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MEMORANDUM 

To: Chuck French, U.S. Environmental Protection Agency, OAQPS 

From: Mike Burr, Donna Lazzari, and Danny Greene, ERG 

Date: April 2011 

Subject: Draft Development of the RTR Emissions Dataset for the Secondary Lead 

Smelting Source Category 

This memorandum summarizes the data and methodologies used to develop the sitespecific emissions and stack release characteristics that were used to conduct the risk assessment 

modeling for the Secondary Lead Smelting source category. This memorandum is organized as 

follows: 

1.0 Background 

2.0 Release Characteristics and Locations of Stack and Fugitive Emissions Sources 

3.0 Metal HAP Emissions From Stacks 

4.0 Organic Compound Emissions from Stacks 

5.0 Metal HAP Emissions From Fugitive Dust Sources 

6.0 Alternative Method for Estimating Fugitive Dust Emissions 

7.0 Estimating MACT-allowable emissions 

8.0 Estimating Short-Term Acute Emissions 

9.0 Estimating Emissions Reductions for Control Scenarios 

1.0 BACKGROUND 

Table 1-1 lists the 14 secondary lead smelters currently in operation in the United States. 

In June of 2010, EPA issued an information collection request (ICR) pursuant to section 114 of 

the Clean Air Act (CAA) to six companies who own all of the 14 secondary lead smelting 

facilities. The six companies submitted responses for all 14 facilities. The ICR requested 

available information on process equipment, control devices, stack and fugitive emissions from 

their perspective facility, stack parameters, as well as other aspects of the facilities’ operations. 

The ICR also requested that each facility submit historical stack test data for any test conducted 

in 2003 or later. Additionally, 8 facilities were asked, as part of the ICR, to conduct stack tests 

for a variety of pollutants and processes that were considered representative of the industry. 
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Table 1-1. Secondary Lead Smelters Currently Operating in the U.S. 

FACILITY NAME PARENT COMPANY CITY STATE 

Facility 

Abbreviation 

East Penn 

Manufacturing 

East Penn Manufacturing 

Co., Inc. 

Lyon Station Pennsylvania East Penn 

EnviroFocus 

Technologies, LLC Gopher Resources, LLC Tampa Florida EnviroFocus 

Gopher Resources, LLC Gopher Resources, LLC Eagan Minnesota Gopher Eagan

Quemetco, Inc., 

California 

Eco-Bat Technologies, LTD 

(Quemetco West, LLC) 

City of 

Industry 

California Quemetco CA 

Quemetco, Inc., Indiana 

Eco-Bat Technologies, LTD 

(Eco-Bat Indiana, LLC) Indianapolis Indiana Quemetco IN 

Revere Smelting and 

Refining Corporation 

(RSR) 

Eco-Bat Technologies, LTD 

(Eco-Bat New York, LLC) Middletown New York RSR 

Sanders Lead Company Sanders Lead Company Troy Alabama Sanders Lead

Baton Rouge Recycling 

Center 

Exide Technologies, Inc. Baton Rouge Louisiana 

Exide Baton 

Rouge 

Canon Hollow 

Recycling Facility 

Exide Technologies, Inc. Forest City Missouri Exide Forest City 

Frisco Battery Recycling Exide Technologies, Inc. Frisco Texas Exide Frisco

Exide Technologies, 

Indiana 

Exide Technologies, Inc. Muncie Indiana Exide Muncie 

Exide Technologies –

Reading Recycling 

Exide Technologies, Inc. Reading Pennsylvania Exide Reading 

Exide Technologies, 

California 

Exide Technologies, Inc. Vernon California Exide Vernon 

Buick Resource 

Recycling Facility, LLC 

The Doe Run Resources 

Corporation 

Boss Missouri Buick RRF 

The emissions and process data collected under the ICR were used to develop sitespecific baseline emissions estimates and emissions source release characteristics (i.e., elevation, 

stack height, stack diameter, stack gas exit velocity, stack gas flow rate, stack gas exit 

temperature, and stack location (latitude and longitude)) for each of the facilities. The baseline 

emissions estimates include stack and fugitive dust emissions from secondary lead smelting 

processes. Table 1-2 summarizes the pollutants included in the baseline emissions estimates for 

both stack and fugitive emissions. We also developed a separate facility-wide dataset that 

included emissions from other process located on site in addition to those associated with the 

secondary lead smelting processes. However, because the level of detail in the ICR surveys for 

the non-secondary lead processes varied considerably, emissions for these processes were 

obtained from the facility records contained in the EPA’s 2005 National Emissions Inventory 

(NEI). These baseline emissions estimates and emissions source release characteristics were 

used as the data inputs for the EPA’s risk assessment modeling for this source category. 
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Table 1-2. Pollutants Included in the Secondary Lead Smelting Modeling File. 

HAP STACK FUGITIVE

1,1,2,2-Tetrachloroethane ü

1,3-Butadiene ü

1,3-Dichloropropene ü

2,3,7,8-TCDD TEQ ü

Acetaldehyde ü

Acetophenone ü

Acrolein ü

Acrylonitrile ü

Antimony ü ü

Arsenic ü ü

Benz[a]Anthracene ü

Benzene ü

Benzo[a]Pyrene ü

Benzo[b]Fluoranthene ü

Benzo[k]Fluoranthene ü

Beryllium ü ü

Biphenyl ü

Bis(2-Ethylhexyl)Phthalate ü

Cadmium ü ü

Carbon Disulfide ü

Chlorine ü

Chlorobenzene ü

Chloroform ü

Chromium (VI) ü ü

Chromium III ü ü

Chrysene ü

Cumene ü

Dibenzo[a,h]Anthracene ü

Dibutyl Phthalate ü

Divalent Mercury ü ü

Elemental Gaseous Mercury ü

Ethyl Benzene ü

Ethyl Chloride ü

Formaldehyde ü

Hexane ü

Hydrochloric Acid ü

Indeno[1,2,3-c,d]Pyrene ü

Lead ü ü
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Table 1-2. Pollutants Included in the Secondary Lead Smelting Modeling File. 

