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 facilit y 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 cu rrent 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 liste d in the original MACT.

The EPA is making these revisions under CAA Section s 112(f)(2) and 112(d)(6) . As outlined in the Act, sources must comply with standards issued under 11 2(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 protect ed 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. T he facility will likely need to upgrade the existing baghouses

, add new baghouses in

- series for two stacks , and/or implement someMemorandum, October 31, 2011 Page 2

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 device s 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

199 9 NESHAP and State progr ams which ensure emissions are limited. The facility is subject to a

number of strict limitations as a result of their SIP and Consent Decree s . 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 re fining operations and that a 60 day compliance period is appropriate for the new emission limit applicable to the main stack

.