TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

AGENDA ITEM REQUEST

for Proposed Revision to the State Implementation Plan

AGENDA REQUESTED: June 22, 2011

DATE OF REQUEST: June 3, 2011

INDIVIDUAL TO CONTACT REGARDING CHANGES TO THIS 

REQUEST, IF NEEDED: Joyce Spencer, 239-5017

CAPTION: Docket No. 2011-0282-SIP. Consideration for publication 

of, and hearing on, proposed Collin County Attainment Demonstration 

State Implementation Plan (SIP) Revision for the 2008 Lead National 

Ambient Air Quality Standard (NAAQS).

This proposed SIP revision would address Federal Clean Air Act (FCAA)

Section 191(a) requirements that states with lead nonattainment areas 

submit to the EPA an implementation plan within 18 months of the 

designation effective date. Section 110(a)(1) of the Federal Clean Air Act 

(FCAA) requires states to submit a state implementation plan (SIP) revision 

for areas that have been designated nonattainment to provide for the 

implementation, maintenance, and enforcement of the NAAQS. States are 

required to adopt and submit attainment demonstration SIP revisions 

within 18 months of designation. In accordance with FCAA, §172 and 

implementation guidance published with the November 12, 2008, final 

Lead NAAQS (73 FR 66964), the proposed SIP revision contains a 

reasonably available control measures analysis, a reasonably available 

control technology analysis, demonstration of attainment through air 

dispersion modeling, a control strategy demonstration, an emissions 

inventory, a demonstration of reasonable further progress, and contingency 

measures. (Holly Brightwell, Amy Browning) (Non-Rule Project No. 2011-

001-SIP-NR)

Susana M. Hildebrand

Chief Engineer

David Brymer

Division Director

Joyce Spencer

Agenda Coordinator

Copy to CCC Secretary? NO X YES

Texas Commission on Environmental Quality

Interoffice Memorandum

To:

Thru:

From:

Docket No.:

Commissioners

LaDonna Castañuela, Chief Clerk

Mark R. Vickery, P.G., Executive Director

Susana M. Hildebrand, P.E., Chief Engineer

2011-0282-SIP

Date: June 3, 2011

Subject: Commission Approval for Proposed 2011 Collin County Attainment 

Demonstration State Implementation Plan (SIP) Revision for the 2008 

Lead National Ambient Air Quality Standard (NAAQS)

Short Title: 2008 Lead Attainment Demonstration SIP Revision 

Non-Rule Project No. 2011-001-SIP-NR

Background and reasons for the SIP revision:

On October 15, 2008, the United States Environmental Protection Agency (EPA) 

substantially strengthened the NAAQS for lead. The new standard, set at 0.15 micrograms 

per cubic meter (μg/m3) measured as a rolling three-month average, is 10 times more 

stringent than the previous standard established in 1978 of 1.5 μg/m3 measured as a 

quarterly average. Effective December 31, 2010, the EPA designated an area surrounding 

Exide Technologies (Exide) located in Frisco, Collin County, as nonattainment for the 

2008 lead NAAQS (75 FR 71033).

Section 110(a)(1) of the Federal Clean Air Act (FCAA) requires states to submit a SIP 

revision for areas that have been designated nonattainment to provide for the 

implementation, maintenance, and enforcement of the NAAQS. States are required to 

adopt and submit attainment demonstration SIP revisions within 18 months of 

designation. In accordance with FCAA, §172 and implementation guidance published with 

the November 12, 2008, final Lead NAAQS (73 FR 66964), the proposed SIP revision 

contains a reasonably available control measures analysis, a reasonably available control 

technology analysis, demonstration of attainment through air dispersion modeling, a 

control strategy demonstration, an emissions inventory, a demonstration of reasonable 

further progress, and contingency measures.

Scope of the proposed SIP revision:

A.) Summary of what the SIP revision will do:

The 2008 Lead Attainment Demonstration SIP revision would demonstrate attainment 

using an air dispersion modeling analysis that includes existing control strategies as well as 

the control strategies being implemented concurrently with this SIP revision. This SIP 

revision also includes FCAA required elements, including a reasonably available control 
Commissioners

Page 2

June 3, 2011

Re: Docket No. 2011-0282-SIP

measures (RACM) analysis, a reasonably available control technology (RACT) analysis, 

demonstration of reasonable further progress (RFP), and a contingency plan.

The control measures and contingency measures that have been identified for the 2008 

Lead Attainment Demonstration SIP revision will be enforceable through an Agreed Order 

between the Texas Commission on Environmental Quality (TCEQ) and Exide (Agreed 

Order No. 2011-0521-MIS), the only lead source in the nonattainment area. To ensure 

compliance with the 2008 lead NAAQS, the Agreed Order is being proposed concurrently 

with this SIP revision. The Agreed Order provides enforceable measures to reduce 

emissions necessary for the Collin County lead nonattainment area to attain the 2008 lead 

NAAQS by November 1, 2012, and contains contingency measures designed to ensure 

continued compliance with the standard. 

B.) Scope required by federal regulations or state statutes:

In accordance with FCAA, §172(c) and implementation guidance published with the final

2008 lead NAAQS (73 FR 66964), an attainment demonstration for lead must include the 

following elements: 

• RACM and RACT analysis;

• dispersion modeling demonstrating attainment by the required December 2015

deadline;

• control strategy demonstration;

• emissions inventory;

• contingency measures; and

• demonstration of RFP.

Submission of RFP is typically separate from attainment demonstration SIP submissions, 

but in the case of lead nonattainment areas, RFP is met by “adherence to an ambitious 

compliance schedule,” which is expected to periodically yield significant emission 

reductions. The EPA believes that the expeditious implementation of RACM/RACT within 

the nonattainment area is an appropriate approach to RFP.

C.) Additional staff recommendations that are not required by federal rule or 

state statute:

None

Statutory authority:

The authority to propose and adopt this SIP revision is derived from Texas Health and 

Safety Code, Texas Clean Air Act (TCAA), §382.002, which provides that the policy and 

purpose of the TCAA is to safeguard the state’s air resources from pollution; TCAA, 

§382.011, which authorizes the commission to control the quality of the state’s air; TCAA, 

§382.012, which authorizes the commission to prepare and develop a general, 

comprehensive plan for the control of the state’s air; and Texas Water Code, §5.02, General 

Powers, and §5.013, General Jurisdiction of the Commission. 
Commissioners

Page 3

June 3, 2011

Re: Docket No. 2011-0282-SIP

FCAA, 42 United States Code §§7401, et seq., requires states to submit SIP revisions that 

specify the manner in which the NAAQS will be achieved and maintained within each air 

quality control region of the state. Additionally, the specific requirements for the 2008 lead 

NAAQS were published in the November 12, 2008, issue of the Federal Register (73 FR 

66964).

Effect on the:

A.) Regulated community:

The affected regulated community consists only of Exide, the sole significant contributing

source of lead in the nonattainment area. The affected source would be required to install 

additional control technologies to meet the NAAQS, implement new work practices, and

comply with additional monitoring and recordkeeping requirements. For further 

information, please refer to the executive summary in the narrative of the proposed 2008 

Lead Attainment Demonstration SIP revision, which contains details of the controls set out 

in the Agreed Order.

B.) Public:

The general public in the Frisco area would benefit from improved air quality from reduced 

lead emissions.

C.) Agency programs:

This SIP revision will have no new effect on agency programs.

Stakeholder meetings:

A stakeholder meeting for the proposed 2008 Lead Attainment Demonstration SIP 

revision was held on January 19, 2011, in Frisco. Stakeholders expressed numerous 

concerns about air quality, public health, industry-related emissions, proposed control 

strategies, and property values.

Potential controversial concerns and legislative interest:

The City of Frisco, the citizens of Frisco, and the Honorable Florence Shapiro, Texas 

Senator District 8, have expressed considerable concern regarding Frisco’s air quality. 

Parties have also expressed great interest in expediting emission reductions at the Exide

facility.

Will this SIP revision affect any current policies or require development of 

new policies?

No

What are the consequences if this SIP revision does not go forward? Are there 

alternatives to this SIP revision?

The commission could choose to not comply with requirements to develop and submit this 

lead attainment demonstration SIP revision to the EPA. If the 2008 Lead Attainment 
Commissioners

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June 3, 2011

Re: Docket No. 2011-0282-SIP

Demonstration SIP revision is not submitted by June 30, 2012, the EPA could issue a 

finding of failure to submit, requiring that the commission submit the required SIP 

revision within a specified time period, and imposing sanctions on the state. The EPA 

would be required to promulgate a Federal Implementation Plan (FIP) if the commission 

failed to make the submission within two years. Sanctions could include transportation 

funding restrictions and grant withholdings. The EPA would be required to impose such 

sanctions and implement a FIP until it approved a replacement SIP for the area.

Alternatively, the commission could propose a SIP revision that relies on rule changes as 

the control strategy for the SIP. This would require the proposal, followed by a public 

notice and comment period for any rule changes and a different SIP revision.

Key points in the proposal SIP revision schedule:

Anticipated proposal date: June 22, 2011

Public hearing date: July 28, 2011

Public comment period: June 24, 2011 through August 8, 2011

Anticipated adoption date: December 7, 2011

Agency contacts:

Holly Brightwell, 239-4905, Air Quality Division

Amy Browning, 239-0891, Environmental Law Division

cc: Chief Clerk, 2 copies

Executive Director's Office

Susana M. Hildebrand, P.E.

Anne Idsal

Curtis Seaton

Ashley Morgan

Office of General Counsel

Holly Brightwell

Joyce Spencer
REVISIONS TO THE STATE OF TEXAS AIR QUALITY 

IMPLEMENTATION PLAN FOR THE CONTROL OF LEAD AIR 

POLLUTION

COLLIN COUNTY LEAD NONATTAINMENT AREA

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

P.O. BOX 13087

AUSTIN, TEXAS 78711-3087

2011 COLLIN COUNTY ATTAINMENT DEMONSTRATION 

STATE IMPLEMENTATION PLAN REVISION FOR THE 

2008 LEAD NATIONAL AMBIENT AIR QUALITY 

STANDARD

2011-001-SIP-NR

Proposal

June 22, 2011
This page intentionally left blank
ES-1

On October 15, 2008, the United States Environmental Protection Agency (EPA) substantially 

strengthened the National Ambient Air Quality Standard (NAAQS) for lead. The new standard

0.15 micrograms per cubic meter (μg/m

EXECUTIVE SUMMARY

3), measured as a rolling three-month average, is 10 

times more stringent than the previous standard of 1.5 μg/m3 measured as a quarterly average.

On October 14, 2009, the governor of Texas submitted to the EPA a recommendation that a 

portion of Collin County, surrounding the Exide Technologies’ (Exide) battery recycling plant 

located in Frisco, Texas, be designated as a lead nonattainment area. This recommendation was 

based on 2006 through 2008 monitoring data, air dispersion modeling, and analysis of 

additional factors as prescribed by the EPA. On October 12, 2010, the governor of Texas 

submitted an updated recommendation which reflected a permit amendment lowering Exide’s 

maximum permitted allowable emission rate and the resulting smaller nonattainment area. On 

November 22, 2010, the EPA designated the final recommended portion of Collin County as 

nonattainment for the 2008 lead NAAQS, effective December 31, 2010 (75 Federal Register

Section 191(a) of the Federal Clean Air Act (FCAA) requires that states with lead nonattainment 

areas submit to the EPA an attainment demonstration state implementation plan (SIP) revision

within 18 months of the effective designation date. The state is required to submit to the EPA an 

attainment demonstration SIP revision for lead by June 30, 2012, and to demonstrate that the 

area will reach attainment of the 2008 lead NAAQS by the December 31, 2015, attainment date.

[FR] 71033). 

This SIP revision demonstrates attainment using air dispersion modeling that includes control 

strategies already in use at the Exide site as well as additional measures being proposed 

concurrently with this SIP revision. This SIP revision also contains FCAA-required elements,

including a reasonably available control measures analysis, a reasonably available control 

technology analysis, demonstration of reasonable further progress, and a contingency plan.

The control measures and contingency measures that have been identified for this proposed SIP 

revision will be enforceable through an agreed order between the Texas Commission on 

Environmental Quality (TCEQ) and Exide (see Appendix A: Agreed Order 2011-0521-MIS), the 

only lead source in the nonattainment area. To ensure compliance with the 2008 lead NAAQS, 

the Agreed Order is being proposed concurrently with this SIP revision. The Agreed Order 

provides enforceable measures to reduce emissions necessary for the Collin County lead 

nonattainment area to attain the 2008 lead NAAQS by November 1, 2012, and contains

contingency measures designed to ensure continued compliance with the standard. 
i

SECTION V: LEGAL AUTHORITY

A. 

The Texas Commission on Environmental Quality (TCEQ) has the legal authority to implement, 

maintain, and enforce the National Ambient Air Quality Standards (NAAQS) and to control the 

quality of the state’s air, including maintaining adequate visibility.

General

The first air pollution control act, known as the Clean Air Act of Texas, was passed by the Texas 

Legislature in 1965. In 1967, the Clean Air Act of Texas was superseded by a more 

comprehensive statute, the Texas Clean Air Act (TCAA), found in Article 4477-5, Vernon’s Texas 

Civil Statutes. The legislature amended the TCAA in 1969, 1971, 1973, 1979, 1985, 1987, 1989, 

1991, 1993, 1995, 1997, 1999, 2001, 2003, 2005, 2007, and 2009. In 1989, the TCAA was 

codified as Chapter 382 of the Texas Health and Safety Code.

Originally, the TCAA stated that the Texas Air Control Board (TACB) was the state air pollution 

control agency and the principal authority in the state on matters relating to the quality of air 

resources. In 1991, the legislature abolished the TACB effective September 1, 1993, and its 

powers, duties, responsibilities, and functions were transferred to the Texas Natural Resource 

Conservation Commission (TNRCC). With the creation of the TNRCC, the authority over air 

quality is found in both the Texas Water Code and the TCAA. Specifically, the authority of the 

TNRCC is found in Chapters 5 and 7. Chapter 5, Subchapters A - F, H - J, and L, include the 

general provisions, organization, and general powers and duties of the TNRCC, and the 

responsibilities and authority of the executive director. Chapter 5 also authorizes the TNRCC to 

implement action when emergency conditions arise and to conduct hearings. Chapter 7 gives the 

TNRCC enforcement authority. In 2001, the 77th Texas Legislature continued the existence of 

the TNRCC until September 1, 2013, and changed the name of the TNRCC to the Texas 

Commission on Environmental Quality (TCEQ). In 2009, the 81st Texas Legislature, during a 

special session, amended section 5.014 of the Texas Water Code, changing the expiration date of 

the TCEQ to September 1, 2011, unless continued in existence by the Texas Sunset Act.

