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MEMORANDUM

To: Nathan Topham, U.S. Environmental Protection Agency, OAQPS

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

Date: December 16, 2011

Subject: 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 Estimating MACT-allowable emissions

7.0 Estimating Short-Term Acute Emissions

8.0 Estimating Emissions Reductions for Control Scenarios

1.0 BACKGROUND

Table 1-1 lists the secondary lead smelters currently in operation or under construction in 

the United States and Puerto Rico. In June of 2010, the EPA issued an information collection 

request (ICR) pursuant to section 114 of the Clean Air Act (CAA) to six companies who own 14 

secondary lead smelting facilities currently in operation in the United States. 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. A limited request for information 

was sent to The Battery Recycling Company in Puerto Rico in August of 2011. The Johnson 
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Controls facility in Florence, South Carolina will not be operational until 2012 and was not 

surveyed. 

Table 1-1. Secondary Lead Smelters in the U.S. and Puerto Rico

FACILITY NAME PARENT COMPANY CITY STATE

Facility 

Abbreviation

East Penn 

Manufacturing Co., Inc.

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., City of 

Industry, Ca

Eco-Bat Technologies, LTD 

(Quemetco West, LLC)

City of 

Industry California Quemetco CA

Quemetco, Inc., 

Indianapolis, In

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

Exide Technologies, 

Baton Rouge, La Exide Technologies, Inc. Baton Rouge Louisiana Exide Baton Rouge

Exide Technologies, 

Cannon Hollow 

Recycling Facility

Exide Technologies, Inc. Forest City Missouri Exide Forest City

Exide Technologies, 

Frisco, Tx Exide Technologies, Inc. Frisco Texas Exide Frisco

Exide Technologies, 

Muncie, In Exide Technologies, Inc. Muncie Indiana Exide Muncie

Exide Technologies –

Reading Recycling Exide Technologies, Inc. Reading Pennsylvania Exide Reading

Exide Technologies, 

Vernon, Ca Exide Technologies, Inc. Vernon California Exide Vernon

Buick Resource 

Recycling Facility, LLC

The Doe Run Resources 

Corporation Boss Missouri Buick RRF

The Battery Recycling 

Company

The Battery Recycling 

Company

Arecibo Puerto Rico BATTERY 

RECYCLING

Johnson Controls 

Battery Group, Inc. 

Johnson Controls

International Florence South Carolina JCI

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 evaluated 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. Facility-wide emissions were essentially the same as those of 
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the source category, so a separate facility-wide analysis was not performed. 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.

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

HAP STACK FUGITIVE

1,1,2,2-Tetrachloroethane 

1,3-Butadiene 

1,3-Dichloropropene 

2,3,7,8-TCDD TEQ 

Acetaldehyde 

Acetophenone 

Acrolein 

Acrylonitrile 

Antimony  

Arsenic  

Benz[a]Anthracene 

Benzene 

Benzo[a]Pyrene 

Benzo[b]Fluoranthene 

Benzo[k]Fluoranthene 

Beryllium  

Biphenyl 

Bis(2-Ethylhexyl)Phthalate 

Cadmium  

Carbon Disulfide 

Chlorine 

Chlorobenzene 

Chloroform 

Chromium (VI)  

Chromium III  

Chrysene 

Cumene 

Dibenzo[a,h]Anthracene 

Dibutyl Phthalate 

Divalent Mercury  

Elemental Gaseous Mercury 

Ethyl Benzene 

Ethyl Chloride 

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

HAP STACK FUGITIVE

Hexane 

Hydrochloric Acid 

Indeno[1,2,3-c,d]Pyrene 

Lead  

Manganese  

Methyl Bromide 

Methyl Chloride 

Methyl Iodide 

Methyl Isobutyl Ketone 

Methylene Chloride 

m-Xylene 

Naphthalene 

Nickel  

o-Cresol 

o-Xylene 

Particulate Mercury  

Phenol 

Propionaldehyde 

p-Xylene 

Pyrene 

Selenium  

Styrene 

Tetrachloroethylene 

Toluene 

Trichloroethylene 

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

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 the 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 
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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 

