. ..............................................................................................................................16

4.2. Facility Operations and Lead Emission Points.....................................................................................................16

4.3. Identification and Summary of Possible RACM Candidates. ..............................................................................17

4.4. Application of RACM Criteria to Possible RACM Candidates. ..........................................................................19

5.0. RACM DEVELOPMENT FOR THE LEAD ACID BATTERY MANUFACTURING SOURCE CATEGORY...27

5.1. Overview of Source Category. ..............................................................................................................................27

5.2. Facility Operations and Lead Emission Points.....................................................................................................27

5.3. Identification and Summary of Possible RACM Candidates. ..............................................................................28

5.4. Application of RACM Criteria to Possible RACM Candidates. ..........................................................................29

6.0. RACM DEVELOPMENT FOR THE IRON AND STEEL FOUNDRIES SOURCE CATEGORY. ......................34

6.1. Overview of Source Category. ..............................................................................................................................34

6.2. Facility Operations and Lead Emission Points.....................................................................................................35

6.3. Identification and Summary of Possible RACM Candidates. ..............................................................................36

6.4. Application of RACM Criteria to Possible RACM Candidates. ..........................................................................38

7.0. RACM DEVELOPMENT FOR THE INTEGRATED IRON AND STEEL MILLS SOURCE CATEGORY. ......51

7.1. Overview of Source Category. ..............................................................................................................................51

7.2. Facility Operations and Lead Emission Points.....................................................................................................51

7.3. Identification and Summary of Possible RACM Candidates. ..............................................................................53

7.4. Application of RACM Criteria to Possible RACM Candidates. ..........................................................................54

8.0. RACM DEVELOPMENT FOR FUGITIVE DUST CONTROL MEASURES .......................................................60

8.1. The Economic Feasibility of Fugitive Dust Control Measures. ............................................................................60

8.2. The Capital Costs, Annualized Costs, and Cost Effectiveness of Fugitive Dust Control Measures.....................61
iii

8.3. Fugitive Dust Control Measures Adopted in Federal and State Regulations.......................................................62

8.4. Implications for RACM Development for Fugitive Dust Control Measures. ......................................................65
1

1.0. INTRODUCTION.

1.1. Purpose – Supporting the Implementation of the 2008 Lead NAAQS by Analyzing Relevant

Control Measures for RACM Development.

In order to support the implementation of the 2008 Lead National Ambient Air Quality Standards

(NAAQS), this document contains an analysis of air control measures for the purpose of determining

what controls may constitute reasonably available control measures (RACM), including reasonably 

available control technologies (RACT), for controlling lead emissions pursuant to Section 172(c)(1) of 

the Clean Air Act (CAA). This document was prepared pursuant to EPA Contract EP-D-07-001, Work 

Assignment # 4-10, by EC/R Incorporated. 

This document identifies control measures used to control lead emissions from sources in the Secondary

Lead Smelting, Lead Acid Battery Manufacturing, Iron and Steel Mills, and Iron and Steel Foundries 

source categories. For each identified control measure, this document contains a RACM criteria 

assessment to determine how likely each control measure is to constitute RACM. In addition, for the 

Primary Lead Smelting, Secondary Aluminum Production, Secondary Copper Smelting, Mining, and 

Petroleum Refineries source categories, data relevant to a RACM determination was collected from

EPA‟s CoST database and is presented here for a RACM criteria assessment.

A prior EPA document identifies potential RACM for controlling lead emissions.

1

This document, 

“Implementation of the 2008 Lead National Ambient Air Quality Standards (NAAQS): Guide to 

Developing Reasonably Available Control Measures (RACM) for Controlling Lead Emissions,” is 

intended to replace such prior document, and any other EPA-issued document, with respect to

identifying RACM for controlling lead emissions.

1.2. The 2008 Lead NAAQS and RACM Requirements.

On November 12, 2008, EPA published the final rule on the Lead NAAQS. Based on its review, EPA

made revisions to the primary and secondary Lead NAAQS to provide requisite protection of the public

health and welfare. EPA revised the primary standard to provide increased protection for children and

other at-risk populations against an array of adverse health effects. Such health effects most notably

include neurological effects in children, including neurocognitive and neurobehavioral effects. EPA

revised the level from 1.5 to 0.15 micrograms per cubic meter (μg/m3). EPA revised the secondary

standard to be identical in all respects to the revised primary standard.2

The CAA requires that states submit for each nonattainment area a state implementation plan (SIP) that

contains RACM, including RACT. Specifically, section 172(c)(1) of the CAA requires that

nonattainment SIPs “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 the attainment of the NAAQS [emphasis added].”3

The first step in addressing RACM for the 2008 Lead NAAQS is to identify potential measures for

controlling lead emissions from lead sources in nonattainment areas. In addition, if states are aware of

 

1

“Lead Guideline Document,” EPA-452/R-93-009, April 1993.

2National Ambient Air Quality Standards for Lead; Final Rule, 73 FR 66964, 67036 (Published November 12, 2008).

3

Id. at 67036.
2

information or receive substantive public comments that demonstrate through appropriate

documentation that additional control measures may be reasonably available in a specific area, the

measures should be added to the list of available measures for consideration in that particular area.4

While EPA does not presume that control measures are reasonably available in all areas, a reasoned 

justification for rejection of any available control measure should be prepared. If it can be shown that

such control measures, if applied to individual sources or to a source category, are unreasonable because

emissions from the affected sources are insignificant (i.e., would not have any effect on attainment),

then the control measures may be excluded from further consideration as they would not be

representative of RACM for the affected area. The resulting control measures should then be evaluated

for reasonableness, considering their technological feasibility and the cost of control in the area for

which the SIP applies.5

 

4

Id.

5

Id.
3

2.0. EPA CRITERIA AND PROCEDURES FOR RACM

DEVELOPMENT.

This section provides EPA criteria and procedures for the development of RACM, which will be used in 

subsequent sections to assess how likely each control measure is a RACM.

2.1. EPA Criteria for Determining whether a Control Measure is a RACM.

EPA provides that in determining whether a control measure is a RACM, the following factors should 

be considered:

1. The economic feasibility of the control measure, 

2. The capital costs, annualized cost, and cost effectiveness of the control measure; and 

3. The extent of adoption of the control measure by state regulations.6

2.1.1. The Economic Feasibility of the Control Measure.

The economic feasibility of a control measure refers to the cost of reducing emissions and the difference 

between the cost of the control measure at the particular source in question and the costs of control 

measures that have been implemented at similar sources. Economic feasibility is largely determined by 

evidence that other sources in a particular source category have applied the control measure in question, 

although EPA does encourage the development of innovative measures not previously employed that

may be technically and economically feasible. Absent other indications, EPA, as a general matter,

expects that it is reasonable for similar sources to bear the costs for similar control measures.7

2.1.2. The Capital Costs, Annualized Costs, and Cost Effectiveness of the Control Measure.

Substantial weight should be given to cost effectiveness in evaluating whether a control measure is a 

RACM. The cost effectiveness of a technology is its annualized cost (e.g, $/year) divided by the 

emissions reduced (e.g., tons/year) which yields a cost per amount of emission reduction (e.g., $/ton).8

In considering what level of control is reasonable, EPA has not adopted a specific dollar per ton cost 

threshold. However, a control measure is likely to be a RACM if it has a cost per ton similar to other 

measures previously employed for that pollutant, or similar to that of other measures needed to achieve 

expeditious attainment in the area within the CAA‟s timeframes. A higher cost per ton value may be 

reasonable in areas with more serious air quality problems than in areas with less serious problems 

because it is expected that the residents in the areas with more serious air quality problems could realize 

greater public health benefits from attaining the standard as expeditiously as practicable. A higher cost 

per ton value also may be reasonable in areas where essential reductions are difficult to achieve (e.g., 

because many sources are already controlled).9

In addition, EPA believes that in determining appropriate emission control levels, the state should 

consider the collective public health benefits that can be realized in the area due to projected 

 

6

Id. at 67035-67037.

7

Id. at 67036.

8

Id.

9

Id.
4

improvements in air quality.

10 One such collective public health benefit might be improved air quality in 

areas with large demographic populations that are the subject of environmental justice concerns, as more 

expensive control measures might be more reasonable for sources in a nonattainment area with large 

demographic populations that are the subject of environmental justice concerns. Considering 

environmental justice concerns in this way is consistent with EPA Plan EJ 2014, which represents a 

strategy aimed at protecting health in communities that are over-burdened by pollution.11

2.1.3. The Adoption of Control Measures by States.

The fact that a control measure has been adopted or is in the process of being adopted by states is an 

indicator that the measure may be a RACM.

12 This document will specifically focus on the state 

regulations and permit requirements that pertain to source categories with corresponding sources in such 

states.

Similarly, the fact that EPA has identified a control measure as a generally available control technology 

(GACT), best demonstrated technology (BDT), or a maximum available control technology (MACT)

might also suggest that the control measure is reasonably available. EPA identifies control measures as 

GACT when promulgating National Emission Standards for Hazardous Air Pollutants (NESHAP) for 

area sources in a source category. In determining what constitutes GACT for a particular area source 

category, EPA evaluates the control technologies and management practices that are generally available 

for the area sources in a source category that reduce hazardous air pollutants (HAP). EPA may consider 

costs in determining what constitutes GACT for the area source category.13 The fact that EPA has 

considered a control measure GACT after considering costs would generally suggest that such a control 

measure is likely a RACM. 

EPA identifies control measures as BDT when promulgating New Source Performance Standards 

(NSPS). BDT refers to the best system of continuous emissions reduction that has been demonstrated to 

work in a given industry, considering economic costs and other factors, such as energy use.14 The fact 

that EPA has considered a control measure BDT after considering costs would generally suggest that 

such a control measure is a RACM.

EPA identifies control measures as MACT when promulgating NESHAP standards for major sources in 

a source category. For major sources, MACT standards must reflect the maximum degree of emissions 

reductions of HAP achievable after considering cost, energy requirements, and non-air quality health 

and environmental impacts. The MACT „„floor‟‟ is the minimum control level allowed for MACT 

standards promulgated under CAA section 112(d)(3) and may not be based on cost considerations. For 

new sources, the MACT floor cannot be less stringent than the emissions control that is achieved in 

practice by the best controlled similar source. The MACT floors for existing sources can be less 

stringent than floors for new sources, but they cannot be less stringent than the average emissions 

limitation achieved by the best performing 12 percent of existing sources in the category or subcategory 

(or the best performing five sources for categories or subcategories with fewer than 30 sources).15 In 

 

10Id.

11EPA Plan EJ 2014, EPA Office of Environmental Justice (Published September 2011).

12National Ambient Air Quality Standards for Lead; Final Rule, 73 FR 66964, 67036 (Published November 12, 2008).

13See, for example, NESHAP for Area Source: Acrylic and Modacrylic Fibers Production, Carbon Black Production, 

Chemical Manufacturing, Flexible Polyurethane Foam Production and Fabrication, Lead Acid battery Manufacturing, and 

Wood Preserving; Final Rule, 72 FR 38864, 38880 (Published July 16, 2007).

14NSPS for Portland Cement Manufacturing, 75 CFR 54970, 54974-54975 (Published September 9, 2010).

15See, for example, Proposed NESHAP for Iron and Steel Foundries, 67 CFR 78274, 78276 (Published December 23, 2002).
5

some circumstances, such as when a large amount of time has passed since a control measure was 

identified as MACT, the fact that a control technology was identified as MACT might suggest that such 

a control measure is a RACM.

2.2. Using Particulate Matter Cost-Effectiveness Information as a Surrogate for Lead CostEffectiveness Information.

As indicated in Section 2.1, cost-effectiveness information is an important factor to consider when 

determining whether a control measure is a RACM. However, cost-effectiveness information for 

controlling lead is often limited. Consequently, EPA often uses the cost-effectiveness information for 

controlling particulate matter (PM) for a control measure as a surrogate for the cost-effectiveness of 

controlling lead for the measure. That is, EPA will use evidence that suggests that a control measure is 

cost effective for controlling PM emissions to support the contention that the control measure is also 

cost effective for controlling lead emissions.

For example, for the development of RACM/RACT for the 2008 Lead NAAQS, EPA guidance indicates

that states should rely on the RACM guidance issued for PM. Regulations and guidance that address the 

implementation of pre-existing NAAQS for lead are mainly provided in the following documents: (1) 

„„state Implementation Plans; General Preamble for the Implementation of Title I of the Clean Air Act 

Amendments of 1990,‟‟57 FR 13549, April 16, 1992, (2) „„state Implementation Plans for Lead 

Nonattainment Areas; Addendum to the General Preamble for the Implementation of Title I of the Clean 

Air Act Amendments of 1990,‟‟58 FR 67748, December 22, 1993, and (3) regulations listed at 40 CFR 

51.117.16

In accordance with such EPA guidance, when lead cost-effectiveness information is limited for a control 

measure, this document contains cost-effectiveness data for controlling PM for control measures to 

glean whether the control measure might also be cost effective for controlling lead. However, it is 

important to note that the cost-effectiveness for a control measure at a specific facility depends on many 

factors such as the type, size and amount of emissions; the layout of the facility; control technology 

specifications and several other factors. Consequently, it will not always be the case that a control 

measure that is cost effective to control PM at one facility will be cost effective to control lead at the 

same facility, at another facility within the same source category, or at another facility from a different 

source category.

 

16National Ambient Air Quality Standards for Lead; Final Rule, 73 FR 66964, 67030 (Published November 12, 2008).
6

3.0. OVERVIEW OF RACM DEVELOPMENT FOR THE 

IMPLEMENTATION OF THE 2008 LEAD NAAQS.

This section provides an overview of RACM development for the 2008 Lead NAAQS. Section 3.1

explains why this document assesses control measures for RACM development within the context of

source categories. Section 3.2 explains why this document focuses on certain source categories -

Secondary Lead Smelting, Lead Acid Battery Manufacturing, Iron and Steel Foundries, and Iron and 

Steel Mills – for RACM development. Section 3.3 provides a strategy for RACM development for

sources in source categories not focused on in this document.

3.1. Overview of RACM Development.

This document presents control measures within specific source categories because applying the RACM 

criteria discussed in Section 2.117 is most conveniently analyzed and clearly presented within the context 

of source categories. For example, economic feasibility of a control measure is largely determined by 

the extent of adoption by sources is the same source category. Moreover, the cost-effectiveness of a 

control measure is often more similar (although variable) across a certain source category. In addition, 

state and federal regulations are generally written for specific source categories and, therefore, the extent 

to which a control measure is adopted by state/federal regulations is most easily analyzed within the 

context of source categories. 

3.2. Selecting the Source Categories for which RACM Development is Focused on in this 

Document. 

This document focuses on four source categories for which RACM development for the 2008 Lead 

NAAQS is likely to be most relevant. Some source categories do not emit lead in great enough 

quantities to cause lead NAAQS exceedances. Other source categories do not have corresponding 

sources in nonattainment areas with respect to lead and, therefore, no sources will be subject to the 

RACM requirement. Section 3.2.1 identifies sources categories with corresponding sources in 

nonattainment areas with respect to lead, and for such source categories, Section 3.2.2 provides an 

assessment of how relevant RACM development would likely be for each source category. Sections 4 

through 7 present control measures relevant to each of the four selected source categories and assess he 

likelihood that each such control measure would constitute a RACM. 

3.2.1. Identification of Lead-Emitting Sources in Nonattainment Areas with respect to the 2008 Lead

NAAQS.

The task of identifying the lead-emitting sources in nonattainment areas with respect to the 2008 Lead

NAAQS is a two-step process. First, the nonattainment areas with respect to the 2008 Lead NAAQS

must be identified. Then, the lead-emitting sources within such nonattainment areas can be identified.

In order to identify the areas of nonattainment with respect to the 2008 Lead NAAQS, EPA‟s Area

Designations for 2008 Lead Standards Website was reviewed.

18 Specifically, the counties and specific

 

17(1) The economic feasibility of the control measure, as indicated by extent of adoption; (2) the capital costs, annualized 

cost, and the cost effectiveness of the control measure; and (3) the extent of adoption of the control measure by state 

regulations.

18EPA‟s Area Designations for 2008 Lead Standards Website (Accessed December, 2011).
7

cities/townships that were in nonattainment were identified in the designation support documents for

each specific state as of December 1, 2011.

19 Table 3-1 provides a summary of the nonattainment areas

with respect to the 2008 Lead NAAQS. Overall, there were 21 nonattainment areas within 22 counties.

Once the nonattainment areas were identified, the corresponding designation support documents were

reviewed and the lead-emitting sources (emitting ≥ 0.10 TPY of lead) in each nonattainment area were

identified. In order to determine the corresponding source category for each source, the corresponding

North American Industry Classification System (NAICS) code and NAICS description for each source

were identified using EPA‟s National Emission Inventory Database.

20 Table 3-2 provides a summary of

the most significant lead-emitting sources in areas of nonattainment with the 2008 Lead NAAQS, with

corresponding NAICS codes and descriptions. Table 3-2 also provides the values for emitted TPY of 

lead for each facility as provided by each state in its respective designation support document, except 

when indicated otherwise.

EPA‟s purpose in identifying the lead-emitting sources in nonattainment areas in Table 3-2 is to help 

determine the source categories for which information related to RACM development will be most 

useful and relevant. In preparing this draft document, EPA assumed that the source categories with the 

most and largest lead-emitting sources in nonattainment areas would be the source categories for which 

information on RACM development would be most useful and relevant. Therefore, this draft document 

was prepared to provide more in-depth RACM development information in Sections 4 through 8 for 

such source categories. However, EPA emphasizes that the list of sources identified in Table 3-2 is not 

an exhaustive list of all the lead-emitting sources in nonattainment areas. In addition, even though EPA 

focused its search on sources emitting more than 0.10 TPY of lead, EPA recognizes that sources 

emitting less than 0.10 TPY are might be required to install RACM pursuant to CAA §172(c)(1) and 

might be significant contributors to NAAQS exceedances.

 

19Puerto Rico Support Document, Pennsylvania Support Document I, Pennsylvania Support Document II, Pennsylvania 

Support Document III, Alabama Support Document , Tennessee Support Document , Florida Support Document , Illinois 

Support Document I, Illinois Support Document II, Indiana Support Document , Michigan Support Document , Minnesota 

Support Document , Ohio Support Document I, Ohio Support Document II, Ohio Support Document III , Texas Support 

Document , Iowa Support Document , Kansas Support Document , Missouri Support Document I , Missouri Support 

Document II , California Support Document I. (All documents represent the most recent state designation documents for the 

2008 Lead NAAQS as of December, 2011). 

20EPA‟s National Emission Inventory Database (Accessed December, 2011).
8

Table 3-1. Nonattainment Areas with respect to the 2008 Lead NAAQS.

State Area Name County Name

Alabama Troy Pike (partial) 

California

Los Angeles County within the South Coast Air Basin, 

excluding San Clemente and Santa Catalina Islands 

(Southern Los Angeles County)

Los Angeles (partial) 

Florida Tampa Hillsborough (partial) 

Illinois Granite City Madison (partial) 

Chicago Cook (partial) 

Indiana Muncie Delaware (partial)

Iowa Pottawattamie County Pottawattamie (partial)

Kansas Saline County Saline (partial)

Michigan Belding Ionia (partial) 

Minnesota Eagan Dakota (partial) 

Missouri

Iron County Iron (partial), Dent (partial), 

Reynolds (partial) 

Jefferson County Jefferson (partial) 

Ohio

Bellefontaine Logan (partial) 

Cleveland Cuyahoga (partial) 

Delta Fulton (partial) 

Pennsylvania

Lower Beaver Valley Beaver (partial) 

Lyons Berks (partial) 

North Reading Berks (partial) 

Puerto Rico Arecibo Arecibo (partial) 

Tennessee Bristol Sullivan (partial) 

Texas Frisco Collin (partial) 

Total 21 Nonattainment Areas 22 partial counties (parts of Berks 

County, PA in 2 areas)
9

Table 3-2. Lead-emitting Sources (≥ 0.10 TPY) in Nonattainment Areas with the 2008 Lead NAAQS

Region State County Source Name Emissions 

(TPY)

NAICS Code and Description

Secondary Lead Smelting

2 PR Arecibo The Battery 

Recycling 

Company

1.22 331492 Secondary Smelting, and 

Alloying of Nonferrous 

Metal

3 PA Berks East Penn Manfg.

Co.

0.20 331492 ...

3 PA Berks Exide Technologies 1.4421 331492 ...

4 AL Pike Sanders Lead

Comp.

4.44 331492 ...

4 FL HillsboroughEnviroFocus

Technologies

1.30 331492 ...

5 IN Delaware Exide Technologies 0.81 331492 ...

5 MN Dakota Gopher Resource 

Corp.

0.3622 331314 ...

6 TX Collin Exide Corp. 2.0 331492 ...

7 MO Iron, 

Dent, 

Reynolds

Buick Resources 

Recycling

12.1 331492 ...

9 CA LA Exide Technologies 2.00 335911 ...

9 CA LA Quemetco Inc. 0.32 331492 ...

Lead Acid Battery Manufacturing

3 PA Berks East Penn Manf. 2.49 335911 Storage Battery Manf.

3 PA Berks Yuasa Battery Inc. 0.1823 335911 ...

4 TN Sullivan Exide Technologies 0.78 335912 Primary Battery Manf.

7 KS Salina Exide Technologies 2.17 335912 ...

Iron and Steel Foundries

5 IL Madison ASF-Keystone, Inc. 

(Amsted Rail)

0.1924 331513 Steel Foundries

5 OH Fulton Northstar 

Bluescope Steel, 

LLC

.30 331515 Iron Foundries

7 IA PottawattamieGriffin Pipe 

Facility

1.20 331515 ...