The TCAA specifically authorizes the TCEQ to establish the level of quality to be maintained in 

the state’s air and to control the quality of the state’s air by preparing and developing a general, 

comprehensive plan. The TCAA, Subchapters A - D, also authorize the TCEQ to collect 

information to enable the commission to develop an inventory of emissions; to conduct research 

and investigations; to enter property and examine records; to prescribe monitoring 

requirements; to institute enforcement proceedings; to enter into contracts and execute 

instruments; to formulate rules; to issue orders taking into consideration factors bearing upon 

health, welfare, social and economic factors, and practicability and reasonableness; to conduct 

hearings; to establish air quality control regions; to encourage cooperation with citizens’ groups 

and other agencies and political subdivisions of the state as well as with industries and the 

federal government; and to establish and operate a system of permits for construction or 

modification of facilities.

Local government authority is found in Subchapter E of the TCAA. Local governments have the 

same power as the TCEQ to enter property and make inspections. They also may make 

recommendations to the commission concerning any action of the TCEQ that affects their 

territorial jurisdiction, may bring enforcement actions, and may execute cooperative agreements 

with the TCEQ or other local governments. In addition, a city or town may enact and enforce 

ordinances for the control and abatement of air pollution not inconsistent with the provisions of 

the TCAA and the rules or orders of the commission.
ii

Subchapters G and H of the TCAA authorize the TCEQ to establish vehicle inspection and 

maintenance programs in certain areas of the state, consistent with the requirements of the 

Federal Clean Air Act; coordinate with federal, state, and local transportation planning agencies 

to develop and implement transportation programs and measures necessary to attain and 

maintain the NAAQS; establish gasoline volatility and low emission diesel standards; and fund 

and authorize participating counties to implement vehicle repair assistance, retrofit, and 

accelerated vehicle retirement programs.

B. 

The following statutes and rules provide necessary authority to adopt and implement the state 

implementation plan (SIP). The rules listed below have previously been submitted as part of the 

SIP.

Applicable Law

All sections of each subchapter are included, unless otherwise noted.

Statutes

TEXAS HEALTH & SAFETY CODE, Chapter 382 September 1, 2009

TEXAS WATER CODE September 1, 2009

Chapter 5: Texas Natural Resource Conservation Commission

Subchapter A: General Provisions

Subchapter B: Organization of the Texas Natural Resource Conservation Commission

Subchapter C: Texas Natural Resource Conservation Commission

Subchapter D: General Powers and Duties of the Commission

Subchapter E: Administrative Provisions for Commission

Subchapter F: Executive Director (except §§5.225, 5.226, 5.227, 5.2275,5.231, 5.232, and 

5.236)

Subchapter H: Delegation of Hearings

Subchapter I: Judicial Review

Subchapter J: Consolidated Permit Processing

Subchapter L: Emergency and Temporary Orders (§§5.514, 5.5145, and 5.515 only)

Subchapter M: Environmental Permitting Procedures (§5.558 only)

Chapter 7: Enforcement

Subchapter A: General Provisions (§§7.001, 7.002, 7.0025, 7.004, and 7.005 only) 

Subchapter B: Corrective Action and Injunctive Relief (§7.032 only)

Subchapter C: Administrative Penalties

Subchapter D: Civil Penalties (except §7.109)

Subchapter E: Criminal Offenses and Penalties: §§7.177, 7.179-7.183

All of the following rules are found in 30 Texas Administrative Code, as of the following latest 

effective dates:

Rules

Chapter 7: Memoranda of Understanding, §§7.110 and 7.119

December 13, 1996 and May 2, 2002

Chapter 19: Electronic Reporting March 15, 2007

Chapter 35: Subchapters A-C, K: Emergency and Temporary Orders and 

Permits; Temporary Suspension or Amendment of Permit Conditions July 20, 2006
iii

Chapter 39: Public Notice, §§39.201; 39.401; 39.403(a) and (b)(8)-(10); 

39.405(f)(1) and (g); 39.409; 39.411 (a), (b)(1)-(6), and (8)-(10) and (c)(1)-(6) 

and (d); 39.413(9), (11), (12), and (14); 39.418(a) and (b)(3) and (4); 

39.419(a), (b), (d), and (e); 39.420(a), (b) and (c)(3) and (4); 39.423 (a) and 

(b); 39.601-39.605 June 24, 2010

Chapter 55: Requests for Reconsideration and Contested Case Hearings; 

Public Comment, §§55.1; 55.21(a) - (d), (e)(2), (3), and (12), (f) and (g); 

55.101(a), (b), and (c)(6) - (8); 55.103; 55.150; 55.152(a)(1), (2), and (6) and 

(b); 55.154; 55.156; 55.200; 55.201(a) - (h); 55.203; 55.205; 55.209, and 

55.211 June 24, 2010

Chapter 101: General Air Quality Rules May 12, 2011

Chapter 106: Permits by Rule, Subchapter A May 12, 2011

Chapter 111: Control of Air Pollution from Visible Emissions and Particulate 

Matter July 19, 2006

Chapter 112: Control of Air Pollution from Sulfur Compounds July 16, 1997

Chapter 113: Standards of Performance for Hazardous Air Pollutants and for 

Designated Facilities and Pollutants May 14, 2009

Chapter 114: Control of Air Pollution from Motor Vehicles December 13, 2010

Chapter 115: Control of Air Pollution from Volatile Organic Compounds February 17, 2011

Chapter 116: Permits for New Construction or Modification March 3, 2011

Chapter 117: Control of Air Pollution from Nitrogen Compounds May 12, 2011

Chapter 118: Control of Air Pollution Episodes March 5, 2000

Chapter 122: §122.122: Potential to Emit December 11, 2002

Chapter 122: §122.215: Minor Permit Revisions June 3, 2001

Chapter 122: §122.216: Applications for Minor Permit Revisions June 3, 2001

Chapter 122: §122.217: Procedures for Minor Permit Revisions December 11, 2002

Chapter 122: §122.218: Minor Permit Revision Procedures for Permit 

Revisions Involving the Use of Economic Incentives, Marketable Permits, and 

Emissions Trading June 3, 2001
iv

SECTION VI: CONTROL STRATEGY

A. Introduction (No change)

B. Ozone (No Change)

C. Particulate Matter (No change)

D. Carbon Monoxide (No change)

E. Lead (Revised)

1. 1980 State Implementation Plan for the Control of Lead Air Pollution (No change)

2. 1993 Lead SIP Revisions for Collin County (No change)

3. 1999 Lead SIP Revisions for Collin County (No change)

4. 2009 Collin County Maintenance Plan for Lead (No change)

5. 2011 Collin County Attainment Demonstration SIP Revision for the 2008 Lead NAAQS 

(New)

F. Oxides of Nitrogen (No change)

G. Sulfur Dioxide (No change)

H. Conformity with the National Ambient Air Quality Standards (No change)

I. Site Specific (No change)

J. Mobile Sources Strategies (No change)

K. Clean Air Interstate Rule (No change)

L. Transport (No change)

M. Regional Haze (No change)
v

TABLE OF CONTENTS

Executive Summary

Section V: Legal Authority

Section VI: Control Strategy

Table of Contents

List of Acronyms

List of Tables

List of Figures

List of Appendices

Chapter 1: General

1.1 Background

1.2 Introduction

1.3 Current SIP Revision

1.4 Summary of Measured Lead Concentrations in Frisco

1.5 Health Effects

1.6 Public Comment and Stakeholder Participation

1.6.1 Stakeholder Meetings

1.6.2 Public Hearings and Comment Information

1.7 Social and Economic Considerations

1.8 Fiscal and Manpower

Chapter 2: Emissions Inventory

2.1 Introduction

2.2 Point Sources

2.2.1 Emissions Inventory Development

2.2.2 Updated 2010 Emissions Inventory

2.3 Other Source Categories

Chapter 3: Air Dispersion Modeling

3.1 Introduction

3.2 Modeling Approach

3.2.1 Meteorology for Base Case and Future Case

3.2.2 Meteorology Sensitivity Analysis
vi

3.3 Base Case Analysis

3.3.1 Base Case Emissions Inventory

3.3.1.1 Source Characterizations and Emission Rates

3.3.1.2 Other Sources

3.3.1.3 Background Sources

3.3.2 Source Input Parameters

3.3.3 Base Case Modeling Results

3.4 Future Case Analysis

3.4.1 Future Case Emissions Inventory

3.4.2 Background Sources

3.4.3 Source Input Parameters

3.4.4 Future Case Modeling Results

3.5 References

Chapter 4: Control Strategy And required Elements

4.1 Introduction

4.2 Existing Control Measures

4.3 RACT and RACM Analysis

4.3.1 Results of RACM (Including RACT) Analysis

4.3.1.1 RACM (Including RACT) Determination

4.4 New Control Measures

4.5 Monitoring Network

4.5.1 Lead Monitoring Sites in Frisco

4.6 Contingency Plan

4.6.1 Contingency Measures

4.6.1.1 Contingency Measure Requirements

4.6.1.2 Contingency Trigger Levels

Chapter 5: Reasonable Further Progress

5.1 General

5.2 RFP Demonstration

5.3 RACM (Including RACT)
vii

LIST OF ACRONYMS

ADEC Alaska Department of Environmental Conservation

AERMOD American Meteorological Society/Environmental Protection Agency Regulatory 

Model

ASOS Automated Surface Observing System 

AQS Air Quality System

AQS ID Air Quality System Identification

BPIPPRM The Building Profile Input Program for Plume Rise Model Enhancements

CFR Code of Federal Regulations

DEMs digital elevation models 

EAF electric arc furnaces

EPA United States Environmental Protection Agency

FCAA Federal Clean Air Act

FR Federal Register

GEP good engineering practice 

GPS Global Position System

HEPA high efficiency particulate air

ISHD Integrated Surface Hourly Data

IQ Intelligence Quotient

km kilometer

lb/hr pounds per hour

lb/hr•m2

m/sec meters per second

pounds per hour per square meter

mph miles per hour

NAAQS National Ambient Air Quality Standards

NCDC National Climactic Data Center

NLCD National Land Cover Database 

NWS National Weather Service

PTFE polytetrafluoroethylene

psia pounds per square inch absolute

R2

SIP state implementation plan

correlation coefficient

SSE south-southeast

TAC Texas Administrative Code
viii

TACB Texas Air Control Board

TCAA Texas Clean Air Act

TCEQ Texas Commission on Environmental Quality (commission)

TNRCC Texas Natural Resource Conservation Commission

tons/hr tons per hour

tpd tons per day

USGS United States Geological Survey

μg/m3

WESP Wet Electrostatic Precipitation

micrograms per cubic meter
ix

LIST OF TABLES

Table 1-1: Monitoring Data from Collin County Lead Monitors

Table 1-2: Public Hearing Information

Table 3-1: Missing and Calm Hours in Meteorological Data

Table 3-2: Exide Source Description List

Table 3-3: Base Case Point Source Parameters

Table 3-4: Base Case Area Source Parameters

Table 3-5: Base Case Source Contribution at Location of Maximum Predicted Concentration

Table 3-6: Stack Test Details from Baghouses Covered Under Exide Permit 1147A

Table 3-7: Stack Test Details from Baghouses Covered Under Exide Permit 3048A

Table 3-8: Future Case Point Parameters

Table 3-9: Future Case Area Source Parameters

Table 3-10: Future Case AreaPoly Source Parameters

Table 3-11: Vertices of AreaPoly Source ROAD

Table 3-12: Future Case Source Contribution at Location of Maximum Predicted Concentration
x

LIST OF FIGURES

Figure 1-1 Map of Collin County Lead Nonattainment Area

Figure 4-1 Collin County Lead (Pb) Nonattainment Area
xi

LIST OF APPENDICES

Appendix

Appendix A Agreed Order Docket No. 2011-0521-MIS

Appendix Name

Appendix B Monitoring Data from Collin County Lead Monitors

Appendix C Annual Emissions Inventory Update for Exide Technologies’ Frisco 

Battery Recycling Plant

Appendix D Reasonably Available Control Measures (RACM) and Reasonably 

Available Control Technology (RACT) Analyses

Appendix E RACM RFP Implementation Schedule
1-1

CHAPTER 1: GENERAL

1.1 BACKGROUND

The History of the Texas State Implementation Plan (SIP), a comprehensive overview of the SIP 

revisions submitted to the United States Environmental Protection Agency (EPA) by the State of 

Texas, is available on the Texas Commission on Environmental Quality’s (TCEQ) SIP 

Introduction Web page (http://www.tceq.texas.gov/airquality/sip/sipintro.html). 

1.2 INTRODUCTION

The EPA designated a portion of Collin County as a lead nonattainment area for the 1978 Lead 

National Ambient Air Quality Standard (NAAQS) on November 6, 1991 (56 Federal Register

• automate the scale and feed for the reverberatory furnace; 

[FR] 56694). The EPA approved the Collin County lead attainment demonstration SIP revision 

for the 1978 NAAQS on November 29, 1994 (59 FR 60930). The EPA redesignated the area to 

attainment and approved the first 10-year maintenance plan in October 15, 1999 (64 FR 55421). 

In 2009, the TCEQ submitted to the EPA the second and final 10-year maintenance plan for the 

1978 lead NAAQS. The maintenance plan included contingency measures to promptly correct 

any violation of the 1978 lead NAAQS. Because there is only one significant lead source in the 

nonattainment area, all measures are directed at this source. The contingency measures 

included in the 2009 maintenance plan would require Exide Technologies’ battery recycling 

plant (Exide) to do one of the following if the area monitored lead concentrations above the 1978 

lead NAAQS:

• expand the existing water misting dust suppression system; or 

• implement an alternative measure that will provide, at a minimum, emissions reductions 

equivalent to those listed previously.

On November 12, 2008, the EPA substantially strengthened the NAAQS for lead. The new 

standard, set at 0.15 micrograms per cubic meter (μg/m3) measured as a rolling three-month 

average, is 10 times more stringent than the previous standard of 1.5 μg/m3 measured as a 

quarterly average (73 FR 66964). On November 22, 2010, the EPA designated a portion of Collin 

County surrounding Exide as nonattainment for the 2008 lead NAAQS, effective December 31, 

2010 (75 FR 71033). The 2008 lead NAAQS final rule contained a revised method for calculating 

averaging time for the purposes of comparing monitored data to the NAAQS. Compliance with 

the 2008 lead NAAQS is based on 36 three-month rolling averages. For an ambient air 

monitoring site to meet this standard, no three-month rolling average for the previous 36 

months prior to the attainment date may exceed 0.15 μg/m3. Therefore, Collin County must 

monitor attainment of the NAAQS beginning November 1, 2012, to meet the December 31, 2015,

attainment deadline. Appendix B: Monitoring Data from Collin County Lead Monitors

1.3 CURRENT SIP REVISION

describes available monitoring data in Collin County from the past 36 months.

