Mr. Karl Brooks Regional Administrator U.S. EPA, Region VII 11201 Renner Boulevard Lenexa, KS 66219

Dear Mr. Brooks:

The Missouri Department of Natural Resources' Air Pollution Control Program (Air Program) hereby submits the following Missouri State Implementation Plan (SIP) revision for your approval:

2008 Lead (Pb) National Ambient Air Quality Standard (NAAQS) Compliance PlanExide Technologies-Canon Hollow Facility

Through this SIP submittal, the Air Program is requesting that EPA approve the consent judgment in order to strengthen the Missouri SIP to address violations of the 2008 Lead NAAQS

near the Exide Technologies-Canon Hollow facility in Holt County, MO.

The Missouri Air Conservation Commission adopted this plan at the September 25,2014 commission meeting. A public hearing for the proposed plan was held on August 28,2014. A 30-day public comment period opened by July 28, 2014 and closed on September 4,2014. During the public comment period, the Air Program received comments from three sources. All
comments were received as public hearing testimonies. A summary of the comments received and our responses are attached.

In order to comply with Attachment A of the "Regional Consistency for the Administrative Requirements of State Implementation Plan Submittals and the Use of 'Letter Notices'" memo dated April 6, 2011, a searchable pdf version of this document will be emailed to the EPA Regional Office. Within three business days, this complete submittal package will be posted on

our website at http://dnr.mo.gov/env/apcp/stateplans.htm.

Also, due to their size, paper copies of the appendices to the plan are not included in this package. The disk(s) included with this package include an electronic copy of the plan and appendices.



# o

Rt.'(::O clcd P a perMr. Karl Brooks Page Two

Thank you for your attention to this matter. If you have any questions regarding this submittal, please contact Ms. Wendy Vit with the Missouri Department of Natural Resources' Air Pollution Control Program at P.O. Box 176, Jefferson City, MO 65102 or by telephone at (573) 751-4817.

Sincerely,

### ~U~CONTROLPROGRAM

Kyra L. Moore Director

KLM:jwc

Enclosures:

Copy of plan (paper copies of the appendices are not included) Copy of the court-lodged, signed Consent Judgment Copy of commission signature page certifying Missouri Air Conservation Commission adoption Copy of public hearing notices Copy of public hearing transcript introductory statement Copy of recommendation for adoption Copy of the summary of comments and responses CD with electronic copy of the plan and appendices

c: Missouri Air Conservation Commission File# 2008-Lead-3C Exide

Celebrating 40 years of taking care of Missouri's natural resources. To learn more about the Missouri Department of Natural Resources visit dnr

. mo.gov

.

# Missouri State Implementation Plan Revision

________________
2008 Lead (Pb) National Ambient Air Quality Standard (NAAQS) Compliance Plan

– Exide Technologies-Canon Hollow Facility



# ________________
Adoption September 25, 2014

Prepared for the Missouri Air Conservation Commission

Missouri Department of Natural Resources Division of Environmental Quality Air Pollution Control Program Jefferson City, Missouri

Project # 2008-Lead-3C Exidei 

### Table of Contents

1. PURPOS E ........................................................................................................... 1
2. BACKGROUND AND AIR QU ALITY MONITORING ............................. 1
3. EMISSIONS IN VENTO RY ............................................................................. 6
4. CONTROL ST RATEGY .................................................................................. 7

4.1 MACT Cont rols ................................................................................................................. .......................... 9

4.2 Non-MACT Controls ............................................................................................................. .................... 10 

### 5. AIR DISPERSION MODELING ................................................................... 14

5.1 Model Selection and Settin gs .................................................................................................. .................. 15

5.2 Modeled Pollutants and Averaging Periods ...................................................................................... ......... 15

5.3 Modeled Sources and Th eir Release Pa rameters ............................................................................. .......... 15

5.3.1 Point Sources Emissions and Release Parameters ......................................................................... ..... 16

5.3.2 Volume Sources ......................................................................................................... ......................... 18

5.3.3 Area Sources ........................................................................................................... ............................ 20

5.4 Terrain Data .................................................................................................................. ............................. 25

5.5 Building Do wnwash ............................................................................................................. ..................... 27

5.6 Meteorological Data Set ....................................................................................................... ..................... 27

5.7 Recepto rs ..................................................................................................................... .............................. 29

5.8 Model Input, Out put, and Results ............................................................................................. ................ 30

5.9 Background Lead Concentration ................................................................................................. .............. 30

5.10 Post Processing in LEADPOST ................................................................................................... .............. 32 5.11 Description of Modeling Results ......................................................................................... ...................... 33 

### 6. CONTINGENCY ME ASURES ..................................................................... 34
7. PUBLIC PARTIC IPATIO N ........................................................................... 35
8. CONCL USION ................................................................................................ 36

### List of Appendices

Appendix A – Consent Judgment

Appendix B – Standard Operating Pro cedures Manual for Fugitive Dust Sources & Baghouses (Exide-Canon Hollow plant)

Appendix C – Meteorological Station Settlement Agreement

Appendix D – ENVIRON – Exide-Canon Hollow Final Modeling Report

Appendix E – Exide Airport Selection Analysis

Appendix F – AERMOD Input and Output Files1 

## 1. PURPOSE As required by Section 110(a) of the federa l Clean Air Act Amendments of 1990 (CAA), Missouri’s State Implementation Plan (SIP) must ensure attainment and maintenance of all National Ambient Air Quality Standards (NAAQS ). The Missouri Department of Natural Resources’ Air Pollution Control Program (Air Program) is amending and strengthening the Missouri SIP to address violations of the 2008 Lead NAAQS measured at the Forest City monitoring site in Northwest Missouri. This si te is located near th e Exide Technologies-Canon Hollow plant, a secondary lead smelter which recycl es lead from lead-acid automobile batteries.

This SIP revision contains a demonstrati on of NAAQS compliance through air dispersion modeling and a consent judgment detailing control proj ects, record keeping, new work practices, provisions for public access preclusion to non-ambi ent areas, as well as a contingency measure plan in case lead NAAQS violations continue. Furthermore, a marg in of safety was built into the entire attainment modeli ng analysis by using conser vative assumptions in the establishment of an ambient background concentration a nd the fact that emissions were modeled as being worst-case rather than typical faci lity operating conditions.

After this proposed SIP revision undergoes the appropriate requisite public participation procedures to include 30-day public notice and comment period, public hearing and adoption before the Missouri Air Conservation Commission, the Air Program intends to submit this plan to the U.S. Environmental Protection Agency (EPA) for inclusion into the Missouri State Implementation plan at 40 CFR §52.1320.



## 2. BACKGROUND AND AIR QUALITY MONITORING The Clean Air Act requires the EPA to establish NAAQS for lead and five other criteria air pollutants impacting public health and the environment. The othe r criteria pollutants are ozone, particulate matter (including PM 10 and PM 2.5 ), nitrogen dioxide, ca rbon monoxide, and sulfur dioxide. The CAA also requires EPA to period ically review the sta ndards and the latest scientific information to ensure they provide adequa te health and environmental protection, and to update those standards as necessary.

Lead is a metal found naturally in the environm ent, as well as in manufactured products. The major sources of lead emissions have historically been motor vehicles and industrial sources. As a result of the permanent phase-out of leaded gasoline and other national and state regulations, airborne lead concentrations have decreased in the U.S. by 94 percent between 1980 and 2007. Industrial processes are now the major source of airborne lead emi ssions, including lead smelters, waste incinerators , utilities, and lead-acid battery manufacturers.

While lead emissions have been greatly reduced nationwide, scientific evidence about the impact of lead on health has expanded dramatically si nce the U.S. Environmental Protection Agency (EPA) first issued a lead standa rd in 1978. Lead can be emitted into the air in the form of particles small enough to stay susp ended in the air. Lead emitte d into the air can be inhaled directly or ingested after it se ttles onto surfaces or soils. Once in the body, lead is rapidly absorbed into the bloodstream and accumulates in the bones. Lead exposure is associated with2 several health effects that have an adverse imp act on the cardiovascular system, central nervous system, kidneys, and immune system.