HAP STACK FUGITIVE

Manganese ü ü

Methyl Bromide ü

Methyl Chloride ü

Methyl Iodide ü

Methyl Isobutyl Ketone ü

Methylene Chloride ü

m-Xylene ü

Naphthalene ü

Nickel ü ü

o-Cresol ü

o-Xylene ü

Particulate Mercury ü ü

Phenol ü

Propionaldehyde ü

p-Xylene ü

Pyrene ü

Selenium ü ü

Styrene ü

Tetrachloroethylene ü

Toluene ü

Trichloroethylene ü

Xylenes (Mixture of o, m, and p)Isomers) ü

2.0 RELEASE CHARACTERISTICS AND LOCATIONS OF STACK AND 

FUGITIVE EMISSIONS SOURCES 

Fixed parameters for stack release points, such as elevation, stack height, stack diameter, 

and stack location, were extracted from the surveys submitted by the facilities. The location 

coordinates for each emissions source submitted in the ICR surveys were checked using Google 

Earth©. For Exide Frisco and the RSR NY facilities, the stack coordinates were found to be 

inaccurate. Therefore, the stack coordinates for Exide Frisco were extracted from a 2008 

modeling file provided by EPA contractor ICF International and the stack coordinates for RSR 

were estimated using Google Earth©. Google Earth©was also used to estimate the location and 

dimensions of the fugitive dust emissions sources at each facility. For risk assessment modeling 

purposes, the coordinates of the fugitive emissions sources were placed at the southwest corner 

of each facility and the dimensions were chosen such that the source spanned the entire facility. 

Values for stack exit velocity, flow rate, and exit temperature were obtained from the 

corresponding emissions test reports from which emissions data were extracted. In cases where 
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emissions from multiple test reports were averaged, the stack parameters from those reports were 

averaged. In the event that any of the varying parameters were not available in the test report, 

estimates provided by the industry in their ICR surveys were used. 

3.0 METAL HAP EMISSIONS FROM STACKS 

Table 3-1 presents the metal hazardous pollutants (HAP) emissions estimates for stacks at 

each facility. The emissions estimates shown in Table 3-1 were developed using the site-specific 

emissions data collected by the ICR. In cases where stack test results included values reported as 

being below a test method detection limit (BDL), the detection limits specified in the test reports 

were used in the emissions estimates. For beryllium, none of the emissions test data were above 

the method detection limit. Consequently, stack emissions estimates for this metal were not 

developed. 

3.1 Lead

Because of the annual (or biannual) performance testing required by the current National 

Emissions Standards for Hazardous Air Pollutants (NESHAP) for the Secondary Lead Smelting 

source category (40 CFR part 63, subpart X), a large amount of data were available for lead 

emissions from stack (i.e., point) sources. Consequently, the site-specific lead emissions 

estimates were compiled using stack test data obtained for the years 2006 through 2010. In cases 

where multiple test reports in the 2006-2010 timeframe were available for a particular stack at a 

facility, the average of the emissions values from the test reports was used in the emissions 

estimate. If a facility had undergone recent modifications that affected stack emissions, only 

post-modification emissions were used in the emissions estimates (this holds true for all 

pollutants). 

We obtained lead stack test data for 99 release points, which account for the vast majority 

of release points. However, site-specific lead emissions data were not available for two stack 

release points identified in the ICR surveys. For these emissions points, default emissions 

factors were developed using data from similar processes at other facilities. 

3.2 Other Metals

Where available, site-specific data for non-lead metal HAP (i.e., arsenic (As), cadmium 

(Cd), trivalent chromium (Cr+3), hexavalent chromium (Cr+6), mercury (Hg), manganese (Mn), 

and nickel (Ni)) emissions from stacks were used for the emissions estimates. In cases where 

site-specific data were not available, emissions estimates for non-lead metal HAP were 

developed using facility lead emissions and ratios of non-lead metal HAP to lead. 
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Table 3-1. Point Source Metal HAP Emissions Estimates (lbs/yr) by Facility. 