Effective December 15, 2010, the EPA designated a 1.28 square mile area surrounding Exide in 

Frisco, Texas, as nonattainment for the 2008 lead NAAQS (75 FR 71033). The nonattainment 

area is a portion of Collin County located in the City of Frisco that is bounded to the north by 

latitude 33.153, to the east by longitude -96.822, to the south by latitude 33.131, and to the west 

by longitude -96.837. Figure 1-1: Map of Collin County Lead Nonattainment Area provides a 

visual representation of the nonattainment area. Lead nonattainment areas designated in 2010, 

are required to attain the 2008 lead NAAQS as expeditiously as practicable but no later than 

December 31, 2015. The state must submit a SIP revision addressing the lead nonattainment 
1-2

area requirements of the Federal Clean Air Act (FCAA) by June 30, 2012. To ensure that the 

Collin County nonattainment area attains the 2008 lead NAAQS as expeditiously as practicable, 

this SIP revision includes control measures implemented during SIP development but prior to 

proposal as agreed upon by Exide.

Figure 1-1: Map of Collin County Lead Nonattainment Area

This proposed SIP revision demonstrates attainment of the 2008 lead NAAQS using an air

dispersion modeling analysis and contains control measures necessary to bring Collin County 

into attainment by November 1, 2012. In addition to control measures included to demonstrate 

attainment by November 1, 2012, this proposed SIP revision contains contingency measures to 

be implemented if the area fails to meet that deadline or fails to meet reasonable further 

progress (RFP) requirements. As required by the FCAA and the EPA’s implementation guidance 

for the 2008 lead NAAQS, this proposed SIP revision also contains a reasonably available 

control technology analysis, a reasonably available control measures analysis, and an RFP 

demonstration.

The control measures and contingency measures that have been identified for this proposed SIP 

revision would be enforceable through Agreed Order 2011-0521-MIS between the TCEQ and 

Exide, the only lead source in the nonattainment area. To ensure compliance with the 2008 lead 

NAAQS, the Agreed Order is being proposed concurrently with this SIP revision. The Agreed 

Order provides enforceable measures to reduce emissions necessary for the Collin County lead 

nonattainment area to attain the 2008 lead NAAQS by November 1, 2012, and contains

contingency measures designed to ensure continued compliance with the standard.
1-3

1.4 SUMMARY OF MEASURED LEAD CONCENTRATIONS IN FRISCO 

The 2008 lead NAAQS final rule contained a revised method for calculating averaging time for 

the purposes of comparing monitored data to the NAAQS. Compliance with the 2008 lead 

NAAQS is based on 36 three-month rolling averages. For an ambient air monitoring site to meet 

this standard, no three-month rolling average for the previous 36 months may exceed 0.15 

μg/m3

As of May 20, 2011, the lead design value for Collin County is 0.71 μg/m

. Collin County must monitor attainment of the NAAQS beginning with the November 1, 

2012, through January 31, 2013, three-month rolling average to meet the December 31, 2015,

attainment date. 

3. Table 1-2: Monitoring 

Data from Collin County Lead Monitors describes the most recent 36-month period of lead 

monitoring data in Collin County.

Table 1-1: Monitoring Data from Collin County Lead Monitors

Monitor/Air Quality System

Identification Number

Highest 3-month ambient air 

concentration average in the 

most recent 36-month period

(μg/m3

Most recent three-month rolling 

average

) (μg/m3

Eubanks 480850009

)

0.71 0.49

Ash Street 480850007 0.15 0.11

Parkwood 480850003 0.37 0.11

Stonebrook 480850029 0.15 0.15

1.5 HEALTH EFFECTS

On October 15, 2008, the EPA substantially strengthened the NAAQS for lead. According to the 

EPA’s final rule for the 2008 lead NAAQS (73 FR 66964), scientific evidence about lead and 

health has expanded dramatically since the EPA issued the initial standard of 1.5 μg/m3

Lead that is emitted into the air can be inhaled directly or ingested after it settles onto surfaces 

or soils. However, for the general population, exposure to lead occurs primarily via ingestion 

through contact with contaminated soils or other surfaces. Once taken into the body, lead 

distributes throughout the body in the blood and accumulates in the bones. Depending on the 

level of exposure, lead can adversely affect the nervous system, kidney function, immune 

system, reproductive and developmental systems, and the cardiovascular system. Lead exposure 

also affects the oxygen-carrying capacity of the blood.

in 1978. 

More than 6,000 new studies on lead health effects, environmental effects, and lead in the air 

have been published since 1990. Evidence from health studies shows that adverse effects occur 

at much lower levels of lead in blood than previously thought.

Lead effects most commonly encountered in current populations are neurological effects in 

children and cardiovascular effects (e.g., high blood pressure and heart disease) in adults. 

Children are at a higher risk of exposure to lead when compared to adults. The risk of exposure 

is higher because children tend to put their hands and other objects, which may contain lead,

into their mouths (e.g., lead-based paint chips from older homes). Children also have a higher 

risk of adverse effects because their brains are still developing. Infants and young children are 

especially sensitive to low levels of lead, which may contribute to behavioral problems, learning 

deficits, and lowered Intelligence Quotient (IQ).
1-4

1.6 PUBLIC COMMENT AND STAKEHOLDER PARTICIPATION

1.6.1 Stakeholder Meetings

The TCEQ held a lead stakeholder meeting to discuss concepts for potential control strategies 

for the Collin County lead nonattainment area and to present an overview of the SIP

development process. The meeting was held at the City of Frisco Council Chambers on January 

19, 2011. TCEQ staff from the Toxicology, Air Permits, and Air Quality Divisions presented

information. Staff was also on hand to answer questions. Staff presented stakeholders with an 

overview of the health effects of lead, an update on the 2008 lead NAAQS and the associated SIP

revision, an overview of the role of modeling in demonstrating attainment, and a draft list of 

potential control strategies. The presentation and additional information about the lead 

stakeholder meeting can be found at the Lead Stakeholder Group Web page 

(http://www.tceq.texas.gov/airquality/sip/stakeholders/pb_stakeholder).

1.6.2 Public Hearings and Comment Information

The commission will hold a public hearing for the proposed 2011 Collin County Attainment 

Demonstration SIP Revision for the 2008 Lead NAAQS, which includes Agreed Order 2011-

0521-MIS, at the following time and location:

Table 1-2: Public Hearing Information

City Date Time

Frisco

Location

July 28, 2011 6:00 PM

Frisco City Council Chambers

6101 Frisco Square Boulevard

Frisco, TX 75034

The public comment period will open on June 24, 2011, and close on August 8, 2011. Written 

comments will be accepted via mail, fax, or through the eComments system. All comments 

should reference the “2011 Collin County Attainment Demonstration SIP Revision for 

the 2008 Lead NAAQS” and Project Number 2011-001-SIP-NR. Comments may be 

submitted to C. Holly Brightwell, MC 206, State Implementation Plan Team, Chief Engineer’s 

Office, Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas, 78711-

3087 or faxed to (512) 239-5687. Electronic comments may be submitted through the 

eComments system (http://www5.tceq.texas.gov/rules/ecomments). File size restrictions may 

apply to comments being submitted via the eComments system. Comments must be received by 

close of business August 8, 2011.

1.7 SOCIAL AND ECONOMIC CONSIDERATIONS

No significant fiscal implications are anticipated for the TCEQ or other units of state or local 

governments as a result of administration or enforcement of proposed Agreed Order 2011-0521-

MIS. Because Exide is the sole source contributing to the nonattainment area, all controls to 

reach attainment will be borne by this source. As such, any economic impacts will be limited to 

the single lead source associated with this SIP revision. The proposed Agreed Order is expected 

to have significant fiscal impact to Exide. The citizens of a portion of Collin County will benefit 

from reduced exposure to ambient lead emissions.

1.8 FISCAL AND MANPOWER

The TCEQ has determined that its fiscal and manpower resources are adequate and will not be 

adversely affected through implementation of this plan. 
2-1

CHAPTER 2: EMISSIONS INVENTORY

2.1 INTRODUCTION

The Federal Clean Air Act, §172(c)(3) requires the development of emissions inventories (EI) for 

nonattainment areas. The Texas Commission on Environmental Quality (TCEQ) maintains a

point source EI with up-to-date information on major lead sources. The EI identifies the types of 

emissions sources present in an area, the amount of each pollutant emitted, and the types of 

processes and control devices employed at each plant or source category.

On November 22, 2010, the Environmental Protection Agency (EPA) designated a portion of 

Collin County, located in Frisco, Texas, as a lead nonattainment area, effective December 31, 

2010 (75 Federal Register [FR] 71033). This nonattainment area surrounds Exide Technologies’

(Exide) lead battery recycling plant, a point source that submits annual emissions inventory 

data to the TCEQ. This chapter discusses general EI development for the point source category.

Contributions from non-point sources were found to be insignificant. See section 2.3 Other 

Source Categories 

2.2 POINT SOURCES

for more information about emissions from non-point source categories.

2.2.1 Emissions Inventory Development

Stationary point source emissions data are collected annually from sites that meet the reporting 

requirements of 30 Texas Administrative Code §101.10. To collect the data, the TCEQ sends

emissions inventory questionnaires (EIQ) to all sites identified as meeting the reporting 

requirements. Companies are required to report emissions data and to provide samples of 

calculations used to determine the emissions. Information characterizing the process 

equipment, the abatement units, and the emission points is also required. All data submitted in 

the EIQ are reviewed for quality assurance purposes and then stored in the State of Texas Air 

Reporting System database.

2.2.2 Updated 2010 Emissions Inventory

The TCEQ requested that Exide submit an expedited 2010 lead emissions inventory for all leademitting sources located at the company’s battery recycling plant in Frisco, Texas. Exide 

submitted the 2010 lead emissions inventory data to the TCEQ on February 24, 2011. Total

reported lead emissions for 2010 are 1.09 tons per year. No other lead-emitting point sources 

have been identified in the lead nonattainment area. 

The 2010 lead emissions inventory that Exide submitted on February 24, 2011, is reproduced in 

Appendix C: Annual Emissions Inventory Update for Exide Technologies’ Frisco Lead Battery 

Recycling Plant

2.3 OTHER SOURCE CATEGORIES

.

According to the Air Emissions Reporting Requirements (73 FR 76539), only annual point 

source emissions are required to be reported to EPA for the 2010 inventory year. Since the next 

triennial reporting year is 2011, the mobile and area source periodic emissions inventories were 

not developed for 2010. However, a review of 2008 data indicated an insignificant contribution 

of lead emissions (less than 0.1%) from these non-point sources. Therefore, the point source 

category is the only inventory category developed for the inventory year as Exide Technologies’ 

battery recycling plant in Frisco is the only point source reporting lead emissions in the 

nonattainment area.
3-1

CHAPTER 3: AIR DISPERSION MODELING

3.1 INTRODUCTION

Two dispersion modeling analyses were performed for the 2011 Collin County Attainment 

Demonstration State Implementation Plan (SIP) Revision for the 2008 Lead National Ambient 

Air Quality Standard (NAAQS). One was an analysis of current conditions (base case). The other 

analysis examined the potential effectiveness of proposed emission controls (future case). 

The base case evaluated a reasonable estimate of maximum actual emissions to determine the

sources that contribute most to the highest predicted concentrations. This determination helps 

identify the sources that may contribute most to actual monitored concentrations. The sources 

identified as likely contributors to predicted maximum concentrations are targeted in the 

proposed Agreed Order 2011-0521-MIS that is associated with this proposed SIP revision. 

The future case evaluated control strategies listed in section 4.4 New Control Measures

3.2 MODELING APPROACH

of this 

proposed SIP revision and described in Agreed Order 2011-0521-MIS between the Texas 

Commission on Environmental Quality (TCEQ) and Exide Technologies (Exide). Dispersion 

modeling was used to validate that the proposed control strategies will bring the Collin County 

lead nonattainment area into compliance with the 2008 lead National Ambient Air Quality 

Standard (NAAQS).

The dispersion modeling analysis was performed using the American Meteorological 

Society/Environmental Protection Agency Regulatory Model (AERMOD) modeling system. 

There are two input data processors that are regulatory components of the AERMOD modeling 

system: AERMET, a meteorological data preprocessor that incorporates air dispersion based on 

planetary boundary layer turbulence structure and scaling concepts, and AERMAP, a terrain 

data preprocessor that incorporates complex terrain using United States Geological Survey 

(USGS) Digital Elevation Data. The Building Profile Input Program for Plume Rise Model 

Enhancements (BPIPPRM), a multi-building dimensions program incorporating the good 

engineering practice (GEP) technical procedures for PRIME applications was also used.

Both the base and future case analyses used identical model programs, model settings, 

meteorological data, downwash data, and receptor grids. The selections made for these analyses 

are summarized below.

• AERMOD (Version 09292) was used with default regulatory settings. Since the current 

version of AERMOD is not capable of calculating rolling three-month average 

concentrations, the EPA post-processor LeadPost was used. The input values to LeadPost 

are monthly average values at each receptor in the POSTFILE output format from AERMOD. 

• AERMET (Version B10300) was used to process meteorological data for the period 2006

through 2010. 

• Downwash parameters were generated using BPIPPRM (Version 04274). Building and point 

source locations were derived from global positioning system (GPS) measurements by TCEQ 

regional staff and validated by TCEQ Air Permits staff using aerial photography. 

• The receptor grid used in the modeling analyses consisted of receptors with 100 meter 

spacing and extended approximately 3 kilometers (km) from the Exide site property line in 

all directions. Discrete receptors were used for the locations of the existing ambient air 

monitoring stations.

• Terrain elevations within the modeling domain were determined using AERMAP (Version 

09040). The input data used for this analysis were USGS seamless data covering the 
3-2

following digital elevation models (DEMs): Little Elm, Frisco, Lewisville East, and Hebron 

data sets.

3.2.1 Meteorology for Base Case and Future Case

In order to generate meteorological input data for use with AERMOD, surface characteristics 

(Bowen ratio, noontime albedo, and surface roughness length) of the modeling domain must be 

obtained for input for AERMET. Values for Bowen ratio and surface roughness length for the 

modeling domain were calculated using the methodology proposed by the Alaska Department of 

Environmental Conservation (ADEC) described in ADEC Guidance re AERMET Geometric 

Means, How to Calculate the Geometric Mean Bowen Ratio and the Inverse-Distance 

Weighted Geometric Mean Surface Roughness Length in Alaska,1

The 2001 NLCD was used rather than the 1992 NLCD due to the rapid growth of the Frisco area. 

From United States Census Bureau data, the 1990 population of Frisco was less than 10,000, the 

2000 population was over 30,000, and the 2010 population was over 116, 000. For this reason,

the 1992 NLCD was deemed not representative of current land cover characteristics. The 2001 

NLCD is the most recent available dataset, so it was used for this modeling analysis.

with input of land cover data 

from the USGS National Land Cover Database (NLCD) 2001. The ADEC guidance provided an 

equivalent calculation method to the surface characteristic pre-processor program 

AERSURFACE (Version 08009), which requires the input of land cover data from the USGS 

NLCD 1992. The ADEC guidance is for use with land cover data other than the 1992 NLCD.