7 KS Saline Metlcast Products 0.14 331515 ...

Iron and Steel Mills

5 IL Madison US Steel Corp. 1.3325 33111 Iron and Steel Mills

Other Source Categories26

7 MO Jefferson Doe Run 59.0027, 28 331419 Primary Smelting and 

 

21PA state 2008 inventory (As of December 2011).

222008 NEI v1.5 (As of December, 2011).

23Id.

242008 NEI v1.5 (As of December 2011).

25Id.

26These are source categories with at least one corresponding source in a nonattainment area, which are not focused on in this 

document. This document focuses on developing RACM for the following source categories: Secondary Lead Smelting, Lead 

Acid Battery Manufacturing, Iron and Steel Foundries, Iron and Steel Mills
10

Region State County Source Name Emissions 

(TPY)

NAICS Code and Description

Herculaneum Refining of Nonferrous 

Metal (except Copper and 

Aluminum)

5 IL Cook H. Kramer & 

Company

0.1229 331423 Secondary Smelting, 

Refining, and Alloying of 

Copper

5 MI Ionia Mueller Industries 0.8030 331421 Copper Rolling, Drawing, 

and Extruding

2 PR Arecibo PREPA 

Cambalache 

Combustion 

Turbine Plant

0.17 221112 Fossil Fuel Electric Power 

Generation 

7 MO Iron, 

Dent, 

Reynolds

Doe Run 

Company-Buick 

Mill

0.10 212231 Lead Ore and Zinc Ore 

Mining

5 IL Cook Fisk Electric 

Generating Station

0.0731 221112 Fossil Fuel Electric Power 

Generation

9 CA Los 

Angeles

BP West Coast 

Products LLC

0.79 324110 Petroleum Refineries

9 CA Los 

Angeles

Tesoro LA 

Refinery

0.15 324110 Petroleum Refineries

3.2.2. Source Categories with Corresponding Sources in Nonattainment Areas for which RACM 

Development is Likely to be Most Relevant. 

RACM development is only relevant for a source category if corresponding sources from the source 

category are located in nonattainment areas. For such source categories with a least one corresponding 

source in a nonattainment area, we used four factors to determine which of these source categories to 

include in this document for further assessment.

The first factor is the number of sources a corresponding source category has in nonattainment areas.

The more sources a corresponding source category has in nonattainment areas, the more likely that the 

source category would be included in this document. 

 

27The Regulatory Impact Analysis of the Proposed Revisions to the National Ambient Air Quality Standards for Lead 

(Published October 2008). Page 7.

28EPA‟s purpose in identifying the lead-emitting sources in nonattainment areas in Table 3-2 is to help determine the source 

categories for which information related to RACM development will be most useful and relevant. In preparing this draft 

document, EPA assumed that the source categories with the most and largest lead-emitting sources in nonattainment areas 

would be the source categories for which information on RACM development would be most useful and relevant. Therefore, 

this draft document was prepared to provide more in-depth RACM development information in Sections 4 through 8 for such 

source categories. However, EPA emphasizes that the list of sources identified in Table 3-2 is not an exhaustive list of all the 

lead-emitting sources in nonattainment areas. In addition, even though EPA focused its search on sources emitting more than 

0.10 TPY of lead, EPA recognizes that sources emitting less than 0.10 TPY might be required to install RACM pursuant to 

CAA §172(c)(1) and might be significant contributors to NAAQS exceedances.

29Id.

30Id.

31Id.
11

The second factor is the total annual emissions emitted from all the sources within a source category.

Specifically, higher emissions are likely to make control measures more cost effective and, therefore,

more appropriate to include in this document. 

The third factor is the overall number of sources in a corresponding source category. The more sources 

in a source category, the more likely that a source will be identified as being in an area classified as 

nonattainment in the future and, therefore, more appropriate to include in this document. 

The fourth factor is other reasons cited in designation support documents, such as if modeling indicates 

that certain sources within a source category are significantly contributing to nonattainment with the 

NAAQS. Specifically, control measures are more likely to be necessary for a source if emission 

reductions are needed to attain the NAAQS.

Table 3.3 contains some of the information we used to decide which source categories to cover in this 

document, including the overall lead emissions from each source category in TPY and the number of 

sources in each source category.32

 

32The Regulatory Impact Analysis of the Proposed Revisions to the National Ambient Air Quality Standards for Lead 

(Published October 2008). Page 7. (Unless indicated otherwise). Note that in the referenced RIA, the table lists many more 

source categories and accounts for all lead emissions from stationary sources except for 7.08 % of the total national annual 

lead emitted. The table was revised in this document to only list the source categories with corresponding lead-emitting 

sources in nonattainment areas. In the referenced RIA, the smallest lead-emitting source category listed emitted 5 TPY of 

lead. In the referenced RIA, the source categories of Petroleum Refineries and Fossil Fuel Electric Power Generation were 

not listed, and therefore, the lead emissions are assumed to be less than 5 TPY.
12

Table 3-3. Nationwide Lead Emissions from Stationary Source Categories with Corresponding

Sources in Current Nonattainment Areas.

Source Category Annual 

Emission 

(Tons 

Lead/Year)

Number of 

Sources in Source 

Category 

Relative % of Total 

Emissions from Stationary 

Source Categories

Iron and Steel Foundries 83 600+ 33 6.05

Primary Lead Smelting 59 1

34 4.30

Secondary Lead Smelting 44 15 35 3.21

Iron & Steel Mills 17 18 36 1.24

Lead Acid Battery 

Manufacturing

17 60 37 1.24

Mining 15 Undetermined 1.09

Secondary Aluminum 

Production

9 Undetermined 0.66

Secondary Copper Smelting 6 Undetermined 0.44

Petroleum Refineries < 5 Undetermined < 0.40

Fossil Fuel Electric Power 

Generation

< 5 Undetermined < 0.40

Remainder of Lead Emissions from Sources in Other Source 

Categories

88%38

Application of the four factors suggests that the following source categories are the most relevant for 

including in this document: Secondary Lead Smelting, Lead Acid Battery Manufacturing, Iron and Steel

Mills, and Iron and Steel Foundries. The source category of Secondary Lead Smelting has the highest

number of corresponding sources in nonattainment areas, as shown in Table 3-2. Moreover, such

sources have some of the highest annual emissions of lead, with three sources each emitting four tons of

lead per year, also shown in Table 3-2. Overall, there are 15 secondary lead smelting sources in the

United States.39 However, this small number of facilities is responsible for the emission of 44 tons of

lead per year, which represents 3.21% of all lead emitted, as shown in Table 3-3. Consequently, control 

measures for this source category are reviewed in this document.

 

33NESHAP for Iron and Steel Foundries - Background Information for Proposed Standards. Document # EPA-HQ-OAR2006-0359-0002 (Published December, 2002). Page 2-1 .

34Memorandum – Summary of Information Collection Request, Received from Source- Doe Run Resources Corporation, 

From V. Hanzel, RTI International, To Docket. November 19, 2010.

35Memorandum –Draft Development of the RTR Emissions Dataset for the Secondary Lead Source Category, From Mike 

Burr, ERG, To Chuck French of EPA/OAQPS. April 2011. Page 1.

36NESHAP for Iron and Steel Foundries - Background Information for Proposed Standards. Document # EPA-HQ-OAR2006-0359-0002 (Published December, 2002). Page 2-1.

37Memorandum – Lead Acid Battery Manufacturing Area Source Category Additional Information to Support Proposed Rule, 

From Nancy Jones, EC/R, To U.S. EPA Docket Number EPA-HQ-OAR-2006-0897. February 28, 2007. Page 3.

38The largest-emitting source categories that make up this 88% are mobile sources (45.44%), 

Industrial/Commercial/Institutional Boilers & Process Heaters (3.87%), and Hazardous Waste Incinerators (3.43%). All other 

source categories have relative % of total lead emissions of less than 2%. Generally, many of the source categories that make

up this 88% were not focused on by this document because the emissions per source were too low to likely cause significant 

contributions to NAAQS exceedances.

39Memorandum – Draft Development of the RTR Emissions Dataset for the Secondary Lead Smelting Source Category, 

From Mike Burr, ERG, To Chuck French of EPA/OAQPS. April 2011. Page 1.
13

The source category of Lead Acid Battery Manufacturing has the second highest number of

corresponding sources in nonattainment areas, as shown in Table 3-2. Moreover, such sources have

relatively high levels of annual lead emissions, with two sources each emitting over two tons of lead per

year, as shown in Table 3-2. Overall, there are roughly 60 lead acid battery manufacturing sources in the

United States.40 This high number of facilities is responsible for 17 tons of lead per year, which

represents 1.24% of all lead emitted, as shown in Table 3-3. Consequently, control measures for this 

source category are reviewed in this document. 

The source category of Iron and Steel Foundries has the third highest number of corresponding sources

in nonattainment areas, as shown in Table 3-2. Such sources have relatively moderate levels of annual

emissions of lead - only emitting less than two tons of lead per year. However, overall there are over 600

iron and steel foundries sources in the United States.

41 This large number of facilities is responsible for

the emission of 83 tons of lead per year, which represents 6.05% of all lead emitted, as shown in Table

3-3. The percent of lead emissions emitted from the sources within the Iron and Steel Foundries source 

category is higher than the lead emissions emitted from sources within any other one source category

with at least one corresponding source in a nonattainment area. Consequently, control measures for this 

source category are reviewed in this document.

The source category of Iron and Steel Mills only has two sources in nonattainment areas, which have

relatively small annual lead emissions, as shown in Table 3-3. However, there are 18 iron and steel mill

sources in the United States.42 This number of facilities is responsible for 17 tons of lead per year, which

represents 1.24% of all lead emitted, as shown in Table 3-3. Consequently, control measures for this 

source category are reviewed in this document.

Other source categories with at least some corresponding sources in nonattainment areas are not 

included in this document for several reasons, including: (1) lack of a large number of corresponding 

sources in nonattainment areas, or (2) a small likelihood that a source category‟s corresponding sources 

in nonattainment areas will contribute significantly to NAAQS exceedances due to low emissions or 

otherwise. Such source categories include the following: Primary Lead Smelting, Secondary Aluminum

Production, Secondary Copper Smelting, Mining, and Petroleum Refineries.

The source category of Primary Lead Smelting has only one corresponding source in a nonattainment

area, as shown in Table 3-2. Such a source currently has a very large level of annual emissions of lead,

with the one source emitting over 60 tons of lead per year, as shown in Table 3-2. However, there are no

other primary lead smelters currently operating in the United States, even though the emissions from this

one source account for 4.3% of the total lead annual emissions.43 More importantly, this one source is

being rebuilt from the ground up with state-of-the art control technology. Consequently, control 

measures for this source are not reviewed in this document.

The source category of Secondary Aluminum Production has only two corresponding sources in

nonattainment areas, as shown in Table 3-2. Moreover, while one source is a fairly large emitter,

 

40Memorandum – Lead Acid Battery Manufacturing Area Source Category Additional Information to Support Proposed Rule, 

From Nancy Jones, EC/R, To U.S. EPA Docket Number EPA-HQ-OAR-2006-0897. February 28, 2007. Page 3.

41NESHAP for Iron and Steel Foundries - Background Information for Proposed Standards. Document # EPA-HQ-OAR2006-0359-0002 (Published December 2002). Page 2-1.

42NESHAP for Integrated Iron and Steel Plants - Background Information for Proposed Standards, Document # EPA-453/R01-005. (Published January 2001). Page 2-1.

43Memorandum – Summary of Information Collection Request, Received from Source- Doe Run Resources Corporation, 

From V. Hanzel, RTI International, To Docket. November 19, 2010.
14

emitting over three tons of lead per year, the other source emits less than one ton of lead per year, as

shown in Table 3-2. Moreover, while there are a very large number (> 100) of secondary aluminum

production facilities,

44 the overall annual emissions of lead from such facilities is very small - only 9

tons of lead per year. This is less than one percent of the total annual lead emitted from all source

categories, as shown in Table 3-3. Consequently, control measures for this source category are not 

reviewed in this document.

The source category related to Secondary Copper Production has only two corresponding sources in 

nonattainment areas, as shown in Table 3-2. Both facilities emit under one ton of lead per year each, as 

shown in Table 3-2.

45 Moreover, such facilities account for a less than one percent of the overall annual 

lead emissions (6 tons, or less than 0.6%). Consequently, control measures for this source category are 

not reviewed in this document.

The source category of Petroleum Refineries has only two corresponding sources in nonattainment 

areas, as shown in Table 3-2. Moreover, both facilities emit well under one ton of lead per year each, as 

shown in Table 3-2. While the total number of facilities in the source category was not determined, the 

annual emissions from all facilities in the source category are very small, not even registering in Table 

3-3. Furthermore, the designation support document for the corresponding nonattainment county 

indicates that a secondary lead smelter in the county is responsible for the elevated lead concentrations, 

and not the petroleum refineries listed.46 Consequently, control measures for this source category are not 

reviewed in this document.

The source category of Fossil Fuel Electric Power Generation has only one corresponding source in a 

nonattainment area, as shown in Table 3-2. Moreover, the emissions from this source are less than 0.5 

TPY, as shown in Table 3-2. While the number of facilities in the source category was not determined, 

the annual emissions from all facilities in the source category are very small, not even registering in 

Table 3-3. Consequently, control measures for this source category are not reviewed in this document.

The source category of Mining has only one corresponding source in a nonattainment area, as shown in 

Table 3-2. Moreover, the emissions from this source are less than 0.5 TPY. While the number of mining 

facilities was not determined, the annual emissions from all mining facilities are only about 1 percent, as 

shown in Table 3-3. Consequently, control measures for this source are not reviewed in this document.

3.3. Strategy for Developing RACM for Source Categories not Focused on in this Document. 

Most sources that will be required to implement RACM will be in the source categories focused on by 

this document – Secondary Lead Smelting, Lead Acid Battery Manufacturing, Iron and Steel Foundries, 

and Iron and Steel Mills. However, there might be some sources in other source categories that will be 

required to implement RACM for controlling lead emissions. 

For source categories not focused on by this document states can begin to determine what constitutes

RACM accordingly. First, states can begin developing RACM by using EPA‟s CoST database. A review 

of all stationary source categories was conducted to determine the control measures typically used to 

 

44List of Sources Subject to the Secondary Aluminum Production MACT Standard, EPA.

45Current Status of Secondary Copper Production Facilities in the United States, Document # EPA-HQ-OAR-2006-0510-

0008 (Published March 31, 2006).

46California Designation Support Document I. (Most recent state designation document for 2008 Lead NAAQS as of 

December, 2011).
15

control lead emissions. Specifically, EPA‟s CoST database contains the most cost effective control 

technologies typically used to control PM process emissions and, therefore, likely lead process 

emissions, including fabric filters (e.g., reverse air, mechanical shaker, pulse jet), scrubbers (e.g., 

impingement and Venturi) and electrostatic precipitators (e.g., wet and dry). The database contains the

most cost effective control technologies typically used to control PM fugitive dust emissions, including

paving unpaved roads, chemically stabilizing unpaved roads, and vacuum sweeping paved roads.47

In addition, states can glean information from the control measure information for the source categories 

focused on in this document. States might analyze the three RACM factors for its corresponding source 

category to see how they compare to the control measures for source categories focused on in this 

document. As an example, suppose a state is determining how likely a particular control measure is 

RACM for a hypothetical source category. Suppose that the extent of adoption of the control measure in 

the hypothetical source category is as widespread as the extent of the adoption of the control measure in 

the Secondary Lead Smelting source category. Further, suppose that the cost effectiveness of the control 

measure for sources in the hypothetical source category is similar to the cost effectiveness of the control 

measure for sources in the Secondary Lead Smelting source category. Also suppose that the control 

measure has been adopted by state regulations pertaining to the hypothetical source category to a similar 

extent that the control measure has been adopted by state regulations pertaining to the Secondary Lead 

Smelting source category. In this situation, the control measure is as likely to be a RACM for the 

hypothetical source category as it is likely to be RACM for the Secondary Lead Smelting source 

category.

States can also search other sources of information on how the RACM criteria apply to various possible 

control measures for controlling lead emissions. With respect to the first two RACM factors – the 

economic feasibility of the control measures (as indicated by extent of adoption by other sources in 

source category) and the cost effectiveness of the control measures – information related to such factors 

can be found in support documents located in the dockets of related MACT standard development.

Information related to the third RACM factor - extent of adoption by state regulations-can be obtained 

through state environmental agencies.

In addition, it is important to note that, while not all sources will be covered by the four source 

categories focused on by this document, many of the sources in source categories not focused on in this 

document may have implemented corresponding RACM in order to comply with other federal or state 

regulations. For instance, the controls required by MACT standards for sources in the Fossil Fuel 

Electric Power Generation and Petroleum Refinery source categories may be RACM.

 

47EPA CoST database.
16

4.0. RACM DEVELOPMENT FOR THE SECONDARY LEAD

SMELTING SOURCE CATEGORY.

This section presents control measures to consider for RACM development for the Secondary Lead

Smelting source category. Section 4.1 provides an overview of the Secondary Lead Smelting source

category. Section 4.2 provides a summary of the operations and lead emission points with respect to 

secondary lead smelting facilities. Section 4.3 provides a summary of the control measures utilized at 

secondary lead smelting facilities, and Section 4.4 provides a more detailed application of the RACM

criteria to each identified control measure.

4.1. Overview of Source Category.

The Secondary Lead Smelting source category includes any facility at which lead-bearing scrap

material, primarily, but not limited to, lead acid batteries, is recycled into elemental lead or lead alloys

by smelting.48 The corresponding NAICS Code for the Secondary Lead Smelting source category is

331492. The NAICS description for facilities with such NAICS code is “establishments primarily

engaged in alloying purchased nonferrous metals and/or recovering nonferrous metals from scrap.” The

NAICS description specifically includes establishments engaged in “lead recovering from scrap and/or

alloying purchased metals.”

49

As of March, 2012, there are 15 secondary lead smelting facilities in the United States. No new

secondary lead smelters have been built in the last 20 years. However, one facility is currently in the

process of expanding its operations.50 Another facility is currently under construction in South 

Carolina.51

4.2. Facility Operations and Lead Emission Points.

The secondary lead smelting process consists of pre-processing lead-bearing materials, melting lead

metal and reducing lead compounds of lead metal in the smelting furnace, and refining and alloying lead

to customer specifications. There are three types of emissions from secondary lead smelting facilities:

process emissions, process fugitive emissions, and fugitive dust emissions. Each type of emissions has

its own corresponding control measures.

52

Process emissions include exhaust gases from feed dryers and from blast, reverberatory, rotary, and

electric-melting furnaces. While such emissions include some organic compounds, process emissions

are mostly metal, primarily lead compounds. Such emissions are released from a stack directly into the

atmosphere. The control measures used to control such process emissions are fabric filters, wet

electrostatic precipitators (WESPs), and cartridge controls.53

 

48Memorandum – Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category, From Mike 

Burr, ERG, to Chuck French, EPA/OAQPS. April 2011. Page 2.

49North American Industry Classification System Website (Accessed December, 2011).

50Memorandum – Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category, From Mike 

Burr, ERG, to Chuck French, EPA/OAQPS. April 2011. Page 2.

51Correspondence with Nathan Topham of EPA/RTP (December, 2011). 

52Id at 2.

53Id.
17

Process fugitive emissions are released from various sources throughout the smelting process, including

smelting furnace charging and tapping points, refining kettles, agglomerating furnace product taps, and

kiln transition equipment. Process fugitive emissions are comprised primarily of metal emissions, such

as lead.54 The control measures used to control such emissions include partial and total enclosures,

which may or may not be maintained under negative pressure.

Fugitive dust emissions are another type of emissions from secondary lead smelting facilities. Such

emissions are not associated with a specific process or process fugitive vent or stack. Fugitive dust

emissions are comprised of metal emissions, such as lead, and result from the entrainment of emissions

in ambient air due to material handling activities, vehicle traffic, wind, and other activities.55 The control

measures used to control such emissions include paving unpaved roads, vacuuming paved roads, and

chemical stabilization of paved roads.

4.3. Identification and Summary of Possible RACM Candidates.

Table 4-2 provides a summary of control measures for which the RACM criteria are applied and the

relative likelihood that each control measure is a RACM. Specifically, each control measure is assigned 

a rating of 1 through 3; where the higher the number, the more likely that the control measure is a

RACM. Table 4-1 provides an explanation of these assigned values.

Table 4-1. General Meanings of Assigned RACM Ratings.

RACM 

Rating

General Meaning of RACM Rating

1 There is limited support for identifying the control measure as a RACM.

2 There is some support for identifying the control measure as a RACM; more than for a control measure 

with a RACM Rating of “1.”

3 There is substantial support for identifying the control measure as a RACM.

U 

(+ or -)

A “U” indicates that the likelihood that the control measure constitutes a RACM is undetermined due to 

incomplete information. A corresponding “+” indicates that despite incomplete information, an 

application of RACM criteria would likely suggest that the control measure is a RACM, while a “-” 

indicates that despite incomplete information, an application of the RACM criteria would likely suggest 

that the control measure is not a RACM.

 

54Id.

55Id.
18

Table 4-2. Secondary Lead Smelting Source Category - Summary of Known Control Measures

and Relative Likelihood that each Control Measure is a RACM.

RACM 

Rating

Control Measure Brief Reasoning for RACM Rating

3 Fabric filters controlling uncontrolled 

lead process emissions from stacks. 

1. Adoption by almost all sources.

2. Cost data suggest cost effective.

3. Identified as MACT for almost 14 years.

4. California‟s South Coast Air Quality 

Management District (SCAQMD) adopted a rule

practically requiring such a control measure; it

requires that filter media other than filter bags 

are to be rated by the manufacturer of achieving 

99.97% capture efficiency for 0.3 micron 

particles. 

1.5 Fabric filters with downstream add-on 

control devices controlling uncontrolled 

lead process emissions from stacks.