Children are more susceptible to the damaging effect s of airborne lead than adults because they breathe in more air per minute, typically spe nd more time outdoors, and exhibit greater hand-tomouth activity than adults. Children are also mo re vulnerable to the health effects of lead because their minds and bodies are developing rapidly.

For information on lead as a criteria polluta nt, including more deta ils on the NAAQS revision, the health effects of lead and other useful links, please see th e Air Program’s airborne lead webpage: http://www.dnr.mo.gov/env/apcp/airbornelead.htm

.
On October 15, 2008, EPA established a new lead NAAQS of 0.15 micrograms per cubic meter (μg/m 3 ), measured as a rolling three-month average [73 Federal Register 66964; November 12, 2008]. This new lead standard is 10 times more stringent than the prev ious 1978 standard of 1.5 μg/m3 based on a quarterly average.

The Missouri Department of Natural Resources’ (department) conducted monitoring of airborne lead concentrations near the Schuylkill Metals facility (now the Exide-Canon Hollow facility) under the 1978 NAAQS from 1990 to 2000. Based on air monitoring data originally reported by the department and retrieved from the EPA’s Air Quality System (AQS), that standard was violated only once, in 1994.

EPA promulgated the regulations ne cessary to implement the 2008 standard at the same time that they revised the standard. These regulations re quired the state to opera te a monitoring station near facilities estimated to emit 1.0 tons of lead per year. The monitor provisions were later modified to require monitoring ne ar facilities that are estimated to emit 0.5 or more ton of lead per year [75 FR 81126].

On May 19, 2011, EPA proposed revisions to the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Secondary Lead Sm elters. In supporting documentation for this proposal, lead emissions from the Exide-Canon Hollow facility were estimated to be greater than 0.5 ton per year [76 FR 29031]. Therefore, the department resumed airborne lead monitoring near the Exide facility at a site called Forest City, Exide Levee. Figure 1 shows the location of this monitoring site and the Exide facility on an aerial photograph. For more details on the recent upgrade to Missouri’s Air Quality mon itoring network at Fore st City see the 2011 monitoring network plan at: http://dnr.mo.gov/env/apcp /docs/2011monitoringnetwork.pdf

Monitoring was begun using a sampler that collects airborne particulate matter smaller than 10 micrometers aerodynamic diameter (PM 10 ) on March 1, 2012 on an every-sixth-day schedule. On August 1, 2012, monitoring was begun at the same location on the same schedule with a total suspended particulate matter (TSP) sampler, as known as a hi-volume sampler. The PM 10 lead concentration can be used to show violation of the standard, but the TSP lead concentration is most directly comparable to the NAAQS, and only the TSP lead concentration can be used to show attainment of the standar d. Compliance with the lead sta ndard is based on averaging the3 every-sixth-day monitored concentrations of l ead the ambient air over a 3-month period and comparing that average to 0.15 μg/m 3 [40 CFR 50.16(a)]. Since this is done on a three-month rolling basis, there is a concentration value to be compared to the standard generated every month.

Three-month rolling average airborne lead conc entrations resulting from this monitoring through April 30, 2014 are listed in Table 1 and shown in Figure 2 . The TSP lead concentration was at or below the level of the standard for tw o (overlapping) 3-month periods– December 2012 through March 2013 (0.151 μg/m 3 would meet the standard, because it rounds to 0.15) and for the four most recent (overlapping) 3-month peri ods for which data are available, November 2013 through April 2014. The PM 10 lead concentrations show violati ons of the standard except for three (overlapping) periods from November 2012 through March 2013 and the three most recent (overlapping) 3-month periods from December 2013 through March 2014. PM 10 monitoring at this site was discontinued at the end of March 2014.

Monitoring with the TSP sampler at this location will need to continue at least until the site achieves three years of continuous compliant data, b ecause three years of monitoring results at or below the level of the standard are requi red to show attainment [40 CFR 50.16(b)].

Missouri’s most recent monitoring network plan may be found at http://dnr.mo.gov/env/apcp/monitoring/monitoringnetworkplan.pdf

. A map of the statewide lead monitoring network along with the state’s cu rrent lead Air Quality data and analysis may be found at: http://dnr.mo.gov/env/apcp/ docs/leadmonitordata.pdf

. Subsequently, on November 6, 2012, the Air Program hosted a meeting with Exide staff, their environmental consultant– ENVI RON, and EPA Region VII staff for the purpose of coordinating the development of this compliance plan to addr ess the measured violation of the Lead NAAQS. Since that initial meeting there have been num erous and regularly-scheduled conference calls, meetings and discussions culminating in this robust compliance plan that demonstrates attainment and maintenance of the 2008 lead NAAQS in the vicin ity of Forest City, Missouri through air dispersion modeling. This plan was developed with the consensus and cooperation of the Air Program, Exide Technologies, EPA Re gion VII and the Missouri Attorney General.

Concurrent to the developmen t of this plan, the Exide T echnology-Canon Hollow facility (Exide) installed, and is opera ting, new air pollution control equipment to comply with the provisions of the revised Secondary Lead Smelting NESHAP, promulgated on January 5, 2012 [77 FR 556]. These federal control require ments, also known as the Maximum Achievable Control Technology (MACT) are found at 40 CFR 63 Subpart X and include fully enclosing all lead process operations and achieving a negative pressure differential to these lead process buildings through baghouse-filtered ventilation. For this purpos e, Exide constructed two new baghouses (Negative Pressure #1 & #2 with associated stacks and a 40-foot stack for the Acid Demister. Pursuant to the MACT, these proj ects were completed and operating by January 6, 2014.4 In addition to the revised MACT, other requiremen ts of this plan, such as plant truck traffic restrictions to limit fugitive lead dust on the roadways and stack emission limitations, will be enforced through the court-lodged consent j udgment among the department, the Missouri Attorney General, and Exide Technologies.

Lastly, though an attachment to this plan, Exid e voluntarily agrees to co llect complete, accurate onsite weather data for trend analysis or in cas e an additional air disper sion modeling analysis becomes necessary. (For this plan, air dispersi on modeling used meteorological data obtained from the nearby Brenner, Nebraska airfield be cause no onsite meteorologi cal existed during the development of this plan.)

Figure 1. Aerial photograph of the Exide-Canon Ho llow facility and surrounding area, showing the facility boundary and the location of the Forest City, Exide Levee monitoring site.5 Table 1

. 3-month rolling average le ad concentrations (μg/m 3 ) measured at the Forest City, Exide Levee site. Note: 3-month averages are calculated from monthly aver ages of concentrations originally reported by the department and retrieved from the EPA’s Air Qua lity System (AQS), except for the February-March-April 2014 average, which uses pr eliminary data for April.

3-Month Period PM 10 TSP March-May 2012 0.285 April-June 2012 0.252 May-July 2012 0.341 June-August 2012 0.438 July-September 2012 0.674 August-October 2012 0.543 0.993 September-November 2012 0.396 0.634
October-December 2012 0.158 0.270 November 2012-January 2013 0.100 0.193 December 2012-February 2013 0.073 0.151 January-March 2013 0.070 0.116 February-April 2013 0.196 0.362 March-May 2013 0.496 0.680 April-June 2013 0.521 0.725 May-July 2013 0.492 0.612 June-August 2013 0.250 0.379 July-September 2013 0.332 0.541 August-October 2013 0.346 0.547 September-November 2013 0.368 0.572
October-December 2013 0.215 0.299 November 2013-January 2014 0.095 0.150 December 2013-February 2014 0.021 0.063 January-March 2014 0.019 0.054 February-April 2014 0.053

Source: Missouri Department of Natural Resources ’ Environmental Services Program - Air Quality Monitoring Section (as reported to EPA’s Air Quality System (AQS)).6 Figure 2. Time series graphs of 3-month rolling av erage lead concentrations measured at the Forest City, Exide Levee site.



## 3. EMISSIONS INVENTORY The Air Program creates air emission inventor ies for criteria pollutants and hazardous air pollutants to meet federal re porting requirements under EPA’s Ai r Emissions Reporting Rule to provide data that supports the f unctions of the Air Program, incl uding SIP inventory needs. The lead emission inventory includes anthropogenic emissions from point source facilities like industrial plants, mobile source emissions from aircraft, and nonpoint sources of emissions where many small sources are estimated at the count y level. Point source facility emissions are reported directly by permitted sources in Missouri, while nonpoint and mobile source emissions are estimated using EPA guidelines and state-specific data.