Using the 1992 NLCD classifications obtained from the AERSURFACE User’s Guide2, land cover 

data from 2001 were reclassified to reasonably equivalent 1992 NLCD classifications using 

documentation from the NLCD 1992/2001 Retrofit Land Cover Change Product3

Meteorological raw input data were used with generalized surface characteristics of the 

application site and processed with AERMET (Version B10300). This beta version was obtained 

from the United States Environmental Protection Agency (EPA) Region 6. This version of 

AERMET integrates one-minute Automated Surface Observing System (ASOS) wind data with 

Integrated Surface Hourly Data (ISHD) using the EPA’s AERMINUTE program. ISHD and oneminute ASOS wind data were obtained from the National Climactic Data Center (NCDC). The 

upper air data was obtained from the National Oceanic Atmospheric Administration Earth 

System Research Laboratory. 

. 

Representative Bowen ratio and surface roughness length values were calculated using the 

reclassified 2001 NLCD with the ADEC guidance. The noontime albedo value was calculated 

using the reclassified 2001 NLCD for all land classifications within a 10 km square, as specified 

by the AERSURFACE User’s Guide, surrounding the Exide site. The Bowen ratio calculated was 

0.76, surface roughness was 0.234 meters, and albedo was 0.174.

Meteorological data from 2006 through 2010 from the Dallas-Fort Worth surface station 

(Station # 03927) and the Fort Worth upper air station (Station # 03990) were used in these 

analyses. Missing data from the Dallas-Fort Worth surface station were replaced with available 

2006 through 2010 data from the McKinney Airport surface station (Station # 53914). The 

McKinney Airport was selected because it is the nearest National Weather Service (NWS) station 

to the lead nonattainment area. The McKinney Airport ISHD and one-minute ASOS wind data 

were processed in conjunction with Fort Worth upper air data using AERMET. Any hours that 

contained missing data in the Dallas-Fort Worth input file were replaced with the corresponding 

hourly data in the McKinney Airport input file when available. Table 3-1: Missing and Calm 

Hours in Meteorological Data lists the number of hours with missing and filled data. A “calm” is 

defined as a reported wind speed less than three knots.
3-3

Table 3-1: Missing and Calm Hours in Meteorological Data

Year Total 

Hours

Missing Hours 

Before Fill

Missing Hours 

After Fill

Calm Hours 

Before Fill

2006

Calm Hours After 

Fill

8760 202 166 28 29

2007 8760 314 294 37 39

2008 8784 211 183 117 119

2009 8760 95 83 19 20

2010 8760 62 42 63 63

3.2.2 Meteorology Sensitivity Analysis

A sensitivity analysis was performed using the base case emissions with unfilled and filled 

meteorological input data. The rolling 3-month average lead concentrations were compared 

receptor by receptor. At the location of the highest predicted concentration, the difference in 

concentration was 0.07%. For all receptors within 1 km of the Exide site, the difference was less 

than 2% except for five receptors. At those five receptors, the difference was less than 2.5%. Due 

to the small number of missing hours of data, small number of hours with calms compared to 

the total number of hours , the highest predicted concentration being at or near the site property 

line, and the rolling three-month averaging time for predicted concentrations, additional filling 

of meteorological data would not significantly impact the modeling results.

3.3 BASE CASE ANALYSIS

The base case analysis compared modeled predicted rolling three-month, monthly, and 24-hour 

average concentrations to monitored concentrations during the same period. The modeled base 

case was a reasonable attempt to replicate actual conditions. The purpose of modeling actual 

conditions was to determine if all sources were accounted for and appropriately characterized in 

the modeling. If all sources were accounted for and characterized, the modeling results should 

reasonably agree qualitatively with the monitoring data. Qualitative agreement would not be 

exact agreement between modeled and monitored concentrations in time and space but would 

represent similarity in concentration trends over time and dispersion patterns in a general area. 

Once the current actual conditions have been sufficiently replicated, the effectiveness of the 

control strategies can be estimated through the future case analysis.

3.3.1 Base Case Emissions Inventory

3.3.1.1 

Sources 18, 21, 22, 23, 37, 38, 39, 45, and 48, authorized by Exide Permit 1147A, are stacks that

were characterized as point sources in the model. Reference Table 3-2: 

Source Characterizations and Emission Rates

Exide Source 

Description List

Emissions from sources 10, 35, 36, 41, 42, 43, 44, 52, and 53, also authorized by Exide Permit 

1147A, are all fugitive in nature and were characterized as area sources. Fugitive emissions 

sources are those emissions that are not emitted to the atmosphere through a vent, stack, or 

discrete emission point. The dimensions of the sources are representative of the areas where the 

emissions are generated. The height of release for Exide sources 10, 35, 36, 44, and 52 was based 

, for a list of emission points referenced in this proposed SIP revision. The 

actual height and diameter for each source was modeled. The stack exit temperature and 

velocity for each source was based on stack test data provided by Exide for each stack. The 

emission rates modeled were the highest hourly emission rate from the most recent stack test. 

Stack test-based exit temperatures, velocities, and emission rates were used for the base case 

analysis because they are representative of actual routine operations.
3-4

on the height where the emissions escape a structure. The release height for sources Exide 41, 

42, and 43 (vehicle traffic) was set to 1 meter, which is a reasonable height for road generated 

emissions. The release height of source 53 was the height of the conveyance system to the blast 

furnace.

In order to simplify the modeling analysis, Exide sources 10 and 35 were combined. The 

modeling analysis used for the lead nonattainment area designation (designation modeling) 

shows that source 10 has a higher contribution than source 35 at the location of the maximum 

predicted concentration. The combined emissions from both sources were represented as 

coming from only source 10. Sources 41, 42, and 43 were also combined. The designation 

modeling shows that source 41 has a higher contribution than sources 42 or 43 at the location of 

the maximum predicted concentration. The combined emissions from all three sources were 

represented as coming from only source 41. A modeling analysis is considered more 

conservative when all emissions are assumed to come from one source with the highest 

predicted concentration rather than apportioned to multiple sources.

Sources 11, 12, 13, 14, 15, 16, 17, 24, 25, and 26, authorized by Exide Permit 3048A, are stacks 

that were characterized as point sources. The actual height and diameter for each source was 

modeled. The stack exit temperature and velocity for each source was based on stack test data 

for each stack. The emission rates modeled were the highest hourly emission from the most 

recent stack test. The rationale for using the stack test results for stack exit temperatures, 

velocities, and emission rates was the same as for sources authorized by Exide Permit 1147A.

Emissions from sources 27 and 28, also authorized by Exide Permit 3048A, are all fugitive in 

nature and were characterized as area sources. The dimensions of the sources are representative 

of the areas where the emissions are generated. The height of release for sources 27 and 28 was 

based on the height where the emissions escape a structure.
3-5

Table 3-2: Exide Source Description List

Emission Point 

Number

10

Source Name

Furnace Fugitives

11 Oxide Reactor No. 3 Baghouse Stack

12 Oxide Reactor No. 2 Baghouse Stack

13 Oxide Reactor No. 1 Baghouse Stack

14 Oxide Hygiene Baghouse Stack (MELTPOT1, MELTPOT2, MELTPOT3)

15 North Hammerhill Baghouse Stack

16 Oxide Reactor No. 4 Baghouse Stack

17 South Hammerhill Baghouse Stack

18 Hard Lead Ventilation Baghouse Stack

21 Soft Lead Ventilation Baghouse Stack 

22 Specialty Alloy Baghouse Stack

23 Refining Building Vacuum Stack

24 Oxide Reactor No. 5 Baghouse Stack

25 Oxide Reactor No. 6 Baghouse Stack

26 Oxide Reactor No. 7 Baghouse Stack

27 West Truck Loading Fugitives

28 East Truck Loading Fugitives

35 Furnace Fugitives

36 Refining/Casting

37 Reverbatory/Blast Furnaces Fugitives Baghouse Stack

38 Reverbatory/Blast Furnaces Metallurgical Scrubber Stack

39 Slag Fixation Baghouse Stack

41 Vehicle Traffic

42 Vehicle Traffic

43 Vehicle Traffic

44 Raw Material Storage

45 Raw Material Storage/Shredder Baghouse Stack

48 Battery Breaker Scrubber Stack

52 Slag Handling

53 Material Handling

999 Battery Breaker Operation

3.3.1.2 

In comparing monitoring data to modeling results considering only the sources authorized by 

Exide Permits 1147A and 3048A, there was a disparity between some actual and predicted 

concentrations. The actual concentrations were significantly higher than those predicted given 

certain meteorological conditions. The commission concluded that a source or sources were not 

accounted for in the modeling. Based on the review and analysis of actual and predicted 24-hour 

concentrations, there appeared to be an unaccounted source to the south-southeast (SSE) of the 

Frisco Eubanks monitor (Air Quality System Identification [AQS ID] 480850009). When winds 

Other Sources
3-6

were blowing from the SSE, the Frisco Eubanks monitor tended to record concentrations 

significantly higher (one order of magnitude higher) than the other two existing monitors which 

are located northeast and southeast of the Frisco Eubanks monitor. In addition, higher wind 

speeds from the SSE tended to result in higher monitored concentrations.

Exide management informed TCEQ staff that the unaccounted source could be the fugitive 

emissions from the battery breaking operation. The fugitive emissions from the battery breaking 

operations for the lead battery recycling industry were previously believed to be negligible due to 

the large amount of liquid in the batteries suppressing particulate emissions. However, ambient 

air monitoring conducted at the Exide Technologies site in Vernon, California, show that 

emissions from the battery breaker operation provided to the TCEQ by Exide were a large 

contributor to monitored concentrations.

Monitoring data from Exide’s Frisco, Texas, and Vernon, California, sites was used to develop an 

emission rate from the battery breaker operation for the base case. Data from three monitored 

samples for each site were considered. The data consisted of the 24-hour average monitored 

concentration of lead and 1-hour average wind speeds. All six sample days experienced winds 

predominantly blowing from the battery breaker operation to the monitor. Winds during all six 

sample days were high enough that atmospheric stability was assumed to be neutral.

The SCREEN3 (version 96043) dispersion screening model was used to estimate the emission 

rate necessary to result in the monitored concentration given the distance from the operation to 

the monitor, wind speed, and neutral stability for that day. The source was represented as an 

area source the size of the battery breaker operation for the appropriate site. The emission rates 

in pounds per hour (lb/hr) were converted to an emissions flux in pounds per hour per square 

meter (lb/hr•m2). The six data points were plotted as emission flux (lb/hr × m2) versus wind 

speed in miles per hour (mph). A power series correlation was performed on the six data points. 

The resulting equation to estimate emissions was emission flux = 2.0 × 10-6 × (wind speed)1.9822. 

The correlation coefficient (R2) value for the correlation was 0.9807 which suggests a strong 

correlation. An R2 

The base case modeling was performed again considering the emissions from the battery 

breaker operation. The source (999) was represented as an area source with dimensions 

representative of the operation. Since the emissions from this source were assumed to be wind 

generated, wind category scalars were used in the modeling to account for this behavior. The 

scalar values were determined from the equation emission flux = 2.0 × 10

value of 1 would denote a perfect correlation.

-6 × (wind speed)1.9822

3.3.1.3 

. 

The scalar values for each upper bound wind speed in meters per second (m/sec) were 1.00 for 

1.54 m/sec, 4.03 for 3.09 m/sec, 11.14 for 5.14 m/sec, 28.56 for 8.24 m/sec, and 49.18 for 10 

m/sec.

The largest nearby source of lead emissions is approximately 50 km from the Exide site with 

annual reported emissions approximately 10% of the annual emissions reported by Exide. Due 

to the great distance to the Exide site and the small reported emission rate, no other sources of 

lead emissions would have a significant contribution near the Exide site or the modeling domain 

used for this analysis.

Background Sources

3.3.2 Source Input Parameters

Table 3-3: Base Case Point Source Parameters contains input parameters for all point sources 

modeled for the base case. Table 3-4: Base Case Area Source Parameters contains input 

parameters for all area sources modeled for the base case. The total annual lead emissions 
3-7

represented is 4.39 tpy, based on a representative worst case 24-hour period. The modeling 

assumes that emission rates are continuous 24 hours a day, 365 days a year. Because Exide’s

process rate varies from day to day, the continuous emissions assumption predicts a higher 

ambient concentration than would be expected in reality.
3-8

Table 3-3: Base Case Point Source Parameters

Source 

ID

Easting

(meters)

Northing 

(meters)

Elevation 

(meters)

Height

(meters)

Temp 

(Kelvin)

Velocity 

(meters 

per 

second)

Diameter 

(meters)

11

Emission 

Rate (pound 

per hour)

702713 3668797 194.89 16.76 369 12.04 0.3048 0.0069

12 702713 3668794 194.87 16.76 369 8.50 0.3048 0.0134

13 702713 3668792 194.85 15.85 391 13.17 0.3048 0.0015

14 702721 3668793 194.95 16.76 328 27.96 0.5334 0.0061

15 702725 3668808 195.17 16.76 350 14.17 0.3810 0.0031

16 702718 3668803 195 17.37 369 13.47 0.2530 0.0030

17 702729 3668780 194.88 16.76 355 14.02 0.3810 0.0058

18 702628 3668768 193.7 30.63 313 4.98 1.6154 0.0400

21 702627 3668739 193.59 31.24 311 18.08 1.5210 0.0600

22 702686 3668804 194.63 22.86 304 15.05 0.8108 0.0200

23 702637 3668765 193.77 7.70 351 14.19 0.1778 0.0004

24 702722 3668783 194.85 16.46 369 11.49 0.3810 0.0010

25 702722 3668778 194.8 16.46 358 9.45 0.3810 0.0015

26 702736 3668783 194.97 9.14 355 11.58 0.1524 0.0015

37 702683 3668810 194.63 22.86 309 19.15 1.6764 0.0500

38 702620 3668772 193.65 50.29 315 15.94 1.3716 0.0952

39 702546 3668731 193.17 19.10 0* 45.00 0.4877 0.0530

45 702623 3668714 193.5 32.16 303 12.92 1.8044 0.0700

48 702585 3668771 193.38 15.77 0* 12.28 1.0097 0.0025

*Denotes ambient temperature
3-9

Table 3-4: Base Case Area Source Parameters

Source 

ID

Easting

(meters)

Northing 

(meters)

Elevation 

(meters)

Height 

(meters)

East - West 

Length 

(meters)

North - South 

Length 

(meters)

Rotation 

Angle

10

Emission 

Rate 

(pounds per 

hour)

702643 3668771 193.87 4.57 28.956 24.384 -2 0.0800

27 702734 3668768 194.80 4.57 0.914 0.914 0 0.0010

28 702756 3668782 195.40 4.57 0.914 0.914 0 0.0010

35 702654 3668740 193.79 4.57 22.860 30.480 -2 0.0000

36 702646 3668755 193.80 4.57 32.004 15.240 -2 0.0100

41 702518 3668769 193.03 1.00 94.488 21.336 40 0.0388

42 702625 3668693 193.42 0.30 80.772 44.196 -2 0.0000

43 702703 3668745 194.26 0.30 62.484 39.624 -2 0.0000

44 702591 3668760 193.42 3.99 24.384 41.148 -2 0.0300

52 702632 3668766 193.72 4.57 21.336 16.764 -2 0.0100

53 702616 3668762 193.58 1.83 16.764 19.812 -2 0.1300

999 702555 3668760 193.21 1.00 40 40 -2 0.0380
3-10

3.3.3 Base Case Modeling Results

Table 3-5: Base Case Source Contribution at Location of Maximum Predicted Concentration

lists the contributions of each source at the location of the maximum rolling three-month 

predicted concentration in microgram per cubic meter (μg/m3). These results suggest which 

sources require controls and to what extent in order for the Exide Frisco Site to operate in 

compliance with the 2008 lead NAAQS. The sources with the highest contributions are 10, 41, 

44, 53, and 999. The contribution of these five sources at the location of the maximum predicted 

concentration is 1.2922 μg/m3. The contribution from all other sources is 0.1493 μg/m3

The post-processor LeadPost reports results were rounded to three decimal places. In order to 

display the rolling three-month concentrations to five decimal places, output files from 

AERMOD using the MAXIFILE option for monthly averages with a reporting threshold of 

0.00001 μg/m

.