1. Adoption by 1 of 14 sources and plans to 

adopt by two other sources.

2. Cost data suggest not cost effective.

3. Not required by any known federal regulation.

1 Replacing old fabric filters controlling 

uncontrolled lead process emissions 

from stacks with new fabric filters. 

1. No known adoption.

2. Cost data suggest not cost effective.

3. Not required by any known federal regulation.

4. California‟s SCAQMD adopted a rule that 

might practically require such a control measure; 

it requires that filter media other than filter bags 

are to be rated by the manufacturer of achieving 

99.97% capture efficiency for 0.3 micron 

particles. 

U + Other control measures for process 

emissions from fabric filters: (1) 

switching bag types, (2) properly 

installing bags, (3) sealing ducts and 

dust conveyance devices, (4) replacing 

and not repairing torn bags.

1. Not enough information to apply RACM 

criteria. 

2. California‟s SCAQMD adopted a rule that 

might practically require such a control measure; 

it requires that filter media other than filter bags 

are to be rated by the manufacturer of achieving 

99.97% capture efficiency for 0.3 micron 

particles. 

3 Enclosure hoods and partial enclosures 

with wet suppression for process units 

and storage areas to capture process 

fugitive emissions. 

1. Adoption by all sources, and exceeded by a 

supermajority of sources.

2. No known cost data.

3. Identified as MACT for almost 14 years.

4. California‟s SCAQMD adopted a rule that 

requires total enclosures for many areas and 

operations. 

3 In addition to enclosure hoods, a 

combination of negative pressure total 

enclosures and partial enclosures with 

wet suppressions for process units and 

storage areas to capture fugitive 

emissions.

1. Adoption by 11 of 14 sources.

2. No known cost data.

3. Required by 2012 NESHAP for secondary 

lead smelters. 

4. California‟s SCAQMD adopted a rule that 

requires total enclosures under negative pressure 

for many areas/operations. 
19

RACM 

Rating

Control Measure Brief Reasoning for RACM Rating

3 In addition to enclosure hoods, negative 

pressure total enclosures for all process 

units and storage areas to capture 

process fugitive emissions.

1. Adoption by 7 of 14 sources.

2. No known cost data. 

3. Not required by any known federal 

regulations.

4. California‟s SCAQMD adopted a rule that 

requires total enclosures under negative pressure 

for many areas/operations, and the 2012 

NESHAP for secondary lead smelting requires 

such controls. 

3 Paving unpaved roads and cleaning 

paved roads for controlling fugitive dust 

sources.

1. Adoption by all sources.

2. Cost data suggest cost effective.

3. Identified as MACT for almost 14 years.

4. Required by California‟s SCAQMD rule as 

this rule requires cleaning surfaces subject to 

vehicular traffic and paving facility ground 

subject to traffic. 

3 Partial enclosure, wet suppression, and 

pavement cleaning of operating areas 

and storage piles; totally enclosing 

operating areas and storage piles; and 

vehicle washing at each facility exit to 

control fugitive dust lead emissions.

1. Adoption by all sources.

2. No known cost data available.

3. Identified as MACT for almost 14 years.

4. Required by rule adopted by California‟s 

SCAQMD. Rule requires several such measures 

including requiring dust-forming material to be 

stored in enclosure, washing/vacuuming 

surfaces accumulating lead-containing dust, etc.

U + Other control measures for controlling 

fugitive dust emissions: more complete 

vehicle washing inside buildings, 

improved roadway cleaning techniques, 

pavement of entire facility, cleaning of 

building and roofs, etc. 

1. Seven of 14 facilities adopted a combination 

of such control measures, and, generally, 

emissions from such facilities were lower. 

2. California‟s SCAQMD rule requires several 

such control measures.

3. The 2012 NESHAP for secondary lead 

smelting requires many such control measures. 

4.4. Application of RACM Criteria to Possible RACM Candidates.

4.4.1. Fabric Filters (or other Primary Controls) Controlling Uncontrolled Lead Emissions from Stacks.

The common use of fabric filters by secondary lead smelters suggests that fabric filters are the most

economically feasible control technologies for regulating process lead emissions from stacks. A 2011

review of information collection request responses from secondary lead smelters revealed that almost all

(if not all) secondary lead smelters use fabric filters to control uncontrolled PM (including lead) 

emissions from stacks. Several types of fabric filters are used by the industry, including shaker, pulse jet,

and reverse pulse jet fabric filters.

56

In addition, the available data suggest that fabric filters are cost effective for regulating process lead

emissions. Specifically, cost-effectiveness information for PM was available for selected control

technologies in the source category of Lead Processing, as shown in Table 4-3, where cost-effectiveness

 

56Id at 4.
20

values for fabric filters are on average roughly $400/ton.

57 This information suggests that fabric filters

are cost effective for regulating lead as well.

Table 4-3. Cost-Effectiveness Information for Selected Control Technologies for Controlling

Particulate Matter for the Lead Processing Source Category.

Control Technology Cost Effectiveness* 

($/ton PM)

Low/High Control

Efficiency

Dry Electrostatic Precipitator – Wire Plate Type 400 95/98

Fabric Filter – Reverse-Air Cleaned Type 500 99/99.5

Fabric Filter (Mech. Shaker Type) 450 99/99.5

WESP – Wire Plate Type 800 99/99.5

* Rounded to the nearest $50 and escalated from 1999 to 2011 U.S. dollars.58

The 1997 NESHAP for Secondary Lead Smelting suggests that such fabric filters are reasonably 

available. Specifically, the 1997 NESHAP applies to process emissions from the following furnace

configurations: collated blast and reverberatory furnace; blast furnace; and reverberatory, rotary and

electric furnaces. The 1997 NESHAP provides an emissions limit for lead compounds of 2.0 milligrams

per dry standard cubic meter (mg/dscm) from each such furnace configuration. Such a standard does not

explicitly require a control, such as a fabric filter, but such a control is practically required in order to 

comply with the emission limit. The fact that such controls were MACT 14 years ago, and have been 

required by all currently operating sources for at least 11 years, suggests that such controls may be

RACM today.

59

A review of state rules from California and Missouri further suggests that such control measures are 

reasonably available. These states were chosen for review because they both have secondary lead 

sources (2 in each state) within their states. Missouri incorporates the federal 1997 NESHAP into state 

law.60 California‟s SCAQMD adopted a rule practically requiring such a control measure adopted a rule

that might practically require such a control measure; it requires that filter media other than filter bags 

are to be rated by the manufacturer of achieving 99.97% capture efficiency for 0.3 micron particles.61

4.4.2. Fabric Filters (or other Primary Controls) Controlling Uncontrolled Lead Emissions with Add-on

Downstream Control Technologies.

The current use of add-on control technologies, such as WESP and high efficiency particulate air 

(HEPA) filters, downstream of fabric filters (or other primary controls) to further reduce lead emissions

from stacks suggests that such add-on control technologies are less economically feasible but are

becoming more economically feasible. Specifically, while only one secondary lead smelting facility uses

a WESP as an add-on control to a fabric filter, two other facilities currently have plans to install WESP

 

57EPA CoST database.

58In order to escalate from 1999 dollars to 2011 dollars, used the formula and approach presented in EPA‟s Control Strategy 

Tool (CoST) Control Measures Database (CMDB) Documentation, Page 9. 

59NESHAP for Secondary Lead Smelting, 40 CFR 63, Subpart X (Published June 13, 1997).

6010 CSR 10-6.075 Maximum Achievable Control Technology Regulations; Air Quality Standards, Definitions, Sampling, 

and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri. (Published August 16, 1977). 

Page 91.

61California (South Coast Air Quality Management District), Rule 1420.1 - Emission Standards for Lead from Large Lead 

Acid Battery Recycling Facilities (Adopted November 5, 2010).
21

units to be used as add-on controls to fabric filters. Several facilities also reported using HEPA filters as

add-on controls downstream of their fabric filters.

62

However, the available data suggest that using add-on control technologies downstream of fabric filters

is much less cost effective for controlling lead than the cost effectiveness of the primary control. 

Specifically, installing an add-on control technology, such as a WESP, downstream of the primary 

control would double the control technology costs. Moreover, because fabric filters can achieve 

efficiencies of greater than 99%, the amount of further lead emissions captured is relatively low

compared to the amount captured with a fabric filter controlling uncontrolled emissions. In fact, one 

recent estimate of the cost effectiveness of an add-on WESP at a secondary lead smelting facility in 

Quemetco, California, revealed that the cost effectiveness of the add-on WESP would be $295,900/ton 

PM (and $2,279,500/ton of lead)

63

. Thus using a WESP as an add-on control can be over 250 times less 

cost effective than using a WESP as a primary control. There is no known federal standard currently

requiring such a control measure.

There is no known federal standard currently requiring such a control measure. However, California‟s 

SCAQMD, which has two sources, adopted a rule that practically requires such a control measure by 

requiring 99.97% capture efficiency for 0.3 micron particles.

64

4.4.3. Replacing Old Fabric Filters Controlling Uncontrolled Lead Emissions from Stacks with New

Fabric Filters.

A recent comparison of fabric filter outlet lead emissions revealed that the controlling factor determining

the effectiveness of the fabric filter was the age of the fabric filter. Generally, older fabric filters have

higher outlet lead emissions, while newer fabric filters have lower outlet emissions. The average outlet

lead concentration for lead emissions for fabric filters installed in the 1960s is roughly 0.40 mg/dscm, in

the 1970s roughly 0.30 mg/dscm, in the 1980s roughly 0.20 mg/dscm, and in the 2000s less than 0.10

mg/dscm. Consequently, one possible control measure would be to replace old fabric filters with new

fabric filters, as on average, this could reduce lead emissions by a factor of four or more.65

Similarly, a recent comparison of fabric filter outlet lead emissions also revealed that another factor that

determines the effectiveness of the fabric filter is the type of fabric filter (e.g., shaker, pulse jet, reverse

bag pulse jet). Specifically, shaker fabric filters appear to have higher outlet lead concentrations than

those of the pulse jet or reverse bag pulse jet type. However, this finding may be misleading because the

majority of the older units appear to be shaker types.66

There is no known federal standard currently requiring old fabric filters to be replaced by higher 

efficiency types. A review of state rules from California and Missouri weakly suggests that such control 

measures might be within economic reach. Such states were chosen for review because they both have 

secondary lead sources (2 in each state) within their states. Missouri incorporates the federal 1997 

NESHAP into state law, which does not require such a measure.67 However, California‟s SCAQMD,

 

62Memorandum – Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category, From Mike 

Burr, ERG, to Chuck French, EPA/OAQPS. April 2011. Page 4.

63Cost estimate provided by Nathan Topham/EPA/OAQPS/SPPD/MIG.

64California (South Coast Air Quality Management District), Rule 1420.1 - Emission Standards for Lead from Large Lead 

Acid Battery Recycling Facilities (Adopted November 5, 2010).

65Id at 7.

66Id.

67Air10 CSR 10-6.075 Maximum Achievable Control Technology Regulations; Air Quality Standards, Definitions, 
22

which has two sources, adopted a rule that might practically require such a control measure; it requires 

that filter media other than filter bags are to be rated by the manufacturer of achieving 99.97% capture 

efficiency for 0.3 micron particles.68

4.4.4. Other Control Measures for Controlling Process Lead Emissions.

One company in the industry has suggested that Teflon (polytetrafluoroethylene) bags specifically

supplied by Gore-Tex© performed better than other bag types, such as polyester. The company also

suggested that the most critical factors influencing fabric filter performance are proper installation and

maintenance practices. The company mentioned specific practices such as ensuring proper installation of

the bags and properly sealing all ducts and dust conveyance devices help increase control efficiency. 

Additionally, the company claimed that replacing torn bags, rather than repairing them, can significantly

improve fabric filter performance. However, while such control measures might be utilized, information

is not available for a RACM criteria analysis.69

4.4.5. Partial and Total Enclosures to Control Fugitive Process Lead Emissions.

The complete adoption of partial and total enclosures by secondary lead smelters to control fugitive

process emissions suggests that partial and total enclosures are economically feasible control measures.

Specifically, all secondary lead smelting facilities currently use partial and total enclosures to control

process fugitive emissions from the following emission sources: smelting furnace and dryer charging

hoppers, chutes, and skip hoists; smelting furnace lead taps, and molds during tapping; smelting furnace

slag taps, and molds during tapping; refining kettles; dryer transition pieces; and agglomerating furnace

product taps. All secondary lead smelters equip such fugitive emission sources with an enclosure hood

or locate such sources in a total enclosure subject to general ventilation that maintains the building at a

lower than ambient pressure to ensure in-draft through any doorway opening accordingly. All process

fugitive hoods (except for refining kettles and dryer transition pieces) are ventilated to ensure a face

velocity of at least 90 meters per minute at all hood openings. Process fugitive hoods for refining kettles

are ventilated to maintain a face velocity of at least 75 meters per minute. Process fugitive hoods for

dryer transition pieces are ventilated to maintain a face velocity of at least 110 meters per minute. Such

ventilation air is conveyed to a controlled device. 70 No cost-effectiveness information was available for

such control measures.

The 1997 NESHAP for Secondary Lead Smelting requires such partial and total enclosure control

measures for fugitive process lead emissions. The fact that such controls were MACT 14 years ago, and 

have been required by all currently operating sources for 11 years, suggests such controls are RACM 

today.

71

A review of state rules from California and Missouri further suggests that such control measures are 

reasonable. Such states were chosen for review because they both have secondary lead sources (2 in 

 

Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August 

16, 1977). Page 91.

68California (South Coast Air Quality Management District), Rule 1420.1 - Emission Standards for Lead from Large Lead 

Acid Battery Recycling Facilities (Adopted November 5, 2010).

69Memorandum – Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category, From Mike 

Burr, ERG, to Chuck French, EPA/OAQPS. April 2011. Page 7.

70Id at 11.

71NESHAP for Secondary Lead Smelting, 40 CFR 63, Subpart X (Published June 13, 1997).
23

each state) located within the state. Missouri incorporates the federal 1997 NESHAP into state law.72

California‟s SCAQMD adopted a rule that requires total enclosure of several areas (e.g., battery 

breaking areas; materials storage and handling areas; dryer and dryer areas; smelting furnaces; 

agglomerating furnaces; and refining and casting areas).

4.4.6. In Addition to Enclosure Hoods, a Combination of Negative Pressure Total Enclosures and Partial

Enclosures with Wet Suppression for Process Units and Storage Areas.

The common use of, in addition to enclosure hoods, a combination of negative pressure total enclosures

and partial enclosures with wet suppression for process units and storage areas, suggests these additional 

control measures are economically feasible. Specifically, 12 of the 14 secondary lead smelting facilities

use a combination of negative pressure total enclosures and partial enclosures with wet suppression for

process units and storage areas in addition to enclosures hoods. Additionally, half of the secondary lead

smelting facilities, in addition to enclosure hoods for process fugitive sources, use negative pressure

total enclosures for all process units and storage areas.73 No cost-effectiveness information was available

for such control measures.

74

There is no identified federal standard currently requiring such a control measure. However, California

requires negative pressure total enclosures for several areas (e.g., battery breaking areas; materials 

storage and handling areas; dryer and dryer areas; smelting furnaces; agglomerating furnaces; and 

refining and casting areas).

75 Also, the 2012 NESHAP for Secondary Lead Smelting requires facilities to 

locate and control sources of fugitive lead emissions within total enclosures that are maintained under 

negative pressure and vented to a control device.76 These emissions sources include the smelting 

furnaces; smelting furnace charging areas; lead taps; slag taps; molds during tapping; battery breakers, 

refining kettles; casting areas; dryerts; material handling areas; and areas where dust from fabric filters, 

sweepings, or used fabric filters are processed.

4.4.7. Paving Unpaved Roads and Cleaning Paved Roads for Controlling Fugitive Dust Lead Emissions.

The common practice of paving plant roadways, including all areas subject to vehicle traffic – and

cleaning such pavement twice per day, except when natural precipitation makes cleaning unnecessary or

when sand or similar material has been spread on plant roadways to provide traction on ice and snow,

suggest that such practice is economically feasible. Specifically, all secondary smelting facilities have

adopted such practices.77

In addition, available data suggest that such control measures are cost effective for controlling lead

emissions. Specifically, cost-effectiveness information was available for the control measures in the

source category of Lead Processing for PM in 2010 dollars, as shown in Table 4-3, where cost-

 

72Air10 CSR 10-6.075 Maximum Achievable Control Technology Regulations; Air Quality Standards, Definitions, 

Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August 

16, 1977). Page 91.

73Memorandum – Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category, From Mike 

Burr, ERG, to Chuck French, EPA/OAQPS. April 2011. Page 11.

74Id. at 11.

75California (South Coast Air Quality Management District), Rule 1420.1 - Emission Standards for Lead from Large Lead 

Acid Battery Recycling Facilities (Adopted November 5, 2010).

76NESHAP for Secondary Lead Smelting (Published January, 2012).

77Memorandum – Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category, From Mike 

Burr, ERG, to Chuck French, EPA/OAQPS. April 2011. Page 11.
24

effectiveness values for such measures were on average roughly $500/ton.78 Since lead is commonly

associated with PM, this information suggests that such control measures are cost effective for

controlling lead as well.

Table 4-4. Cost-Effectiveness Information for Selected Control Measures for Controlling

Particulate Matter with respect to All Source Categories.

Control Measure Cost Effectiveness*

($/ton PM)

Control Efficiency

(%)

Vacuum Sweeping Paved Roads 500 50.0

Hot Asphalt Paving of Unpaved Roads 800 66.6

* Rounded to the nearest $100 and escalated from 1999 to 2011 U.S. dollars.79

A review of state rules from California and Missouri suggests such control measures reasonable. Such 

states were chosen for review because they both have secondary lead sources (2 in each state) within the 

state. Missouri incorporates the federal 2007 NESHAP into state law, which only requires such control 

measures for major sources.80 A California‟s SCAQMD rule requires paving facility grounds and daily 

cleaning/sweeping of such paved surfaces.

81

4.4.8. Partially Enclosing , Wet Suppressing, and Pavement Cleaning of Operating Areas and Storage

Piles; Totally Enclosing of Operating Areas and Storage Piles; and Vehicle Washing at each

Facility Exit to Control Fugitive Dust Lead Emissions.

The common practices of (1) partially enclosing, wet suppressing, and pavement cleaning of operating

areas and storage piles, (2) totally enclosing operating areas and storage piles, and (3) vehicle washing at

each facility exit to control fugitive dust lead emissions suggests that such practices are economically

feasible. All secondary lead smelting facilities have adopted such practices. Specifically, for battery

breaking areas, all secondary lead smelting facilities partially enclose storage piles, wet suppress storage

piles with sufficient frequency and quantity to prevent the formation of dust, and clean the pavement of 

such areas twice per day; or alternatively, totally enclose the battery breaking area. For furnace areas, all

secondary lead smelting facilities partially enclose such areas and clean the pavement of such areas

twice per day, or alternatively, totally enclose and ventilate the enclosed areas to a control device. For

refining and casting areas, all secondary lead smelting facilities partially enclose and clean the pavement

of such areas twice per day; or alternatively, totally enclose and ventilate such areas to a control device.

For material and storage handling areas, all secondary lead smelting facilities partially enclose such

areas, wet suppress the storage piles with sufficient frequency and quantity to prevent the formation of

dust, wash vehicles at each exit from the such areas, and pave such areas; or alternatively, totally enclose

such areas and ventilate to a control device. Moreover all facilities wash vehicles at the exits of facility 

property.

82

 

78EPA CoST database.

79In order to escalate from 1999 dollars to 2011 dollars, used the formula and approach presented in EPA‟s Control Strategy 

Tool (CoST) Control Measures Database (CMDB) Documentation, Page 9. 

80Air10 CSR 10-6.075 Maximum Achievable Control Technology Regulations; Air Quality Standards, Definitions, 

Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August 

16, 1977). Page 91.

81California (South Coast Air Quality Management District), Rule 1420.1 - Emission Standards for Lead from Large Lead 

Acid Battery Recycling Facilities (Adopted November 5, 2010).

82Memorandum – Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category, From Mike 

Burr, ERG, to Chuck French, EPA/OAQPS. April 2011. Page 11.
25

No cost-effectiveness information is available for such practices. The 1997 NESHAP for Secondary

Lead Smelting requires such control measures for controlling fugitive dust process lead emissions. The

old NESHAP was published June 1997. The fact that such controls were MACT 14 years ago, and have 

been required by all currently operating sources for 15 years, suggests such controls are RACM today.83

The 2012 NESHAP requires the total enclosure under negative pressure with ventilation to a control 

device of process areas that are sources of fugitive lead emissions. The 2012 NESHAP also requires 

facilities to adopt a list of specified work practice standards to minimize fugitive emissions, including 

wet suppression, pavement cleaning, and vehicle washing at facility exits.84

A review of state rules from California and Missouri suggests such control measures are reasonable. 

Such states were chosen for review because they both have secondary lead sources (2 in each state) 

within the state. Missouri incorporates the federal 1997 NESHAP into state law, which only requires 

such a control measure for major sources.85 California‟s SCAQMD rule requires such control measures 

and is even more stringent.86

4.4.9. Other Control Measures for Controlling Fugitive Dust Emissions.

A recent review revealed that, generally, facilities that adopted the following additional fugitive dust

emissions controls had lower fugitive dust emissions:

1. More complete vehicle washing inside buildings.

2. Improved roadway cleaning techniques and frequency.

3. Pavement of entire facility grounds.

4. Cleaning of building roofs and exteriors.

5. Use of daily ambient monitoring to diagnose plant activities that lead to exceedances of the

NAAQS for lead.

