MEMORANDUM 

Date: October 31, 2011

Subject: Estimated Time Needed to Comply with the Revisions to the NESHAP

From: Nathan Topham, Project Lead

Risk and Technology Review – National Emissions Standards for Hazardous Air 

Pollutants (NESHAP) for Primary Lead Processing

To: Docket No.: EPA-HQ-OAR-2004-0305

The purpose of this memorandum is to present the results of an analysis of the time required for the 

primary lead smelting facility covered by this rule to comply with the revisions to the existing primary

lead smelting NESHAP.

1.0 SUMMARY OF REVISIONS

The original NESHAP for primary lead smelting was promulgated on June 4, 1999. As a result of the

Risk and Technology Review (RTR) for the Primary Lead Smelting source category, the Environmental 

Protection Agency is adding a new stack emissions limit and reducing the main stack emission limit.

 

For stack emissions, the EPA is adding an emission limit of 1.2 tons per year (TPY) for the combined 

furnace area stack and refining operations stacks. This limit reflects an approximate 90% reduction in 

estimated emissions at full production capacity from these two stacks. The current main stack, 

production-based emission limit of 1.0 pound per ton of lead produced has been revised under Section 

112(d)(6) of the Clean Air Act (CAA) to 0.97 pound per ton of lead produced and will remain applicable 

to the same emission points listed in the original MACT. 

The EPA is making these revisions under CAA Sections 112(f)(2) and 112(d)(6). As outlined in the Act, 

sources must comply with standards issued under 112(f)(2) within 90 days of promulgation. However, 

the Administrator may grant a waiver allowing up to a two-year compliance period if the Administrator 

finds that “such period is necessary for the installation of controls and that steps will be taken during the 

period of the waiver to assure that the health of persons will be protected from imminent endangerment” 

(CAA Section 112(f)(4)(A)-(B)). In this memorandum, we estimate the time that will be required for 

The Doe Run Company facility, the only primary lead processor currently operating in the United 

States, to comply with the revised Primary Lead Processing NESHAP. The results of our analyses are 

presented in the following sections.

2.0 STACK EMISSION STANDARD

Based on the combined stack emission limit described in section 1.0 of this memorandum, the facility 

will need to reduce stack emissions up to 90% from the refining operations and furnace area stacks. This 

level of reduction is significant, given these operations are currently controlled by baghouses that have 

been upgraded with membrane bags as a result of 2007 SIP requirements. The facility will likely need to 

upgrade the existing baghouses, add new baghouses in-series for two stacks, and/or implement some 
Memorandum, October 31, 2011

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other type of control to accomplish the required reduction in emissions (see Risk and Technology 

Review, National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Primary Lead 

Smelting Source Category and the Technical Support Document for more details). We estimate that the 

upgrade of existing and/or addition of new control devices would require 21 to 24 months to be fully 

operational. This includes 2 to 4 months for evaluation of existing control devices and development of 

an engineering plan to meet the revised emissions limits, 2 to 4 months for engineering of replacement

control device(s) or new equipment, 2 to 3 months for capital approval, 5 to 7 months for delivery of the 

control device or new equipment, 2 to 4 months for construction and installation, and 2 to 3 months of 

operation until stack testing is conducted. In addition, the facility will have other ongoing projects to 

comply with the proposed fugitive emissions standard as described below.

For the main stack, the reduced emission limit represents the emission level currently achieved by the 

facility and no additional controls or measures will be necessary to meet the new limit. Therefore, 

compliance with the new emission limit for the main stack will be required 60 days from the date of 

promulgation of the final rule.

4.0 CONCLUSIONS

Based on our analysis, an affected facility would need 21 to 24 months to complete the projects 

necessary for compliance with the new emission limit for the furnace area and refining operation stacks. 

With regard to the steps that will be taken during the period to assure that the health of persons will be 

protected from imminent endangerment, we conclude that the public will be protected from imminent 

endangerment during these extra months because facilities will continue to comply with the existing 

1999 NESHAP and State programs which ensure emissions are limited. The facility is subject to a 

number of strict limitations as a result of their SIP and Consent Decrees. These limitations include total 

annual production as well as limited operating hours for a number of emission sources. Therefore, we 

believe that a two year compliance period is appropriate for the new emission limit applicable to the 

furnace area and refining operations and that a 60 day compliance period is appropriate for the new 

emission limit applicable to the main stack.