3 were generated. The three-month rolling averages to five decimal places were 

calculated from the monthly averages reported by the MAXIFILE output.
3-11

Table 3-5: Base Case Source Contribution at Location of Maximum Predicted 

Concentration

Source ID

Source Contribution 

(μg/m3)

10

Source Contribution 

Percent of Maximum

0.19758 13.71%

11 0.00375 0.26%

12 0.00789 0.55%

13 0.00084 0.06%

14 0.00219 0.15%

15 0.00141 0.10%

16 0.00157 0.11%

17 0.00274 0.19%

18 0.00878 0.61%

21 0.00794 0.55%

22 0.00616 0.43%

23 0.00039 0.03%

24 0.00052 0.04%

25 0.00081 0.06%

26 0.00126 0.09%

27 0.00178 0.12%

28 0.00163 0.11%

36 0.02303 1.60%

37 0.00781 0.54%

38 0.00517 0.36%

39 0.02714 1.88%

41 0.08894 6.17%

44 0.07487 5.19%

45 0.01068 0.74%

48 0.00165 0.11%

52 0.02412 1.67%

53 0.32835 22.78%

999 0.60249 41.80%

ALL 1.44149 100.00%

3.4 FUTURE CASE ANALYSIS

The future case modeling analysis evaluated the proposed emission controls that demonstrate 

attainment of the 2008 lead NAAQS in the current lead nonattainment area surrounding the 

Exide site. The emission controls represented in the future case analysis are:
3-12

• fully enclose under negative pressure of the battery breaker operation and raw material 

storage area (sources 44 and 999). This change will eliminate fugitive emissions from these 

areas. The collected emissions will be routed to a new baghouse (source 10A and 35A);

• fully enclose under negative pressure of the blast furnace and reverberatory furnace areas

(sources 10 and 35). This change will eliminate fugitive emissions from these areas. The 

collected emissions from the blast furnace area will be routed to a new baghouse (source 

10A). The collected emissions from the reverberatory furnace area will be routed to a new 

baghouse (source 35A). In addition, the emissions generated in the reverberatory furnace 

area will be reduced by replacing the hydraulic ram loader with a rotary screw;

• fully enclose, under negative pressure, the slag handling area, material handling area, and 

refining/casting area (sources 52, 53, and 36). This change will eliminate the fugitive 

emissions from these areas. The collected emissions from the slag handling and material 

handling areas will be routed to a new baghouse (source 10A). The collected emissions from 

the refining/casting area will be routed to a new baghouse (source 35A);

• relocate the slag treatment building and replacement of the existing slag fixation baghouse 

(source 39) with a new baghouse. The new baghouse will be fitted with 

polytetrafluoroethylene (PTFE) membrane media and improved setting design. This change

will reduce emissions due to improved emissions collection; and 

• reroute the truck traffic (sources 41, 42, and 43). This change will reduce emissions from 

truck traffic due to the route not going through the process areas. The emissions from the 

new route (source ROAD) will replace emissions from sources 41, 42, and 43.

Additional emission control measures not taken into consideration for the future case analysis 

are:

• replacement of bag media, with polytetrafluoroethylene (PTFE) membrane media, in

sources 18, 22, 23, and 37. This change would reduce emissions from these sources due to 

improved collection of particulate matter; 

• replacement of tube sheeting in sources 18, 21, 22, 23, 37, and 39. This change would reduce 

emissions from these sources due improved collection of particulate matter; and

• installation of secondary high efficiency particulate air (HEPA) filtration on all baghouses 

that receive lead emissions (sources 11 through 18, 21 through26, 37, and 39) except for the 

reverbatory and blast furnace baghouse (source 38).

The reduction in emissions due to the tube sheeting and new baghouse media has not been 

quantified due to engineering design specifications not being available. Though a reduction in 

emissions is expected, no reduction in emissions has been attributed to these emission control 

measures.

3.4.1 Future Case Emissions Inventory

For the future case, all baghouse stacks associated with the soft lead and hard lead production 

(sources 18, 21, 22, 23, 37, 38, 39, 45, and 48) were represented exactly as they were for the base 

case with the exception of the emission rates. The emission rates modeled were based on stack 

tests data, the production rate at the time of the stack tests, and the maximum permitted daily 

production of 400 tons of finished lead product. Details of the stack test are contained in Table 

3-6: Stack Test Details from Baghouses Covered Under Permit 1147A.
3-13

Table 3-6: Stack Test Details from Baghouses Covered Under Exide Permit 1147A

Source 

ID

Modeled 

Rate 

(pound 

per hour)

Stack 

Test Date

Production 

(tons per day)

Corrected 

Max. Rate 

(pound per 

hour)

Avg. Test 

Rate (pound 

per hour)

Test Rate 

(pound per 

hour)

18 0.0275 2003 226 0.0160 0.0090 0.0116

18 0.0275 2003 226 0.0160 0.0090 0.0113

18 0.0275 2003 226 0.0160 0.0090 0.0042

18 0.0275 2005 221 0.0198 0.0110 0.0118

18 0.0275 2005 221 0.0198 0.0110 0.0105

18 0.0275 2005 221 0.0198 0.0110 0.0106

18 0.0275 2007 221 0.0225 0.0124 0.0070

18 0.0275 2007 221 0.0225 0.0124 0.0115

18 0.0275 2007 221 0.0124 0.0188

18 0.0275 2009 230 0.0519 0.0298 0.0435

18 0.0275 2009 230 0.0519 0.0298 0.0256

18 0.0275 2009 230 0.0519 0.0298 0.0203

21 0.1743 2003 235 0.7730 0.4542 0.3800

21 0.1743 2003 235 0.7730 0.4542 0.4875

21 0.1743 2003 235 0.7730 0.4542 0.4950

21 0.1743 2005 216 0.0340 0.0184 0.0141

21 0.1743 2005 216 0.0340 0.0184 0.0147

21 0.1743 2005 216 0.0340 0.0184 0.0263

21 0.1743 2007 216 0.4074 0.2200 0.2100

21 0.1743 2007 216 0.4074 0.2200 0.2300

21 0.1743 2009 235 0.0815 0.0479 0.0359

21 0.1743 2009 235 0.0815 0.0479 0.0566

21 0.1743 2009 235 0.0815 0.0479 0.0511

22 0.0086 2003 220 0.0101 0.0056 0.0062

22 0.0086 2003 220 0.0101 0.0056 0.0047

22 0.0086 2003 220 0.0101 0.0056 0.0058

22 0.0086 2005 226 0.0062 0.0035 0.0039

22 0.0086 2005 226 0.0062 0.0035 0.0037

22 0.0086 2005 226 0.0062 0.0035 0.0029

22 0.0086 2007 226 0.0077 0.0043 0.0040

22 0.0086 2007 226 0.0077 0.0043 0.0050

22 0.0086 2007 226 0.0077 0.0043 0.0040

22 0.0086 2009 236 0.0105 0.0062 0.0161

22 0.0086 2009 236 0.0105 0.0062 0.0020

22 0.0086 2009 236 0.0105 0.0062 0.0004
3-14

Source 

ID

Modeled 

Rate 

(pound 

per hour)

Stack 

Test Date

Production 

(tons per day)

Corrected 

Max. Rate 

(pound per 

hour)

Avg. Test 

Rate (pound 

per hour)

Test Rate 

(pound per 

hour)

37 0.0450 2003 235 0.0323 0.0190 0.0199

37 0.0450 2003 235 0.0323 0.0190 0.0169

37 0.0450 2003 235 0.0323 0.0190 0.0202

37 0.0450 2005 221 0.0594 0.0328 0.0234

37 0.0450 2005 221 0.0594 0.0328 0.0370

37 0.0450 2005 221 0.0594 0.0328 0.0380

37 0.0450 2007 221 0.0761 0.0421 0.0541

37 0.0450 2007 221 0.0761 0.0421 0.0350

37 0.0450 2007 221 0.0761 0.0421 0.0372

37 0.0450 2009 236 0.0122 0.0072 0.0098

37 0.0450 2009 236 0.0122 0.0072 0.0026

37 0.0450 2009 236 0.0122 0.0072 0.0093

38 0.1005 2003 230* 0.1658 0.0953 0.0920

38 0.1005 2003 230* 0.1658 0.0953 0.0820

38 0.1005 2003 230* 0.1658 0.0953 0.1120

38 0.1005 2005 230* 0.0151 0.0087 0.0030

38 0.1005 2005 230* 0.0151 0.0087 0.0030

38 0.1005 2005 230* 0.0151 0.0087 0.0200

38 0.1005 2007 243 0.1500 0.0911 0.0695

38 0.1005 2007 243 0.1500 0.0911 0.0455

38 0.1005 2007 243 0.1500 0.0911 0.1584

38 0.1005 2009 223 0.0712 0.0397 0.0338

38 0.1005 2009 223 0.0712 0.0397 0.0210

38 0.1005 2009 223 0.0712 0.0397 0.0642

45 0.0688 2003 220 0.0944 0.0519 0.0523

45 0.0688 2003 220 0.0944 0.0519 0.0536

45 0.0688 2003 220 0.0944 0.0519 0.0498

45 0.0688 2005 223 0.0676 0.0377 0.0473

45 0.0688 2005 223 0.0676 0.0377 0.0353

45 0.0688 2005 223 0.0676 0.0377 0.0305

45 0.0688 2007 223 0.0533 0.0297 0.0357

45 0.0688 2007 223 0.0533 0.0297 0.0331

45 0.0688 2007 223 0.0533 0.0297 0.0203

45 0.0688 2009 347 0.0599 0.0519 0.0459

45 0.0688 2009 347 0.0599 0.0519 0.0379

45 0.0688 2009 347 0.0599 0.0519 0.0720
3-15

Source 

ID

Modeled 

Rate 

(pound 

per hour)

Stack 

Test Date

Production 

(tons per day)

Corrected 

Max. Rate 

(pound per 

hour)

Avg. Test 

Rate (pound 

per hour)

Test Rate 

(pound per 

hour)

23 0.0006 2003 226 0.0006 0.0004 0.0004

23 0.0006 2003 226 0.0006 0.0004 0.0003

23 0.0006 2003 226 0.0006 0.0004 0.0004

39 0.0513 2010 230* 0.0513 0.0295 0.0155

39 0.0513 2010 230* 0.0513 0.0295 0.0515

39 0.0513 2010 230* 0.0513 0.0295 0.0216

48 0.0037 2010 230* 0.0037 0.0021 0.0025

48 0.0037 2010 230* 0.0037 0.0021 0.0025

48 0.0037 2010 230* 0.0037 0.0021 0.0013

* Default value due to daily production value not being available

Stack test data from 2003, 2005, 2007, 2009, and 2010 were considered for sources 18, 21, 22, 

23, 37, 38, 39, 45, and 48. The average emission rate for each stack test and the associated daily 

production on the date of the stack test were used to calculate a maximum 24-hour emission 

rate. The average emission rate was multiplied by the maximum permitted daily production 

divided by actual daily production on the date of the stack test. For example, if the average 

emission rate for the stack test was 1.0 lb/hr and the daily production on the day of the stack test 

was 200 tons, then the value 2.0 lb/hr = (1.0 lb/hr) × (400 tons/200 tons) was used. The 

emission rate modeled for a source was the average rate for all stack tests. 

Production data were not available for all stack tests. A default value of 230 tons was used for all 

days when the daily production value was not available. The average daily production for days 

during stack tests was 232 tons, therefore 230 tons is a reasonable value. 

For source 21, stack tests from 2005, 2007, and 2009 were considered. The data from the 2003 

stack tests were not considered as the calculated rates were over a 10 times higher than any 

other test. Since the 2003 values are so much higher than other tests, they are judged to be 

anomalies and not indicative of normal operations.

All baghouse stacks associated with the lead oxide reactors (sources 11, 12, 13, 16, 24, and 25) 

were represented exactly as they were for the base case with the exception of the emission rates. 