For the purposes of this plan, the area of interest is Holt County Missouri, the county encompassing Exide Technologies. The emission inventory data presented is only for lead emissions. A single point source drives the l ead inventory for the area, but other smaller (nonpoint) sources are also described for complete ness. Nonpoint sources are too numerous to inventory at the individual source level; nonpoint lead sour ces include av iation gasoline distribution and human cremation. Mobile sour ces of lead emissions are also considered7 including piston-driven aircraft, commercial marine vessels, and diesel locomotives. Both the nonpoint and mobile source inventory incl uded below are for all of Holt County.

Large emitters with Part 70 (P70) operating perm its, such as Exide Technologies, submit their emissions inventory annually. The 2012 emission inventory year corresponds to the start of the current air quality sampling effort at the Forest City levee monitoring site as well as the most recent year at the commencement of this plan’s development. Nonpoint and mobile source emissions are from the 2011 National Emissions Inve ntory (NEI), a dataset prepared triennially through state, tribal, and EPA cooperation. Ex ide Technologies submitted their 2012 inventory data to the state of Missouri, and that data was quality assure d prior to forwarding to EPA for further review. The 2012 lead emission totals for Exide Technologies ar e 5.0045 tons per year. There are no other point sources in the county that have reported lead emissions to the Emissions Inventory Unit. Table 2 below shows the emissions inventory information for Exide Technologies and the reported lead emissions for 2010, 2011, and 2012.

Table 2 – Point Source Facility Inventory in Holt County
2012 2011 2010

Exide Lead Emissions (tons per year) 5.0045 a 0.0146 0.1801

a Emission reporting includes fugitive emissions from smelting, kettle, and casting processes in 2012. These areas were unreported in prior years, and they do not constitute an increase in emissions or activity, or a decrease in control.



## 4. CONTROL STRATEGY The process at the Exide Technologies–Canon Hollow f acility near Forest C ity, MO is typical of secondary lead smelters. Secondary lead smelters perform three basic unit operations: battery breaking, smelting, and refining (includes alloying and casting). Battery breaking is accomplished by crushing or cutting junk batterie s into pieces. The plastic, spent acid, and lead-bearing materials are then separated. Lead-b earing materials are then processed in the blast furnace. Molten lead from this furnace is further processed in refinery kettles and subsequently cast into molds for use in new car battery manufacturing. Figure 3 is a process flow diagram of the Exide plant including the new controls adde d as a result of the revised Secondary lead MACT and this plan.8Figure 39 There are three types of emission sources at seco ndary lead facilities. This plan proposes controls at each of these em issions points---process sources, process fugitive sources, and fugitive dust sources.

1. Process sources include lead emission from process stacks. Dust filtration systems called baghouses are used to control process emissions 2. Process fugitive sources of lead emissions are characterized by th e uncaptured portion of lead particulate matter that are generated by lead smelting processes but might otherwise escape from going up the stack. Controls for process fugitives include process hoods (local exhaust ventilation), and baghouse f iltered hygiene ventilation of the process building to negative pressure. 3. Examples of Fugitive dust sources include uncaptured lead escaping a process building and lead dust kicked up by truck traffic on ha ul routes and wind-blown re-entrainment. Total enclosure of the process buildings and work practices such as haul route sweeping and truck frequency restrictions he lp control fugitive dust sources.



### 4.1 MACT Controls The development of this plan coincides with th e implementation of the revised Secondary Lead Smelting NESHAP or MACT Subpart X promul gated on January 5, 2012 [77 FR 556] and effective on January 6, 2014. The majority of the emission reductions used to demonstrate compliance with the 2008 lead standard result fro m this federal regulation. The revised MACT is used to control lead as an air toxic or hazardous air pollutant (HAP), while this plan was developed to demonstrate compliance with the sta ndards for lead as a criteria pollutant. The MACT regulation is designed to control emi ssions of all HAPs from secondary smelters including arsenic, mercury, dioxin and furans.

According to EPA, the revised secondary lead MACT will cut lead and arsenic emissions by 68 percent from their previous levels . Some of the provisions of th e revised MACT that are used by this plan to demonstrate complia nce with the lead NAAQS include–

 Requiring facilities to fully enclose al l operations within a building and vent emissions through a controlled stack;

 Ventilating lead process buildings to a control device and maintaining a negative differential pressure of at least 0.013 millimeters of Mercury (mm Hg);

 Lowering the emissions limit for lead to 0.2 mg/dry standard cubic meter (dscm) from 2.0 mg/dscm;

 Establishing a fugitive dust control plan and implementing comprehensive work practices to reduce fugitive lead emissions.

Pursuant to the MACT, Exide has complied w ith these requirements by January 6, 2014 through a capital improvement and construction campa ign that includes the following projects:

 Improvements to lead process building enclosures;

 Construction of two new baghouses, each w ith a flow capacity of approximately 315,000 cubic feet per minute -10 1. Negative Pressure Baghouse #1 to improve refinery ventilation * 2. Negative Pressure Baghouse #2 to imp rove lead process building hygiene ventilation **;

 Construct a stack for the Acid Demister with a minimum height of 40 feet.

[ Note : During the development of this plan, the nami ng convention for the newly-constructed baghouses had changed. * - Negative Pressure Baghouse #1 may have been referred to as South Baghouse due to its location, or, in the Baghouse SOP manual of Appendix B, it is called West Baghouse #2 because it provides negative pressure ventilation to the West side of the process buildings. ** - Negative Pressure Baghouse #2 is called North Baghouse in the Baghouse SOP manual of Appendix B.]

The work practices requirements of the MACT regulation include a Fugitive Dust Control & Baghouse Operation plan enforced via a Standard Operating Procedure (SOP) manual. Exide developed a fugitive dust control plan and submitted the SOP manual to the Air Program by the deadline of January 5, 2013. The Air Program approved the plan on August 19, 2013. The SOP includes work practices and plant-specific controls for fugitive dust on the plant roadways, material storage/transportation, operation a nd maintenance of the Baghouses, housekeeping within the process buildings and recordkeeping to name just a few. Exide’s Standard Operating Procedures Manual for Fugitive Dust Sources & Standard Operating Procedures Manual for Baghouses (along with the department’s approval letter) are attached to this plan for reference as Appendix B

. A specific example of a work practice to be main tained by Exide pursuant to the Fugitive Dust SOP is found on page 2 of the manual. Exide must clean all in-plant road ways and parking lots by wet washing or vacuum sweeping at least twice daily between 7:00 am and 7:00 pm. Attachment A of the SOP manual is a map of th e plant campus showing the corresponding areas to be cleaned. To further reduce lead fugitive being kicked up by vehicle traffic, a 5 mile per hour speed limit is enforced on all plant roadways.

Moreover, pursuant to 40 CFR 63.548 of the Secondary Lead Smelting NESHAP, Exide shall operate at all times according to the Baghouse SO P of Appendix B that describes in detail procedures for inspection, maintenance, bag leak detection and correctiv e action plans for all baghouses that are used to control process, pro cess fugitive or fugitive dust emissions from any applicable source including t hose used to control emissions from building ventilation.



### 4.2 Non-MACT Controls
In addition to the reductions to be achieved by the MACT, two other control measures not found in the MACT were also used in this attainment demo: Stack Emission Limits and Truck Traffic Restrictions. For this plan, the workgroup has chosen to make these two control measures enforceable through a Consent Judgment to be l odged with the court. This Consent Judgment was developed in conjunction with this pl an and is included in this plan as Appendix A . The enforceable provisions for these lead emissi on reductions may be found in Paragraph V.7. Required Practices and Procedures of the Consent Judgment in Appendix A. The installation, operation and schedule for the control projects (including the MACT-related ones) are outlined in Paragraph V. 6. of the Consent Judgment. The parties to the Consent Judgment are the11 department, the Missouri Attorney General and Ex ide technologies. The pa rties shall sign and be bound by the Consent Judgment once it has been adopted by the Missouri Air Conservation Commission after appropriate opportun ities has been made by the publ ic or any interested parties during the 37-day public hearing and comment pr ocess as discussed in chapter 7 of this document.