Name of Facility As Sb Cd Cr+6 Cr+3 Elemental 

Hg* Divalent Hg* Particulate Hg* Pb Mn Ni Se 

Buick RRF 2,352.0 441.3 425.6 0.3 11.4 21.4 2.7 2.7 9,389.4 104.4 34.0 117.4 

East Penn 3.8 14.1 0.9 0.1 3.2 7.4 0.9 0.9 299.5 15.0 6.0 3.7 

Exide Vernon 12.0 23.5 0.4 0.1 9.7 13.9 1.7 1.7 499.6 45.6 16.0 6.2 

Exide Reading 27.8 101.5 2.4 0.2 7.4 9.4 1.2 1.2 2,160.1 31.3 14.5 27.0 

Exide Muncie 8.8 20.0 0.4 0.1 4.7 6.1 0.8 0.8 425.8 22.1 7.8 5.3 

Exide Baton Rouge 42.8 203.9 7.2 0.2 5.6 7.2 0.9 0.9 4337.3 21.3 13.4 54.2 

Exide Forest City 5.5 13.5 0.2 0.1 1.8 2.4 0.3 0.3 286.2 7.9 3.7 3.6 

Exide Frisco 31.6 115.6 2.5 0.1 8.1 10.2 1.3 1.3 2,459.2 32.9 16.3 30.7 

Gopher Eagan 31.6 20.6 0.9 0.1 3.2 3.9 0.5 0.5 437.8 10.6 4.9 5.5 

EnviroFocus 10.0 45.2 1.3 0.1 2.1 2.8 0.3 0.3 962.7 9.7 4.2 12.0 

Quemetco (CA) 4.1 0.8 2.3 0.1 3.7 21.0 2.6 2.6 16.5 19.4 4.4 0.2 

Quemetco (IN) 43.5 23.9 1.0 0.1 8.7 35.8 4.5 4.5 507.4 37.3 13.5 6.3 

RSR 50.2 40.8 2.9 0.2 10.4 20.7 2.6 2.6 869.0 31.4 15.3 10.9 

Sanders Lead 51.2 103.5 4.5 0.3 13.2 10.2 1.3 1.3 2,201.7 40.3 23.3 27.5 

Total for the Source 

Category 

2675 1168 453 2 93 172* 22* 22* 24,852 429 177 311 

*Most stack test results for mercury were below the detection limit and the limit of detection was used as the concentration estimate; 

therefore, these mercury estimates are high-end conservative estimates of emissions. The true mercury emissions are probably much 

lower. 
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Analysis of the available emissions data collected by the ICR survey and test program 

revealed that a logarithmic relationship between the metal-to-lead ratios and the lead 

concentrations produced the best correlation. Least-squares regressions analyses were conducted 

on the logarithmic metal HAP/lead ratios and lead emissions to obtain trend line equations. 

Figure 3-1 shows the scatter plots of the data and the corresponding regression equations. 

The regression line equations and site-specific lead emissions data were used as an empirical 

model to calculate non-lead metal HAP emissions for emissions points where other metal data 

were not available. 

Stack test data were not collected for selenium and antimony under the ICR test program. 

Therefore, site-specific estimates were made for these pollutants using the metal-to-lead ratios 

developed for the EPA’s 2002 Inhalation Risk Estimate report1. In this report, separate non-lead 

metal-to-lead ratios were developed from test data for process, process fugitive, and fugitive dust 

emissions sources. For this analysis, the selenium and antimony ratios for process fugitive 

emissions were selected because these ratios were most similar to the ratios developed from the 

ICR data for other metals. 

The site-specific emissions estimates for total mercury and chromium were speciated to 

account for the different oxidation states of these metals. Total mercury emissions were 

speciated as follows based on EPA’s default mercury speciation profile: 80 percent elemental 

mercury, 10 percent gaseous divalent mercury, and 10 percent particulate divalent mercury. 

These profiles are available on the EPA’s Technical Transfer Network (TTN) at: 

http://www.epa.gov/ttn/chief/net/2005inventory.html. 

New stack test data for hexavalent chromium (Cr+6) were available for 7 of the emissions 

points included in the source category; all 7 of these emissions points were stacks containing 

furnace exhaust. A ratio of Cr+6 to total chromium was calculated based on the new stack test 

data and then used to estimate Cr+6 at the remaining furnace emissions points. The difference 

between total chromium and Cr+6 at these emissions points was designated as Cr+3. For nonfurnace emissions points, total chromium emissions, that were either extracted from test reports 

or estimated based on the logarithmic relationship previously outlined, were speciated to one 

percent Cr+6 and 99 percent Cr+3 based on speciation profiles provided by EPA (available at: 

http://www.epa.gov/ttn/chief/net/2005inventory.html). 

 

1 Memorandum from EC/R to EPA, “Updated Draft Population Inhalation Risk Estimates for the Secondary Lead 

Smelter Residual Risk Assessment,” November 26, 2002. 
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Figure 3-1. Correlations Used to Estimate Stack Emissions of Non-Lead Metal HAP. 
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4.0 ORGANIC COMPOUND EMISSIONS FROM STACKS 

Table 4-1 presents the organic HAP, dioxin and furan (D/F), and total hydrocarbons 

(THC) emissions for stacks at each facility. The emissions estimates shown in Table 4-1 were 

developed using the site-specific emissions data collected by the ICR. 

4.1 Organic HAP

Emissions of certain organic compounds were available only in the newest stack tests 

submitted under the ICR. The ICR test program collected emissions data for the following 

organic compounds: D/F, THC, 1,3-butadiene, naphthalene, and benzene. Note that while THC 

is not modeled, it is used to estimate emissions of other organic compounds by using ratios of 

these compounds to THC, as described later in this section. Because the smelting furnaces are 

the primary source of these pollutants, emissions estimates were made only for emissions points 

containing furnace exhaust. 

Of the 17 emissions points containing furnace exhaust, stack test data for D/F, THC, 1,3-

butadiene, naphthalene, and benzene were available for 8 points. Therefore, a methodology for 

developing emissions of these pollutants for the remaining 9 emissions points was developed. 

Note that for D/F, emissions are expressed in terms of the Toxic Equivalency Quotient (TEQ), 

rather than individual D/F congeners. The TEQ values were calculated using the speciated 

dioxin and furan congener data submitted in the ICR test reports and the Toxic Equivalency 

Factors (TEFs) recommended by the World Health Organization (WHO) in 2005 (see Table 4-2). 

Emissions factors for D/F TEQ, 1,3-butadiene, naphthalene and benzene were developed based 

on the 8 emissions points for which stack test data exists. Because emissions of organic 

compounds are highly dependent on furnace operating temperature, and thus also on furnace 

type, emissions factors were chosen for the missing emissions points based on the highest degree 

of commonality between furnace types. 