6. Timely cleaning of accidental releases.

7. Inspection of outside battery storage areas for broken batteries.

87

Moreover, California‟s SCAQMD adopted a rule that requires several such control measures for 

controlling fugitive dust emissions, which include the following:

1. Clean roof top structures and other areas where lead-containing waste generated from 

housekeeping activities are stored, disposed of, recovered, or recycled by wet wash or vacuum 

equipped with a filter rated by the manufacturer to achieve 99.97% capture efficiency for 0.3 

micron particles in a manner that does not generate fugitive lead dust (monthly or quarterly, 

depending on the height of the roof).

2. Monthly inspection of total enclosures and facility structures that contain fugitive dust emissions 

for gaps, breaks, separations, leak points, etc. 

3. Pave, concrete, asphalt or encapsulate certain facility grounds.

 

83NESHAP for Secondary Lead Smelting, 40 CFR 63, Subpart X (Published June, 1997).

84NESHAP for Secondary Lead Smelting (Published January, 2012).

85Air10 CSR 10-6.075 Maximum Achievable Control Technology Regulations; Air Quality Standards, Definitions, 

Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August 

16, 1977). Page 91.

86California (South Coast Air Quality Management District), Rule 1420.1 - Emission Standards for Lead from Large Lead 

Acid Battery Recycling Facilities (Adopted November 5, 2010).

87Memorandum – Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category, From Mike 

Burr, ERG, to Chuck French, EPA/OAQPS. April 2011. Page 11.
26

4. Storing all materials capable of generating any amount of fugitive lead-dust in a sealed, leakproof container.

88

In addition, the 2012 NESHAP for Secondary Lead Smelting requires many such control measures for 

controlling fugitive emissions to be installed by January 2014. Sources that will be subject to the 

NESHAP must prepare an operating procedures manual that describes in detail the work practice 

standards that will be put in place and implemented to control fugitive dust emissions from plant 

roadways, plant buildings, plant building exteriors, accidental releases, battery storage areas, equipment 

maintenance areas, material storage areas and material handling areas. Specifically, the proposed 

NESHAP would require the following fugitive dust control measures to be included in the operating 

procedures manual: 

1. Cleaning certain areas by wet wash or a vacuum equipped with a filter rated by the manufacturer 

to achieve 99.97 percent capture efficiency for 0.3 micron particles.

2. Paving all areas subject to vehicle traffic and cleaning such pavement twice per day.

3. Monthly or quarterly cleaning of building roofs and exteriors, depending on the height of such 

roofs and exteriors.

4. Initiating cleaning of affected areas within one hour after any accidental release of lead dust.

5. Inspection of unenclosed battery storage areas twice each day.

6. Washing of vehicles at each exit of the material storage and handling areas.

7. Paving grounds on the facility sufficient to prevent wind-blown dust.89

 

88California (South Coast Air Quality Management District), Rule 1420.1 - Emission Standards for Lead from Large Lead 

Acid Battery Recycling Facilities (Adopted November 5, 2010).

89NESHAP for Secondary Lead Smelting (Published January, 2012).
27

5.0. RACM DEVELOPMENT FOR THE LEAD ACID BATTERY

MANUFACTURING SOURCE CATEGORY.

This section presents control measures to consider for RACM development for the Lead Acid Battery

Manufacturing source category. Section 5.1 provides an overview of the Lead Acid Battery source

category. Section 5.2 provides a summary of operations and lead emission points for lead acid battery 

facilities. Section 5.3 provides a summary of the control measures utilized at lead acid battery 

manufacturing facilities, and Section 5.4 provides a more detailed application of the RACM criteria to 

each identified control measure. 

5.1. Overview of Source Category.

The Lead Acid Battery Manufacturing source category includes any facility that manufactures either

starting lighting/ignition batteries that are primarily used in automobiles or industrial/traction batteries

that are used for uninterruptible power supply or to power electric vehicles such as forklifts.90 The

corresponding NAICS code for the Lead Acid Battery Manufacturing source category is 335911. The

NAICS Description for facilities with such NAICS Code is “establishments primarily engaged in

manufacturing primary batteries.” The NAICS description specifically includes “lead acid storage

batteries manufacturing.”91

Today, there are approximately 60 lead acid battery manufacturing facilities in the United States, all of 

which are area sources. Such facilities are located throughout 23 states and Puerto Rico.92

5.2. Facility Operations and Lead Emission Points.

Lead acid batteries are produced from lead alloy ingots, sheet lead, and lead oxide. Lead acid battery

manufacturing consists of several processes, including the following: (1) grid casting, (2) grid stamping,

lead paste mixing, (3) the three-process operation of plate stacking, plate burning and plate assembly, (4)

charge formation, and (5) lead reclamation.93

Specifically, the manufacturing process includes preparing battery grids through stamping or casting

lead. Lead oxide paste is added to the grids in the grid pasting operation creating plates that are cured

and assembled into a battery. Batteries are then charged using sulfuric acid in the forming operations.

Lead oxide may be prepared by the battery manufacturer, as is the case for many larger battery

manufacturing facilities, or may be purchased from a supplier. The control measures that are used to

control such process emissions are fabric filters for the paste mixing, three-process plate operation, lead

oxide manufacturing, and other lead emitting processes; and impingement scrubbers for the grid casting

and lead reclamation operations.

94

 

90Memorandum – Lead Acid Battery Manufacturing Area Source Category Additional Information to Support Proposed Rule, 

From Nancy Jones, EC/R, To U.S. EPA Docket Number EPA-HQ-OAR-2006-0897. February 28, 2007. Page 1.

91North American Industry Classification System Website (Accessed December, 2011).

92Memorandum – Lead Acid Battery Manufacturing Area Source Category Additional Information to Support Proposed Rule, 

From Nancy Jones, EC/R, To U.S. EPA Docket Number EPA-HQ-OAR-2006-0897. February 28, 2007. Page 1.

93Id at 1.

94Id at 2.
28

5.3. Identification and Summary of Possible RACM Candidates.

Table 5-2 provides a summary of control measures used in the Lead Acid Battery source category for

which the RACM criteria are applied in section 5.4 and the relative likelihood that each control measure

is a RACM. Specifically, each control measure is assigned a rating of 1 through 3; where the higher the

number, the more likely that the control measure is a RACM. Such assigned values are explained in

Table 5-1.

Table 5-1. General Meanings of Assigned RACM Ratings.

RACM 

Rating

General Meaning of RACM Rating

1 There is limited support for identifying the control measure as a RACM. 

2 There is some support for identifying the control measure as a RACM; more than for a control measure 

with a RACM Rating of “1.”

3 There is substantial support for identifying the control measure as a RACM.

U 

(+ or -)

A “U” indicates that the likelihood that the control measure constitutes a RACM is undetermined due 

to incomplete information. A corresponding “+” indicates that despite incomplete information, an 

application of RACM criteria would likely suggest that the control measure is a RACM, while a “-” 

indicates that despite incomplete information, an application of the RACM criteria would likely 

suggest that the control measure is not a RACM.

Table 5-2. Lead Acid Battery Source Category - Summary of Known Control Measures and

Relative Likelihood that each Control Measure is a RACM.

RACM 

Rating

Control Measure Brief Reasoning for RACM Rating

3 Fabric Filters to Control Process 

Lead Emissions from Paste Mixing, 

Three-Process Plate Operation, 

Lead Oxide Manufacturing, and 

Other Lead Emitting Processes.

1. Adoption by almost all (or all) sources.

2. Cost data suggest cost effective.

3. EPA determined such control measures constitute 

BDT over thirty years ago and as GACT four years 

ago. 

4. California‟s SCAQMD adopted a rule practically 

requiring such a control measure, as it requires 98% 

efficiency for lead for facilities exceeding specific 

process and emission thresholds (i.e., processing 

more than 2 tons of lead per year with daily 

emissions of lead greater than or equal to 

0.5lbs/day).

3 Impingement Scrubbers to Control 

Process Lead Emissions from Lead 

Reclamation and Grid Casting 

Operations.

1. Adoption by almost all (or all) sources.

2. Cost data suggest cost effective.

3. EPA determined such control measures constitute 

BDT over thirty years ago and as GACT four years 

ago.

4. California‟s SCAQMD adopted a rule practically 

requiring such a control measure, as it requires 98% 

efficiency for lead for facilities exceeding specific 

process and emission thresholds (i.e., processing 

more than 2 tons of lead per year with daily 

emissions of lead greater than or equal to 

0.5lbs/day).

1 Other control measures to control 

process lead emissions from stacks.

1. Only limited adoption by facilities revealed 

through a review of publicly available information 
29

RACM 

Rating

Control Measure Brief Reasoning for RACM Rating

and correspondence with EPA employees.

2. EPA determined that cost data suggested such 

additional control measures not cost effective.

3. EPA refused to develop any such controls as 

GACT technology as recent as four years ago. 

4. California‟s SCAQMD adopted a rule practically 

requiring such control measures as it requires 98% 

efficiency for lead for facilities exceeding specific 

process and emission thresholds (i.e., processing 

more than 2 tons of lead per year with daily 

emissions of lead greater than or equal to 

0.5lbs/day)..

1.5 Paving unpaved roads and cleaning 

unpaved roads for controlling 

fugitive dust sources.

1. Only limited adoption by facilities revealed 

through a review of public available information and 

correspondence with EPA employees.

2. Cost data suggest cost effective.

3. Not required by any known federal regulation.

4. Required in part by California‟s SCAQMD. The 

SCAQMD rule requires cleaning surfaces subject to 

vehicular traffic weekly.

U - Other Control measures to control 

fugitive emissions. 

1. Lack of known adoption by any facilities for 

controlling lead emissions.

2. No known cost data. However, lead acid battery 

facilities are all area sources, which results in

fugitive dust control measures being less likely to be 

cost effective.

3. Not required by any known federal regulation. 

4. California‟s SCAQMD requires several such 

measures, such as requiring dust-forming material to 

be stored in enclosures, washing/vacuuming surfaces 

accumulating lead-containing dust, etc.

5.4. Application of RACM Criteria to Possible RACM Candidates.

5.4.1. Fabric Filters to Control Process Lead Emissions from Paste Mixing, the Three-Process Plate 

Operation, Lead Oxide Manufacturing, and Other Lead Emitting Processes; and Impingement 

Scrubbers to Control Process Lead Emissions from Lead Reclamation and Grid Casting 

Operations. 

The almost complete adoption of fabric filters by lead acid battery manufacturing facilities in the United 

States to control process lead emissions from paste mixing, the three-process plate operation, lead oxide 

manufacturing, and other lead-emitting processes; and almost complete adoption of impingement 

scrubbers to control process emissions from lead reclamation and grid casting operations, suggests that 

such control measures are the most economically feasible control technologies for regulating lead 

emissions from such operations in the Lead Acid Battery source category. Specifically, almost all 

(53/58) of the lead acid battery manufacturing facilities comply with the current NSPS and NESHAP 

standards for the Lead Acid Battery source category, which are identical standards. The NSPS and 
30

NESHAP emission limitations, control efficiencies, and control bases for relevant operations are listed 

in Table 5-3.

95

Table 5-3. NSPS and NESHAP for Lead Acid Battery Manufacturing (40 CFR 60, Subpart KK; 

40 CFR 63, Subpart PPPPPP).

Operation Emission Limitation Control Efficiency Control Basis

Paste mixing 1 mg/dscm

(0.00044 gr/dscf)

99% Fabric filter

(6:1 air to cloth ratio)

Three-process operation 1 mg/dscm

(0.00044 gr/dscf)

99% Fabric filter

(6:1 air to cloth ratio)

Lead oxide 

manufacturing

5 mg/kg of lead

processed

> 99% Fabric Filter

(2:1 air to cloth ratio)

Other lead emitting 

processes

1 mg/dscm

(0.00044 gr/dscf)

90% Fabric filter

(6:1 air to cloth ratio)

Grid casting 0.4 mg/dscm

(0.00024 gr/dscf)

90% Impingement scrubber

Lead Reclamation 4.5 mg/dscm

(0.0022 gr/dscf)

90% Impingement scrubber

The available cost information might further suggest that such control measures are cost effective. For 

example, a recent cost analysis was conducted to determine the cost effectiveness of fabric filters for the 

paste mixing, three plate process, and other lead process operations for a typical lead acid battery 

manufacturing plant. Such cost analysis assumed the characteristics for the fabric filters and plants listed 

in Table 5-4. Such cost analysis revealed that the cost effectiveness of the fabric filters ranged from 

roughly $381,000 to $4.3 million per ton of lead.96

Table 5-4. Cost Effectiveness of Fabric Filters Controlling Previously Uncontrolled Lead 

Emissions for Paste Mixing, Three Plate Process, and Other Lead Processes in a Typical Lead 

Acid Battery Manufacturing Plant.

Operation Capital Costs 

Low/High 

($)

Annual Costs 

Low/High 

($)

Equipment 

Life 

(Years)

Annual 

Emissions

(Tons Lead 

per year)

Cost Effectiveness, 

Low/High 

($/Ton Lead)

Paste 

Mixing

70,000/

70,000

224,000 / 

224,000

20 0.052 4,375,000 / 4,375,000

Three 

Plate 

Process 

130,000/

520,000

253,000 / 

321,000

20 0.420 617,857 / 826,190

Other 

Lead 

Processes

234,000/

773,000

290,000 / 

385,000

20 0.790 381,898 / 536,265

Current and past federal regulations suggest that such control measures are reasonably available. 

Specifically, the NSPS for Lead Acid Battery Manufacturing Plants (40 CFR 60, Subpart KK), 

 

95Id. at Attachment 2.

96Memorandum – Lead Acid Battery Manufacturing Area Source Category Costing Information in Response to Comments on 

Proposed Rule, From Nancy Jones, EC/R, To Sharon Nizich, EPA/OAQPS/SPPD/MICG. June 12, 2007. Page 4.
31

published in 1982, imposes the control technologies with corresponding emissions limitations and 

control efficiencies shown in Table 5-3.

97 Such standards require control technologies that are BDT. The 

fact that such control measures were BDT almost thirty years ago suggests that each such control 

measure constitutes a RACM.

Moreover, the current NESHAP for the Lead Acid Battery Manufacturing Area Sources (40 CFR 63, 

Subpart PPPPPP), published in 2007, incorporates the exact same control measures and corresponding 

emission limits and control efficiencies as the older NSPS.98 The current NESHAP requires control 

technologies that are generally available control technologies (GACT). The fact that EPA determined 

that such control measures were GACT technologies in the source category four years ago further

suggests that such control measures are RACM.

A review of rules from California and Missouri further suggests that such control measures are 

reasonable. Such states were chosen for review because they both have lead acid battery manufacturing 

sources within the state. Missouri incorporates the federal NESHAP into state law. 99 California‟s 

SCAQMD adopted a rule practically requiring such a control measure, as it requires 98% efficiency for 

lead for facilities exceeding specific process and emission thresholds (i.e., processing more than 2 tons 

of lead per year with daily emissions of lead greater than or equal to 0.5lbs/day).

100

5.4.2. Other Control Measures to Control Process Lead Emissions from Stacks. 

A review of publicly available literature and correspondence with several EPA employees revealed 

limited adoption of other control measures to control process lead emissions from the stacks from lead 

acid battery facilities. Specifically, one lead acid battery manufacturing facility has fabric filter 

baghouses with HEPA filter add-ons to control process lead emissions from two of its mills.101 Such 

limited known adoption suggests that other control measures to control lead process emissions from 

stacks in lead acid battery manufacturing plants are not reasonably economically feasible. 

The available cost data further suggest that other control measures to control process emissions from 

stacks is not cost effective. For example, a recent analysis was performed to determine the cost for a 

typical battery manufacturing plant to upgrade from the current 90/99.0 percent controls (i.e., controls 

required by current NESHAP and NSPS) to 99.9 percent controls. Such estimate revealed that the total 

capital investment to upgrade to 99.9 percent controls could range from more than $600,000 to almost 

$1.7 million, depending on the technologies selected. Moreover, the annual costs of such additional 

control for a typical plant would be around $1.2 million per year due to increased operator labor costs, 

maintenance labor/material costs, electricity/other utility costs, taxes, insurance and capital recovery 

costs. Such cost represents about 5 percent of the total shipments for an average lead acid battery 

establishment. EPA has indicated that it does not believe that such costs are appropriate for the area 

sources in the category. Such costs incurred per ton of lead emissions reduced would be around 

 

97NSPS for Lead acid Battery Manufacturing Plants, 40 CFR 60, Subpart KK (Published April 16, 1982).

98NESHAP for Lead Acid Battery Manufacturing Plants, 40 CFR 63 Subpart PPPPPP (Published July 16, 2007).

99Air10 CSR 10-6.075 Maximum Achievable Control Technology Regulations; Air Quality Standards, Definitions, 

Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August 

16, 1977). Page 91.

100California (South Coast Air Quality Management District), Rule 1420 - Emission Standards for Lead (Published 

September, 1992).

101Correspondence with Stephanie Doolan /EPA Region 7 in December, 2011 revealed that the Exide Facility in Salina, 

Kansas has adopted such additional control measures that control process lead emissions from stacks. 
32

$450,000 to $500,000 based on replacing existing control devices or installing additional devices to 

increase control efficiency up to 99.9 percent.102

In addition, the EPA decision to not incorporate other control measures to control process emissions 

from stacks in recent standard development further suggests that there are no other control measures that 

are economically feasible. Specifically, citing the excessive costs, EPA decided that other control 

measures to control process emissions from stacks did not constitute GACT in the recent NESHAP for 

the Lead Acid Battery Manufacturing Source Category.103

A review of state rules from California and Missouri suggests that such control measures might be 

within economic reach. Such states were chosen for review because they both have lead acid battery 

manufacturing sources within the state. Missouri only incorporates the federal NESHAP into state 

law.104 However, California‟s SCAQMD adopted a rule that might practically require such a control 

measure as it requires 98% efficiency for lead for facilities exceeding specific process and emission 

thresholds (i.e., processing more than 2 tons of lead per year with daily emissions of lead greater than or 

equal to 0.5lbs/day).

105

5.4.3. Hot Asphalt Paving of Unpaved Roads, Chemical Stabilization of Unpaved Roads, and Vacuum 

Cleaning of Paved Roads to Control Fugitive Dust Lead Emissions. 

A review of publicly available literature and correspondence with several EPA employees revealed 

limited adoption of control measures, like paving unpaved roads, chemically stabilizing unpaved roads, 

and vacuum cleaning of paved roads, to control fugitive dust emissions from lead acid battery facilities.

Specifically, one lead acid battery manufacturing facility is paved on two sides, needs repair on one side, 

and the state in which the facility is located wants the facility to pave the unpaved side and repair the 

other side to control emissions.

106 Such limited adoption of such control measures suggests that such

control measures do not constitute RACM.

Cost-effectiveness data for PM suggest that such control measures might be cost effective for controlling 

lead emissions as well. Specifically, such control measures have been shown to be cost effective, on 

average, for all facilities in all source categories for controlling PM, as shown in Table 5.5.

107 However, 

all of the facilities in the Lead Acid Battery Manufacturing source category are area sources, which 

suggests that the amount of emissions are much smaller than on average for all facilities.108

Consequently, with lower emissions, the cost effectiveness for such control measures would decrease. 

 

102Memorandum – Lead Acid Battery Manufacturing Area Source Category Costing Information in Response to Comments 

on Proposed Rule, From Nancy Jones, EC/R, To Sharon Nizich, EPA/OAQPS/SPPD/MICG. June 12, 2007. Page 4.

103Introductory text to Lead Acid Battery Manufacturing Area Source NESHAP, 40 CFR 63, Subpart PPPPPP (Published 

July 16, 2007).

104Air10 CSR 10-6.075 Maximum Achievable Control Technology Regulations; Air Quality Standards, Definitions, 

Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August 

16, 1977). Page 91.

105California (South Coast Air Quality Management District), Rule 1420 - Emission Standards for Lead (Published 

September, 1992).

106Correspondence with Stephanie Doolan /EPA Region 7 in December, 2011, regarding the Exide Facility in Salina, Kansas.

107EPA CoST database.

108Memorandum – Lead Acid Battery Manufacturing Area Source Category Additional Information to Support Proposed 

Rule, From Nancy Jones, EC/R, To U.S. EPA Docket Number EPA-HQ-OAR-2006-0897. February 28, 2007.
33

Table 5-5. Cost-Effectiveness Information for Selected Control Measures for Controlling 

Particulate Matter with respect to the All Source Categories.

Control Measure Cost Effectiveness*

($/Ton of PM)

Control Efficiency

(%)

Vacuum Sweeping Paved Roads 400 50.0

Hot Asphalt Paving of Unpaved Roads 700 66.6

Chemical Stabilization of Unpaved Road 2600 37.5

* Rounded to the nearest $100 and escalated from 1999 to 2011 U.S. dollars.109

No federal standards adopt such control measures. A review of state rules from California and Missouri 

suggests such control measures are reasonable. Such states were chosen for review because they both 

have secondary lead sources within the state. Missouri incorporates the federal NESHAP into state law, 

which does not require such control measures.110 A California SCAQMD rule partially provides for such 

control measures by requiring sources to clean surfaces weekly that are subject to vehicular traffic.111

5.4.4. Other Control Measures for Controlling Fugitive Lead Emissions.

A review of state rules from California and Missouri suggests such control measures might be within 

economic reach, but there is a lack of support that such control measures are reasonably available. Such 

states were chosen for review because they both have secondary lead sources within the state (2 in each 

state). Missouri only incorporates the federal NESHAP into state law, which does not require such 

control measures.112 However, a California SCAQMD rule requires several such control measures 

including requiring dust-forming material to be stored in an enclosure, washing/vacuuming surfaces 

accumulating lead-containing dust, etc.113

 

109In order to escalate from 1999 dollars to 2011 dollars, used the formula and approach presented in EPA‟s Control Strategy 

Tool (CoST) Control Measures Database (CMDB) Documentation, Page 9. 