The MACT prescribes a plant-wide stack emi ssion limitation of below 0.20 milligrams of lead per dry standard cubic meter. This is an aggr egate flow-weighted average concentration of all the lead process stacks at the facility. To transl ate this aggregated averag e limit into a worst-case impact for modeling purposes, each stack was assigned an individual limit in pounds per hour (lb/hr).

For this compliance plan, Exide agrees to lim it emissions from each of their stacks/emission points at the rate (in lb/hr) shown in Paragraph V.7.E. of the Consent Judgment and Table 3 below. These were the maximum emission rates used to model attainment and employ a margin of safety through their conservative estimation. Enforcement of these emission limits shall be through regular stack tests in the same manner and schedule required by the revised secondary lead smelter MACT.

Table 3 – Stack Emission Limits



### Emission Point Control Device Emission Source / Description Emission Rate (lb/hr)

AD Acid Demister (CD007) Battery Break Crusher Room 0.024

EP01 Wheelabrator Air Pollution Control System Blast Furnace, Refinery & Casting Process Hoods 0.322

BH01 Negative Pressure Baghouse #1 (CD005) Blast Furnace, Refinery & Casting Bldg. Neg. Pressure 0.236

BH02 Negative Pressure Baghouse #2 (CD006) Other Building Negative Pressure 0.196

Similarly, to further reduce fugitive dust emissions and to demonstrate attainment of the lead standard, Exide agrees to limit truck traffic, fr equency and hours of operation on the plant roads to the schedules outlined in Table 4 below [P aragraph V.7.F. of the Consent Judgment]. For12 more information on truck haul route emissions, see paragraph 5.3.3 Area Sources of this document.

Table 4 – Truck Traffic Restrictions: Fr equency and Hours of Operations

Group Route Description Total Trips Per Month Unrestricted Trips Per

Month*

A Cores/Scrap 368 0 Industrials

B Furnace Coke 87 4 Lime (bulk) Furnace Fluxes

C Trash 61 3 Acid (bulk) Plastic Chips

D Cement (bulk) 22 1 Oxygen (liquid) E Lead Products 260 13

F Slag Mix to Landfill 217 11

G Service 26 1 Total 1040 34 *Note: Restricted trips only use th e haul roads 12 hours per day (7AM7PM). Unrestricted trips use the haul roads 24 hours per day.

The previous secondary lead smelting NESHAP promulgated in 1999, called for total enclosures of lead process buildings or th e operation of local exhaust ven tilation process hoods (LEV’s). The new secondary lead smelting NESHAP revi sed as of 2012 requires both total building enclosures and negative pressure differential fi ltered-ventilation. It no longer specifies the operation of LEV’s. Nevertheless, to optimize the capture, containment and control of leadbearing particles in the lead process buildings, Exide agrees, through this plan, to operate LEV’s at the following emission units when the units are operating: (1) Blast Furnace charging, (2) Furnace lead and slag tapping, and (3) refinery ke ttles. [Paragraph 7.C. of the Consent Judgment]

Section 5 of this document on Air Dispersion Mo deling demonstrates that the control strategy mentioned above reduces emissions sufficiently to attain and maintain the 2008 lead standard in all areas of ambient air. The maximum modele d concentration of lead in the ambient air (including background concentration) is 0.1498 μg/m 3 at a model receptor s ite located about 600 yards northwest of the lead pr ocess buildings on the Exide pr operty. Figure 1 above shows Exide’s property boundary at the Canon Hollow facilit y. Air is considered to be ambient even within a facility’s property boundaries if public access has not been sufficiently precluded. Exide has chosen a smaller area than their pr operty boundary to be considered non-ambient. Pursuant to Paragraph V.7.D. of the Consent Judgment, Exide shall maintain fencing or otherwise preclude public access on two perimeters or quadrants within their grounds. One13 quadrant is west of Canon Hollow Road and nor th of Highway (HWY) 111 to a line about midway through their property. The other quadr ant extends east of Canon Hollow Road and North of HWY 111 to surround their active proce ssing plant campus, parking lots and hazardous waste landfill site. Figure 4 shows the two public access preclusion zones to be maintained. The existing fencing is in green while and the new fencing to be built is highlighted in purple. This map and a list of “fenceline” coordinates wi th 10-meter spacing are attached to the Consent Judgment. 10-meter spacing is appropriate b ecause it represents th e approximate distance between hypothetical “fence posts” th at may later be used to define a fenceline. Any change to the fencelines that would allow public access to these two preclusion zones will require a SIP revision as well as a new modeled attainment demonstration.14 

## 5. AIR DISPERSION MODELING The lead-specific State Implementation Plan (S IP) regulations found at 40 CFR 51.117 (entitled “Additional provisions for l ead”) require the use of dispersion modeling for the demonstration of attainment. Air quality dispersion modeling is a computer simulation that predicts air quality concentrations from various types of emission s ources. For pollutants emitted through a stack, it considers the emission rate, stack height, stack di ameter, and stack gas te mperature and velocity, as well as the effect of nearby buildings and terrain. Other emi ssion sources like vehicle traffic or wind erosion from storage piles are repr esented as 2-dimensi onal area sources or 3- dimensional volume sources.

Air quality dispersion models use meteorological data such as temperature, wind direction, and wind speed to calculate concentrations for sele cted modeling receptor grids. Five years of National Weather Service (NWS) meteorological data is typically used fo r air quality modeling according to 40 CFR 51 Appendix W [ Guideline on Air Quality Models ] . In some cases one or more year(s) of on-site me teorological data is used.

Model results are compared to ambient air standard s to determine if they meet state and federal requirements. Sometimes results are used to help site ambient air monitors or they may be input into human health risk assessments or ecological risk assessments.

Typically, in a SIP modeling exercise, two dispersi on modeling analyses are used. One is used to verify the accuracy of the modeled inputs by compar ing the monitored data to the modeled results (base case). The second analysis examines the effectiveness of the pr oposed emission controls (future case) necessary to demonstrate attainme nt. In order to conduct a base case model, emissions, monitoring and meteor ological data must all be re presentative, concurrent and correlative. For this plan, a representative corresponding period of ma tching data sets for establishing a base case s cenario did not exist.

At the start of the development of this plan in late 2012, no on-site meteorological data was available. Also, at this time, there were only a couple months of NAAQS-comparable monitoring data available. (For more information see chapter 2 Background and Air Quality Monitoring). So that compliance with the lead air quality st andard may be achieved as expeditiously as possible, the Air Program move d forward with the plan usin g meteorological data from a representative National Weather Service site despite its potential limitations due to terrain differences. Exide has agreed to conduct on-site meteorological monitoring for trend analysis or in case future air dispersion modeling should b ecome necessary. The on-site meteorological station became operational in early 2014. (See also section 5.6 Meteorological Data Set). Lastly, Exide started process changes and constructi on projects related to the newly revised secondary lead MACT control measures that cha nged the facility’s “bas eline.” Consequently, there was an inability to establish concurrent and correlative model input s necessary for a base case evaluation. The decision to move forwar d with the plan without a base case modeling analysis was made in coordina tion with EPA Region VII staff.

The Air Program is confident that all lead s ources have been appropr iately identified and characterized in the model because this plan uses the same source accounting analysis utilized by15 the State in other recent SIP revisions for simila r lead smelting facilities and by the EPA in their recent MACT lead residual risk assessment.

The following section is based on Exide’s modeling report (attached to this plan as Appendix D) that was prepared by ENVIRON Internationa l Corporation (ENVIRON). The Air Program completed its own independent modeling analysis and verification study and concurs with the results.


### 5.1 Model Selection and Settings Modeling procedures used in this attainment demonstration follow curre nt air quality modeling guidelines as contained in 40 CFR 51 Appendi x W. The EPA’s recommended dispersion model for addressing lead is the AMS/EPA Regulator y Model (AERMOD). AERMOD can predict the concentration distribution of pollu tants from surface and elevated releases located within simple or complex terrain. The model allows for the input of multiple sources, terrain elevations, structure effects, various grid receptors, wet and dry depletion cal culations, urban or rural terrain, and averaging period ranging from one hour to one year. The latest available version of AERMOD (13350), was used in this attainment demonstration, as well as its pre- and postprocessors: AERMAP, AERMET, BPIPPRM, and LEADPOST.