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 101 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), 
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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 113.4 110.9 4.3 0.9 23.9 28.6 3.6 3.6 2595.871 87.5 26.5 32.4

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

Battery Recycling 6.7 5.9 0.2 0.1 0.9 1.3 0.2 0.2 184.0 4.1 2.0 2.3

Total for the Source 

Category 2763 1169 455 3 110 192 24 24 25173 488 190 315

*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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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.

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 the 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 the 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 18 emissions points containing furnace exhaust, stack test data for D/F, THC, 1,3-

butadiene, naphthalene, and benzene were available for 9 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. Due to lack of emissions data from rotary furnaces that 

process lead scrap, organic HAP emissions were not estimated for the rotary furnace emission 

point at The Battery Recycling Company’s Arecibo, Puerto Rico facility.

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 Resource 

Recycling Facility 17320.73 695.15 1853.72 5.2E-03 3.3E+05
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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

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

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 12.00 2.40 3.20 1.3E-04 6.5E+03

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

Battery Recycling2 Not Estimated Not Estimated Not Estimated Not Estimated Not 

Estimated

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

 

2 Organic HAP emissions for were not estimated for The Battery Recycling Company due to insufficient data.
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Dioxin/Furan Congener Toxic Equivalency Factor

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

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 

challenging 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 surveyed, five 

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

incomplete estimates. Additional information was later submitted by one of the facilities (East 

Penn). 
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Based on our review, the estimates provided by five facilities (Exide Frisco, Exide 

Muncie, Exide Vernon, Gopher Eagan, and East Penn) seemed reasonable and relatively 

complete. Nevertheless, among those facilities, we concluded that Exide Frisco provided the best 

supported and most complete estimate. Therefore, due to the lack of reasonable estimates at nine 

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 

model facility and an estimate of total lead fugitives was calculated based on a number of factors

that described the activity level at the facility. 

Table 5-1 is a comparison of the estimates made by the facilities for the ICR, estimates 

submitted to the TRI, and estimates used to support the proposal and final rule risk assessments

using the methodology described in this memo. Only one facility submitted a reasonably 

complete calculation methodology for the information contained in the survey. Because the TRI 

information appeared to be inaccurate or incomplete in many cases, we elected not to use the 

TRI estimates for the purposes of developing an emissions dataset for the RTR risk assessment.

Based on this comparison, and the similarity of results between submitted and calculated using 

the derived method for the facilities that provided reasonably well supported (although 

incomplete) estimates, we elected to use our estimation method for all facilities. We 

acknowledge that there is a significant amount of uncertainty associated with all of the fugitive 

emissions estimates presented in this memo and that substantial changes in the fugitive emissions 

estimates used as inputs in the risk assessment modeling would likely lead to substantial changes 

in the modeled impacts. 

Table 5-1. Comparison of Estimated and Submitted Fugitive Lead Emissions Estimates 

for the Secondary Lead Smelting Source Category

Facility

Final Rule Fugitive 

Pb Emissions 

Estimates (lb/yr)*

Proposal 

Fugitive Pb 

Emissions 

Estimates 

(lb/yr) 

Fugitive Emissions 

Estimates 

Submitted in ICR 

(lb/yr)

TRI Fugitive 

Emissions Estimates 

(lb/yr)

Exide Baton Rouge 1277 1680 4 0

Exide Forest City 807 1140 No estimate provided 0

Exide Frisco 1463 2060 1463 458

Exide Muncie 370 520 440 0.0003

Exide Reading 1070 1500 1540 306

Exide Vernon 327 460 206 83

RSR 121 180 No estimate provided 0
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Quemetco (CA) 85 120 No estimate provided 0

Quemetco (IN) 113 160 No estimate provided 0

Sanders Lead 2133 2800 6480 2520

EnviroFocus 472 660 140 426

Gopher Eagan 553 780 700 502

Buick RRF 4773 6260 37.6 25880

East Penn 119 660

No estimate provided, 

later email received 

estimated 140 544

Battery Recycling 488 N/A N/A 7

*These estimates were used in the risk assessment modeling for the final rule. Other estimates 

are presented for comparison only.