The emission rates modeled were based the stack tests for that source and the maximum 

permitted hourly production of 2,300 lb/hr of lead oxide. Details of the stack test are contained 

in Table 3-7: Stack Test Details from Baghouses Covered Under Exide Permit 3048A.
3-16

Table 3-7: Stack Test Details from Baghouses Covered Under Exide Permit 3048A

Source 

ID

Modeled 

Rate 

(lb/hr)

Stack 

Test Date

Production 

(lb/hr)

Corrected 

Max. Rate 

(lb/hr)

Avg. Test 

Rate (lb/hr)

Test Rate 

(lb/hr)

14 0.0055 1995 No Data 

Available 0.0055 0.0055 0.0061

14 0.0055 1995 No Data 

Available 0.0055 0.0055 0.0055

14 0.0055 1995 No Data 

Available 0.0055 0.0055 0.0050

26 0.0004 1994 No Data 

Available 0.0004 0.0004 0.0004

26 0.0004 1994 No Data 

Available 0.0004 0.0004 0.0006

26 0.0004 1994 No Data 

Available 0.0004 0.0004 0.0003

13 0.0012 1994 2232 0.0014 0.0014 0.0015

13 0.0012 1994 2232 0.0014 0.0014 0.0013

13 0.0012 1994 2232 0.0014 0.0014 0.0014

13 0.0012 1995 2232* 0.0010 0.0010 0.0010

13 0.0012 1995 2232* 0.0010 0.0010 0.0010

13 0.0012 1995 2232* 0.0010 0.0010 0.0009

12 0.0043 1994 2227 0.0018 0.0017 0.0029

12 0.0043 1994 2227 0.0018 0.0017 0.0012

12 0.0043 1994 2227 0.0018 0.0017 0.0011

12 0.0043 1995 2227* 0.0068 0.0066 0.0134

12 0.0043 1995 2227* 0.0068 0.0066 0.0026

12 0.0043 1995 2227* 0.0068 0.0066 0.0037

11 0.0021 1994 2173 0.0008 0.0007 0.0005

11 0.0021 1994 2173 0.0008 0.0007 0.0006

11 0.0021 1994 2173 0.0008 0.0007 0.0011

11 0.0021 1995 2173* 0.0034 0.0032 0.0069

11 0.0021 1995 2173* 0.0034 0.0032 0.0015

11 0.0021 1995 2173* 0.0034 0.0032 0.0011

16 0.0014 1994 2227 0.0012 0.0012 0.0008

16 0.0014 1994 2227 0.0012 0.0012 0.0015

16 0.0014 1994 2227 0.0012 0.0012 0.0012

16 0.0014 1995 2227* 0.0017 0.0016 0.0030

16 0.0014 1995 2227* 0.0017 0.0016 0.0008

16 0.0014 1995 2227* 0.0017 0.0016 0.0010
3-17

Source 

ID

Modeled 

Rate 

(lb/hr)

Stack 

Test Date

Production 

(lb/hr)

Corrected 

Max. Rate 

(lb/hr)

Avg. Test 

Rate (lb/hr)

Test Rate 

(lb/hr)

24 0.0017 1994 2214 0.0005 0.0005 0.0003

24 0.0017 1994 2214 0.0005 0.0005 0.0005

24 0.0017 1994 2214 0.0005 0.0005 0.0006

24 0.0017 1995 2214* 0.0030 0.0029 0.0070

24 0.0017 1995 2214* 0.0030 0.0029 0.0006

24 0.0017 1995 2214* 0.0030 0.0029 0.0010

25 0.0010 1994 2192 0.0014 0.0013 0.0015

25 0.0010 1994 2192 0.0014 0.0013 0.0012

25 0.0010 1994 2192 0.0014 0.0013 0.0013

25 0.0010 1995 2192* 0.0007 0.0007 0.0009

25 0.0010 1995 2192* 0.0007 0.0007 0.0005

25 0.0010 1995 2192* 0.0007 0.0007 0.0006

17 0.0017 1994 6639 0.0030 0.0029 0.0058

17 0.0017 1994 6639 0.0030 0.0029 0.0023

17 0.0017 1994 6639 0.0030 0.0029 0.0005

17 0.0017 1995 6639* 0.0005 0.0005 0.0005

17 0.0017 1995 6639* 0.0005 0.0005 0.0007

17 0.0017 1995 6639* 0.0005 0.0005 0.0003

15 0.0025 1994 6460 0.0023 0.0022 0.0015

15 0.0025 1994 6460 0.0023 0.0022 0.0029

15 0.0025 1994 6460 0.0023 0.0022 0.0021

15 0.0025 1995 6460* 0.0027 0.0025 0.0028

15 0.0025 1995 6460* 0.0027 0.0025 0.0031

15 0.0025 1995 6460* 0.0027 0.0025 0.0017

* Default value due to daily production value not being available

The remaining baghouses associated with lead oxide production (sources 14, 15, 17, and 26) 

were represented exactly as they were for the base case with the exception of the emission rates. 

The emission rates modeled were based the stack tests for that source and the maximum 

permitted hourly production of 6,900 pound per hour of lead oxide.

The maximum hourly rates are used for the lead oxide sources rather than a 24-hour rate 

because there are only hourly and annual production limits in the existing permit 3048A.

Stack test data from 1994 and 1995 were considered for sources 11, 12, 13, 14, 15, 16, 17, 24, 25, 

and 26. The 1994 and 1995 data were the only data available. The average emission rate for each 

stack test and the associated hourly production on the date of the stack test were used to 

calculate a maximum hourly emission rate. The average emission rate was multiplied by the 

maximum permitted hourly production divided by actual hourly production during the stack 

test. For example, if the average emission rate for the stack test was 1.0 lb/hr and the hourly 

production during the stack test was 1,000 lb/hr, then the value 2.3 lb/hr = (1.0 lb/hr) × (2,300 
3-18

lb/1,000 lb) was used. The emission rate modeled for a source was the average rate for all stack 

tests for that source. 

Production data were not available for the 1995 stack tests. The production values for the 1994 

stack test were assumed to be typical and were used with the 1995 stack test data.

Emissions from the sources 27, 28, and ROAD (vehicle traffic), are all fugitive in nature and 

were characterized as area sources. The dimensions of the sources are representative of the 

areas were the emissions are generated. The height of release for sources 27 and 28 is based on 

the height where the emissions escape a structure. The release height for source ROAD was set 

to 1 meter, which is a reasonable release height for road generated emissions. 

The emission rate used for source 27 was based on a maximum hourly loading rate of 12 tons per 

hour (tons/hr) of lead oxide. The emission rate used for sources 28 was based on a maximum 

hourly loading rate of 24 tons/hr of lead oxide. The emission rate used for source ROAD was 

based on the anticipated number of vehicles.

3.4.2 Background Sources

The largest nearby source of lead emissions is approximately 50 km from the Exide site with 

annual reported emissions approximately 10% of the annual emissions reported by Exide. Due 

to the distance from the Exide site and the small reported emissions, no other sources of lead 

emissions would have a significant contribution near the Exide site or the modeling domain 

used for this analysis.

3.4.3 Source Input Parameters

Table 3-6: Future Case Point Parameters contains input parameters for all point sources 

modeled for the future case. Table 3-7: Future Case Area Source Parameters, Table 3-8: Future 

Case AreaPoly Source Parameters, and Table 3-9: Vertices of AreaPoly Source ROAD all 

contain input parameters for all area sources modeled for the future case. The total annual lead 

emissions represented is 2.39 tons and is based on a representative worst case 24-hour period.

The modeling assumes that emission rates are continuous 24 hours a day, 365 days a year. In 

reality, the process rate varies from day to day.
3-19

Table 3-8: Future Case Point Parameters

Source ID Easting 

(meters)

Northing 

(meters)

Elevation 

(meters)

Height

(meters)

Temp 

(Kelvin)

Velocity 

(meters 

per 

second)

Diameter 

(meters)

Emission Rate 

(pound per 

hour)

11 702713 3668797 194.89 16.76 369 12.04 0.3048 0.0021

12 702713 3668794 194.87 16.76 369 8.50 0.3048 0.0043

13 702713 3668792 194.85 15.85 391 13.17 0.3048 0.0012

14 702721 3668793 194.95 16.76 328 27.96 0.5334 0.0055

15 702725 3668808 195.17 16.76 350 14.17 0.3810 0.0025

16 702718 3668803 195.00 17.37 369 13.47 0.2530 0.0014

17 702729 3668780 194.88 16.76 355 14.02 0.3810 0.0017

18 702628 3668768 193.70 30.63 313 4.98 1.6154 0.0275

21 702627 3668739 193.59 31.24 311 18.08 1.5210 0.1743

22 702686 3668804 194.63 22.86 304 15.05 0.8108 0.0086

23 702637 3668765 193.77 7.70 351 14.19 0.1778 0.0006

24 702722 3668783 194.85 16.46 369 11.49 0.3810 0.0017

25 702722 3668778 194.80 16.46 358 9.45 0.3810 0.0010

26 702736 3668783 194.97 9.14 355 11.58 0.1524 0.0004

37 702683 3668810 194.63 22.86 309 19.15 1.6764 0.0450

38 702620 3668772 193.65 50.29 315 15.94 1.3716 0.1005

39 702659 3668833 194.34 30.48 0* 21.560 0.9144 0.0513

45 702623 3668714 193.50 32.16 303 12.92 1.8044 0.0688

48 702585 3668771 193.38 15.77 0* 12.28 1.0097 0.0037

10A 702636 3668804 193.96 30.48 0* 16.82 1.5240 0.0103

35A 702683 3668739 194.00 30.48 0* 19.80 2.1336 0.0238

48A 702618 3668794 193.70 15.77 0* 12.28 1.5240 0.0047

* Denotes ambient temperature
3-20

Table 3-9: Future Case Area Source Parameters

Source ID Easting 

(meters)

Northing 

(meters)

Elevation 

(meters)

Height 

(meters)

East - West 

Length 

(meters)

North - South 

Length 

(meters)

Rotation 

Angle

Emission 

Rate 

(lb/hr)

27 702734 3668768 194.80 4.57 0.914 0.914 0 0.0006

28 702756 3668782 195.40 4.57 0.914 0.914 0 0.0013

Table 3-10: Future Case AreaPoly Source Parameters

Source 

ID

Easting 

(meters)

Northing 

(meters)

Elevation 

(meters)

Height 

(meters) Vertices Emission Rate (lb/hr)

ROAD 702532 3668809 193.02 1.00 9 0.0017
3-21

Table 3-11: Vertices of AreaPoly Source ROAD

Vertex Easting 

(meters)

Northing 

(meters)

1 702532 3668809

2 702807 3668880

3 702811 3668755

4 702867 3668755

5 702865 3668778

6 702830 3668776

7 702825 3668904

8 702527 3668833

9 702532 3668812

3.4.4 Future Case Modeling Results

The maximum predicted three-month rolling concentration for the future case was 0.147 μg/m3

(0.14739 μg/m3). The post-processor LeadPost reports results were rounded to three decimal 

places. In order to display the three-month rolling concentrations to five decimal places, output 

files from AERMOD using the MAXIFILE option for monthly averages with a reporting 

threshold of 0.00001 μg/m3

Since the maximum predicted three-month rolling concentration is less than 0.15 μg/m

were generated. The three-month rolling averages to five decimal 

places were calculated from the monthly averages reported by the MAXIFILE output.

3

Table 3-10: 

, 

attainment of the 2008 lead NAAQS is expected, based upon implementation of proposed

emission controls.

Future Case Source Contribution at Location of Maximum Predicted Concentration

Table 3-12: Future Case Source Contribution at Location of Maximum Predicted 

Concentration

lists the contributions of each source at the location of the maximum rolling 3-month predicted

concentration.

Source

ID

Source Contribution 

(μg/m3)

10A

Source Contribution 

Percent of Maximum

0.00378 2.56%

11 0.00139 0.94%

12 0.00294 1.99%

13 0.00080 0.54%

14 0.00282 1.91%

15 0.00150 1.02%

16 0.00090 0.61%

17 0.00098 0.67%

18 0.00957 6.49%

21 0.04009 27.20%

22 0.00413 2.80%
3-22

Source

ID

Source Contribution 

(μg/m3)

23

Source Contribution 

Percent of Maximum

0.00052 0.35%

24 0.00105 0.71%

25 0.00062 0.42%

26 0.00032 0.22%

27 0.00059 0.40%

28 0.00134 0.91%

35A 0.00712 4.83%

37 0.01424 9.66%

38 0.00891 6.04%

39 0.01902 12.91%

45 0.01843 12.50%

48 0.00255 1.73%

48A 0.00157 1.07%

ROAD 0.00221 1.50%

ALL 0.14739 100.00%

3.5 REFERENCES

1. “ADEC Guidance re AERMET Geometric Means, How to Calculate the Geometric Mean 

Bowen Ratio and the Inverse-Distance Weighted Geometric Mean Surface Roughness 

Length in Alaska,” Alaska Department of Environmental Conservation, Revised June 17, 

2009.

2. “AERSURFACE User’s Guide”, EPA-454/B-08-001, United States Environmental Protection 

Agency, Office of Air Quality Planning and Standards, Air Quality Assessment Division, Air 

Quality Modeling Group, Research Triangle Park, North Carolina, January 2008.

3. “NLCD 1992/2001 Retrofit Land Cover Change Product”, website 

http://www.mrlc.gov/multizone.php, U.S. Department of the Interior, U.S. Geological 

Survey, February 25, 2008.
4-1

CHAPTER 4: CONTROL STRATEGY AND REQUIRED ELEMENTS

4.1 INTRODUCTION

The Collin County nonattainment area for the 2008 lead National Ambient Air Quality Standard 

(NAAQS) consists of a 1.28 square mile area surrounding the Exide Technologies, Inc. (Exide) 

lead-acid battery recycling operations in Frisco, Texas. Exide is the sole contributor to ambient 

air lead emissions in the area. In addition to permits 1147A and 3048A held by Exide for the 

secondary lead smelting and lead oxide operations at the lead-acid battery recycling facility, the 

Texas Commission on Environmental Quality (TCEQ) has made control measures and 

contingency measures enforceable through agreed orders adopted as part of the 1993 Lead state 

implementation plan (SIP) for Collin County, the 1999 Collin County Redesignation and 

Maintenance Plan for Lead, and the 2009 Collin County Maintenance Plan for Lead.

As part of this proposed SIP revision, the TCEQ is pursuing Agreed Order 2011-0521-MIS as a 

means to establish enforceable control measures and operational work practices to reduce lead 

emissions from point and fugitive lead-dust sources in support of achieving attainment of the 

2008 lead NAAQS by the December 31, 2015, compliance date.

In support of the agreed order and SIP revision, the TCEQ commissioned third-party contractor 

Eastern Research Group, Inc. (ERG) to perform a comprehensive evaluation of air quality 

control technologies for lead-acid battery recycling operations with secondary lead smelters and 

lead oxide facilities. On April 25, 2011, ERG submitted their report, Comprehensive Evaluation 

of Air Quality Control Technologies used for Lead-Acid Battery Recycling

(http://www.tceq.texas.gov/airquality/sip/stakeholders/pb_stakeholder). The report evaluated 

available control measures and work practices for the reduction of lead emissions from point 

sources and fugitive lead-dust emissions and identified control measure recommendations 

specific to the sources of lead emissions at the Exide facilities. The TCEQ has analyzed the 

recommended control technologies and measures in the report and is proposing as part of 

Agreed Order 2011-0521-MIS those measures that were found to advance attainment as soon as 

practicable and meet the criteria of reasonably available control technology (RACT) and

reasonably available control measures (RACM). For further information regarding individual 

control measures please see Appendix D: 

This chapter describes existing lead emission control measures in place at Exide, control 

measures implemented as part of the agreed order associated with this proposed SIP revision, as 

well as how Texas is proposing to meet lead nonattainment area SIP requirements of RACT, 

RACM, and contingency measures.

Reasonably Available Control Technology and 

Reasonably Available Control Measure Analysis. 