This analysis was conducted using AERMOD with all regulatory defaults. The following regulatory default modeling cont rol options were included:

 adjusting stack heights for stack-tip downwash,

 using upper-bound concentration estimates for sources influenced by building downwash from super-squat buildings,

 incorporating the effects of elevated terrain,

 employing the calms processing routine, and

 employing the missing data processing routine



### 5.2 Modeled Pollutant s and Averaging Periods The only pollutant that was modeled is lead (C AS Number: 7439-92-1). Calculation of chemical concentrations for use in demonstrating attainment of the 2008 Lead NAAQS (EPA 2008b) requires the selection of appropriate concentration aver aging times. To demonstrate agreement with the 2008 Lead NAAQS, the Air Program and ENVIRON executed the AERMOD model and generated PO ST files using a monthly av eraging period. These POST files were processed through the EPA’s LEADPOST (Version 12114) FORTRAN based computer program to generate consecutive thre e-month rolling averages for comparison against the lead NAAQS.



### 5.3 Modeled Sources and Th eir Release Parameters This modeling analysis included the following lead emitting sources and their associated control devices at the Exide facility: the blast furnace exhaust is routed to the west Wheelabrator baghouse. The blast furnace and refining/casting ventilation hoods are routed to the east Wheelabrator baghouse. Both west and east bagh ouses share one stack (EP01) and it is called the Wheelabrator air pollution control system. Refining/Casting ventila tions, Battery Breaker16 area, Deminimis Storage area, Containment Build ing, Maintenance Buildin g are routed to the Negative Pressure Baghouse #2, one of the newly constructed baghouses (CD006). Some of the Blast Furnace and Refining/Casti ng areas are routed to the ot her newly-constructed baghouse, Negative Pressure Baghouse #1 (CD005). Other ar eas that are controlled by the acid demister baghouse (CD007) are the Stabilization Unit, Bl ast Slag, and Mixing areas. The battery break/crushing area is routed to CD007. The source identifiers for th e point sources used in this AERMOD modeling were chosen based on the de signations used by the facility. Process fugitives and haul roads emissions were modeled as volume and area sources respectively. No other emission sources besides Exide were m odeled. Any other small mobile or nonpoint sources of lead are contributors to background con centration which is discussed in section 5.9 of this document. The following sections de scribe the how the emission rates and model parameters were determined for each type of source.

5.3.1 Point Sources Emissions and Release Parameters In order to demonstrate ambient im pacts less than the 2008 Lead NAAQS (0.15  g/m 3 ) and all relevant federal New Source Performance Standa rd (NSPS) and NESHAP standards applicable to the sources involved, the Wheelabrator Air Po llution Control System was modeled based on a lead concentration of 1 milligram per dry standard cubic meter (mg/dscm), and the other point sources were modeled based on 0.2 mg/dscm, with exception of Negative Pressure Baghouse # 2 (CD005) which was modeled based on 0.17 mg/dscm

. The emission rate for the Wheelabrator Air Pollution Control System is the maximum a llowed for any one source under the NESHAP. It is higher than the most recent stack test emission rate in order to ensure that normal operational variations would not create conditions where the lead NAAQS is exceeded. The emission rates for the two negative pressure baghouses and the acid demister were set in accordance with the facility wide, flow weighted average lead emi ssion limit set in the NESHAP for secondary lead smelters; however, the actual emission rates from these sources are expected to be less than the modeled values. The emission rate for each source is calculated in Table 5 . All of the stacks were modeled as vertical point sources with unrestricted flow. Table 6 includes a list of the point source inputs that were incl uded in this m odeling exercise. Figure 5 shows the location of all point sources within the f acility. The modeled stack velocities for the two new baghouses (CD005 and CD006) are corresponding to conservativ ely assumed flow rate s that still achieve the negative pressure requirements of §63.544( c)(1) of 40 CFR 63 Subpart X; however, the emission rates for those two sources were c onservatively modeled assuming 100 percent flow.

Table 5 - Point Source Emissions Calculations

Emission Point/ID Description Emission Source Air Flow Capacity Modeled Lead Concentration Modeled Lead Emission Rate

acfm m 3 /s dscfm % mg/dscm lb/hr g/s

AD Acid Demister Battery Break Crusher Room 32000 15.10 0 100% 0.20 0.024 3.02E-03

WBH Wheelabrator Air Pollution Control System Blast Furnace, Refining /Casting

Process Hoods 83160 39.25 86074 100% 1.00 0.322 4.06E-02

BH01 Negative Pressure Baghouse 1 Blast Furnace, Refining/Casting bldg. Neg. Pressure 315000 148.66 0 100% 0.20 0.236 2.97E-0217 BH02 Negative Pressure Baghouse 2 Other Building Negative Pressure 315000 148.66 0 100% 0.17 0.196 2.53E-02

Table 6- Point Source Inputs to AERMOD

Source ID Description X-Coordinate (m) Y-Coordinate (m) Base Elevation (m) Stack Height Above Grade (m) Stack Temp.

(K) a Stack Velocity

(m/s) Stack Diameter (m)

AD Acid Demister 309533.77 4433697.58 279.81 12.19 0 15.40 1.12

WBH Wheelabrator Air Pollution Control System 309412.20 4433607.01 285.92 39.00 326.11 14.94 1.83

BH01 Negative Pressure Baghouse 1 309383.71 4433596.53 286.05 27.89 299.82 18.19 2.79

BH02 Negative Pressure Baghouse 2 309556.87 4433717.66 280.26 25.45 299.82 18.19 2.79

a The Acid Demister stack is assumed to be at ambient temperature. The input file contains a value of 0 for this source parameter. AERMOD will apply the hourly ambient temperature to the stack18 Figure 5 - Point Emission Sources within Exide

5.3.2 Volume Sources The source group designated FUG was included to represent process fugitive emissions from the furnace, refining, and casting that may escape through openings in the facility buildings. §63.544(c)(1) of 40 CFR 63 Subpart X requires conti nuous ventilation of th e total enclosure to ensure negative pressure values of at least 0.007 inches of wate r column. Assuming a worst case scenario with all external equipment doors open at the same time, the facility’s future negative pressure total enclosure design will achieve the minimum of 0.007 in ches water column. However, measures will be put in place to en sure that under normal operating conditions, all exterior doors will not be open at the same time , and the facility will exceed the minimum of 0.007 inches of water as explained below.

Additionally, Exide will implement design and housekeeping provisions that go beyond the NESHAP requirements; these provisions includ e equipment door designs that minimize building inflow and the use of local exhaust ventilati on (LEV) hoods. Service vehicle or equipment door openings will be equipped with airlocks, speed doors, dock seals, metal roll up doors, or other controls to minimize changes in differential pr essure or building infl ow during occasional but necessary traffic. Exide intends to keep al l doors closed during normal operation barring the protection of employee welfare. Exide will conti nue to operate and maintain LEV’s at the Blast Furnace (both charging and tapping) and at the refinery kettles to reduce process fugitive19 emissions after installation of the new baghouses. EPA’s Secondary Lead Smelting Background Information Document for Propos ed Standards (EPA 1994, page D- 58) suggests that the capture efficiency of local exhaust ventilation hoods is 95%. Exide used 95% building capture efficiency in this modeling exercise. The eff ect of the local exhaust ventilation hoods and the negative pressure total enclosure reduced the fugitive emissions from this source group to less than 31.33 lb/yr. Table 7 shows the calculation of the proc ess fugitive emissions, both before and after the installation of the total enclosure negative pressure ventilation system. The emission rate in Table 7 was divided evenly across all of the modeled volume sources in the source group FUG.

The fugitive process emissions were characterized as volume sources with square area footprints. It was assumed that fugitive emissions that may escape the building will escape from open equipment doors to the manufactur ing area; therefore, those e quipment doors were represented as volume sources in the model ( Figure 6 ). The height and width of each door were used to calculate the initial lateral dime nsion and the initial vertical dimension for each volume source. Per EPA’s User’s Guide for the AMS/EPA Regulatory Model – AERMOD (EPA 2004), the initial lateral dimension was set as the length of the square area footprint divided by 4.3, and the initial vertical dimension was set as the doorway hei ght divided by 2.15. Table 8 includes a listing of the fugitive volume sources and th eir parameters for input into AERMOD.