110Air10 CSR 10-6.075 Maximum Achievable Control Technology Regulations; Air Quality Standards, Definitions, 

Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August 

16, 1977). Page 91.

111California (South Coast Air Quality Management District), Rule 1420 - Emission Standards for Lead (Published 

September, 1992).

112Air10 CSR 10-6.075 Maximum Achievable Control Technology Regulations; Air Quality Standards, Definitions, 

Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August 

16, 1977). Page 91.

113California (South Coast Air Quality Management District), Rule 1420 - Emission Standards for Lead (Published 

September, 1992).
34

6.0. RACM DEVELOPMENT FOR THE IRON AND STEEL

FOUNDRIES SOURCE CATEGORY.

This section presents control measures to consider for RACM development for the Iron and Steel 

Foundries source category. Section 6.1 provides an overview of the Iron and Steel Foundries source 

category. Section 6.2 provides a summary of operations and lead emission points for iron and steel 

foundry facilities. Section 6.3 provides a summary of the control measures utilized at iron and steel 

foundries facilities, and Section 6.4 provides a more detailed application of the RACM criteria to each 

identified control measure. 

6.1. Overview of Source Category.

The Iron and Steel Foundries source category is actually two source categories that are normally

considered collectively due to the similarity in processes, emissions and controls. The Iron Foundries

source category consists of plants engaged in producing final shape castings from grades of iron. The

production steps related to the source category include raw materials handling, metal melting, mold/core

production, and casting/finishing.114 The corresponding NAICS Code for the Iron Foundries source

category is 331511. The NAICS Description for facilities with such NAICS Code is “establishments

primarily engaged in manufacturing iron castings and further manufacturing them into finished products

that are further classified based on the specific finished product.”115

The Steel Foundries category includes any facility engaged in producing final shape steel castings by the

melting, alloying, and molding of pig iron and steel scrap. This source category also includes raw

materials handling, metal melting, mold/core production, and casting/finishing.

116 The corresponding

NAICS codes for the Steel Foundries source category are 331512 and 331513. The NAICS Descriptions

for facilities with NAICS Codes of 331512 and 331513 are “establishments primarily engaged in

manufacturing steel casings (except steel investment castings) and manufacturing steel investment

castings and further manufacturing them into finished products” and “establishments primarily engaged

in manufacturing steel investment castings and manufacturing steel castings and further manufacturing

them into finished products,” respectively.

117

A 1992 census revealed that there were roughly 2800 iron and steel foundries in the United States at that

time. Exactly 595 iron and steel foundries returned survey data from an EPA Information Collection

Request in 2002, and roughly 100 of such sources are major sources, while the remaining are area 

sources.118

 

114National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 

1-2.

115North American Industry Classification System Website.

116National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 

1-2.

117North American Industry Classification System Website.

118National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 

5-12.
35

6.2. Facility Operations and Lead Emission Points.

The operations and processes for iron and steel foundries include the following: (1) pattern making, (2)

mold/core making, (3) scrap preparation, (4), metal melting, (5) pouring, cooling, and shakeout, (6) sand

handling, (7) mechanical finishing, and (8) cleaning and coating.119

The first step in production of castings is making a pattern, which is a metal, wood, or plaster replica of

a finishing casting, which can be used to create molds into which molten metal is poured. The next step

in production of castings is preparing and melting metal, where typically recycled scrap metals are used

as the source of metal. Such scrap metals typically undergo some type of preparation prior to melting

such as sizing, cleaning, and drying. Then such scrap is “charged” to a furnace for melting, and the

molten metal is poured from the furnace (i.e., tapped) into either a holding furnace or a transfer ladle,

and then the molten metal is transported to the pouring location. Upon reaching the pouring area, the

molten metal is poured into a mold. After it has solidified and cooled, it is separated from the mold, and

the casting is transferred to a finishing and cleaning area. Specific finishing and cleaning operations will

vary depending on the type of mold used to produce the casting and casting specifications. Finishing

typically involves mechanical operations such as abrasive cleaning, torch cutoff, air-carbon arc cleaning,

chipping, core knockout, and grinding. Cleaning usually involves the use of organic solvents to remove

rust, oil, grease, and dirt from the surface of the casting. The casting may also be given a coating.

120

Emissions points for lead are associated with the following operations: (1) scrap preparation, (2) metal

melting, and (3) pouring, cooling, and shakeout. With respect to scrap preparation, the primary lead

emissions come from preheaters, which are used to preheat the scrap for melting in the furnace. The

control devices used to control lead emissions from preheaters are generally fabric filters.121

With respect to the metal melting process, the predominant types of furnaces used to melt metal include

cupolas, which are used only at iron foundries; electric arc furnaces (EAF), which are used mainly at 

steel foundries; and electric induction furnaces (EIF), which are commonly used at both iron and steel

foundries. For lead emissions from cupolas, such emissions arise primarily from the melting operations.

The control devices used to control lead emissions from cupolas are generally fabric filters and also wet

scrubbers (usually Venturi scrubbers).122

For lead emissions from electric furnaces, such furnaces do not have well-defined stacks like cupolas.

Consequently, control systems for these furnaces must include hoods or other types of capture

mechanisms ducted to the control device. Moreover, the charging, melting, and tapping phases of the

melting cycle occur in sequence, not simultaneously as with cupolas. Consequently, it is more likely that

the charging and melting emissions may be captured by different systems because the furnace is

different for the two operations. The two exhaust streams may be ducted to separate control devices or to

the same device. Depending on the capture systems used, tapping emissions may also be captured,

usually incidentally because these emissions are relatively insignificant and no system dedicated to these

emissions is normally used. The control devices used to control lead emissions from electric furnaces

include fabric filters and wet scrubbers. Similar control devices are used for EAFs. Capture systems

 

119Id. at 3-3.

120Id.

121Id.

122Id.
36

used for EAFs and EIFs include side draft hoods, direct evacuation control system, fume rings, closefitting hoods, canopy hoods, total furnace enclosures, and building and bay evacuation.

123

With respect to the pouring, cooling, and shakeout operations, lead emissions are primarily a problem in

the shakeout process. Such emissions are usually controlled by fabric filters and cartridge filters, but wet

scrubbers and other devices are also used.

124

6.3. Identification and Summary of Possible RACM Candidates.

Table 6-2 provides a summary of control measures used in the Iron and Steel Foundries source category 

for which the RACM criteria are applied in section 6.4 and the relative likelihood that each control 

measure is a RACM. Specifically, each control measure is assigned a rating of 1 through 3; where the 

higher the number, the more likely that the control measure is a RACM. Such assigned values are 

explained in Table 6-1. 

Table 6-1. General Meanings of Assigned RACM Ratings.

RACM 

Rating

General Meaning of RACM Rating

1 There is limited support for identifying the control measure as a RACM. 

2 There is some support for identifying the control measure as a RACM; more than for a control measure 

with a RACM Rating of “1.”

3 There is substantial support for identifying the control measure as a RACM.

U 

(+ or -)

A “U” indicates that the likelihood that the control measure constitutes a RACM is undetermined due 

to incomplete information. A corresponding “+” indicates that despite incomplete information, an 

application of RACM criteria would likely suggest that the control measure is a RACM, while a “-” 

indicates that despite incomplete information, an application of the RACM criteria would likely 

suggest that the control measure is not a RACM.

 

123Id.

124Id.
37

Table 6-2. Iron and Steel Foundries Source Category - Summary of Known Control Measures and 

Relative Likelihood that each Control Measure is a RACM.

RACM 

Rating

Control Measure Brief Reasoning for RACM Rating

1 Control devices (e.g., filters, cyclones, 

scrubbers) to control process lead 

emissions from preheaters during scrap 

preparation operations (e.g., loading, 

heating, and discharging).

1. Minority, albeit significant, adoption by sources.

2. Cost data suggest not cost effective.

3. Not identified as GACT for recent NESHAP.

4. Lack of adoption of such controls by state regulations.

5. California‟s SCAQMD adopted a rule practically 

requiring such a control measure, as it requires 98% 

efficiency for lead for facilities exceeding specific process 

and emission thresholds (i.e., processing more than 2 tons 

of lead per year with daily emissions of lead greater than or 

equal to 0.5lbs/day).

3 Control devices (e.g., filters, wet 

scrubbers, electrostatic precipitators) to 

control process lead emissions from 

cupolas during the melting operations at 

iron foundries.

1. Almost complete adoption by sources. 

2. Cost data suggest cost effective for large and medium 

sources, but less cost effective for small sources. 

3. Identified as GACT for larger area sources and MACT 

for major sources.

4. Many state regulations practically require such controls 

for cupolas.

5. California‟s SCAQMD adopted a rule practically 

requiring such a control measure, as it requires 98% 

efficiency for lead for facilities exceeding specific process 

and emission thresholds (i.e., processing more than 2 tons 

of lead per year with daily emissions of lead greater than or 

equal to 0.5lbs/day).

3 Control devices (e.g., filters and wet 

scrubbers) to control process lead 

emissions from electric arc furnaces 

(EAFs) during the melting operations. 

1. Almost complete adoption by sources. 

2. Cost data suggest cost effective for large and medium 

sources, but less cost effective for small sources. 

3. Identified as GACT for larger area sources and MACT 

for major sources.

4. Many state regulations practically require such controls 

for EAFs.

5. California‟s SCAQMD adopted a rule practically 

requiring such a control measure, as it requires 98% 

efficiency for lead for facilities exceeding specific process 

and emission thresholds (i.e., processing more than 2 tons 

of lead per year with daily emissions of lead greater than or 

equal to 0.5lbs/day).

2.5 Control devices (e.g., filters and wet 

scrubbers) to control process lead 

emissions from electric induction 

furnaces (EIFs).

1. Minority, and less widespread, adoption by sources. 

2. Cost effective for large foundries, but less cost effective

for medium and small foundries. 

3. Identified as GACT for larger area sources and MACT 

for major sources.

4. Some state regulations might practically require such 

controls for EIFs.

5. California‟s SCAQMD adopted a rule practically 

requiring such a control measure, as it requires 98% 

efficiency for lead for facilities exceeding specific process 

and emission thresholds (i.e., processing more than 2 tons 

of lead per year with daily emissions of lead greater than or 
38

RACM 

Rating

Control Measure Brief Reasoning for RACM Rating

equal to 0.5lbs/day).

1 Control devices (e.g., filters) to control 

process lead emissions from the 

shakeout process. 

1. Minority, albeit significant, adoption by sources.

2. Cost data suggest not cost effective.

3. Not identified as GACT for recent NESHAP.

4. Lack of adoption of such controls by state regulations.

U + Improving currently installed control 

devices (e.g., filters and wet scrubbers) 

to more efficiently control process lead 

emissions (e.g., decreasing air to cloth 

ratio, increasing pressure differential, 

using horizontally hanging bags instead 

of vertically hanging bags).

1. Evidence suggests that such measures are more efficient, 

but there are limited cost data available. 

2 Capture systems (e.g., side draft hoods, 

direct evacuation control systems, fume 

rings, close-fitting hoods, canopy 

hoods, total furnace enclosures, and 

building and bay evacuation) to control 

process fugitive lead emissions from 

EAFs during melting operations.

1. Majority use for at least some operations. 

2. No cost data identified.

3. Identified as GACT for large area source foundries, but 

not for small foundries.

4. Many state regulations practically require such controls.

2 Capture systems (e.g., side draft hoods, 

direct evacuation control systems, fume 

rings, close-fitting hoods, canopy 

hoods, total furnace enclosures, and 

building and bay evacuation) to control 

process fugitive lead emissions from 

EIFs during melting operations.

1. Less widespread use compared to EAFs.

2. No cost data identified.

3. Identified as GACT for large area source foundries, but 

not for small foundries.

4. Many state regulations practically require such controls.

2.5 Pollution prevention measure of using 

scrap management practices and 

materials specifications to reduce lead 

content of scrap.

1. Extent of use not identified.

2. Cost data suggest cost effective. 

3. Identified as GACT for both large and small area source 

foundries.

U + Fugitive dust control measures. 1. Extent of use not identified.

2. No cost data identified.

3. A GACT emission limit exists, which prohibits foundries 

from discharging certain levels of fugitive emissions.

6.4. Application of RACM Criteria to Possible RACM Candidates.

6.4.1. Control devices (e.g., filters, cyclones, and scrubbers) to control process lead emissions from 

preheaters during scrap preparation operations (i.e., loading, heating, and discharging). 

The common, but less than majority, use of control devices (e.g., filters, cyclones and scrubbers) for

controlling process lead emissions from preheaters during scrap preparation operations suggests that 

such controls are somewhat economically feasible for larger foundries but less economically feasible for 

smaller foundries. For example, a majority of the total number of preheaters at iron and steel foundries 

are uncontrolled. Specifically, about 61 % of the total number of preheaters at iron foundries (68 of the 

113 preheaters) and about 48% of iron foundries (76 of 157 iron foundries) use no controls to control 

process emissions from preheaters during all scrap preparation operations (i.e., loading, heating and 
39

discharging); 

125 and about 78% of the total number of preheaters at steel foundries (7 of the 9 

preheaters) and 90 % of the steel foundries (18 of the 20 steel foundries) use no controls to control 

process emissions from preheaters during scrap preparation operations (i.e., loading, heating and 

discharging).126

However there is a significant, albeit minority, use of such controls to control process emissions from 

preheaters at iron and steel foundries. Specifically, about 15% of the total number of preheaters at iron 

foundries (17 of the 113 preheaters) and about 15% of iron foundries (24/157 iron foundries) use filters 

to control process emissions from preheaters during all scrap preparation operations (i.e., loading, 

heating and discharging).127 About 25% of the total number of preheaters at iron foundries (28 of 113 

preheaters) and about 44% of iron foundries (50 of 113 iron foundries) use a control device (i.e., filter, 

scrubber, cyclone) to control process emissions from preheaters during some scrap preparation 

operations (i.e., loading, heating, discharging), but not all scrap preparation operations.

128 No steel 

foundries use filters to control process emissions from preheaters during all scrap preparation operations 

(i.e., loading, heating, and discharging).

129 One steel foundry uses a filter on one preheater to control 

process emissions from preheaters during scrap preparation for heating and discharging operations, but 

not for loading. One steel foundry uses a scrubber on one preheater to control process emissions during 

scrap preparation during discharging operations, but not for heating or loading.

130

Available cost-effectiveness data suggest that such controls to control lead process emissions from 

preheaters is not cost effective. Specifically, EPA determined from an assessment of the impacts of 

meeting different candidate control options using three different model plants (small model plant with 

capacity of 500 TPY, medium model plant with capacity of 5,000 TPY, and large model plant with 

capacity of 50,000 TPY) that such controls were not reasonably cost effective for reducing emissions of 

PM and HAP metal compounds from sources for scrap preparation options (e.g., preheaters).131 This 

suggests that using such controls to control lead emissions from preheaters is also not cost effective. 

The recent NESHAP for Iron and Steel Foundries Area Sources (40 CFR 63, Subpart ZZZZZ) provides 

support that controls to control the process lead emissions from preheaters at foundries are not 

reasonably available.132 Specifically, such standard does not require controls on preheaters. EPA‟s

recent refusal to identify such controls as GACT suggests that such controls may not be RACM. 

The current NESHAP for Iron and Steel Foundries Majors Sources (40 CFR 63, Subpart EEEEE) 

provides some support that controls to control the process lead emissions from preheaters at foundries 

are reasonably available. Specifically, such NESHAP requires that each scrap preheater at a new iron 

and steel foundry must not discharge emissions through a conveyance to the atmosphere that exceed 

either the of following limits for PM and total metal HAP: (1) 0.001 gr/dscf of PM, or (2) 0.0008 gr/dscf 

of total metal HAP; and requires that an existing iron and steel foundry must not discharge emissions 

 

125Id. at 4-8.

126Id.

127Id.

128Id.

129Id.

130Id.

131Memorandum – Impact Estimates for Area Source Iron and Steel Foundries, From Conrad Chin, EPA/SPPD, To EPA 

Docket Number EPA-HQ-OAR-2006-0359-0005-1. September 4, 2007. Page 4.

132NESHAP for Iron and Steel Foundries Area Sources, 40 CFR 63, Subpart ZZZZZ (Published April 22, 2004).
40

through a conveyance to the atmosphere that exceed either of the following limits for PM and total metal 

HAP: (1) 0.005 gr/dscf of PM, or (2) 0.0004 gr/dscf of total metal HAP.133

The lack of adoption of such controls in state regulations suggests that such controls are not highly 

reasonable for preheaters. Specifically, Table 6-3 lists state regulations from the six states with the 

highest foundry metal melting rates.

134 While one has a PM emission limit that applies to all foundry 

operations that might practically require implementation of such control measures on preheaters, no 

other of such states have such PM limits.

California‟s SCAQMD Rule 1420 requires a control efficiency of 98% for all operations.135

Consequently, this requirement would apply to control devices to control process lead emissions from 

preheaters during scrap preparation operations (i.e., loading, heating, and discharging). Notwithstanding, 

this requirement only applies to facilities processing more than 2 tons of lead per year with daily 

emissions of lead greater than or equal to 0.5lbs/day.

 

133Id.

134National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 

4-49.

135California (South Coast Air Quality Management District), Rule 1420 - Emission Standards for Lead (Published 

September, 1992).
41

Table 6-3. State Regulations from the Six States with the Highest Foundry Metal Melting Rates 

that Practically Require Implementation of Lead Control Measures. 

Melting Furnace –

Cupolas 

(gr PM/dscf)

Melting Furnace 

– EAFs

(gr Lead/dscf) 

Melting 

Furnace – EIFs

(gr Lead/dscf)

All Foundry 

Operations

(gr PM/dscf)

Opacity Limit 

for Buildings 

that House 

Process 

Equipment136

Michigan Existing cupolas: 

0.2 (where melting 

capacity <10 

tons/hour) to 

0.08 (where melting 

capacity > 20 

tons/hour).

New cupolas: 

emission factor 

limits.

0.05 None None Opacity 

emission limits 

were found for 

five states, 

which 

generally apply 

to general roof 

vents that may 

contain 

fugitive 

emissions from 

various sources 

throughout the 

foundry. Four 

of the five 

states 

(Alabama, 

Wisconsin, 

Michigan, and 

Ohio) have 20 

% opacity 

limits, while 

one state 

(Indiana) has a 

30% to 40% 

opacity limit, 

depending on 

the location of 

the source.

Wisconsin 0.24 0.05 0.05

Indiana 0.15 None None Cannot discharge 

any gases > 0.07 

Ohio Based on process 

rate capacity of a 

generic PM 

emission source –

vary widely. 

Based on process 

rate capacity of a 

generic PM 

emission source –

vary widely.

Based on 

process rate 

capacity of a 

generic PM 

emission source 

– vary widely.

None

Illinois Based on process 

weight rates – vary 

widely.

Based on process 

weight rates –

vary widely.

Based on 

process weight 

rates – vary 

widely.

None

Alabama Based on process 

weight rates – vary 

widely

Based on process 

weight rates –

vary widely

Based on 

process weight 

rates – vary 

widely

None

6.4.2. Control devices (e.g., filters, wet scrubbers, electrostatic precipitators) to control process lead 

emissions from cupolas during the melting operations at iron foundries.

The almost complete adoption of control devices (e.g., filters, scrubbers, and electrostatic precipitators) 

for controlling process lead emissions from cupola furnaces during melting operations (i.e., charging, 

melting, tapping) at iron foundries suggests that such controls are economically feasible. Specifically, 

about 44% of foundries (48/110) and about 43% (62/143) of the total number of cupolas at iron 

foundries use a filter to control process emissions from cupolas during melting operations (charging, 

melting, and tapping). About 48% of foundries (53/110) and 50% of cupolas (71/143) at such foundries 

 

136EPA examined such limits and determined that almost all States apply an opacity limit for buildings that house the process 

equipment. EPA determined that fugitive emissions from such equipment are effectively regulated by such opacity limits. 

NESHAP for Iron and Steel Foundries –Background Information for Promulgated Standards. EPA Document # EPA-HQOAR-2002-0034-0144 (Published August 2003). Page 109. 
42

use wet scrubbers to control process emissions from cupolas during melting operations. Exactly 1/110 

foundries and 1/143 cupolas at such foundries use electrostatic precipitator to control process emission 

from cupolas during melting (i.e., charging, melting, and tapping). Only about 7% (8/110) of foundries 

and about 6% (9/143) of the cupolas at such foundries did not use any control.137

Available cost-effectiveness data suggest that such controls to control lead process emissions from 

cupolas is generally cost effective. EPA determined from an assessment of the impacts of meeting 

different candidate control options using three different model plants (small model plant with capacity of 

500 TPY, medium model plant with capacity of 5,000 TPY, and large model plant with capacity of 

50,000 TPY) that add-on controls, such as filters (and cyclones or scrubbers) are reasonably cost 

effective for reducing emissions of PM and HAP metal compounds from medium and large sources for 

melting operations on furnaces, but less cost effective for smaller foundries.138 Specifically, the model 

plant analysis also indicated that add-on controls for metal melting furnaces are much less cost effective 

for the small model plant than for the large model plant (costs exceeded $60,000/ton of PM removed for 

the 500 TPY model plant versus $3,000/ton of PM removed or less for the 50,000 TPY model plant). 

EPA further noted that the cost effectiveness for add-on controls for the medium model plants appeared 

to be reasonable for cupolas.

139 This suggests that using such controls to control lead from cupolas is 

cost effective, especially for medium and large plants.