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. The Exide Frisco 

facility that was as used the model facility for the purpose of our estimates was classified as a 

level 2 facility. However, the only process at the facility that is currently fully enclosed and 

vented to a control device is the raw material storage area. Thus, we compared fugitive emissions 

estimates submitted by the Exide Frisco facility prior to enclosure of the raw materials storage 

area with the estimates submitted in the ICR. This comparison revealed that the fugitive 

emissions estimates submitted by Exide Frisco prior to enclosure of the raw materials storage 

area were 1.07 times higher than the estimates submitted in the ICR.

We then analyzed each facility to determine their level of enclosure in comparison with 

the Exide Frisco facility. The facilities that were determined to have a lower level of enclosure 

than Exide Frisco were assigned a factor 1.07. The facilities that were determined to have a 

greater level of enclosure than the Exide Frisco facility, but did not have all processes enclosed

(level 2), were assigned a factor of 0.75. A factor of 0.25 was assigned to facilities with total 

enclosures for all processes (level 3). These factors were applied to the fugitive lead emission 

estimates at the facilities to reflect reductions that are likely to occur due to the level of enclosure 

at each facility. Total enclosures can provide up to 99% control of fugitive emissions from the 

source inside a building. However, the enclosure alone will not always achieve this level of 

control without accompanying work practice standards that prevent fugitive dust from being 

carried out of the enclosure as equipment and vehicles move into and out of the enclosure. Total 
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enclosures can provide a greater level of control for fugitive dust emissions originating from the 

enclosure than our factor indicates (75% reduction from total enclosure).. However, this factor 

was chosen as a reasonable conservative (i.e. our value may underestimate the level of control 

achieved using total enclosures) estimate of the amount of reductions in fugitive emissions that 

originate from processes that would be enclosed. Lead bearing material that is tracked out of the 

enclosure on equipment or vehicles or generated during maintenance activities will not be 

controlled by the enclosure. Therefore, work practice standards and additional housekeeping 

activities are required to reduce emissions beyond that provided by total enclosures. 

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

implemented by each facility to control fugitive emissions. Early interaction with industry

representatives in preparation for development of the proposed rule provided information that 

housekeeping was critical to the successful reduction of fugitive emissions and that significant 

improvements could be made above control achieved through the use of total enclosures. 

Information reported by the industry in their surveys and during the comment period of the 

proposed rule was used to determine the extent to which each facility 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 are likely to occur due to the work practices in 

place at each facility. Taken together, full enclosure and implementation of work practices 

sufficient to prevent re-entrainment of lead bearing dust are estimated to achieve well over a 

90% reduction in fugitive emissions compared to the estimates of fugitive emissions based on 

facilities employing the minimum enclosure and work practice requirements of the 1997 

NESHAP. Table 5-2 summarizes the enclosure and housekeeping factors used for each facility

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 (e.g. vehicle traffic, facility

footprint and arrangement, as well as other 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 (0.71 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:

0.71 tons/yr x 0.76 x 0.75 x 1.0 = 0.41 tons per year.
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In this analysis, we did not take into consideration the legacy sources of fugitive lead 

emissions at the facilities. These sources of lead on or near the facility grounds could contribute 

to higher levels of airborne lead emissions from roadways or other wind-blown dust. We expect 

there to be differences in the amount of lead from legacy sources at these facilities, but were not 

able to quantify them for this assessment. 

The estimates of fugitive lead emissions that are shown in table 5-2 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 5-3). 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.