Table 7 - Process Fugitive Emissions (Controlled)

Source AP-42 Factor (lb/ton) Process Rate (tons/yr) Uncontrolled Emissions

(lb/yr) Hood % Capture Current Fugitive

(lb/yr) Bldg % Capture Controlled Emissions

(lb/yr) Controlled Emissions (g/s)

Furnace 0.2 58,400 11,680 95 584 95 29.2 4.20E-04 Refining 0.0006 58,400 35.04 95 1.752 95 0.0876 1.26E-06 Casting 0.0007 58,400 40.88 0 40.88 95 2.044 2.94E-05

Sum 627 31.33 4.51E-04

Table 8 - Volume Source Inputs to AERMOD

Source

ID Description XCoordinate (m) YCoordinate (m) Elevation (m) a Emission Rate (g/s) b Release Height

(m) Initial Lateral Dimension (m) Initial Vertical Dimension (m)
FUG1 Exterior Door A 309430.36 4433662.71 277.37 3.00E-05 2.13 0.99 1.98
FUG2 Exterior Door B 309440.73 4433686.63 277.37 3.00E-05 2.34 1.13 2.17
FUG3 Exterior Door C 309456.82 4433712.77 276.15 3.00E-05 2.06 0.99 1.91
FUG4 Exterior Door D 309463.59 4433709.70 276.15 3.00E-05 2.06 0.99 1.91
FUG5 Exterior Door J 309442.14 4433645.06 284.99 3.00E-05 1.37 0.85 1.28
FUG6 Exterior Door K 309451.30 4433641.13 284.99 3.00E-05 0.30 0.28 0.28
FUG7 Exterior Door N 309461.54 4433623.08 284.99 3.00E-05 2.44 0.99 2.27 FUG8 Exterior Door Q 309531.32 4433620.90 283.77 3.00E-05 1.52 0.64 1.42
FUG9 Exterior Door R 309534.39 4433619.63 283.77 3.00E-05 1.52 0.64 1.4220 FUG10 Exterior Door S 309539.79 4433619.21 283.77 3.00E-05 2.44 1.17 2.27
FUG11 Exterior Door W 309590.17 4433606.81 284.38 3.00E-05 2.13 1.49 1.98
FUG12 Exterior Door X 309513.01 4433642.07 282.24 3.00E-05 2.13 0.85 1.98
FUG13 Exterior Door Y 309503.07 4433666.52 282.24 3.00E-05 2.13 1.35 1.98
FUG14 Exterior Door Z 309506.92 4433685.97 277.06 3.00E-05 2.13 1.35 1.98
FUG15 Exterior Door AA 309506.24 4433701.76 277.06 3.00E-05 2.13 1.13 1.98

Figure 6- Volume Sources Locations

5.3.3 Area Sources In addition to the fugitive process emissions, fugitive emissions due to re-entrainment of surface dust from traffic were taken into account in the model. Semi-trailers, roll-offs, dump trucks, loaders, and forklifts regularly drive on the f acility roads and contri bute to these fugitive emissions. Vehicular fugitive emissions were mo deled as ground level area sources with input parameters calculated according to the guidan ce provided in the EPA’s Haul Road Workgroup Final Report (March 2, 2012). All of the haul road s were assumed to be 8-meters wide and have two lanes; therefore the width of each area source was set to 14 meters (six meters plus the road width). The other release parameters of each area source (release height, initial vertical dimension, etc.) were calculated based on the fleet average vehicle height for each road segment. The approximate dimensions of the vehicles a nd corresponding area sources that were included21 in the model are in Table 9 . Traffic patterns for each vehicle type were split into equal width rectangles to represent the area sources ( Figure 7 ). A description of the traffic patterns including the vehicle type, number of trips, freque ncy of trips, and hours of day are in Table 10

. Table 11 includes a list of the haul road area sources and th eir release parameters that were included in the modeling.

Table 9 - Area Source Parameters for Haul Roads

Parameter Approximate Vehicle and Plume Dimensions (meters)

Semi-Trailer Roll-Off Dump Truck Loader Forklift Vehicle Height a 4.11 3.66 3.44 3.81 2.13

Vehicle Width a 2.59 3.05 2.87 2.46 1.16 Top of Plume Height b 7.00 6.22 5.86 6.48 3.63 Release Height b 3.50 3.11 2.93 3.24 1.81

Plume Width b 8.59 9.05 8.87 8.46 7.16

Sigma Z b 3.25 2.89 2.72 3.01 1.69

a Approximate average dimensions of the vehicles at the facility.
b Determined by using the Recommended Area Source Configurati on from EPA's Haul Road Workgroup Final Report (March 2, 2012)

Table 10 - Haul Road Vehicle Trips

Route

No. Route Description Vehicle Type % Restricted

Trips* Time of Day Weekly Restricted Trips Monthly Restricted Trips Monthly Unrestricted Trips 1 Cores/Scrap Semi-Trailer 100% 7AM - 7PM 60 303 0

2 Industrials Semi-Trailer 100% 7AM - 7PM 12 65 0

3 Furnace Coke Semi-Trailer 95% 7AM - 7PM 4 16 1 4 Lime (bulk) Semi-Trailer 95% 7AM - 7PM 3 16 1
5 Trash Roll-Off 95% 7AM - 7PM 4 21 1 6 Cement (bulk) Semi-Trailer 95% 7AM - 7PM 2 12 1 7 Acid (bulk) Semi-Trailer 95% 7AM - 7PM 6 25 1 8 Oxygen (liquid) Semi-Trailer 95% 7AM - 7PM 2 8 0

9 Furnace Fluxes Semi-Trailer 95% 7AM - 7PM 3 49 3

10 Lead Products Semi-Trailer 95% 7AM - 7PM 50 247 13 11 Plastic Chips Semi-Trailer 95% 7AM - 7PM 3 12 1

12 Slag Mix to Landfill Dump Truck 95% 7AM - 7PM 50 206 11

13 Service Loader & Forklift 95% 7AM - 3PM 3 25 1

*Note: Restricted trips only use the haul roads 12 hours per da y (7AM-7PM). Unrestricted trips use the roads 24 hours per day.22 Table 11 - Area Source Inputs to AERMOD

Source

ID XCoordinate (m) YCoordinate (m) Elevation (m) Width (m) Length (m) Emission Rate (g/sm 2 ) Release Height

(m) Initial Vertical Dimension (m)

HR01 308867.94 4433711.35 261.65 14.00 41.14 4.17E-08 3.49 3.24

HR02 308899.51 4433668.52 262.41 14.00 42.47 4.17E-08 3.49 3.24
HR03 308937.53 4433628.71 264.06 14.00 43.21 4.17E-08 3.49 3.24 HR04 308975.06 4433587.93 263.93 14.00 206.26 4.17E-08 3.49 3.24 HR05 309281.6 4433339.76 265.86 14.00 95.96 4.17E-08 3.49 3.24 HR06 309281.11 4433339.87 265.86 14.00 38.97 4.63E-09 3.49 3.24 HR07 309317.97 4433304.43 266.13 14.00 58.96 4.63E-09 3.49 3.24 HR08 309377.52 4433256.5 266.09 14.00 199.68 4.63E-09 3.49 3.24 HR09 309283.97 4433382.58 264.79 14.00 29.56 4.63E-08 3.49 3.24
HR10 309284.12 4433379.92 264.92 14.00 65.40 4.63E-08 3.49 3.24