The current NESHAP for Iron and Steel Foundries Area Sources (40 CFR 63, Subpart ZZZZZ) suggests 

that such controls are reasonably available. Specifically, such NESHAP requires that large foundries 

(existing source with annual metal melt production > 20,000 tons or new source with an annual metal 

melt capacity > 10,000 tons), but not small foundries (existing source with annual melt production of ≤ 

20,000 tons or less or new source with an annual metal melt capacity of ≤ 10,000 tons or less) must not 

discharge to the atmosphere emissions from any metal melting furnace or group of all metal melting 

furnaces that exceed the applicable limits: (1) for an existing iron and steel foundry, 0.8 pounds of PM

per ton of metal charged or 0.06 pounds of total metal HAP per ton of metal charged and (2) for a new 

iron and steel foundry, 0.1 pounds of PM per ton of metal charged or 0.008 pounds of total metal HAP 

per ton of metal charged.140 The fact that EPA recently decided that such controls are GACT for some 

area sources suggests that such controls are RACM. 

Moreover, such controls are required by the NESHAP for Iron and Steel Foundries Major Sources (40 

CFR 63, Subpart EEEEE) for both new and existing sources. This provides support that such controls 

are RACM, since such controls represent MACT standards that are 7 years old.141

The fact that many state regulations practically require such controls for cupolas suggests that such 

controls are reasonable. Specifically, Table 6-3 lists state regulations from the six states with the highest 

foundry metal melting rates.142 All states require PM emission limits that might practically require 

implementation of such control measures on cupolas.

 

137National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 

4-11.

138Memorandum – Impact Estimates for Area Source Iron and Steel Foundries, From Conrad Chin, EPA/SPPD, To EPA 

Docket Number EPA-HQ-OAR-2006-0359-0005-1. September 4, 2007. Page 4.

139Id. at 4. 

140NESHAP for Iron and Steel Foundries Area Sources, 40 CFR 63, Subpart ZZZZZ (Published April 22, 2004).

141Id.

142National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 
43

California‟s SCAQMD Rule 1420 requires a control efficiency of 98% for all operations.143

Consequently, this requirement would apply to control devices to control process lead emissions from 

cupolas during the melting operations at iron foundries. Notwithstanding, this requirement only applies 

to facilities processing more than 2 tons of lead per year with daily emissions of lead greater than or 

equal to 0.5lbs/day. 

6.4.3. Control devices to control process emissions from EAFs during the melting operations at iron 

and steel foundries.

The almost complete adoption of control devices (mostly filters) for controlling emissions from EAFs

during melting operations (i.e., charging, melting, tapping) at iron and steel foundries suggests that such 

controls are economically feasible. Specifically, there were no uncontrolled EAFs at iron foundries. One 

hundred percent of the total number of EAFs at iron foundries (28 of the 28) and one hundred percent of 

iron foundries (11 of 11) use controls (mostly filters) to control process emissions from EAFs during at 

least some melting operations (i.e., charging, melting or tapping).144

Moreover, only about 2% (3/136) of the total number of EAFs at steel foundries and about 2% (3/71) of 

the total number of steel foundries are uncontrolled.

145 About 73% (99/135) of the total number of EAFs 

at steel foundries and about 70% (50/71) of steel foundries used filters to control emissions from EAFs 

during some melting operations (i.e., charging, melting, tapping) at steel foundries.146 About 24% 

(33/135) of the total number of EAFs at steel foundries and about 30% (21/71) foundries used filters to 

control emissions from EAFs during the melting operations (i.e., charging, melting, and tapping) at steel 

foundries.147

Available cost-effectiveness data suggest that such controls to control EAFs are cost effective. EPA 

determined from an assessment of the impacts of meeting different candidate control options using three 

different model plants (small model plant with capacity of 500 TPY, medium model plant with capacity 

of 5,000 TPY, and large model plant with capacity of 50,000 TPY) that add-on controls, such as filters 

(and cyclones or scrubbers) are reasonably cost effective for reducing emissions of PM and HAP metal 

compounds from medium and large sources for melting operations on furnaces, but less cost effective 

for smaller foundries.148 Specifically, the model plant analysis also indicated that add-on controls for 

metal melting furnaces are much less cost effective for the small model plant than for the large model 

plant (costs exceeded $60,000/ton of PM removed for the 500 TPY model plant versus $3,000/ton of 

PM removed or less for the 50,000 TPY model plant). EPA further noted that the cost effectiveness for 

add-on controls for the medium model plants appeared to be reasonable for EAFs.

The current NESHAP for Iron and Steel Foundries Area Sources (40 CFR 63, Subpart ZZZZZ) suggests 

that such controls are reasonably available. Specifically, such NESHAP requires that large foundries 

 

4-49.

143California (South Coast Air Quality Management District), Rule 1420 - Emission Standards for Lead (Published 

September, 1992).

144National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 

4-27.

145Id. at 4-27.

146Id.

147Id.

148Memorandum – Impact Estimates for Area Source Iron and Steel Foundries, From Conrad Chin, EPA/SPPD, To EPA 

Docket Number EPA-HQ-OAR-2006-0359-0005-1. September 4, 2007. Page 4.
44

(existing source with annual metal melt production > 20,000 tons or new source with an annual metal 

melt capacity > 10,000 tons), but not small foundries (existing source with annual melt production of ≤ 

20,000 tons or less or new source with an annual metal melt capacity of ≤ 10,000 tons or less) must not 

discharge to the atmosphere emissions from any metal melting furnace or group of all metal melting 

furnaces that exceed the applicable limits: (1) for an existing iron and steel foundry, 0.8 pounds of PM

per ton of metal charged or 0.06 pounds of total metal HAP per ton of metal charged and (2) for a new 

iron and steel foundry, 0.1 pounds of PM per ton of metal charged or 0.008 pounds of total metal HAP 

per ton of metal charged.149 The fact that EPA recently decided that such controls are GACT for some 

area sources suggests that such controls are RACM. 

Moreover, such controls are required by the NESHAP for Iron and Steel Foundries Major Sources (40 

CFR 63, Subpart EEEEE) for both new and existing sources. This further provides support that such 

controls are RACM, since such controls represent MACT standards that are 7 years old.150

The fact that many state regulations practically require such controls for EAFs suggests that such 

controls are reasonable. Specifically, Table 6-3 lists state regulations from the six states with the highest 

foundry metal melting rates.151 Five of the six states require PM emission limits that might practically 

require implementation of such control measures on EAFs. 

California‟s SCAQMD Rule 1420 requires a control efficiency of 98% for all operations.152

Consequently, this requirement would apply to control devices to control process emissions from EAFs 

during the melting operations at iron and steel foundries. Notwithstanding, this requirement only applies 

to facilities processing more than 2 tons of lead per year with daily emissions of lead greater than or 

equal to 0.5lbs/day.

6.4.4. Control devices (e.g., filters, wet scrubbers, and cyclones) used to control the process emissions 

from EIFs during the melting operations at iron and steel foundries.

The less widespread adoption of control devices used to control the process emissions from EIFs during 

the melting operations at iron and steel foundries suggests that such controls are less economically 

feasible for EIFs than for EAFs or cupolas. For example, most iron foundries do not control EIFs with a 

control device. Specifically, about 58% (438 of the 754) of the total number of EIFs at iron foundries

and about 64% (181 of 286) of iron foundries (64%) use no controls to control process emissions from 

EIFs during melting (i.e., charging, melting, tapping). Only about 28% (210 of the 754) of the total 

number of EIFs at iron foundries and about 24% (69 of 286) of iron foundries use filters to control 

process emissions from EIF during melting (i.e., charging, melting, tapping). About 12 % (88 of the 

754) of the total number of EIFs at iron foundries and about 10% (30 of 286) of iron foundries (10%)

use filters to control process emissions from EIF during some melting operations (charging, melting, 

tapping) but not all.153 About 2% (17 of 754) of the total number of EIFs at iron foundries and about 2% 

(6 of 286) of iron foundries use wet scrubbers to control process emissions from EIF during some 

melting (i.e., charging, melting, tapping) but not all. Less than 1% (2 of 754) of the total number of EIFs 

 

149NESHAP for Iron and Steel Foundries Area Sources, 40 CFR 63, Subpart ZZZZZ (Published April 22, 2004).

150NESHAP for Iron and Steel Foundries Major Sources, 40 CFR 63, Subpart EEEEE (Published April 22, 2004). 

151National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 

4-49.

152California (South Coast Air Quality Management District), Rule 1420 - Emission Standards for Lead (Published 

September, 1992).

153Id. at 4-21 through 4-22. 
45

at iron foundries and less than 1% (2 of 286) of the iron foundries use cyclones to control process 

emissions from EIFs during some melting operations (i.e., charging, melting, and tapping) but not all.154

Most steel foundries also do not control EIFs with a control device. Specifically, about 79% (509 of the 

643) of the total number of EIFs at steel foundries and about 77% (144 of 186) of steel foundries use no 

controls to control process emissions from EIFs during melting (i.e., charging, melting, tapping).155

About 13% (81 of the 643) of the total number of EIFs at steel foundries, and about 12% (23 of 186) of 

steel foundries use filters to control process emissions from EIFs during melting (i.e., charging, melting, 

tapping).156 About 5% (34 of the 643) of the total number of EIFs at steel foundries, and about 7% of (13 

of 186) steel foundries use filters to control process emissions from EIFs during some melting (i.e., 

charging, melting or tapping).157 Less than 1% (6 of the 643) of the total number of EIFs at steel 

foundries, and about 1% (2 of 186) of steel foundries use wet scrubbers to control process emissions 

from EIFs during some melting (charging, melting or tapping).158 Less than 1 % (6 of the 643) of the 

total number of EIFs at steel foundries, and about 1% (2 of 186) of steel foundries, use cyclones to 

control process emissions from EIFs during some melting (i.e., charging, melting or tapping).159

Available cost-effectiveness data suggest that such controls to control for lead process emissions from 

EIFs are less cost effective than for cupolas and EAFs. EPA determined from an assessment of the 

impacts of meeting different candidate control options using three different model plants (small model 

plant with capacity of 500 TPY, medium model plant with capacity of 5,000 TPY, and large model plant 

with capacity of 50,000 TPY) that add-on controls, such as filters (and cyclones or scrubbers) are 

reasonably cost effective for reducing emissions of PM and HAP metal compounds from sources for 

melting operations on furnace, but less cost effective for smaller foundries. Specifically, the model plant 

analysis also indicated that add-on controls for metal melting furnaces are much less cost effective for 

the small model plant than for the large model plant (costs exceeded $60,000/ton of PM removed for the 

500 TPY model plant versus $3,000/ton of PM removed or less for the 50,000 TPY model plant). EPA 

further noted that the cost effectiveness for add-on controls for the medium model plants appeared to be 

reasonable for cupolas and EAFs, but were less reasonable for EIFs due to the lower emissions from 

uncontrolled EIFs as compared to cupolas and EAFs.160

The current NESHAP for Iron and Steel Foundries Area Sources (40 CFR 63, Subpart ZZZZZ) suggests 

that such controls are reasonably available. Specifically, such NESHAP requires that large foundries 

(existing source with annual metal melt production > 20,000 tons or new source with an annual metal 

melt capacity > 10,000 tons), but not small foundries (existing source with annual melt production of ≤ 

20,000 tons or less or new source with an annual metal melt capacity of ≤ 10,000 tons or less) must not 

discharge to the atmosphere emissions from any metal melting furnace or group of all metal melting 

furnaces that exceed the applicable limits: (1) for an existing iron and steel foundry, 0.8 pounds of PM

per ton of metal charged or 0.06 pounds of total metal HAP per ton of metal charged and (2) for a new 

iron and steel foundry, 0.1 pounds of PM per ton of metal charged or 0.008 pounds of total metal HAP 

 

154National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 

4-22.

155Id. at 4-23.

156Id. at 4-23.

157Id.

158Id. 

159Id.

160Memorandum – Impact Estimates for Area Source Iron and Steel Foundries, From Conrad Chin, EPA/SPPD, To EPA 

Docket Number EPA-HQ-OAR-2006-0359-0005-1. September 4, 2007. Page 4.
46

per ton of metal charged.161 The fact that EPA has recently decided that such controls are GACT for 

some area sources provides some support that such controls are reasonably available.

Moreover, such controls are required by the NESHAP for Iron and Steel Foundries Major Sources (40 

CFR 63, Subpart EEEEE) for both new and existing sources. This further provides support that such 

controls are RACM, since such controls represent MACT standards that are 7 years old.162

The fact that some state regulations practically require such controls for EIFs might suggest that such 

controls are reasonable. Specifically, Table 6-3 lists state regulations from the six states with the highest 

foundry metal melting rates.163 Four of the six states require PM emission limits that might practically 

require implementation of such control measures for EIFs. 

California‟s SCAQMD Rule 1420 requires a control efficiency of 98% for all operations.164

Consequently, this requirement would apply to control devices used to control the process emissions 

from EIFs during the melting operations at iron and steel foundries. Notwithstanding, this requirement 

only applies to facilities processing more than 2 tons of lead per year with daily emissions of lead 

greater than or equal to 0.5lbs/day.

6.4.5. Control devices (e.g., filters, wet scrubbers) to control the process emissions from the shakeout 

process.

The less widespread adoption of control devices used to control the process emissions from shakeout 

processes at iron and steel foundries suggests that such controls are less economically feasible for 

shakeout stations than for melting operations. For example, about 33% (384 of the 1156) of shakeout 

stations and about 40% (225 of 569) of foundries use no controls to control process emissions from 

shakeout stations.

165 Meanwhile, about 53% (602 of the 1156) of shakeout stations and about 63% (360 

of the 569) foundries use filters to control process emissions from shakeout stations.166 About 14% (161 

of the 1156) of shakeout stations and 14% (79 of the 569) of foundries use wet scrubbers to control 

process emissions from shakeout stations. Less than 1% (9 of the 1156) of shakeout stations and less 

than 2% (7 of the 569) of foundries use other control devices (cyclones) to control process emissions 

from shakeout stations.

Available cost-effectiveness data suggest that such controls to control preheaters are not cost effective.

Specifically, EPA determined from an assessment of the impacts of meeting different candidate control 

options using three different model plants (small model plant with capacity of 500 TPY, medium model 

plant with capacity of 5,000 TPY, and large model plant with capacity of 50,000 TPY) that add-on 

controls, such as filters (and cyclones or scrubbers) were not cost effective for reducing emissions of PM

and HAP metal compounds from sources for shakeout processes.167 This suggests that using such 

controls for controlling lead is also not cost effective. 

 

161NESHAP for Iron and Steel Foundries Area Sources, 40 CFR 63, Subpart ZZZZZ (Published April 22, 2004).

162NESHAP for Iron and Steel Foundries Major Sources, 40 CFR 63, Subpart EEEEE (Published April 22, 2004). 

163National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 

4-49.

164California (South Coast Air Quality Management District), Rule 1420 - Emission Standards for Lead (Published 

September, 1992).

165Id. at 4-41

166Id.

167Memorandum – Impact Estimates for Area Source Iron and Steel Foundries, From Conrad Chin, EPA/SPPD, To EPA 
47

Moreover, such controls are required by the NESHAP for Iron and Steel Foundries Major Sources (40 

CFR 63, Subpart EEEEE) for both new and existing sources. This further provides support that such 

controls are RACM, since such controls represent MACT standards that are 7 years old.168

The lack of adoption of such controls in state regulations suggests that such controls are not highly 

reasonable for the shakeout process. Specifically, Table 6-3 lists state regulations from the six states 

with the highest foundry metal melting rates.169 While one has a PM emission limit that applies to all 

foundry operations that might practically require implementation of such control measures for the 

shakeout process, no other of such states have such PM limits. 

6.4.6. Improving current control devices used to control the process emissions from iron and steel 

foundries.

Several measures could possibly improve the efficiency of controls that control process lead emissions 

from iron and steel foundries. Such measures include increasing the pressure differential of Venturi 

scrubbers, increasing the air-to-cloth ratio of fabric filters, and using horizontally hanging instead of 

vertically hanging bags for fabric filters. 

For example, pressure differential is a key factor affecting the efficiency of a scrubber in removing PM, 

and similarly, lead. As a rule of thumb, a high-efficiency scrubber is one with a pressure differential 

greater than 50 inches of water column.170 The pressure differential at Venturi scrubbers used on cupolas 

is in Table 6-4.

171 Many of the pressure differentials are less than 50 inches of water column. Such 

pressure differentials might be increased to increase the efficiency of such controls.

Table 6-4. Pressure Differentials of Venturi Scrubbers used on Cupola Furnaces at Iron Foundries

Pressure differential, inches of water column Number of Scrubbers

≤ 8 9

20 to 29 5

30 to 39 14

40 to 49 11

50 to 59 9

60 to 70 7

Similarly, the air-to-cloth ratio, which is the major design factor that affects the efficiency of fabric 

filters, might be decreased to increase the efficiency of fabric filters.

A more uncertain method of increasing the efficiency of fabric filters is to use horizontally hanging 

instead of vertically hanging bags. Specifically, two sources have implemented horizontally hanging 

bags rather than the traditional vertically hanging bags, and allege that such horizontally hanging bags 

are cheaper and more efficient. According to an operator of one of these novel fabric filters, a lighter 

 

Docket Number EPA-HQ-OAR-2006-0359-0005-1. September 4, 2007. Page 4.

168NESHAP for Iron and Steel Foundries Major Sources, 40 CFR 63, Subpart EEEEE (Published April 22, 2004). 

169National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 

4-49.

170Id. at 4-12.

171National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 

4-16.
48

weight fabric can be used when the bags are horizontally supported. When bags hang vertically, the tops 

of the bags must be strong enough to hold up the weight of the entire bag, and the entire filter cake on 

that bag. A light-weight bag would not be able to support the weight, and would tear. By having the bags 

supported horizontally, they are able to reduce the weight that the bag material supports to only the 

small amount under the horizontal support. The light-weight bag is easier to clean and is more 

permeable, which allows for a more even distribution of the air flow. Heavier-weight bags tend to get 

more material caught in the bag material, and as a result need to be cleaned more frequently and more 

vigorously. One source indicated that, “since 80% of emissions are associated with cleaning,” by 

lowering the cleaning frequency, the fabric filter emissions are lowered. The light-weight bag is also 

more permeable, so that pressure drop is reduced, and air flow is more evenly distributed. This, along 

with the low air-to-cloth ratio for these fabric filters, allows more of the PM material, and associated 

lead, to be collected on the bag surface, rather than becoming impregnated into the fabric, making it 

easier to clean the bags.172

6.4.7. Capture systems used for EAFs and EIFs including side draft hoods, direct evacuation control 

systems, fume rings, close-fitting hoods, canopy hoods, total furnace enclosures, and building and 

bay evacuation.

Capture systems consist of two general types: close capture and general capture. Close-capture systems, 

which are more effective, use techniques such as side draft hoods, direct evacuation systems, fume rings, 

and close-fitting hoods that capture emissions before they escape from the immediate vicinity of the 

furnace. These systems require only a small volume of air flow, which is drawn through attached 

ductwork to a control device that can be dedicated to specific operations. General-capture systems 

employ canopy hoods or total enclosures, both of which can be used with dedicated control devices but 

require a higher volume of air flow than close-capture systems, or building or bay evacuation systems, 

which also require large volumes of air and must serve the entire building or a large segment of it.173

Tables 6-5 and 6-6 show the extent of adoption of capture systems to control fugitive process emissions 

from control devices attached to EIFs and EAFs at foundries, respectfully.174 Such tables demonstrate 

that capture devices are much more widely adopted for use on EAFs than EIFs. Moreover, for both EIFs 

and EAFs, close-captures are more generally adopted than other types of capture devices.175

 

172Id. at 4-15 through 4.16.

173Id. at 4-30.

174In the following tables, close capture includes side draft hood, fume ring, close-fitting hood, and direct evacuation. Others 

include canopy hood, draft system or ventilation to a fabric filter, area ducting, section tube, and building evacuation to a 

fabric filter. No capture includes not reported, roof vent, exhaust fan, lid or cover, or general ventilation.

175Id. at 4-31.
49

Table 6-5. Use of Capture Systems on EIFs at Iron and Steel Foundries.

Capture system type Melting furnace operation serviced

Charging Melting Tapping

Close Capture

Number of furnaces

Number of foundries

211

66

261

78

160

53

Other Type

Number of furnaces

Number of foundries

185

69

200

84

169

63

No Capture

Number of furnaces

Number of foundries

1001

334

936

315

1068

353

Total number furnaces: 1397 Total number foundries: 445

Table 6-6. Use of Capture Systems on EAFs at Iron and Steel Foundries.

Capture system type Melting furnace operation serviced

Charging Melting Tapping

Close Capture

Number of furnaces

Number of foundries

32

20

120

62

33

19

Other Type

Number of furnaces

Number of foundries

41

18

26

9

17

11

No Capture

Number of furnaces

Number of foundries

92

46

17

10

113

52

Total number furnaces: 168 Total number foundries: 81

The NESHAP for Iron and Steel Foundries Area Sources (40 CFR 63, Subpart ZZZZZ) suggests that 

such controls are reasonably available. Specifically, such NESHAP requires that large foundries 

(existing source with annual metal melt production > 20,000 tons or new source with an annual metal 

melt capacity > 10,000 tons), but not small foundries (existing source with annual melt production of ≤ 

20,000 tons or less or new source with an annual metal melt capacity of ≤ 10000 tons or less) must 

operate a capture and collection system for each metal melting furnace at a new or existing iron and steel 

foundry where each capture and collection system must meet accepted engineering standards.176 The fact 

that EPA has recently decided that such controls are generally available for some area sources provides 

support that such controls are reasonably available.

The fact that many state regulations practically require such controls for EIFs suggests that such controls 

might be reasonable. Specifically, Table 6-3 lists state regulations from the six states with the highest 

foundry metal melting rates.177 Five of the six states require opacity limits resulting from fugitive 

process emissions, and therefore might practically require implementation of such control measures to 

control fugitive process lead emissions. 