There is some uncertainty associated with the fugitive emissions estimates that is derived 

from the uncertainty involved in determining the housekeeping and enclosure factors. This 

uncertainty could have important impacts on the estimated fugitive emissions and the resulting 

modeled ambient concentration. For example, if the level of control assumed through the use of 

full enclosure and robust housekeeping were both increased from 75% to 85%, the estimated 

fugitive emissions at the RSR facility would be about 43 pounds (roughly three times lower than 

those estimated in this rule). If the level of control assumed through the use of full enclosure and 

robust housekeeping were both decreased from 75% to 65%, the estimated fugitive emissions at 

the RSR facility would be about 240 pounds (roughly two times higher than those estimated in 

this rule). As shown in this example, changing the estimates of control efficiency achieved with 

full enclosure and robust housekeeping practices by 10% each could impact the resulting fugitive 

emission estimates for facilities employing that level of control by two to three times.

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. The arsenic emissions at Buick 

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

ratio.

Table 5-2. 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 1.07 1.0 1277

Exide Forest City 0.76 0.75 1.0 807

Exide Frisco 1.03 1.00 1.0 1463

Exide Muncie 1.04 0.25 1.0 370

Exide Reading 1.00 0.75 1.0 1070

Exide Vernon 1.84 0.25 0.5 327
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RSR 1.36 0.25 0.25 121

Quemetco (CA) 1.19 0.25 0.2 85

Quemetco (IN) 1.27 0.25 0.25 113

Sanders Lead 1.40 1.07 1.0 2133

EnviroFocus 0.44 0.75 1.0 472

Gopher Eagan 1.55 0.25 1.0 553

Buick RRF 3.13 1.07 1.0 4773

East Penn 1.34 0.25 0.25 119

Battery Recycling 0.32 1.07 1.0 488

Table 5-3. 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 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 Residual Risk 

Assessment for the Secondary Lead Smelting Source Category document available in the docket.
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7.0 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 “MACT-allowable” 

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 Risk Assessment 

Report) and would not affect the EPA’s 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 

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

Battery Recycling 0.021 0.29 13.6

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 Risk Assessment Report. 

8.0 ESTIMATING EMISSIONS REDUCTIONS FOR CONTROL SCENARIOS

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

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

estimated reductions in baseline emissions that will occur after the controls are installed. The 

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

for the Secondary Lead Smelting Source Category.

8.1 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 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 seven baghouses that by our estimation will need to be replaced. These 

include three baghouses at Doe Run, two baghouses at Sanders, one baghouse at Exide Baton 

Rouge, and one baghouse at Exide Reading. We also identified three additional baghouses that 

will need maintenance in order for the facilities to comply with the revised lead emissions limit. 

These include one baghouse at Doe Run, one baghouse at Exide Frisco, and one baghouse at 

Exide Baton Rouge. In order to estimate emissions from an upgraded/replaced baghouse, 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 emissions points would be reduced 

proportionally to lead.

8.2 Post-Control Fugitive Dust Emissions of Metal HAP

As described in the 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 non-cancer 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 final 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 final 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 final

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

emissions estimates are shown in Table 9-1.
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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.

Table 9-1. Estimated Post-Control Fugitive Lead Emissions.

Facility Post-Control Fugitive Pb Emissions (TPY)

Exide Baton Rouge 0.03

Exide Forest City 0.03

Exide Frisco 0.04

Exide Muncie 0.04

Exide Reading 0.04

Exide Vernon 0.07

RSR 0.05

Quemetco (CA) 0.04

Quemetco (IN) 0.05

Sanders Lead 0.05

EnviroFocus 0.02

Gopher Eagan 0.06

Buick RRF 0.11

East Penn 0.05

Battery Recycling 0.01

8.3 Post-Control Stack and Fugitive Emissions of PM

In order to assess the co-reductions in emissions of PM resulting from the 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 10.1 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.