HR11 309274.78 4433464.7 266.49 14.00 25.97 4.63E-08 3.49 3.24

HR12 309273.72 4433499.08 267.29 14.00 67.38 4.63E-08 3.49 3.24

HR13 309305.08 4433579.75 269.78 14.00 86.72 4.63E-08 3.49 3.24

HR14 309343.89 4433687.11 270.15 14.00 81.32 4.63E-08 3.49 3.24

HR15 309413.82 4433762.09 273.66 14.00 46.57 3.09E-08 3.49 3.24

HR16 309432.13 4433826.13 272.86 14.00 14.14 2.99E-08 3.48 3.24

HR17 309506.25 4433837.19 275.15 14.00 44.96 2.99E-08 3.48 3.24

HR18 309547.76 4433813.41 278.18 14.00 36.57 2.99E-08 3.48 3.24

HR19 309576.12 4433770.76 280.75 14.00 39.22 2.99E-08 3.48 3.24

HR20 309581.79 4433737.45 283.11 14.00 24.55 2.99E-08 3.48 3.24

HR21 309503.12 4433702.86 279.51 14.00 66.58 3.95E-08 3.29 3.06

HR22 309536.87 4433651.1 284.34 14.00 72.37 2.99E-08 3.48 3.24

HR23 309543.5 4433622.24 286.62 14.00 41.67 8.80E-09 3.50 3.25

HR24 309590.63 4433616.33 287.77 14.00 32.16 5.03E-09 3.50 3.25

HR25 309582.83 4433575.11 290.10 14.00 98.01 5.03E-09 3.50 3.25

HR26 309458.58 4433615.02 294.24 14.00 21.77 5.03E-09 3.50 3.25

HR27 309459.87 4433622.87 291.78 14.00 59.89 5.03E-09 3.50 3.25

HR28 309391.87 4433571.98 284.86 14.00 15.34 5.03E-09 3.50 3.25

HR29 309539.21 4433633.23 285.79 14.00 12.83 1.82E-08 3.42 3.18

HR30 309535.81 4433646.71 284.72 14.00 16.20 2.01E-09 3.25 3.03

HR31 309522.27 4433672.42 282.84 14.00 15.22 1.51E-09 3.50 3.25

HR32 309465.16 4433744.97 276.15 14.00 46.50 7.55E-10 3.50 3.25

HR33 309460.09 4433734.84 276.79 14.00 17.67 1.51E-08 3.50 3.25

HR34 309423.8 4433747.03 274.57 14.00 30.81 1.63E-08 3.50 3.25

HR35 309435.83 4433692.24 280.15 14.00 38.44 5.03E-10 3.50 3.25

HR36 309426.1 4433753.19 274.50 14.00 47.61 1.98E-09 3.50 3.25

HR37 309469.11 4433798.59 274.23 14.00 28.20 1.98E-09 3.50 3.25

HR38 309449.29 4433823.61 273.33 14.00 26.47 1.98E-09 3.50 3.2523 HR39 309420.76 4433779.42 273.85 14.00 37.33 1.98E-09 3.50 3.25

HR40 309392.53 4433796.56 271.71 14.00 34.07 1.98E-09 3.50 3.25

HR41 309552.33 4433650.9 284.32 14.00 56.52 9.02E-09 2.93 2.72

HR42 309603.08 4433707.57 287.03 14.00 112.40 9.02E-09 2.93 2.72

HR43 309754.81 4433705.47 303.86 14.00 66.95 9.02E-09 2.93 2.72

HR44 309800.32 4433635.98 316.15 14.00 73.32 2.84E-08 2.93 2.72

HR45 309810.05 4433640.74 312.60 14.00 20.39 2.84E-08 2.93 2.72

HR46 309828.96 4433628 315.06 14.00 19.37 2.84E-08 2.93 2.72

HR47 309815.46 4433582.8 324.27 14.00 31.31 2.84E-08 2.93 2.72

HR48 309809.59 4433544.49 324.93 14.00 60.58 2.84E-08 2.93 2.72

HR49 309893.22 4433563.73 310.58 14.00 34.57 2.84E-08 2.93 2.72

HR50 309863.34 4433563.38 319.40 14.00 31.32 2.84E-08 2.93 2.72

HR51 309846.04 4433608.26 315.84 14.00 34.73 2.84E-08 2.93 2.72

HR52 309801.33 4433542.37 323.67 14.00 27.23 2.84E-08 2.93 2.72

HR53 309821.14 4433503.98 326.79 14.00 62.34 2.84E-08 2.93 2.72

HR54 309903.4 4433530.83 314.54 14.00 18.71 2.84E-08 2.93 2.72

Traffic fugitive emissions were quantified usi ng the Paved Roads section of Chapter 13.2.1 from AP-42 (EPA 2011). The equations in AP-42 require site specific data in cluding the fleet average vehicle weight, vehicle kilometers traveled, and a silt loading value for paved roads. The sitespecific silt and lead content sampling have recen tly been completed for a similar Exide facility in Vernon, California which is currently totally enclosed, consistent w ith the pending NESHAP. These parameters were used in the AP-42 equa tions to estimate the future traffic fugitive emissions on paved roads at the Canon Hollow facili ty when the enclosure project is completed. Exide conducted site-specific sampling for silt lo ading and lead content on the landfill at the Canon Hollow facility to estimate the emissions from dump trucks driving on the landfill. There was no evaluation of windblown lead emissions from the landfill since the Exide-Canon Hollow’s landfill is comprised throu ghout of a concrete-like substan ce that stabilizes and fixates the lead-bearing material contained within, pr eventing the surface from creating dust to be picked up by the wind. Furthermore, the tires of all trucks are washed before exiting the landfill to prevent track-out.

The version of the equation used for Exide’s future truck traffic fugitive emissions calculations takes precipitation into account by applying a corresponding correction term. This equation yields total suspended particulate (TSP) emission factors in grams per vehicle kilometer traveled (g/VKT) for each vehicle type and road surface as shown in Table 12

.

Table 12 - Paved Roads Emission Factor Equation for Daily Basis a

ܧ ௘௫௧ ൌ ݇ሺܮݏሻ ଴.ଽଵ ൈ ܹ ଵ.଴ଶ ሿሺ1 െ ܲ
4ܰ ሻ

Variable Description Value Units Roads Landfill24 k particle size multiplier for part icle size range and units of interest 3.23 g/VKT b

sL c road surface silt loading 0.23 327 g/m 2 W average weight of the vehi cles traveling the road 24.30 c 19.50 d ton

P e number of "wet" days with at least 0.254 mm (0.01 in) of precipitation during the averaging period 103.9 day

N number of days in the averag ing period (e.g., 365 for annual, 91 for seasonal, 30 for monthly) 365 day

E ext annual average particulate matter (TSP or PM-30) emission factor 20.40 12056.33 g/VKT

% Pb lead content 4.70 0.02
a Equation 2 from AP42, Fifth Edition, Volume I, Chapter 13, Section 13.2.1: Paved Roads ( http://www.epa.gov/ttn/chief /ap42/ch13/final/c13s0201.pdf ) b VKT = Vehicle kilometers traveled c,d Values were provided by ENVIRON and ta ke into account truck weight by type e Based on weather data collected from th e Brenner Field Airport, in Falls City, Nebraska, from 1981 to 2010, for the National Oceanic and Atmospheric Administration (NOAA) National Climatic Data Center. Source: http://www1.ncdc.noaa. gov/pub/data/normals/1981-2010/station- inventories/prcp-inventory.txt
The TSP emission factor for HR01 haul road, for example, was multiplied by the path length and number of passes per year in th e future facility configuration to estimate annual emissions of TSP. The percentage of particulate measured to be lead is then used to estimate the annual lead emissions from each roadway segment. The lead emission rates were then divided by the area of each area source for input to AERMOD. The lead emissions from each area source were distributed throughout the hours of the day based on the fraction of traffic through each road segment that occurs during restricted hours (7 AM – 7 PM) or unrestricted hours (24 hours per day) using the Hour of Day (H ROFDY) emissions scaling factor in AERMOD (Table 8 of the Modeling Report). An example of these sca ling factors that were used for HR01 is: SO EMISFACT HR01 HROFDY 0.027 0.027 0.027 0.027 0.027 0.027 0.027 SO EMISFACT HR01 HROFDY 1.973 1.973 1.973 1.973 1.973 1.973 1.973 SO EMISFACT HR01 HROFDY 1.973 1.973 1.973 1.973 1.973 0.027 0.027 SO EMISFACT HR01 HROFDY 0.027 0.027 0.027 ቀ	 ݏ݊݋݅ݏݏ݉݅ܧ	ܾܲ ݃