 

176NESHAP for Iron and Steel Foundries Area Sources, 40 CFR 63, Subpart ZZZZZ (Published April 22, 2004).

177National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 

4-49.
50

6.4.8. Pollution prevention measure of using scrap management practices and materials specifications to 

reduce HAP content of scrap.

EPA conducted an assessment of the impacts of meeting different candidate control options using three 

different model plants (small model plant with capacity of 500 TPY, medium model plant with capacity 

of 5,000 TPY, and large model plant with capacity of 50,000 TPY). One such control option was use of 

scrap management practices to reduce HAP content of scrap.178 EPA decided such measure was cost 

effective enough to include as GACT for small and large area sources. Moreover, the source must 

prepare and operate at all times according to written material that (1) provides for the purchase and use 

of only iron and steel scrap that has been depleted (to the extent practicable) of HAP metals in the 

charge materials used by the iron and steel foundry; (2) provides for metallic scrap materials charged to 

a scrap preheater or metal melting furnace to be depleted (to the extent practicable) of the presence of 

accessible lead-containing components (such as batteries and wheel weights), except that for scrap 

charged to a cupola metal melting furnace that is equipped with an afterburner, specifications for 

metallic scrap materials to be depleted (to the extent practicable) of the presence of chlorinated plastics 

and accessible lead-containing components (such as batteries and wheel weights), and (3) must provide 

specifications of a program to ensure the scrap materials are drained of free liquids.179

6.4.9. Other control measures for controlling fugitive process and dust emissions. 

The NESHAP for Iron and Steel Foundries Area Sources (40 CFR 63, Subpart ZZZZZ) prohibits

discharging to the atmosphere fugitive emissions from foundry operations that exhibit a certain opacity 

limit. This suggests that there might be other fugitive control measures that might be reasonably 

available since EPA decided such a limit was generally available. 

 

178NESHAP for Iron and Steel Foundries Area Sources, 40 CFR 63, Subpart ZZZZZ (Published April 22, 2004).

179Memorandum – Impact Estimates for Area Source Iron and Steel Foundries, From Conrad Chin, EPA/SPPD, To EPA 

Docket Number EPA-HQ-OAR-2006-0359-0005-1. September 4, 2007. Page 4.
51

7.0. RACM DEVELOPMENT FOR THE INTEGRATED IRON AND

STEEL MILLS SOURCE CATEGORY.

This section presents control measures to consider for RACM development for the Iron and Steel Mills

source category. Section 7.1 provides an overview of the Iron and Steel Mills source category. Section 

7.2 provides a summary of operations and lead emission points for iron and steel mill facilities. Section 

7.3 provides a summary of the control measures utilized at iron and steel mill facilities, and Section 7.4 

provides a more detailed application of the RACM criteria to each identified control measure.

7.1. Overview of Source Category.

The Iron and Steel Mills source category includes plants engaged in producing steel. A fully integrated

facility produces steel from raw materials of coal, iron ore, and scrap; whereas non-integrated plants do

not have all of the equipment to produce steel from coal, iron ore, and scrap on-site.

180 The

corresponding NAICS Code for the Integrated Iron and Steel Mills source category is 331111. The

NAICS Description for facilities with such NAICS Code is “establishments primarily engaged in one or

more of the following: direct reduction of iron ore, manufacturing pig iron in molten or solid form,

converting pig iron into steel, making steel, making steel and manufacturing shapes, and making steel

and forming tube and pipe.181

As of 2001, there are roughly twenty integrated iron and steel mills in the United States. The highest

geographic concentration of mills is in the Great Lakes Region. Large, fully-integrated iron and steel

mills have declined considerably in the fifteen year time period before 2001. For example, of the iron

and steel mills that were open during such fifteen year period and still open in 2001, such plants

experienced a 61 percent reduction in the number of production employees over the 15 year period.182

7.2. Facility Operations and Lead Emission Points.

Integrated iron and steel mills engage in processes that include the following process units: (1) sinter

production, (2) iron production (hot metal desulfurization), (3) steel production, (4) semi-finished

product preparation, (6) finished product preparation, and (7) handling and treatment of raw,

intermediate, and waste materials. The iron production process includes the production of iron in blast

furnaces by reduction. The steel production process includes basic oxygen process furnaces (BOPF).

The discussion of emission points for lead will be discussed by the following three categories: sinter

plants, blast furnaces, and BOPF shops.183 Sintering is a process that recovers the raw material value of

waste materials generated at iron and steel plants that would otherwise be landfilled or stockpiled. An

important function of the sinter plant is to return waste iron-bearing materials to the blast furnace to

produce iron and to also provide part or all of the flux material for the iron-making process.184

The sinter plant windbox serves as the capture system for the sintering machine and is the most critical

source of emissions in the sinter plant. After the sinter materials are mixed, they are ignited on the

 

180National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and Steel Plants – Background 

Information for Proposed Standards. EPA-453/R-01-005 (Published January 2001). Page 2-1.

181The North American Industry Classification System Website.

182National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and Steel Plants – Background 

Information for Proposed Standards. EPA-453/R-01-005 (Published January 2001). Page 2-3.

183Id. at 1-2.

184Id. at 3-1.
52

surface by gas burners, and as the materials move through the sinter bed, air is pulled down through the

mixture to burn the fuel by downdraft combustions through a series of windboxes, and evacuated to a

control device. The control devices used to control lead emissions from windboxes are fabric filters and

wet scrubbers.185

The sinter plant emission points on the discharge end include sinter discharge, crusher, hot screen, sinter

cooler, and cold screen. Such emissions points are generally hooded individually with an enclosed hood

or a suspended hood and evacuated to one or more control devices. Possible control devices include

fabric filters and water sprays at various transfer points. Possible controls for storage areas include

chemical dust suppression.186

Casthouse emissions from molten iron and slag occur primarily at the tape hole of the blast furnace in

the iron trough immediately adjacent to it. Emissions also result from the runner that transports the iron

and slag and from the ladle that receives the molten iron. The capture and control systems in place for

such emissions include a combination of flame suppression and covered runners, and also evacuation of

such emissions to a control device, most commonly a fabric filter (which requires total enclosures of the

casthouse) and scrubbers.187

The BOPH primary emissions refer to those emissions leaving the mouth of the furnace vessel during

the oxygen blow that are captured by the primary hood. The associated controls for BOPH depend on

whether the BOPH is associated with an open-hood design or a closed-hood design. Open-hood BOPF

shops are controlled with scrubbers and ESP. Closed-hood designs are controlled with Venturi

scrubbers.188

The BOPF secondary emissions include a hot metal transfer, desulfurization, slag skimming, charging,

turndown, tapping, deslagging, teeming, ladle maintenance, flux handling slag handling and disposal,

and ladle metallurgy operations. Fabric filters, and less frequently, wet scrubbers, are used to control

secondary BOPF shop emissions.189

One source of secondary emissions are emissions that occur during the steps of the furnace cycle that

require the vessel to be tipped out from the hood include scrap charging, hot metal charging, sampling,

tapping, and deslagging. When the vessel is tipped, the primary control system may be rendered entirely

ineffective. Such emissions are captured and controlled by furnace enclosures and partial building

evacuation.190

Other sources of secondary emissions are ancillary operations, including hot metal transfer, 

desulfurization, and slag skimming. Such emissions are usually controlled by hooding ducted to a

control device separate from the primary control device.191

After hot metal is refined into steel in the BOPH, further alloy additions and refining of the steel occur

during ladle treatment and vacuum degassing. Most BOPF shops have a separate ladle metallurgy

 

185Id. at 4-1.

186Id. at 4-7.

187Id. at 4-9.

188Id. at 4-17.

189Id. at 4-25.

190Id. 

191Id.
53

stations. Such emissions are generally captured and controlled from ladle metallurgy operations using a

fabric filter, although wet scrubbers are also used.192

7.3. Identification and Summary of Possible RACM Candidates.

Table 7-3 provides a summary of control measures used in the Iron and Steel Foundries source category 

for which the RACM criteria are applied in section 7.4 and the relative likelihood that each control 

measure is a RACM. Specifically, each control measure is assigned a rating of 1 through 3; where the 

higher the number, the more likely that the control measure is a RACM. Such assigned values are 

explained in Table 7-1. 

Table 7-1. General Meanings of Assigned RACM Ratings.

RACM 

Rating

General Meaning of RACM Rating

1 There is limited support for identifying the control measure as a RACM. 

2 There is some support for identifying the control measure as a RACM; more than for a control measure 

with a RACM Rating of “1.”

3 There is substantial support for identifying the control measure as a RACM.

U 

(+ or -)

A “U” indicates that the likelihood that the control measure constitutes a RACM is undetermined due 

to incomplete information. A corresponding “+” indicates that despite incomplete information, an 

application of RACM criteria would likely suggest that the control measure is a RACM, while a “-” 

indicates that despite incomplete information, an application of the RACM criteria would likely 

suggest that the control measure is not a RACM.

Table 7-2. Iron and Steel Foundries Source Category - Summary of Known Control Measures and 

Relative Likelihood that each Control Measure is RACM.

RACM 

Rating

Control Measure Brief Reasoning for RACM Rating

3 Control devices (e.g., fabric filters 

and wet scrubbers) to control process 

lead emissions from sinter plant 

windboxes.

1. Complete adoption by sources.

2. Cost data suggest cost effective. 

3. Identified as MACT roughly 8 years ago.

4. All sources are subject to state regulations or 

permits that practically require such controls.

3 Control devices to control process 

lead emissions from sinter plant 

discharge end emissions points (e.g., 

discharges, crushers, hot screens, 

coolers, and cold screens).

1. Almost complete adoption by sources for such 

emissions points. 

2. Cost data suggest cost effective. 

3. Identified as MACT roughly 8 years ago.

4. All sources are subject to state regulations or 

permits that practically require such controls.

1.5 Control measures to control fugitive 

lead dust emissions from material 

handling (i.e., material storage, 

material mixing, and sinter storage) at 

sinter plants.

1. Low adoption of such measures by sources.

2. No cost data identified. 

3. Not required by any known federal regulations.

4. Five of the 7 operating sinter plants are subject 

to a building opacity standard to limit releases of 

fugitive emissions that might practically require 

such controls.

3 Control measures (e.g., flame 

suppression, covered runners, and 

control devices) to control process 

1. Widespread adoption of such measures by 

sources.

2. Cost data suggest cost effective. 

 

192Id. at 4-30.
54

RACM 

Rating

Control Measure Brief Reasoning for RACM Rating

lead emissions from casthouses at 

iron and steel mills.

3. Identified as MACT roughly 8 years ago.

4. 24/29 casthouses are subject to visible 

emissions standards that limit the opacity of 

emissions discharged from casthouse openings 

that might practically require such controls.

3 Control devices (e.g., scrubbers and 

ESPs) to control process lead 

emissions from BOPF shops at iron 

and steel mills.

1. Complete adoption by sources.

2. Cost data suggest cost effective. 

3. Identified as MACT roughly 8 years ago.

4. All BOPH shops are subject to state regulations 

or permit requirements that might practically 

require such controls.

3 Control measures to control fugitive 

process lead emissions from BOPF 

shops at iron and steel mills for 

various operations (e.g., hot metal 

reladling, hot metal desulfurization, 

skimming, charging, tapping).

1. Complete adoption by sources.

2. Cost data suggest cost effective.

3. Identified as MACT roughly 8 years ago.

4. All BOPH shops are subject to state regulations 

or permit requirements that might practically 

require such controls.

3 Control devices (e.g., wet scrubbers 

and fabric filters) to control fugitive 

process lead emissions from ladle 

metallurgy stations at iron and steel 

mills. 

1. Complete adoption by sources.

2. Cost data suggest cost effective.

3. Identified as MACT roughly 8 years ago.

4. All ladle metallurgy processes are subject to 

state regulations or permit requirements that might 

practically require such controls.

U + Replacing old control devices with 

new control devices. 

1. At least two sources have been identified as 

needing to replace old control devices (> 30 years 

old) to meet new emission standards.

2. No cost data identified. 

3. Not required by any known federal regulations.

7.4. Application of RACM Criteria to Possible RACM Candidates. 

7.4.1. Control devices (e.g., fabric filters and wet scrubbers) to control process lead emissions from 

sinter plant windboxes. 

The complete adoption of control devices (e.g., fabric filters and wet scrubbers) for controlling process 

lead emissions from sinter plant windboxes suggests that such controls are economically feasible. 

Specifically, all nine sinter plants use a control device to control process lead emissions from sinter plant 

windboxes. Four plants use a fabric filter and five plants use a wet scrubber to control windbox

emissions.193

In addition, the available data suggest that such controls are cost effective for regulating process lead 

emissions. Specifically, cost-effectiveness information for PM was available for selected control 

technologies in the source category of Iron and Steel Production, as shown in Table 7-3.194 This 

information suggests that such controls are cost effective for regulating lead as well. 

 

193Id. at 4-1.

194EPA CoST database.
55

Table 7-3. Cost-Effectiveness Information for Selected Control Technologies for Controlling 

Particulate Matter with respect to the Iron and Steel Production Source Category.

Control Technology Cost Effectiveness 

($/ton PM)

Low/High Control 

Efficiency (%)

Dry Electrostatic Precipitator – Wire Plate Type 200 95/98

Fabric Filter – Reverse-Air Cleaned Type 250 99/99.5

Fabric Filter (Mech. Shaker Type) 200 99/99.5

Fabric Filter – (Pulse Jet Type) 200 99/99.5

Venturi Scrubber 3350 25/73

WESP – Wire Plate Type 350 99/99.5

* Rounded to the nearest $50 and escalated from 1999 to 2011 U.S. dollars.195

Moreover, such controls are practically required by the NESHAP for Integrated Iron and Steel Plants (40 

CFR 63, Subpart FFFFF) for both new and existing sources, as such NESHAP provides emissions limits 

for sinter plant windboxes. This might further provide some support that such controls are RACM, since 

such controls represent MACT standards that are over 8 years old.196

State regulations and permits further suggest such controls are reasonably available. Specifically, all 

sinter plants are subject to state regulations or permit requirements that practically require such control 

devices for sinter plant windoxes.197

7.4.2. Control devices (e.g., fabric filters and wet scrubbers) to control process lead emissions from 

sinter plant discharge end emissions points (e.g., discharges, crushers, hot screens, coolers, and 

cold screens). 

The almost complete adoption of control devices (e.g., fabric filters and wet scrubbers) for controlling 

process lead emissions from sinter plant discharge and emission points (i.e., discharges, crushers, hot 

screens, coolers, and cold screens) suggests that such controls are economically feasible. Specifically, all 

9 sinter plants with discharge emission points use a control device (7 fabric filters, 1 scrubber, 1 

rotozone) to control process lead emissions from discharge emissions points; all 7 sinter plants with 

sinter plant crusher emission points use a control device (6 fabric filters, 1 scrubber) to control process 

lead emissions from crusher emission points; all 8 sinter plants with sinter plant hot screen emission 

points use a control device (6 fabric filters, 1 scrubber, 1 rotozone) to control process lead emissions 

from hot screen emission points; 5 of the 8 (3 fabric filters, 1 cyclone, 1 water sprays) sinter plants with 

sinter plant cooler emission points use a control to control process lead emissions from cooler emissions 

points; and 5 of the 7 sinter plants with sinter plant cold screen emission points control (3 fabric filters, 2 

water sprays) cold screen emission points.198

In addition, the available data suggest that such controls are cost effective for regulating process lead 

emissions. Specifically, cost-effectiveness information for PM was available for selected control 

 

195In order to escalate from 1999 dollars to 2011 dollars, used the formula and approach presented in EPA‟s Control Strategy 

Tool (CoST) Control Measures Database (CMDB) Documentation, Page 9. 

196NESHAP for Integrated Iron and Steel Plants Major Sources, 40 CFR 63, Subpart FFFFF (Published May 20, 2003). 

197National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and Steel Plants – Background 

Information for Proposed Standards. EPA-453/R-01-005 (Published January 2001). Page 5-1.

198Id. at 4-30.
56

technologies in the source category of Iron and Steel Production, as shown in Table 7-3.199 This 

information suggests that such controls are cost effective for regulating lead as well. 

Moreover, such controls are practically required by the NESHAP for Integrated Iron and Steel Plants (40 

CFR 63, Subpart EEEEE) for both new and existing sources, as such NESHAP provides PM emissions 

limits for discharge ends at sinter plants. This provides some support that such controls are RACM, 

since such controls represent MACT standards that are over 8 years old.200

State regulations and permit requirements further suggest such controls are reasonably available. 

Specifically, sinter plants are subject to state regulations or permit requirements that practically require 

such control devices to control sinter plant discharge and emission points.201

7.4.3. Control measures to control fugitive lead dust emissions from material handling (i.e., material 

storage, material mixing, and sinter storage) at sinter plants.

The less widespread control of fugitive lead dust emissions from material handling (i.e., material 

storage, material mixing, and sinter storage) at sinter plants suggests that such controls are not 

economically feasible. Specifically, emissions from material handling are generally fugitive emissions 

and are usually uncontrolled. Only one sinter plant in the country uses a fabric filter to control emissions 

from material storage; the remaining plants use no control. One plant uses water sprays to wet the 

materials at the various transfer points. One plant uses chemical dust suppression on the product to 

control material storage.202

State regulations and permit requirements provide some support that there are control measures that 

might be reasonable. Specifically, 5 of the 7 operating sinter plants are subject to state regulation or 

permit requirements that require building opacity limits that might practically require such controls.203

7.4.4. Control measures (i.e., flame suppression, covered runners, and control devices) to control 

process lead emissions from casthouses at iron and steel mills.

The widespread use of control measures (i.e., flame suppression, covered runners, and control devices) 

to control process lead emissions from casthouses at iron and steel mills suggests that such control 

measures are economically feasible. Specifically, 12 of the 20 iron and steel mills use flame suppression 

at casthouses to control process lead emissions; 15 of the 20 iron and steel mills use covered runners at 

casthouses to control process lead emissions; and 13 of the 20 iron and steel mills evacuate process lead 

emissions to a control device (12 fabric filters, 1 scrubber).204

In addition, the available data suggest that the control devices used are cost effective for regulating 

process lead emissions. Specifically, cost-effectiveness information for PM was available for selected 

control technologies in the source category of Iron and Steel Production, as shown in Table 7-3, where 

 

199EPA CoST database.

200NESHAP for Integrated Iron and Steel Plants Major Sources (40 CFR 63, Subpart FFFFF). 

201National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and Steel Plants – Background 

Information for Proposed Standards. EPA-453/R-01-005 (Published January 2001). Page 5-1.

202Id. at 4-7 to 4-8.

203Id. at 5-1.

204Id. at 4-10.
57

cost-effectiveness values for fabric filters, ESPs and scrubbers all seem reasonable when used.205 This 

information suggests that such controls are cost effective for regulating lead as well. 

Moreover, such controls are practically required by the NESHAP for Integrated Iron and Steel Plants (40 

CFR 63, Subpart EEEEE) for both new and existing sources, as such NESHAP provides PM emissions 

limits for casthouses at blast furnaces. This might further provide some support that such controls are 

RACM, since such controls represent MACT standards that are over 8 years old.206

State regulations and permit requirements suggest that such controls measures are reasonable. 

Specifically, 24 of the 29 casthouses are subject to visible emission standards by state regulations or 

permits that limit the opacity of emissions discharged from casthouse openings, and therefore that might 

practically require such control measures.207

7.4.5. Control devices (e.g., scrubbers and ESPs) to control process lead emissions from BOPF shops at 

iron and steel mills

The complete adoption of control measures to control process lead emissions from BOPH shops at iron

and steel mill suggests that such controls are economically feasible. Specifically, all BOPH shops at iron 

and steel mills use a capture system and control device to control process lead emissions from BOPF 

shops. Specifically, all 16 open-hood BOPF shops use control devices (8 Venturi scrubbers, 8 ESPs) to 

control such emissions, and all 8 of the closed-hood BOPH shops use control devices (8 Venturi 

scrubbers) to control such emissions.

208

In addition, the available data suggest that such controls are cost effective for regulating process lead 

emissions. Specifically, cost-effectiveness information for PM was available for selected control 

technologies in the source category of Iron and Steel Production, as shown in Table 7-3, where costeffectiveness values for fabric filters, ESPs and scrubbers are reasonable when used.209 This information 

suggests that such controls are cost effective for regulating lead as well. 

Moreover, such controls are practically required by the NESHAP for Integrated Iron and Steel Plants (40 

CFR 63, Subpart EEEEE) for both new and existing sources, which provides PM emissions limits for 

BOPFs. This might further provide some support that such controls are RACM, since such controls 

represent MACT standards that are over 8 years old.210

State regulations and permit requirements suggest that such controls measures are reasonable. 

Specifically, all BOPH shops are subject to states regulations or permit requirements that might 

practically require such controls.211

 

205EPA CoST database.

206NESHAP for Integrated Iron and Steel Plants Major Sources, 40 CFR 63, Subpart FFFFF (Published May 20, 2003). 

207Id. at 5-1.

208Id. at 4-20 to 4-21.

209EPA CoST database.

210NESHAP for Integrated Iron and Steel Plants Major Sources, 40 CFR 63, Subpart FFFFF (Published May 20, 2003). 

211National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and Steel Plants – Background 

Information for Proposed Standards. EPA-453/R-01-005 (Published January 2001). Page 5-9.
58

7.4.6. Control measures to control fugitive process lead emissions from BOPF shops at iron and steel 

mills for various operations (e.g., hot metal reladling, hot metal desulfurization, skimming, 

charging, tapping). 