For other organic compounds not tested under the ICR program, ratios of these 

compounds to THC were developed based on prior testing data reported in the 2002 Inhalation 

Risk Estimates report. These ratios were then used to estimate emissions of these compounds at 

each of the furnace emissions points. These ratios are presented in Table 4-3. 

Table 4-1. Organic HAP Emissions Estimates (lbs/yr) by Facility.

Facility Benzene 1,3-Butadiene Naphthalene D/F TEQ THC

Buick RRF 17320.73 695.15 1853.72 5.2E-03 3.3E+05 

East Penn 7.33 7.02 2.72 4.6E-05 7.0E+02 

Exide Vernon 1.37 2.89 44.12 3.9E-06 7.8E+02 

Exide Reading 135.50 31.51 96.79 4.0E-05 6.1E+04 
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Table 4-1. Organic HAP Emissions Estimates (lbs/yr) by Facility.

Facility Benzene 1,3-Butadiene Naphthalene D/F TEQ THC

Exide Muncie 6.09 5.84 2.26 3.8E-05 6.0E+02 

Exide Baton Rouge 592.29 1168.39 279.38 1.3E-02 4.0E+05 

Exide Forest City 470.84 1035.84 207.17 1.1E-02 3.4E+05 

Exide Frisco 409.36 790.77 195.43 8.5E-03 2.8E+05 

Gopher Eagan 10.75 10.31 3.99 6.8E-05 1.0E+03 

EnviroFocus 317.35 698.18 139.64 7.6E-03 2.3E+05 

Quemetco (CA) 94.2 33.6 28.8 1.6E-05 4.9E+03 

Quemetco (IN) 29.70 8.94 11.21 1.5E-05 1.8E+04 

RSR 2126.49 3279.81 76.74 1.5E-05 9.9E+04 

Sanders Lead 1752.00 3854.40 770.88 4.2E-02 1.2E+06 

Table 4-2. Toxic Equivalency Factors (TEFs) used to Calculate the Toxic Equivalency 

Quotient (TEQ). 

Dioxin/Furan Congener Toxic Equivalency Factor

2,3,7,8-tetrachlorinated dibenzo-p-dioxin 1.0

1,2,3,7,8-pentachlorinated dibenzo-p-dioxin 0.5

1,2,3,4,7,8-hexachlorinated dibenzo-p-dioxin 0.1

1,2,3,7,8,9-hexachlorinated dibenzo-p-dioxin 0.1

1,2,3,6,7,8-hexachlorinated dibenzo-p-dioxin 0.1

1,2,3,4,6,7,8-heptachlorinated dibenzo-p-dioxin 0.01

octachlorinated dibenzo-p-dioxin 0.001

2,3,7,8-tetrachlorinated dibenzofuran 0.1

2,3,4,7,8-pentachlorinated dibenzofuran 0.05

1,2,3,7,8-pentachlorinated dibenzofuran 0.5

1,2,3,4,7,8-hexachlorinated dibenzofuran 0.1

1,2,3,6,7,8-hexachlorinated dibenzofuran 0.1

1,2,3,7,8,9-hexachlorinated dibenzofuran 0.1

2,3,4,6,7,8-hexachlorinated dibenzofuran 0.1

1,2,3,4,6,7,8-heptachlorinated dibenzofuran 0.01

1,2,3,4,7,8,9-heptachlorinated dibenzofuran 0.01

octachlorinated dibenzofuran 0.001
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Table 4-3. Ratios of HAPs to THC Used for Emissions Estimates for the Secondary Lead 

Smelting Source Category. 

HAP RATIO 

(HAP/THC) HAP RATIO (HAP/THC)

1,1,2,2-Tetrachloroethane 0.00E+00 Ethyl Chloride 2.83E-02

1,3-Dichloropropene 4.26E-03 Formaldehyde 3.28E-03

Acetaldehyde 6.70E-02 Hexane 3.85E-02

Acetophenone 1.24E-02 Hydrochloric Acid 0.00E+00

Acrolein 2.64E-02 Indeno[1,2,3-c,d]Pyrene 2.59E-05

Acrylonitrile 1.35E-03 Methyl Bromide 1.45E-02

Benz[a]Anthracene 1.71E-03 Methyl Chloride 5.38E-01

Benzo[a]Pyrene 5.79E-06 Methyl Iodide 6.71E-03

Benzo[b]Fluoranthene 6.49E-04 Methyl Isobutyl Ketone 8.25E-01

Benzo[k]Fluoranthene 1.08E-04 Methylene Chloride 8.46E-03

Biphenyl 6.65E-02 m-Xylene 5.23E-02

Bis(2-Ethylhexyl)Phthalate 1.39E-01 o-Cresol 5.68E-03

Carbon Disulfide 1.57E+00 o-Xylene 1.61E-02

Chlorine 0.00E+00 Phenol 3.86E-02

Chlorobenzene 1.16E-02 Propionaldehyde 0.00E+00

Chloroform 1.61E-03 p-Xylene 5.82E-01

Chrysene 7.50E-03 Pyrene 0.00E+00

Cumene 1.83E-03 Styrene 2.40E-01

Dibenzo[a,h]Anthracene 8.45E-06 Tetrachloroethylene 0.00E+00

Dibutyl Phthalate 6.45E-04 Toluene 1.74E-01

Ethyl Benzene 3.90E-02 Trichloroethylene 0.00E+00

Xylenes (Mixture of o, m, and p 

Isomers) 0.00E+00

5.0 METAL HAP EMISSIONS FROM FUGITIVE DUST SOURCES 

Because they cannot be readily captured or directly measured, fugitive emissions are the 

most challenging emissions type to estimate. For this analysis, we evaluated the estimates of 

fugitive lead emissions that were submitted by each of the facilities under the 2010 ICR program. 