4.2 EXISTING CONTROL MEASURES

30 Texas Administrative Code (TAC) Chapter 113 previously incorporated the existing federal 

regulations for control of hazardous air pollutants (HAP) from lead smelting facilities that 

include the National Emission Standards for Hazardous Air Pollutants (NESHAP) for secondary 

lead smelting (40 Code of Federal regulations [CFR] Part 63, Subpart X). The United States 

Environmental Protection Agency (EPA) published a proposed revision to NESHAP for 

secondary lead smelting in the May 19, 2011 Federal Register (76 FR 29032). In addition, Texas 

has maintained enforceable controls measures for Exide through a series of agreed orders for 

the facility. Prior to being operated by Exide, the secondary lead smelter and battery recycling 

facility in Frisco, Texas, was operated by Gould National Battery, Inc., and by GNB 

Technologies, Inc (GNB). In 1992, GNB entered into Agreed Board Order 92-09(k) with the 
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Texas Air Control Board (TACB), a predecessor agency to the TCEQ, and special provisions were 

included in amendments to Air Quality Permits R-1147A and R-5466D to assure maintenance of 

the 1978 lead NAAQS and to resolve notices of violations regarding exceedances of the 1978 lead 

NAAQS.

GNB subsequently amended Air Quality Permits 1147A and issued new permit 3048A to 

incorporate provisions in Agreed Board Order 92-09(k) (Order 92-09k) as permanent and 

enforceable control measures. The maximum allowable emission rate of lead in these permits 

ensured that lead emissions would not exceed 4.27 tons per year (tpy). In 1993, GNB entered 

into Agreed Board Order 93-12 (Order 93-12) with the TACB to establish contingency measures 

related to the 1993 Lead SIP for Collin County. 

As part of the 1999 Collin County Redesignation and Maintenance Plan for Lead, GNB entered 

into Agreed Order 99-0351-SIP, which terminated Orders 93-12 and 92-09(k); however, GNB 

agreed to continue implementation of these measures, or to implement additional measures or 

control technologies proposed by GNB that were judged by the TCEQ executive director to be 

similarly effective in controlling lead emissions from the plant. Exide acquired the GNB plant in 

Collin County in 2000.

The state maintained permanence of the earlier reductions through Agreed Order 2009-0071-

MIS, in which Exide agreed to abide by representations made by GNB to continue 

implementation of the requirements of paragraph eight in Order 92-09(k) as incorporated in 

permits 1147A and 3048A or to implement additional proposed measures or control 

technologies judged by the executive director to be similarly effective in controlling lead 

emissions from the plant.

In 2009, Exide entered into Agreed Order 2009-0071-MIS with the executive director as part of 

the second ten-year maintenance plan for the 1978 lead NAAQS. As part of that agreed order, 

Exide agreed to continue implementation of measures previously implemented. Exide also 

agreed to maintain records for the period of the second ten-year maintenance plan (2009 

through 2019) and make those records available upon request by the TCEQ or any other air 

pollution control agency with jurisdiction.

Below is a list of the existing control measures applicable to the Collin County lead 

nonattainment area under Agreed Order 2009-0071-MIS:

• addition of a supplemental ventilation baghouse to the reverberatory and blast furnace 

metallurgical operations area;

• installation of covers over blast furnace bins and water spray system over the bin area;

• installation of a baghouse and supporting ventilation and ducting at the raw materials 

storage building;

• installation of a feed dryer and baghouse at the reverberatory furnace charging area to 

reduce the possibility of reverberatory furnace explosions due to wet feed;

• development and implementation of a detailed site operation and maintenance plan for all 

site baghouse operations;

• installation of a Tri-bo Flow® System in all baghouse ducts to detect upset emissions;

• maintenance of compliance with all emission limits and standard operating procedures for 

process sources, process fugitive sources, and fugitive dust sources from the National 

Emissions Standards for Hazardous Air Pollutants from Secondary Lead Smelters under 40 

CFR Part 63 Subpart X;

• maintenance of records from the second (2009) maintenance plan sufficient to demonstrate 

compliance with control measures and requirements under the Agreed Orders;
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• restrictions on any increase in actual emissions above 4.27 tpy without qualification and 

approved amendments to permits 1147A and 3048A or through a the issuance of a new 

permit pursuant to 30 TAC Chapter 116, along with executive director approved dispersion 

modeling demonstrating that such an increase will not cause a violation of the lead NAAQS; 

and 

• continue to maintain all air pollution control and monitoring equipment in good working 

order and operate it properly during normal operation.

In addition to the above control measures, Agreed Order 2009-0071-MIS includes contingency 

measures to be implemented in the event that an exceedance of the 1978 lead NAAQS is 

measured at any TCEQ ambient air quality monitoring site in Collin County, or Exide reports an 

exceedance of 4.27 tpy in the annual emissions inventory and that exceedance of 4.27 tpy was 

not the result of a permitted increase in lead emissions. If at any time during the second 10-year 

maintenance period one of the above exceedances occurs, Exide will implement one of the 

following contingency measures within 180 days of notification by the executive director:

• automation of the scale and feed for the reverberatory furnace;

• installation of water misting dust suppression system beyond the system already required 

under permit 1147A; or

• an alternative measure proposed by Exide that results in emission reductions which, at a 

minimum, must be equivalent to the emissions reductions achievable by the above 

contingency measures and approved by the executive director.

4.3 RACT AND RACM ANALYSIS

As published in the November 12, 2008, issue of the Federal Register (73 FR 67035), states 

containing areas designated as nonattainment are required to submit a SIP revision 

demonstrating that the associated enforceable control measures fulfill the RACT and RACM 

requirements for sources of ambient lead concentrations. 

In the September 17, 1979, issue of the Federal Register (44 FR 53762) RACT is defined as the 

lowest emissions limitation that a particular source is capable of meeting by the application of 

control technology that is reasonably available considering technological and economic 

feasibility. Section 172(c)(1) of the Federal Clean Air Act (FCAA) requires states to provide for 

implementation of all RACM, including RACT, as expeditiously as practicable. In the General 

Preamble for implementation of the FCAA Amendments published in the April 16, 1992, issue of 

the Federal Register (57 FR 13498), the EPA explains that it interprets §172(c)(1) of the FCAA as 

a requirement that states incorporate into their SIP all RACM that would advance a region’s 

attainment date. However, regions are obligated to adopt only those measures that are 

reasonably available for implementation considering local circumstances. In the preamble for 

the lead NAAQS final rule (73 FR 67035, November 12, 2008) the EPA provided guidelines to 

help states determine which measures should be considered reasonably available:

If it can be shown that measures, considered both individually as well as in a group, 

are unreasonable because emissions from the affected sources are insignificant (i.e. de 

minimis), than the measures may be excluded from further consideration...the resulting 

control measures should then be evaluated for reasonableness, considering their 

technological feasibility and the cost of control in the area to which the SIP applies...In 

the case of public sector sources and control measures, this evaluation should consider 

the impact of the reasonableness of the measures on the municipal, or other 

governmental entity that must assume the responsibility for their implementation.
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The TCEQ used a two-step process to develop the list of potential control strategies evaluated 

during the RACT and RACM analyses. First, the TCEQ developed a draft list of potential control 

strategy concepts based on an evaluation of the existing point and fugitive sources of lead at 

Exide, the one contributing lead source in the Collin County lead nonattainment area. The draft 

list of potential control strategy concepts was presented to stakeholders for comment at a 

stakeholder meetings held in Frisco, Texas, on January 19, 2011. The TCEQ requested comment 

on the potential control strategies and invited stakeholders to suggest any additional strategies 

that might help advance attainment of the Collin County nonattainment area. The final list of 

potential control strategy concepts for the RACT and RACM analyses includes the strategies 

presented to stakeholders, the strategies suggested by stakeholders during the informal 

stakeholder comment process, and control measures proposed or implemented at similar 

secondary lead smelting facilities in other states. 

Each potential control measure identified through this control strategy development process 

was evaluated to determine if the measure would meet established criteria to be considered 

reasonably available. In addition to the criteria previously mentioned, the TCEQ also considered 

whether the potential control measure could be implemented prior to the November 1, 2012, 

date that Collin County must begin monitoring attainment in order to meet the December 31, 

2015, attainment date. As such, suggested control measures that could not be implemented by 

November 1, 2012, were not considered RACM because the measures would not advance 

attainment. However, Collin County must make progress toward attainment of the 2008 lead 

NAAQS as expeditiously as practicable. Therefore, if a control measure can be implemented 

earlier than November 1, 2012, and will help the area make progress toward attainment of the 

2008 lead NAAQS earlier than November 1, 2012, the measure should be implemented as early 

as feasible. 

The TCEQ also considered whether the control measure was similar or identical to control 

measures already in place at Exide. If the suggested control measure would not provide 

substantive and quantifiable benefit over the existing control measure, then the suggested 

control measure was not considered RACM because comparable reasonable controls were 

already in place. The control measures determined to be RACT or RACM would be made 

enforceable through the adoption by the commission of Agreed Order 2011-0521-MIS.

4.3.1 Results of RACT and RACM Analysis

For RACM analysis, all potential applicable control measures for lead source types relevant to 

the Collin County lead nonattainment area were evaluated to determine if these control 

measures could be considered RACT and RACM and that the current proposed control measures 

outlined in this SIP revision fulfill the EPA RACT and RACM requirements (73 FR 67036).

In order to develop a comprehensive list of potential control strategies for the RACT and RACM 

analysis, the commission solicited comment and input from stakeholders, including an informal 

comment and discussion at a stakeholder meeting held in Frisco, Texas, on January 19, 2011. In 

addition, the commission evaluated existing and potential measures at the Exide facility in 

Frisco and analyzed control measures proposed or implemented at similar secondary lead 

smelting facilities in other states. This analysis included the evaluation of existing and proposed 

control measures at similar facilities such as the Exide Technologies facility in Vernon, 

California; the Quemetco, RSR facility in City of Industry, California; Gopher Resources in 

Eagan, Minnesota; Exide Technologies in Muncie, Indiana; and the Envirofocus facility in 

Tampa, Florida. The TCEQ also commissioned a study of Air Control Technologies for LeadAcid Battery Recycling by ERG and analyzed the control measures contained in the South Coast 
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Air Quality management District Rule 1420.1, Emissions Standard for Lead from Large LeadAcid Battery Recycling Facilities.

Please see Appendix D: Reasonably Available Control Technology and Reasonably Available 

Control Measure Analysis

4.3.1.1 

for a complete list of control measures and RACT and RACM 

determinations.

The TCEQ has determined that full enclosures with negative ventilation sufficient to ensure that 

area fugitive emissions are routed to a high efficiency control device, in most cases a

polytetrafluoroethylene (PTFE) membrane baghouse, is RACM and RACT for secondary lead 

smelting operations, including battery breaking operations, blast and reverberatory furnaces, 

refining and casting operations, slag treatment and fixation, and raw materials storage and 

handling areas. For some operations, high efficiency cartridge filters are used instead of high 

efficiency PTFE membrane baghouses. Due to equivalent control efficiencies, cartridge filters 

used in place of PTFE membrane baghouses are considered RACM (including RACT).

RACT and RACM Determination

The TCEQ has determined that operational work practices and housekeeping requirements that 

minimize fugitive lead-dust emissions to the ambient air, including traffic plans for materials 

loading and unloading, traffic plans that avoid areas with the potential to create fugitive leaddust, inspection and immediate removal of leaking lead-acid batteries upon delivery, and the 

cleaning of equipment that is contaminated with lead inside of a permanent total enclosure prior 

to moving such equipment to a maintenance building is RACM and RACT for lead-acid battery 

recycling operations with secondary lead smelting and lead oxide operations.

The TCEQ has determined that wet scrubbers for battery breaker operations stacks and 

metallurgical scrubbers for furnace operations stacks with high efficiency PTFE membrane

baghouses is RACM and RACT.

The TCEQ has determined that partial enclosure with negative pressure hooding and ducting to 

high efficiency PTFE membrane baghouses of lead oxide operations areas is RACM and RACT. 

The small amount of fugitive lead-dust emissions associated with these operations justifies 

partial enclosures of lead oxide operational areas as a reasonable control measure.

The TCEQ has determined that wet electrostatic precipitation (WESP) is not RACM or RACT for 

lead-acid battery recycling operations with secondary lead smelting and lead oxide operations. 

WESP is not considered to be RACM or RACT due to its high cost and unproven performance 

with large particle sizes in the stack emissions of some secondary lead smelting operations. 

WESP has been installed at other facilities that include secondary lead smelting operations in 

the United States to comply with the AB2588 Toxics Hot Spots program, a unique regulatory 

requirement which specifically addresses cancer risk from arsenic and other heavy metal 

emissions. In that case, WESP may be a reasonable control technology and measure for facilities 

that operate electric arc furnaces (EAF) as part of the secondary lead smelting process. EAFs 

operate at much higher temperatures (2500-3000 degrees Fahrenheit) than the blast furnaces 

used at Exide in Frisco. This higher heat volatilizes compounds such as arsenic and other heavy

metals, while arsenic and other heavy metals (such as lead) are not volatilized in secondary lead 

smelting operations using blast and reverberatory furnaces. There is not sufficient information 

to substantiate that WESP is reasonable for secondary lead smelting facilities using blast and 

reverberatory furnaces at the additional cost of $17 to $25 million with the potential associated 

lead reduction efficiencies estimated at 85 to 95%. In addition, the time required to design and 

install a WESP system would not allow for the associated lead emission reductions to be 
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implemented before the date require for attainment of the NAAQS, disqualifying WESP as 

RACT and RACM.

Agreed Order 2011-0521-MIS, which is associated with this SIP revision, requires the 

installation of high efficiency particulate air (HEPA) filters where technologically feasible as 

secondary control measures in addition to the primary control measure of high efficiency PTFE 

baghouses. The TCEQ has determined that the combination of HEPA filters as secondary 

control measures in addition to high efficiency PTFE membrane baghouses is not RACT or 

RACM. The level of estimated reductions and cost per ton of reductions of lead emissions 

associated with the addition of HEPA filters as a secondary control measure is not reasonable 

when compared to the reduction of lead emissions from the primary control of high efficiency 

PTFE baghouses used alone. This requirement is included in Agreed Order 2011-0521-MIS as a 

voluntary control measures and is beyond RACT and RACM. 

The TCEQ has determined that full enclosure of lead oxide operations in conjunction with

negative ventilation sufficient to ensure that area fugitives are routed to a high efficiency control 

device is neither RACM nor RACT. The amount of fugitive lead-dust emissions associated with 

lead oxide operations is insignificant and not sufficient to justify the determination of this 

control measure as RACM or RACT.

The TCEQ has determined that partial enclosure of lead oxide operations areas in conjunction 

negative pressure hooding and ducting to high efficiency PTFE membrane baghouses is RACM 

and RACT. The small amount of fugitive lead-dust emissions associated with these operations 

justifies partial enclosures of lead oxide operational areas as a reasonable control measure.