The widespread use of control measures to control fugitive process lead emissions from BOPH shops at 

iron and steel mills for various operations (e.g., hot metal reladling, hot meal desulfurization, skimming, 

charging, and tapping) suggests that such measures are economically feasible. Generally, iron and steel 

mills use control measures to control process fugitive lead emissions from BOPH shops for hot metal 

reladling, hot metal desulfurization, skimming, and charging. Specifically, 22 of the 23 BOPHs control 

such emissions for hot metal reladling (13 fabric filters, 4 fabric filters with hoods, 2 fume suppression, 

1 flame suppression, 1 with two fabric filters); 23 of the 23 BOPHs control such emissions for hot metal 

desulfurization (17 fabric filters, 5 fabric filters with hoods, 1 with two fabric filters); 17 of the 23 

BOPHs control such emissions for skimming (12 fabric filters, 5 fabric filters with hoods); 21 of the 23 

BOPHs control such emissions for charging (4 fabric filters, 6 fabric filters with hoods, 5 scrubbers, 6 

electrostatic precipitators).212

Moreover, such controls are practically required by the NESHAP for Integrated Iron and Steel Plants (40 

CFR 63, Subpart EEEEE) for both new and existing sources, which provides PM emissions limits for 

each hot metal transfer, skimming, and desulfurization operation. This provides support that such 

controls are RACM, since such controls represent MACT standards that are over 8 years old.213

State regulations and permit requirements suggest that such controls measures are reasonable. 

Specifically, all BOPH shops are subject to states regulations or permit requirements that might 

practically require such controls.214

7.4.7. Control devices (e.g., wet scrubbers and fabric filters) to control fugitive process lead emissions 

from ladle metallurgy stations at iron and steel mills. 

The complete adoption of control devices (e.g., wet scrubbers and fabric filters) to control fugitive 

process lead emissions from ladle metallurgy stations at iron and steel mills suggests that such controls 

are economically feasible. All ladle metallurgy stations at iron and steel mills control process lead 

emissions with control devices (3 wet scrubbers, 21 fabric filters).215

In addition, the available data suggest that such controls are cost effective for regulating process lead

emissions. Specifically, cost-effectiveness information for PM was available for selected control 

technologies in the source category of Iron and Steel Production, as shown in Table 7-3, where costeffectiveness values for fabric filters, ESPs and scrubbers are reasonable when used.216 This information 

suggests that such controls are cost effective for regulating lead as well. 

Moreover, such controls are practically required by the NESHAP for Integrated Iron and Steel Plants (40 

CFR 63, Subpart EEEEE) for both new and existing sources, as such NESHAP provides PM emissions 

 

212Id. at 4-30.

213NESHAP for Integrated Iron and Steel Plants Major Sources, 40 CFR 63, Subpart FFFFF (Published May 20, 2003). 

214National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and Steel Plants – Background 

Information for Proposed Standards. EPA-453/R-01-005 (Published January 2001). Page 5-12.

215Id. at 4-35 to 4-37.

216EPA CoST database.
59

limits for each ladle metallurgy operation. This might further provide some support that such controls 

are RACM, since such controls represent MACT standards that are over 8 years old.217

State regulations and permit requirements suggest that such control measures are reasonable. 

Specifically, all ladle metallurgy stations are subject to state regulations or permit requirements that 

might practically require such controls.218

7.4.8. Replacing Old Control Devices with New Control Devices.

The age and recent identification of plants that need to replace old control devices with new control 

devices to meet emission standards suggests that such a measure may become more economically 

feasible. Specifically, scrubbers over 30 years old have been identified to be replaced in order to meet 

emission limits at two plants.

219

 

217NESHAP for Integrated Iron and Steel Plants Major Sources, 40 CFR 63, Subpart FFFFF (Published May 20, 2003). 

218National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and Steel Plants – Background 

Information for Proposed Standards. EPA-453/R-01-005 (Published January 2001). Page 5-15.

219Economic Impact Analysis of Final Integrated Iron and Steel NESHAP. EPA 452/R-02-009 (Published September 2002).

Page 3.
60

8.0. RACM DEVELOPMENT FOR FUGITIVE DUST CONTROL 

MEASURES

Sections 4 through 7 supported RACM development with respect to certain source categories –

Secondary Lead Smelting, Lead Acid Battery Manufacturing, Iron and Steel Foundries, and Iron and 

Steel Mills. Such previous sections generally provided an undetermined likelihood that fugitive dust 

control measures would be RACM for most of the source categories. This section applies the RACM 

criteria to fugitive dust control measures to glean what considerations are most vital for determining 

whether fugitive dust control measures, in general, are reasonably available. 

8.1. The Economic Feasibility of Fugitive Dust Control Measures.

Support documents drafted from information collection requests for NESHAP development for the 

Secondary Lead Smelting, Lead Acid Battery Manufacturing, and Iron and Steel Foundries suggest that 

fugitive dust control measures are most economically feasible for the largest emitting sources.

Table 8.1 shows the average lead emissions emitted per facility for a given source category. Such table 

indicates that on average, there is 3 to greater than 10 times more lead being emitted per secondary lead 

smelting facility than from any typical source from one of other source categories included in Table 8.1. 

Table 8.2 shows the extent to which facilities have adopted fugitive dust control measures, as indicated 

from the most recent information collection requests for NESHAP development. The source category of 

secondary lead smelting is the only source category with sources to have adopted several fugitive dust 

control measures. This suggests that fugitive dust controls are most economically feasible for sources 

that emit a high level of emissions.

Table 8-1. Calculation of the Average Annual Lead Emissions Emitted per Facility in a Given 

Source Category. 

Source Category Annual 

Emission 

(Tons/Year)

220

% of Total 

Emissions from 

All Source 

Categories221

Number of 

Sources

Calculated 

Average Lead 

Emissions per 

Facility 

(Tons/Year)

Iron and Steel Foundries 83 6.05 > 2000 222 0.04

Secondary Lead Smelting 14 3.21 15

223 1.00

Lead Acid Battery 

Manufacturing

17 1.24 60 224 0.12

 

220The Regulatory Impact Analysis of the Proposed Revisions to the National Ambient Air Quality Standards for Lead 

(Published October 2008). Page 7.

221Id.

222National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 

1-2.

223Memorandum – Draft Summary of the Technology Review for the Secondary Lead Smelting, From Mike Burr, ERG, To 

Chuck French, EPA/OAQPS. April 2011.

224Memorandum – Lead Acid Battery Manufacturing Area Source Category Additional Information to Support Proposed 

Rule, From Nancy Jones, EC/R, To U.S. EPA Docket Number EPA-HQ-OAR-2006-0897. February 28, 2007.
61

Table 8-2. Extent of Known Adoption of Fugitive Dust Control Measures in the Secondary Lead 

Smelting, Lead Acid Battery Manufacturing, and Iron and Steel Foundry Source Categories. 

Secondary Lead 

Smelting225

Lead Acid Battery 

Manufacturing226

Iron and Steel 

Foundries227

Paving unpaved roads Adoption by all sources No known 

widespread 

adoption228

No known adoption

Cleaning paved road Adoption by all sources No known adoption No known adoption

Chemical stabilization of unpaved 

roads

No known adoption No known adoption No known adoption

Paving of entire facility grounds Adoption by several sources No known adoption No known adoption

Cleaning of building roofs and 

exteriors

Adoption by several sources No known adoption No known adoption

Enclosure hoods and partial 

enclosures for storage areas

Adoption by all sources No known adoption No known adoption

Wet suppression on storage piles Adoption by all sources No known adoption No known adoption

Negative pressure total enclosures

for storage areas

Adoption by 11 of the14

sources

No known adoption No known adoption

Vehicle washing at each facility exit Adoption by all sources No known adoption No known adoption

Vehicle washing inside building Adoption by several sources No known adoption No known adoption

Use of daily ambient monitoring to 

diagnose activities that lead to 

NAAQS exceedances for lead.

Adoption by several sources No known adoption No known adoption

8.2. The Capital Costs, Annualized Costs, and Cost Effectiveness of Fugitive Dust Control 

Measures.

Cost-effectiveness data for fugitive dust control measures are not well-developed. This might be due to 

the fact that the cost effectiveness of a specific fugitive dust control measure is highly variable from 

plant-to-plant. The cost effectiveness will depend on many variables that can change from plant-to-plant 

with even similar levels of emissions, such as the length of roads to be paved, the historic use of 

emissions that might already be deposited around the plant, etc.

However, the available cost-effectiveness data indicate that process emission control measures are much 

more cost effective (by a factor of 2-4) than fugitive dust control measures. Table 8.3 displays the costeffectiveness data for three fugitive dust control measures averaged for all sources in all source 

categories compared to cost effectiveness of mechanical shaker type fabric filters at iron and steel 

foundries, iron and steel mills, and lead processing facilities.

229 Such comparison indicates the fugitive 

dust control measures are much less cost effective than the use of fabric filters. 

 

225Memorandum – Draft Summary of the Technology Review for the Secondary Lead Smelting, From Mike Burr, ERG, To 

Chuck French, EPA/OAQPS. April 2011.

226Memorandum – Lead Acid Battery Manufacturing Area Source Category Additional Information to Support Proposed 

Rule, From Nancy Jones, EC/R, To U.S. EPA Docket Number EPA-HQ-OAR-2006-0897. February 28, 2007..

227National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background 

Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page 

1-2.

228One battery manufacturing facility - the Exide Battery Manufacturing facility in Salina, KS – has paved unpaved roads to 

control fugitive emissions. Stephanie Doolan / EPA Region 7. 

229EPA CoST database.
62

Table 8-3. Cost Effectiveness of Fugitive Dust Control Measures Compared to Fabric Filters.

Control Measure Source Category Cost Effectiveness

($/ton PM)

Control

Efficiency

(%)

Vacuum Sweeping Paved Roads Average of all 550 50.0

Hot Asphalt Paving of Unpaved

Roads

Average of all 700 66.6

Chemical Stabilization of 

Unpaved Road

Average of all 3200 37.5

Fabric Filter (Mech. Shaker 

Type)

Average of Iron 

and Steel 

Foundries

200 99.5

Fabric Filter (Mech. Shaker 

Type)

Iron and Steel 

Production

200 99.5

Fabric Filter (Mech. Shaker 

Type)

Lead Processing 450 99.5

* Rounded to the nearest $100 and escalated from 1999 to 2011 U.S. dollars.230

8.3. Fugitive Dust Control Measures Adopted in Federal and State Regulations. 

The extent to which state and federal regulations require fugitive dust control measures further suggest 

that such control measures are more reasonable for larger sources. Table 8.4 shows the extent of 

adoption of several fugitive control measures by California‟s SCAQMD and the NESHAPs for 

Secondary Lead Smelting Major Sources, Lead Acid battery Manufacturing Area Sources, Iron and 

Steel Foundry Area Sources, and Iron and Steel Foundry Major Sources. Several fugitive dust control 

measures are adopted by the NESHAP for Secondary Lead Smelting for Major Sources, where the 

average lead emissions per facility are highest; whereas no fugitive dust control measures are adopted by 

the NESHAP for Lead Acid Battery Manufacturing for Area Sources, where the average lead emitted 

per facility is smaller. Moreover, no fugitive dust control measures are required by the NESHAP for Iron 

and Steel Foundries Area Sources, but there is at least a limit that applies to fugitive dust lead emissions 

in the NESHAP for Iron and Steel Foundries Major Sources. This further indicates that the amount of 

lead emissions emitted for a facility is a key consideration when determining whether fugitive dust 

control measures are reasonable. 

Moreover, California‟s SCAQMD Rule 1420, requires secondary lead smelting and lead acid battery 

manufacturing facilities to implement several fugitive dust control measures. The fact that California 

requires such adoption might suggest that fugitive dust control measures are not out of economic reach 

for small lead acid battery area sources. However, California‟s SCAQMD Rule 1420.1 applies only to 

large secondary lead smelting sources, and requires even more stringent fugitive dust control measures

than Rule 1420, which further suggests that fugitive dust control measures are more cost effective for 

the largest lead emitting sources. 

 

230In order to escalate from 1999 dollars to 2011 dollars, used the formula and approach presented in EPA‟s Control Strategy 

Tool (CoST) Control Measures Database (CMDB) Documentation, Page 9. 
63

Table 8-4. Extent of Known Adoption of Fugitive Dust Control Measures in Selected Federal and 

State Regulations

1997 

NESHAP 

Secondary 

Lead 

Smelting 

for Major 

Sources231

NESHAP Lead 

Acid Battery 

Manufacturing 

Areas Sources 

232& NESHAP 

Iron and Steel 

Foundries 

Area 

Sources233

NESHAP 

Iron and Steel 

Foundries 

Major 

Sources234

California’s

SCAQMD Rule for 

Lead Processing 

Facilities 

(includes Lead 

Acid Battery 

Manufacturing 

Secondary Lead 

Smelting, Iron and 

Steel Foundries), 

Rule 1420 235, 236

California’s SCAQMD

Rule for Lead from 

Large Lead Acid 

Battery Recycling 

Facilities, Rule 1420.1.

237, 238

Paving unpaved 

roads

Adopted Not adopted Not adopted Not adopted Requires paving facility 

grounds.

Cleaning paved 

road (e.g., vacuum 

sweeping)

Adopted Requires that 

surfaces that 

accumulate leadcontaining dust due 

to traffic be washed, 

vacuumed once / 

week or chemically 

suppressed.

Requires frequent 

cleaning by wet wash or 

vaccum of such areas. 

Chemical 

stabilization of 

unpaved roads

Not adopted Not adopted Not adopted

Paving of entire 

facility grounds

Not adopted Not adopted Requires paving facility 

grounds.

Cleaning of 

building roofs and 

exteriors

Not adopted Not adopted Requires frequent 

cleaning of building 

roofs and exteriors.

Enclosure hoods 

and partial 

enclosures for 

storage areas

Adopted Requires that dust 

forming material to 

be stored in an 

enclosed storage 

area.

Requires total enclosures 

under negative pressure 

for several areas. 

Wet suppression 

on storage piles

Adopted Not adopted Requires total enclosures 

under negative pressure 

for several storage areas.

Cleaning of 

pavement around 

operation / storage 

area

Adopted Requires surfaces 

that accumulate lead 

dust due to foot 

traffic be washed, 

vacuumed, or wetRequires frequent 

cleaning of such areas by 

wet wash or vacuum. 

 

231NESHAP for Secondary Lead Smelting, 40 CFR 63, Subpart X (Published June 13, 1997).

232NESHAP for Lead Acid Battery Manufacturing Plants, 40 CFR 63 Subpart PPPPPP (Published July 16, 2007)..

233NESHAP for Iron and Steel Foundries Area Sources, 40 CFR 63, Subpart ZZZZZ (Published April 22, 2004).

234NESHAP for Iron and Steel Foundries Major Sources, 40 CFR 63, Subpart EEEEE (Published April 22, 2004). 

235California (South Coast Air Quality Management District), Rule 1420 - Emission Standards for Lead (Published 

September, 1992).

236The fugitive dust control requirements of California‟s SCAQMD Rule 1420 only apply to facilities that exceed specified 

processing thresholds (more than 2 tons of lead per year). 

237California (South Coast Air Quality Management District), Rule 1420.1 - Emission Standards for Lead from Large Lead 

Acid Battery Recycling Facilities (Adopted November 5, 2010).

238California (South Coast Air Quality Management District), Rule 1420.1 - Emission Standards for Lead from Large Lead 

Acid Battery Recycling Facilities (Adopted November 5, 2010). Note that 
64

1997 

NESHAP 

Secondary 

Lead 

Smelting 

for Major 

Sources231

NESHAP Lead 

Acid Battery 

Manufacturing 

Areas Sources 

232& NESHAP 

Iron and Steel 

Foundries 

Area 

Sources233

NESHAP 

Iron and Steel 

Foundries 

Major 

Sources234

California’s

SCAQMD Rule for 

Lead Processing 

Facilities 

(includes Lead 

Acid Battery 

Manufacturing 

Secondary Lead 

Smelting, Iron and 

Steel Foundries), 

Rule 1420 235, 236

California’s SCAQMD

Rule for Lead from 

Large Lead Acid 

Battery Recycling 

Facilities, Rule 1420.1.

237, 238

mopped once per 

week or chemically 

suppressed

Negative pressure 

total enclosures

Not adopted Not adopted Requires total enclosures 

under negative pressure 

for several areas.

Vehicle washing at 

each facility exit

Not adopted Not adopted Not adopted

Vehicle washing 

inside building

Not adopted Not adopted Not adopted

Daily ambient 

monitoring to 

diagnose activities 

that lead to 

NAAQS 

exceedances for 

lead

Not adopted Requires 24 hour 

monitoring (once 

very six days) if a 

facility processes 

more than 2 tons of 

lead per year and 

emits lead equal to 

or greater than 0.5 

lbs/day.239

Requires 24 hour 

monitoring once every 

three days, and daily 

monitoring if an 

exceedance is revealed.

Limit for fugitive 

dust emissions

Not adopted Adopted an 

opacity limit 

that applies to 

fugitive dust 

sources.

Requires an opacity 

limit where 

emissions cannot

exceed 0.5 or 10 

percent opacity for 

more than three 

aggregate minutes in 

any 60-minute 

period. 

Not adopted

Storage , disposal, 

recovery, or 

recycling of lead 

or lead-containing 

wastes generated 

from 

housekeeping 

activities using 

practices that do 

not lead to fugitive 

lead-dust 

emissions

Not adopted Not adopted Not adopted Adopted. Not adopted.

 

239Facilities processing between 2-10 tons of lead per year may be exempted if modeling shows they are below half the 

standard.
65

8.4. Implications for RACM Development for Fugitive Dust Control Measures. 

Available cost information suggests that process emission control measures (e.g., fabric filters) are 

generally 2 to 4 times more cost effective than fugitive dust control measures. Moreover, the extent of 

adoption of fugitive dust control measures by sources and federal/state regulations suggests that the most 

important consideration in determining whether fugitive dust control measures are reasonably available 

for a given source in a corresponding source category is the average amount of emissions emitted per 

source in a given source category. Specifically, as the average amount of emissions per source in a given 

source category increases, the more likely that fugitive dust control measures might be reasonably 

available.

Nevertheless, additional considerations may suggest that fugitive dust control measures are reasonably 

available for sources that have already adopted more cost-effective process emission controls (e.g., 

fabric filters). For example, EPA has indicated that where essential reductions are difficult to achieve 

because many sources are already being controlled, the cost per ton of control may necessarily be higher 

and be considered reasonable.240 Consequently, if a source has adopted process emission controls, but is 

still contributing to a lead NAAQS violation, then fugitive dust controls might be the only viable option 

to eliminate the NAAQS violation and may, therefore, be reasonable despite being less cost effective 

than the initial cost of process emissions controls. 

Also, additional considerations may suggest that fugitive dust control measures are RACM for sources

that are area sources or smaller emitting sources. For example, the fact that an area source is in an area 

with more serious air quality problems may make it more reasonable and appropriate for such areas to 

impose emission reduction requirements that are less cost effective.241 Consequently, if an area source is 

contributing to a lead NAAQS violation, and there are no other viable sources from which emissions can 

be reduced to get the area within attainment, then imposing less cost effective control measures to

smaller area sources might be more reasonable and appropriate. Moreover, EPA has indicated that a 

large amount of historically deposited lead might increase the reasonableness of fugitive dust control 

measures.

242

In addition, EPA encourages the development of innovative measures not previously employed which 

may also be technically and economically feasible.243 Therefore, the fact that fugitive dust control 

measures have not been adopted by many facilities or federal/state regulations does not preclude the 

 

240“In addition, where essential reductions are more difficult to achieve (e.g., because many sources are already controlled), 

the cost per ton of control may necessarily be higher.” National Ambient Air Quality Standards for Lead; Final Rule, 73 FR 

66964, 67036 (Published November 12, 2008).

241“Areas with more serious air quality problems typically will need to obtain greater levels of emissions reductions from 

local sources than areas with less serious problems, and it would be expected that their residents could realize greater public 

health benefits from attaining the standard as expeditiously as practicable. For these reasons, we believe that it will be 

reasonable and appropriate for areas with more serious air quality problems and higher design values to impose emission 

reduction requirements with generally higher costs per ton of reduced emissions than the cost of emissions reductions in areas 

with lower design values.” Id. at 67036

242“Some emissions that contribute to violations of the Lead NAAQS may also be attributed to smaller area sources. At 

primary lead smelters, the process of reducing concentrated ore to lead involves a series of steps, some of which are 

completed outside of buildings, or inside of buildings that are not totally enclosed. Over a period of time, emissions from 

these sources have been deposited in neighboring communities (e.g., on roadways, parking lots, yards, and off-plant 

property). This historically deposited lead, when disturbed, may be re-entrained into the ambient air and may contribute to 

violations of the Lead NAAQS in affected areas. “Id.

243“EPA also encourages the development of innovative measures not previously employed which may also be technically 

and economically feasible.” Id.
66

possibility that such fugitive dust control measures are RACM. For example, many control measures 

such as bins, hoppers, totes, plastic curtains, moving stockpiles away from doors and traffic lanes, and 

soil stabilization measures (e.g., landscaping of areas where lead emissions have been historically 

deposited) are all measures that, on their faces, seem inexpensive and could lessen emissions. 

Consequently, such measures might constitute RACM, especially when emission reductions are 

necessary to attain the NAAQS and the availability of other control measures to implement is limited. 

California‟s SCAQMD Rule 1420.1 requires a list of many such fugitive dust control measures that 

facilities might consider. 244 A list of many of the fugitive dust control measures specified by Rule 

1420.1 is provided in 4.4.9 of this document and in Table 8.4 of this document. 

 

244California (South Coast Air Quality Management District), Rule 1420.1 - Emission Standards for Lead from Large Lead 

Acid Battery Recycling Facilities (Adopted November 5, 2010).
United States

Environmental Protection

Agency

Office of Air Quality Planning and Standards

Air Quality Policy Division

Research Triangle Park, NC

EPA-457/R-12-001

March 2012