The responses we received regarding fugitive emissions varied significantly. Of the 14 facilities, 

five facilities provided no estimate for fugitive emissions and five other facilities provided quite 

incomplete estimates. Based on our review, the estimates provided by the remaining four 

facilities (Exide Frisco, Exide Muncie, Exide Vernon, and Gopher Eagan) seemed reasonable 

and relatively complete. Nevertheless, among those four facilities, we concluded that Exide 

Frisco provided the best estimate. Therefore, due to the lack of estimates at five facilities and the 

large amount of variability in emissions estimates and methodologies between the other 

facilities, the emissions provided by the Exide Frisco facility were selected as a basis for 

estimating fugitive emissions at all other facilities. This facility was selected because of the 

estimating methodology (i.e., EPA AP-42 emissions factors and site-specific activity data) and 

the level of detail provided in the supporting documentation. Each facility was compared to the 
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model facility and an estimate of total lead fugitives was calculated based on a number of 

factors, explained below, that described the activity level at the facility. 

Information provided by each facility regarding the degree of containment of secondary 

lead smelting processes was used to categorize the facilities as having Level 1 enclosure, Level 2 

enclosure, or Level 3 enclosure. The facilities categorized as having Level 3 enclosure generally 

have complete enclosures with negative pressure for all their process activities. The facilities 

designated as having Level 2 enclosure have some, but not all parts of their process in negative 

pressure enclosures, while those facilities designated as having Level 1 enclosure generally did 

not have any of their major processes under a negative pressure enclosure. A factor of 0.25 for 

level 3 enclosures and 0.75 for level 2 enclosures was applied to the fugitive lead estimates at 

these facilities to reflect reductions that may occur due to the level of enclosure at each facility. 

A housekeeping factor was also developed to characterize the level of work practices 

implemented by each facility to control fugitive emissions. Information reported by the industry 

in their surveys was used to determine the extent to which they implemented work practices that 

go beyond the requirements of the current Secondary Lead Smelting NESHAP. Factors ranging 

from 1.0 (work practices consistent with the current NESHAP) to 0.2 (work practices far beyond 

the current NESHAP) were then also applied to the fugitive lead estimates at these facilities in 

order to reflect reductions that may occur due to the work practices in place at each facility. 

Table 5-1 summarizes the enclosure and housekeeping factors used and lists the estimated 

fugitive lead emissions for each facility. The size factors were developed based on the activity 

level of each facility based on several factors supplied in the ICR. 

The lead emissions estimates for each facility were calculated by multiplying the fugitive 

lead emissions rate for the Exide Frisco facility (1.03 tons/yr) by the site-specific size factor, 

enclosure factor, and housekeeping factor. For example, we estimated a size factor of 0.76 for 

Exide Forest City. Additionally, Exide Forest City is a level 2 enclosure (0.75) and does work 

practices consistent with the requirements of the current NESHAP (i.e., housekeeping factor = 

1). Therefore, the estimated fugitive lead emissions for Exide Forest City, Mo are calculated as 

follows: 

1.03 tons/yr x 0.76 x 0.75 x 1.0 = 0.57 tons per year. 

The estimates of fugitive lead emissions that are shown in table 5-1 were used as input to 

the risk assessment modeling. To estimate fugitive emissions for metals other than lead (i.e., 

arsenic, cadmium, chromium, manganese, mercury, and nickel), a ratio of these other metals to 

lead was developed based on total stack emissions of these pollutants from all the facilities (see 

Table 5-2). This industry-wide ratio for each metal was multiplied by the individual facility lead 

fugitive emissions estimate to produce estimates of fugitive emissions of non-lead metal HAP. 
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Stack test data for selenium and antimony were not available, and therefore, the process 

fugitive ratios included in the 2002 Inhalation Risk Estimates report were used. These ratios 

were then applied to the fugitive lead emissions at each facility. Note that one facility’s arsenic 

emissions were identified as an outlier and were not considered when developing the arsenic to 

lead ratio. 

Table 5-1. Summary of Fugitive Lead Emissions Estimates for the Secondary Lead 

Smelting Source Category. 

Facility Size Factor Enclosure Factor

Housekeeping 

Factor

Fugitive Pb Emissions 

(lbs/yr)

Exide Baton Rouge 0.84 1.00 1.0 1,680

Exide Forest City 0.76 0.75 1.0 1,140

Exide Frisco 1.03 1.00 1.0 2,060

Exide Muncie 1.04 0.25 1.0 520

Exide Reading 1.00 0.75 1.0 1,500

Exide Vernon 1.84 0.25 0.5 460

RSR 1.36 0.25 0.25 180

Quemetco (CA) 1.19 0.25 0.2 120

Quemetco (IN) 1.27 0.25 0.25 160

Sanders Lead 1.40 1.00 1.0 2,800

EnviroFocus 0.44 1.0 660

Gopher Eagan 1.55 0.25 1.0 780

Buick RRF 3.13 1.00 1.0 6,260

East Penn 1.34 0.25 1.0 660

Table 5-2. Ratios Used to Estimate Fugitive Emissions of Metals Other than Lead. 