The TCEQ has determined that the replacement of the hydraulic ram with a rotary screw feeder 

for the reverberatory furnace charging process is not RACM or RACT because it is not 

economically feasible given the minimal estimated emissions reductions. The level of reductions 

and cost per ton of reductions of fugitive lead-dust emissions associated with this control 

measure is not reasonable for all secondary lead smelters. In addition, any emissions associated 

with this source would be controlled through the furnace area enclosure. The measure was 

included in the Agreed Order as a voluntary control measure to advance and maintain 

attainment as expeditiously as practicable and is beyond RACT and RACM.

4.4 NEW CONTROL MEASURES

The new control measures needed for this proposed SIP revision to demonstrate attainment for 

the 2008 lead NAAQS in the Collin County nonattainment area would be made enforceable by

Agreed Order 2011-0521-MIS.

Agreed Order 2011-0521-MIS includes primary control measures and the associated 

implementation schedule as well as contingency measures to be triggered in the event of an 

exceedance “condition” (as defined in Agreed Order stipulation #10) of the 2008 lead NAAQS 

after November 1, 2012.

Primary control measures for attainment are included in the Agreed Order under order 

stipulations 15 through 27. Following is a list of primary control measures incorporated in the 

agreed order and their associated implementation dates.

• Relocate the slag treatment building to a location adjacent to the furnace and refining 

operations to reduce fugitive emissions. Replace the existing baghouse at the slag fixation 

operation stack (source 39) with a new baghouse fitted with PTFE membrane media and 
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improved seating design or an equivalent or superior design if approved by the executive 

director, to be accomplished as expeditiously as practicable but no later than March 31, 

2012. All baghouses must be maintained in good working order at all times.

• Fully enclose the battery breaker and covered raw materials storage area. This change will 

include the full enclosure of the battery breaker operations and contiguous covered raw 

materials storage area, the installation of negative pressure ventilation sufficient to ensure 

that the battery breaker and covered raw materials storage area fugitives are routed to the 

new baghouse, the installation of a new point source, and installation of a new baghouse 

with PTFE filter media and improved seating design bags, or an equivalent or superior 

design if approved by the executive director. The enclosure performance shall be consistent 

with the requirements of 40 CFR §§63.544(b) and 63.547(e) as of March 7, 2011. This 

measure is to be completed and operational as expeditiously as possible but no later than 

March 31, 2012.

• Fully enclose and place under negative pressure ventilation the blast and reverberatory 

furnace area, including the refining/casting area (sources 10, 35, 36, and 37) as expeditiously 

as possible, but no later than November 1, 2012. This change will include the full enclosure 

of the blast and reverberatory furnace area, including the refining/casting area, the 

installation of negative pressure ventilation sufficient to ensure that blast and reverberatory 

furnace area fugitives, along with the refining/casting area fugitives are routed to the new 

baghouse, the installation of a new point source, and installation of a new baghouse with 

PTFE filter media and improved seating design bags or an equivalent or superior design if 

approved by the TCEQ. The enclosure performance shall be consistent with the 

requirements of 40 CFR §§63.544(b) and 63.547(e) as of March 7, 2011. 

• Complete the retrofitting of baghouses (sources 18, 21, 22, 23, 37, 38). Exide will replace all 

bags in the identified baghouses with PTFE membrane media and replace all of the 

baghouse tube sheets with improved seating design as expeditiously as possible, but no later 

than April 30, 2011, or an equivalent or superior design if approved by the executive 

director. All baghouses must be maintained in good working order at all times.

• Operate under a traffic plan for trucks unloading batteries at the facility and for traffic to, 

from, and across the on-site landfill. Exide will relocate the spent battery loading docks to 

the north side of the battery breaker operation and reconfigure the traffic route such that the 

spent battery delivery trucks enter and leave along the north route and never enter the 

center of the facility. Traffic excluded from this plan includes chemical delivery trucks, plant 

service vehicles, and other scrap delivery vehicles. This measure is to be completed and 

operational as expeditiously as possible, but not later than March 31, 2012.

• Replace the existing seals on the blast furnace “doghouse” emissions capture and ventilation 

hooding system (source 10) as expeditiously as possible, but no later than April 30, 2011. 

• Replace the reverberatory furnace (source 35) hydraulic ram feeder with a rotary screw as 

expeditiously as possible but no later than April 30, 2011.

• Install a non-fouling area misting system in the blast and reverberatory furnace area 

(sources 10 and 35) as expeditiously as possible, but no later than July 31, 2011. This misting 

system will stay in place until the furnace area enclosure is completed and the negative 

ventilation is operational. 

• Fix and seal all holes and cracks greater than 15 square centimeters in surface area and at 

least 1.0 centimeter wide along the entire length of the opening in the existing secondary 

lead process and lead oxide operational area enclosures as expeditiously as possible but no 

later than March 31, 2012. Holes and cracks are defined as unintended openings in roofs and 

walls that occur due to corrosion or damage.

• Install secondary HEPA filtration at all of the baghouses that receive lead emissions (sources 

11 through 18, 21 through 26, and 37 through 39) as expeditiously as possible, but no later 

than November 31, 2012. All filters shall be HEPA filters rated by the manufacturer to 
4-8

achieve a minimum of 99.97% capture efficiency for 0.3 micron particles and larger. For the 

full enclosures with negative ventilation, at least once each shift with each event not less 

than four hours apart, negative pressure monitoring must be conducted according to 40 CFR 

§§63.544(b) and 63.547(e) as of March 7, 2011. 

• Notification to the TCEQ’s Chief Engineer’s Office prior to submitting an application for a 

permit amendment that would allow Exide to increase site-wide actual lead emissions above 

currently permitted levels in order to determine whether an amendment to Agreed Order 

2011-0521-MIS or issuance of a new agreed order with corresponding SIP revisions are 

needed.

• Continued maintenance of all air pollution abatement equipment to the level of good 

working order.

•

• Replace the existing roll-up doors in the raw material storage building, as expeditiously as 

possible but no later than November 1, 2012.

Upon receipt, any lead acid battery or palletized group of batteries that is cracked or leaking 

and is readily visible without removing shipping material, shall immediately be sent to the 

battery breaking area for processing or stored in a full enclosure kept under negative 

pressure with emissions routed to a control device.

• Process or mobile equipment that is contaminated with lead shall be initially cleaned inside 

of a permanent total enclosure prior to being moved to the maintenance building. This 

measure shall be implemented by March 31, 2012.

Contingency measures are included under Agreed Order 2011-0521-MIS stipulations 10(A) and 

10(B). In the event that on or after the three-month period beginning November 1, 2012, an 

exceedance of the 2008 lead NAAQS is monitored at any TCEQ-approved ambient monitor, 

Exide will be required to implement one or more of the following contingency measures as soon 

as is expeditiously practicable.

• Full enclosure of the lead oxide operational area and installation of negative pressure 

ventilation and either a baghouse or cartridge filter (sources 11 - 17, 24-26, 46, 56-58). This 

will include the full enclosure of the lead oxide operational area, the installation of negative 

pressure ventilation sufficient to ensure that lead oxide operational area fugitives are routed 

to the new baghouse, the installation of a new point source, and installation of a new 

baghouse with PTFE filter media and improved seating design bags (see Attachment A), or 

equivalent or superior design if approved by the TCEQ. The enclosure performance shall be 

consistent with the requirements of 40 CFR §63.544(b) and 63.547(e) as of March 7, 2011.

• Installation of vacuum hooding over lead oxide loading operations (currently Sources 27 and 

28).

• Designate that wheeled and powered plant equipment such as forklifts used inside a fully 

enclosed area will not be used outside of such an area.

4.5 MONITORING NETWORK

States are required by 40 CFR, Part 58, Subpart B, to submit an annual air monitoring network 

review (ANR) to the EPA by July 1 of each year. This network review is required to provide the 

framework for establishment and maintenance of an air quality surveillance system. The annual 

monitoring network review must be made available for public inspection and comment for at 

least 30 days prior to submission to the EPA. The review and any comments received during the 

30-day inspection period are then forwarded to the EPA for final review and approval. The 

TCEQ posted the 2010 plan for public comment from June 1 through June 30, 2010. The TCEQ 

then submitted the plan to the EPA on July 1, 2010, for review and approval. The ANR 

document presented the current Texas network of ambient air quality monitors in Texas for 
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which the TCEQ uploads data to the EPA’s Air Quality System (AQS), a national database of air 

quality data.

4.5.1 Lead Monitoring Sites in Frisco

From 1981 until mid-1999, the TCEQ monitored lead levels at a residential location on Hickory 

Street in Collin County, Texas (EPA AQS site identification code 480850001), approximately 

one-half mile northeast of the Exide plant. Monitoring site 480850007, located at 6931 Ash 

Street, replaced the Hickory Street site in mid-1999. Monitor 480850007 is a populationoriented site located in a neighborhood. Another site (480850009) was located on Exide 

property inside Exide’s security fence near the northern property line, and a third site

(480850003) was located on Exide property outside Exide’s security fence west of 5th Street. In 

July 2010, after meeting with the EPA to determine a location that EPA-Region 6 found 

acceptable for the maximum-concentration, source-oriented monitor required by the rule 

establishing the 2008 lead NAAQS, 480850009 was moved off Exide property and outside the 

company’s security fence so that it could be used to monitor ambient air. As defined in Title 40 

Code of Federal Regulations (CFR) Part 50.1, ambient air means that portion of the atmosphere, 

external to buildings, to which the general public has access. To meet EPA criteria for regulatory 

ambient air monitoring data, the following EPA criteria must be met:

• use federal reference method (FRM), federal equivalent method (FEM), or approved 

regional methods (ARM) (40 CFR Part 58, Appendix C);

• meet siting criteria (40 CFR Part 58, Appendix E);

• meet quality assurance (QA) requirements (40 CFR Part 58, Appendix A); and

• meet data certification criteria (40 CFR Part 58, Subpart B).

Monitoring site 480850009 is currently located approximately 15 feet north of its previous 

location on the exterior side of the Exide property fence line. In August 2010, site 480850003 

moved to the east side of 5th Street in Frisco, and is now located on City of Frisco property.

In addition to the monitors required by the EPA, the TCEQ installed a fourth lead monitor

(480850029) located south of the Exide plant at the Frisco Police Station on Stonebrook 

Parkway. Site 480850029 commenced operations in January of 2011.

Figure 4-1: Collin County Lead (Pb) Nonattainment Area shows ambient lead monitoring 

locations in the Collin County lead nonattainment area, Frisco, Texas.
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Figure 4-1: Collin County Lead (Pb) Nonattainment Area
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4.6 CONTINGENCY PLAN 

SIP revisions for nonattainment areas are required by §172(c)(9) of the FCAA to provide for 

specific measures to be implemented should a nonattainment area fail to meet reasonable 

further progress (RFP) requirements or maintain the 2008 lead NAAQS by the attainment date 

set by the EPA. The contingency plan must be enforceable and should identify measures to be 

adopted, a schedule and procedure for adoption and implementation, and a specific time 

constraint on action to be taken by the state. Additionally, the plan should identify specific 

indicators or triggers that will be used to determine when the contingency measures are to be 

implemented. The intent of the indicators and triggers is to allow the state and Exide to take 

early action to remedy an actual or potential violation of the 2008 lead NAAQS prior to the 

attainment date. 

The contingency measures are made enforceable in Agreed Order 2011-0521-MIS.

4.6.1 Contingency Measures

4.6.1.1 

• Full enclosure of the lead oxide operational area and installation of negative pressure 

ventilation, new point source, and filtration media (either a baghouse or cartridge filter) 

(sources 11 through 17, 24 through 26, 46, and 56 through 58). The enclosure performance 

shall be consistent with the requirements of 40 CFR §63.544(b) and 63.547(e) as of March 7, 

2011.

Contingency Measure Requirements 

• Installation of vacuum hooding over lead oxide loading operations (currently sources 27 and 

28).

• Designate that wheeled and powered plant equipment such as forklifts used inside a fully 

enclosed area will not be used outside of such an area.

4.6.1.2 

A contingency measure would be triggered upon failure to meet RFP requirements or failure to 

attain the 2008 lead NAAQS.

Contingency Trigger Levels
5-1

CHAPTER 5: REASONABLE FURTHER PROGRESS

5.1 GENERAL

Section 172(c)(2) the Federal Clean Air Act (FCAA) requires areas that have been designated 

nonattainment for criteria pollutants to include a demonstration of reasonable further progress 

(RFP) in attainment demonstrations. RFP is defined in FCAA §172(c)(2) as such annual 

incremental reductions in emissions of the relevant air pollution as are required by part D, or 

may reasonably be required by the United States Environmental Protection Agency for the 

purpose of ensuring attainment of the applicable National Ambient Air Quality Standard 

(NAAQS) by the applicable attainment date. 

The 2011 Collin County Attainment Demonstration State Implementation Plan (SIP) Revision 

for the 2008 Lead National Ambient Air Quality Standard proposal would fulfill RFP for the 

Collin County lead nonattainment area through an ambitious compliance schedule which yields 

consistent and periodic significant emission reductions. This demonstration includes a detailed 

schedule for compliance of reasonably available control measures (RACM) including reasonably 

available control technologies (RACT) in the nonattainment area. 

5.2 RFP DEMONSTRATION

As stated in the final lead rule (73 FR 67039), RFP is satisfied by the strict adherence to an 

ambitious compliance schedule which is expected to periodically yield significant emission 

reductions. The control measures for attainment of the 2008 lead NAAQS included in proposed 

Agreed Order 2011-0521-MIS (Appendix A) under stipulations 15 through 37, and listed under

4.4, New Control Measures section of this proposed SIP revision have been modeled to achieve 

attainment of the 2008 lead NAAQS as described in Chapter 3: Air Dispersion Modeling

5.3 RACM AND RACT

. The 

stipulations of Agreed Order 2011-0521-MIS require these control measures and resulting 

emissions reductions to be achieved as expeditiously as practicable, but no later than November 

1, 2012. 

The control measures for attainment of the 2008 lead NAAQS included in proposed Agreed 

Order 2011-0521-MIS under order stipulations numbers 15 through 27, listed under Chapter 4

Control Strategy and Required Elements section 4.4, New Control Measures, detailed under 

Chapter 4 Control Strategy and Required Elements section 4.3, RACT and RACM Analysis, and 

included in Appendix D: Reasonably Available Control Technology and Reasonably Available 

Control Measure Analysis of this proposed SIP revision are required to be implemented as soon 

as practicable but no later than November 1, 2012. 

The Texas Commission on Environmental Quality (TCEQ) has developed a detailed 

implementation schedule of the RACM (including RACT) control measures required in proposed 

Agreed Order 2011-0521-MIS. This schedule involves the expeditious implementation of all 

control measures to assure attainment of the 2008 lead NAAQS by November 1, 2012. For the 

associated changes in ambient lead concentrations and percent contribution to ambient lead 

levels in the Collin County lead nonattainment area, please see Appendix E: RACM (including 

RACT) Control Measure Implementation Schedule for Reasonable Further Progress.
Appendices Available Upon Request

Holly Brightwell

holly.brightwell@tceq.texas.gov

512.239.4905