HAP HAP/Pb Ratio 

Arsenic 2.54E-02 

Beryllium 1.73E-04 

Cadmium 1.86E-02 

Chromium 3.76E-03 

Chromium+6 3.76E-05 

Chromium+3 3.72E-03 

Manganese 1.71E-02 

Mercury 8.37E-03 

Elemental Hg 6.70E-03 

Divalent Hg 8.37E-04 

Particulate Hg 8.37E-04 

Nickel 7.07E-03 

Selenium 1.25E-02 

Antimony 3.20E-02 

6.0 ALTERNATIVE METHOD FOR ESTIMATING FUGITIVE DUST EMISSIONS. 

This section describes an alternative methodology for estimating emissions from fugitive 

dust sources that was considered by EPA. After we completed the initial estimates (described 
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above), we consulted with industry representatives and provided them with an opportunity to 

review our initial estimates. We also did further evaluation of the fugitive emissions estimates 

provided in the ICR responses. Based on this additional review and re-evaluation, we concluded 

that same four facilities mentioned above (Exide Frisco, Exide Muncie, Exide Vernon, and 

Gopher Eagan) provided estimates of total fugitive emissions in the ICR responses that are 

reasonable based on the methodology used and the supporting documentation provided. 

Additionally, one facility submitted a revised estimate of total fugitive emissions (in February 

2011) after we had developed the initial set of estimates. For the remaining 9 facilities, we 

searched for other sources of information (such as the EPA’s Toxic Release Inventory (TRI)) to 

try to find reliable estimates of fugitive emissions. Based on that search, we found estimates for 

two other facilities that appeared to be adequate estimates of total fugitive emissions. Thus, we 

identified reasonable estimates for 7 facilities from various sources. The emissions estimates for 

these 7 facilities are shown in Table 6-1. 

Table 6-1. Revised Fugitive Lead Emissions Estimates for 7 Facilities. 

Facility

Level of 

Enclosure

Fugitive Pb 

Emissions Estimate 

(TPY) Source of the Estimate

Exide Frisco, TX Level 2 1.03 ICR Response

Exide Muncie, IN Level 3 0.22 ICR Response

Exide Vernon, CA Level 3 0.103 ICR Response

Sanders Lead, AL Level 1 1.6 2009 TRI

EnviroFocus, FL Level 2 0.213 2009 TRI

Gopher Eagan, MN Level 3 0.35 ICR Response

East Penn, PA Level 3 0.07 Data submitted by East Penn Corp by 

email on February 11, 2011 

For the other 7 facilities, we concluded that the estimates in the ICR were still far too 

incomplete to be reliable estimates of total fugitive emissions for the facilities and we did not 

identify adequate estimates from any other sources. Therefore, the fugitive dust emissions for 

these facilities were calculated using a slightly modified methodology presented in Section 5.0 of 

this memorandum. To estimate fugitive emissions for metals other than lead (i.e., arsenic, 

cadmium, chromium, manganese, and nickel), we used the same ratios of these other metals to 

lead presented in Section 5 of this document. However, we developed a revised methodology for 

estimating the ratio of mercury to lead in fugitive dust. Because the capture efficiency of 

mercury in a baghouse is much lower than the other metals due to its volatile nature, we 

determined that using the ratio of mercury to lead found in stacks may not be appropriate. 

Therefore, we adjusted the ratio of mercury to lead that we calculated based on stack data to 

account for an estimated 70 percent control efficiency for mercury compared to 99.54 percent 

control efficiency for lead. This resulted in the mercury to lead ratio coming from stacks being 

divided by a factor of 65 to more accurately represent the ratio expected in fugitive dust. Table 
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6-2 summarizes the enclosure and housekeeping factors developed for this alternative 

methodology and shows the estimated fugitive lead emissions for each of the 7 facilities. Table 

6-3 presents an overall summary of the fugitive dust emissions estimates for all 14 facilities 

derived in this alternative methodology. Table 6-4 provides a comparison of the fugitive 

emissions estimates using the initial method versus the estimates derived following the 

alternative method. As shown, the alternative estimates presented in this section are generally 

quite similar to the estimates presented in Section 5 above; therefore, EPA did not revise the risk 

assessment using these alternative estimates. 

Table 6-2. Revised Estimates of Fugitive Lead Emissions for 7 Facilities. 

Facility

Emissions 

Factor 

(TPY) Used 

to Calculate 

Emissions 

(Based on 

Model 

Plant)

Size Factor 

(Rough Estimate 

of the Ratio of the 

Size of the Facility 

Compared to Size 

of the Model 

Plant)

Enclosure 

Factor

Housekeeping 

Factor

Fugitive 

Pb 

Emissions 

(TPY)

Exide Baton 

Rouge, LA 1.03 1 1.00 1 1.03

Exide Forest 

City, Mo 1.03 1 0.75 1 0.77

Exide Reading, 

PA 1.03 1 0.75 1 0.77

RSR, NY 1.03 1 0.25 0.25 0.064

Quemetco (CA) 1.03 1 0.25 0.2 0.052

Quemetco (IN) 1.03 1 0.25 0.25 0.064

Doe Run, Buick 

RRF, MO 1.03 2 1.00 1 2.06

Table 6-3. Revised Fugitive Lead Emissions Estimates for all the Secondary Lead 

Smelting Facilities.

Facility

Degree of 

Enclosure

Fugitive Pb 

Emissions Estimate 

(TPY)

Source of the 

Estimate

Exide Baton Rouge, LA Level 1 1.03 EPA estimate

Exide, Forest City, MO Level 2 0.77 EPA estimate

Exide, Frisco, TX Level 2 1.03 ICR Response

Exide, Muncie, IN Level 3 0.22 ICR Response

Exide, Reading, PA Level 2 0.77 EPA estimate

Exide, Vernon, CA Level 3 0.103 ICR Response

RSR, Middletown, NY Level 3 0.064 EPA estimate

Quemetco (CA) Level 3 0.052 EPA estimate

Quemetco (IN) Level 3 0.064 EPA estimate

Sanders Lead, A Level 1 1.6 2009 TRI

EnviroFocus, FL Level 2 0.213 2009 TRI
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Table 6-3. Revised Fugitive Lead Emissions Estimates for all the Secondary Lead 

Smelting Facilities.

Facility

Degree of 

Enclosure

Fugitive Pb 

Emissions Estimate 

(TPY)

Source of the 

Estimate

Gopher Eagan, MN Level 3 0.35 ICR Response

Doe Run, Buick RRF, MO Level 1 2.06 EPA estimate

East Penn, PA Level 3 0.272 2009 TRI

Table 6-4. Comparison of the Initial and Alternative Fugitive Lead Emissions Estimates for 

the Secondary Lead Smelting Facilities. 

Facility

Fugitive Pb Emissions 

Estimates Based on 

Method Described in 

Section 5

Fugitive Pb Emissions 

Estimates Based on 

Method Described in 

This Section

Percent Difference 

Between Original and 

Alternative Estimates

Exide Baton Rouge 0.84 1.03 + 23%

Exide Forest City 0.57 0.77 + 35%

Exide Frisco 1.03 1.03 0

Exide Muncie 0.26 0.22 - 15%

Exide Reading 0.75 0.77 + 1%

Exide Vernon 0.23 0.103 - 45%

RSR 0.09 0.064 - 28%

Quemetco (CA) 0.06 0.052 - 13%

Quemetco (IN) 0.08 0.064 - 19%

Sanders Lead 1.4 1.6 + 14%

EnviroFocus 0.33 0.213 - 55%

Gopher Eagan 0.39 0.35 - 11%

Buick RRF 3.13 2.06 - 30%

East Penn 0.33 0.27 - 19%

7.0 ESTIMATING SHORT-TERM ACUTE EMISSIONS 

As part of the risk assessment conducted for the Secondary Lead Smelting source 

category, the potential for hazard via acute short term exposures is analyzed. Because the dataset 

described in this document is based on the development of estimates of annual emissions for 

each facility, a means of estimating maximum one-hour emissions rates associated with each 

emissions point was needed. For this analysis, it was assumed that the maximum one-hour 

emissions rate from any source other than those resulting in fugitive dust emissions were 10 

times the average annual hourly emissions rate for that source. The factor of 10 is not applied to 

fugitive dust sources because these emissions decrease during the meteorological conditions 

associated with the worst-case short-term impacts (i.e., during low-wind, stable atmospheric 

conditions). Information regarding the development of this factor and other details regarding the 

emissions data used for the acute exposure assessment can be found in the Draft Residual Risk 

Assessment for the Secondary Lead Smelting Source Category document available in the docket. 
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8.0 ESTIMATING MACT-ALLOWABLE EMISSIONS 

The emissions data in our data set represent the estimates of mass of emissions actually 

emitted on an annual basis for stacks and fugitives for the 2008-2010 timeframe. With most 

source categories, we generally find that “actual” emissions levels are lower than the emissions 

levels that a facility is allowed to emit and still comply with the MACT standards. The 

emissions levels allowed to be emitted by the MACT standards are referred to as the “MACTallowable” emissions levels. This represents the highest emissions level that could be emitted by 

facilities without violating the MACT standards. 

For the Secondary Lead Smelting source category, we evaluated actual emissions versus 

allowable emissions for both stack emissions and fugitive dusts emissions. As described above, 

the actual emissions data for this source category were compiled based on the ICR responses, 

available test data, various calculations, and the NEI. Most of this analysis (on actual versus 

allowable emissions) was focused on lead compound emissions, which we considered the most 

important HAP emitted from this source category based our preliminary risk assessments. 

With regard to fugitive dust emissions, based on available information, we believe that 

the higher emitting facilities (and higher risk facilities) are implementing the basic work practice 

standards pursuant to the requirements described in the MACT standards and not doing extra 

work practices (no practices beyond those required by the MACT standard). Therefore, we 

assume that “actual” fugitive dust emissions are equal to “allowable” fugitive dust emissions for 

these facilities. Based on available information (such as ICR responses and other information 

gathered and analyzed about this industry), we do believe that some facilities are implementing 

work practices beyond those required by the MACT standard, and therefore their actual fugitive 

dust emissions are probably lower than allowable. However, we cannot quantify how much 

lower the actual emissions are compared to allowable. Moreover, even if we did have estimates 

of allowable emissions of fugitive dusts from these sources, this information would not affect the 

conclusions about the risks due to fugitive dust emissions (described in the Draft Risk 

Assessment Report) and would not affect EPA’s proposed requirements to address fugitive 

emissions from this source category (described in the preamble). Therefore, we have not 

calculated “allowable” fugitive dust emissions for these sources. Therefore, for our analyses, we 

assume that “actual” fugitive dust emissions are equal to “allowable” fugitive dust emissions for 

all facilities. 

In contrast, we did calculate allowable emissions for the stacks. To estimate emissions at 

the MACT-allowable level from the stacks (e.g., process vents and building vents), we 

developed a ratio of MACT-allowable to actual emissions for each facility in the source 

category. We calculated these ratios by first estimating the emissions from stacks that would 

occur if facilities were emitting lead exactly at the maximum allowed by the standard (i.e., 2.0 
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18 

mg/m3) from all vents. Then we compared these estimated “allowable emissions” to the 

estimated emissions using the actual stack test data for lead for each facility. Estimates of actual 

and allowable lead emissions from this source category are shown in table 8-1. Based on this 

analysis, we conclude that all facilities are emitting lead at levels lower than allowable; however, 

the range is significant. For 2 facilities, the estimated actual emissions were only moderately 

lower than allowable (about 2-3 times lower). The vast majority of facilities have estimated 

actual emissions in the range of about 10 to 100 times lower than allowable. Finally, one 

facility, which has highly advanced controls, has estimated actual emissions of about 1500 times 

below the MACT allowable emissions level. 

Table 8-1. Estimated Ratios of Actual Emissions to MACT-Allowable Emissions For 

Secondary Lead Smelting Facilities. 

Facility Actual Lead Emissions 

Rate (lb/hr)

MACT Allowable 

Emissions (lb/hr)

Ratio of MACTAllowable to Actual

Quemetco (CA) 0.00 2.84 1513.5

Exide Muncie 0.05 4.92 95.3

Exide Vernon 0.06 4.92 77.7

Gopher Eagan 0.05 3.06 59.4

Quemetco (IN) 0.06 3.27 56.5

East Penn 0.04 1.45 34.8

RSR 0.10 3.19 32.2

Exide Forest City 0.04 0.64 17.9

Exide Reading 0.26 2.73 10.6

EnviroFocus 0.12 1.16 9.9

Exide Frisco 0.31 2.63 8.6

Sanders 0.25 1.66 6.6

Exide Baton Rouge 0.53 1.43 2.7

Doe Run 1.21 2.97 2.5

After developing these ratios, we applied these ratios on a facility-by-facility basis to the 

maximum modeled ambient lead concentrations (i.e., ratios were applied to stack emissions 

while leaving fugitive dust emissions at actual levels since, as described above, actual fugitive 

dust emissions were considered equal to allowable fugitive dust emissions) to estimate the 

maximum ambient concentrations that would occur if all stacks were emitting at maximum 

allowable levels. This analysis and the results are described in the Draft Risk Assessment 

Report. 

9.0 ESTIMATING EMISSIONS REDUCTIONS FOR CONTROL SCENARIOS 

To assess the reduction in risk associated with implementation of the control options 

presented in the proposed rulemaking for the Secondary Lead Smelting Source category, we 

estimated reductions in baseline emissions that will occur after the proposed controls are 

installed. The development of the post-control emissions estimates are described in the 
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following sections. The resulting risk analysis based on these emissions can be found in the 

Draft Residual Risk Assessment for the Secondary Lead Smelting Source Category. 

9.1 Post-Control Stack Emissions of Metal HAP

In order to assess the reductions in stack emissions of metal HAP that will occur as a 

result of the proposed revised lead emissions limit, we performed an analysis for each emissions 

point at each facility to determine whether added control would be needed in order to meet the 

limit. 

We identified two baghouses, one at Exide Baton Rouge and one at Buick RRF that by 

our estimation will need to be either upgraded or replaced in order for the facility to comply with 

the proposed revised lead emissions limit. In order to estimate emissions from an 

upgraded/replaced baghouse at the two emissions points, we assumed that the emissions would 

be reduced to a level consistent with the average lead emissions calculated from all emissions 

points in the source category. We assumed that the reductions in emissions of other metal HAP 

from these two emissions points would be reduced proportionally to lead. 

9.2 Post-Control Fugitive Dust Emissions of Metal HAP

As described in the Draft Residual Risk Assessment for the Secondary Lead Smelting 

Source Category, fugitive dust emissions are the primary driver in exceedances of the lead 

NAAQS as well as a substantial contributor to the chronic cancer risks and potential acute noncancer risks. We estimated the reduction in fugitive emissions of metal HAP that would occur as 

a result of the implementation of the fugitive dust controls outlined in the proposed rulemaking 

for this source category. These emissions estimates were used to estimate the post-control risks 

described in the risk assessment document. 

Section 5.0 describes how we estimated the baseline fugitive metal HAP emissions for 

each facility. These baseline fugitive lead emissions estimates were used as the starting point for 

the development of post-control fugitive emissions estimates. We adjusted the baseline 

housekeeping and enclosure factors for each facility to reflect the level of fugitive dust control 

required in the proposed rule. This included level 3 enclosure (enclosure factor of 0.25) and 

implementation of work practices beyond the current NESHAP which are described in the 

proposed rule (housekeeping factor of 0.2) for each facility. The resulting post-control fugitive 

lead emissions estimates are shown in Table 9-1. 

After we determined the post-control fugitive lead emissions for each facility, we used 

the ratios (shown in table 5-2 above) to estimate post-control emissions of all other metal HAP 

by applying the ratios to the estimates shown for lead in table 9-1. 
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Table 9-1. Estimated Post-Control Fugitive Lead Emissions. 

Facility Post-Control Fugitive Pb Emissions (TPY)

Exide Baton Rouge 0.05

Exide Forest City 0.05

Exide Frisco 0.06

Exide Muncie 0.06

Exide Reading 0.06

Exide Vernon 0.11

RSR 0.09

Quemetco (CA) 0.06

Quemetco (IN) 0.08

Sanders Lead 0.09

EnviroFocus 0.03

Gopher Eagan 0.01

Buick RRF 0.20

East Penn 0.08

9.3 Post-Control Stack and Fugitive Emissions of PM

In order to assess the co-reductions in emissions of PM resulting from the proposed 

revisions to the Secondary Lead Smelting NESHAP, we developed a ratio of lead to PM based 

on emissions data submitted in the ICR. Based on that data, we calculated a lead to PM ratio of 

1 to 12 and applied it to the lead emissions reductions from stack and fugitive sources. In order 

to estimate the fraction of the PM emissions reductions that are PM2.5, we developed a range of 

particle size distributions for secondary lead smelters based on AP-42 emissions data and a 2009 

emissions inventory for the Exide Frisco facility. Based on this information, we estimated that 

between 30 and 48 percent of the PM emissions from secondary lead smelters is PM2.5.