ݏ݉ ଶ ቁൌܧ
௘௫௧ ቀ ݃ ܶܭܸ ൬ܺቁ ܶܭܸ
ݎ݄ ൬ܺ൰ ݎ1݄
60݉݅݊ ൰ܺ൬ 1݉݅݊
60ݏ ൰ܺ൬ 1

ܽݎ݁ܽ ሺ ݉ ଶ ሻ ൰ ܺ	%ܾܲ

E ext (g/VKT) = 20.40 VKT/hr = 8.99E-02 for HR01 min/hr = 60 seconds/min = 60 Area (m 2 ) = 575.91 %Pb = 4.70% lead content on paved road

HR01 Pb Emissions = 20.40 X 8.99E-02 X 1/60 X 1/60 X 1/575.91 X 0.047 = 4.18E-0825 Figure 7 - Modeled Area Sources (Haul Roads)



### 5.4 Terrain Data Terrain elevations were incorporated in to the model using version 11103 of AERMAP, AERMOD’s terrain preprocessor, as per EPA guidance (2009). Te rrain elevation data for the entire modeling domain were extracted from 1/3- arc second National Elevation Data (NED) files with a resolution of approximately 10 meters . These NED files were obtained from the U.S. Geological Survey’s Seamless Data Serv er (http://seamless.usgs.gov). AERMAP was configured to assign elevations for all roadwa y volume sources and receptors in the modeling domain. Because the terrain varies across the facility, elevations of buildings ( Table 13 & Figure 8 ) and other sources above mean sea level were assigned based on data provided by Exide’s own surveying.26 Table 13 - Buildings Heights and Their Base Elevations

AERMOD Building ID Description Building Base Elevation (meters) a Building Height Above Grade (feet) a Building Height (meters) a

B01 Storage Area 284.38 22 6.71 B02 New Battery Storage 284.38 27 8.23 B03 Air Pollution System 284.99 60 18.29 B04 Main Office 271.27 12 3.66 B05 Shops 276.15 24 7.32 B06 Battery Recycling Area 282.24 21 6.40 B07 Smelting/Casting Area 277.37 35 10.67 B08 Charge Floor 284.99 30 9.14 B09 Slag Product Work Area 282.24 21 6.40 B10 Plate Storage Area, Ba ttery Breaking, Misc. 284.99 25 7.62 B11 Furnace/Refinery 284.99 21 6.40 B12 Dock Entry Building 283.77 23 7.01 B13 Battery Storage 283.77 27 8.23 B14 Stabilization Area, Slag Treatment, Slag Storage 277.06 25 7.62 B15 Reagent Building 276.15 25 7.62 B16 Finished Goods 276.15 25 7.62 B17 North Baghouse (BH-2) 282.24 43 13.11 B18 Demister Building 279.81 20 6.10 B19 South Baghouse (BH-1) 285.90 60 18.29 a Building heights and base elevations provided by Exide.27 Figure 8 - Exide’s Buildings


### 5.5 Building Downwash Building downwash algorithms incorporated into AERMOD account for the plume dispersion effects of the aerodynamic wakes and eddies produced by buildings and structures. The Building Profile Input Program - Plume Ri se Model Enhancements (BPIPPRM) model (incorporated into AERMOD) is used to dete rmine the direction-specific building downwash parameters. Buildings on Exide property including the new two baghouses structures ( Figure 5 ) were placed into the model then the BPI PPRM program (Version 04274) was executed on the point sources.


### 5.6 Meteorological Data Set No quality-assured on-site meteorological data was available during the development of this plan. The air dispersion modeling described in this section uses surface met data from the Brenner Field Airport (KFNB) near Falls Cit y, Nebraska about 22 miles west of the ExideCanon Hollow facility. For off-site met data, genera lly five years’ worth of complete data is used. As little as one year’s worth of data may be appropriate if quality-assured on-site met data is available. To this end, Exide has agreed to aid the State’s air quality analysis efforts by installing a 10-meter met tower at the Forest C ity levee monitoring site and operating the met station under a Quality Assurance Project Plan (QAPP). That ag reement is attached to this28 document as Appendix C . The Exide meteorological station became operational in about April 2014. This met data will be used for trend data and for any future air dispersion modeling, should it become necessary.

AERMOD requires a meteorological input file to characterize th e transport and dispersion of pollutants in the atmosphere. Surface and upper air meteorological data input s as well as surface parameter data describing the land use and surface characteristics near the site were first processed using AERMET, the meteorological preprocessor to AERMOD. The output files generated by AERMET are the meteorological in put files required by AERMOD. Details of AERMET and AERMOD meteorological data need s are described in EPA guidance documents (EPA 2004a, 2004b).

Based on EPA modeling guidance, it is preferable that one year or more, up to five years, of onsite meteorological data be used in the disp ersion modeling exercise (40 CFR Part 51 Appendix W (November 2005)). EPA’s Meteorological Monitoring Guidance for Regulatory Modeling Applications (EPA 2000) describes the criter ia that should be considered when siting meteorological instruments for modeling purpos es. Typically, wind instruments should be placed on a boom that is located at least two meters away from an open lattice ten-meter tower in an area that is free from obstructions. The pl acement of wind instrume nts on buildings, cooling towers or stacks should be avoided due to the potential for downwash influences. The effect on the wind speed and direction can be significant an d can result in non-repres entative, poor quality data. If an instrument is placed on a building, the probe would have to be clear of any wake zones that are present and should be representati ve of the conditions that are occurring at the point of release (minimum of ten meters). Due to the fact that Exide’s meteorological station is located on a roof of a building, it was determined that data collected by it is not appropriate for a SIP attainment demonstration modeling evaluati on, and the collection of one year of on-site meteorological data is not feasible at this ti me. Instead, meteorological data collected at a representative airport was used for the SIP modeling analysis.

The Air Program evaluated three airports’ mete orological data (Kansa s City International Airport, Rosecrans Memorial Air port, and Brenner Field located near Falls City, Nebraska) to determine which data most closely represent cond itions at the facility. These airports were selected due to their proximity to Exide. Ot her airports, located fart her away, have weather patterns which were deemed different from that of the facility.

By taking into account the distance from the s ite and comparing the surface roughness, albedo, and Bowen ratio at each airport to those parameters at the site, the Air Program determined that the characteristics of the Brenner Field Airport station (KFNB), in Nebraska, most closely resembles those at Exide. Therefore, Brenner meteorological data was used in this modeling exercise. The Airport Selection Analysis may be found in Appendix E . Wind speed, wind direction, ambient temperature, atmospheric pre ssure, and cloud cover data were chosen from KFNB the five years from 2007 to 2011 as the most representative available data for use in the air dispersion analysis of the Exide facility.

The 2007 to 2011 surface data for KFNB were pr epared using TD-3505 surface data and TD6805 AERMINUTE data. The data were proces sed using the AERMET meteorological data29 processor (version 13350). Upper air data for the peri od of 2007 to 2011 was selected by the Air Program from the Topeka, KS Airport stati on (KTOP). KTOP was chosen based on its proximity to both Brenner Field and the facility.



### 5.7 Receptors With exception of the path of Canon Hollow Ro ad, ground-level lead concentrations located inside the facility boundaries were excluded from the impact assessment because the general public does not have ready access to the Exide property. The Exide property within the fenced perimeter was considered on-site for purposes of determining the property line as recommended by the Air Program and EPA. Ground level rece ptors along the property line and Canon Hollow Road were placed at 10-meter and 25-meter spacing intervals respectively ( Figure 9 ). All denoted property boundaries will be fenced to pr eclude public access. It should be noted that Exide has elected to use these zones of public access preclusions as the ambient air/receptor boundaries instead of the property boundary outlined in Figure 1

. In addition to the fence line receptors, a Cartes ian grid of receptors with 50-m spacing extending from the fence line to approximately 250-m beyond the fence line was utilized. Receptors with 100-m spacing were extended from approximate ly 250 m to 500 m beyond the fence line. Lastly, a receptor grid with 200-m spacing wa s extended from approximately 500 m to 1000 m beyond the fence line. Additional 10-m grid spacing was utilized around the area of highest concentration ( Figure 11 ). In addition to the aforementioned fence line and gridded discrete receptors, one ground-level, discrete receptor wa s placed at the approximate location of the ambient lead monitor, located southwest of the site (UTMx = 309221, UTMy = 4433181). All receptor elevations and Hill Height Scales were assigned by AERMAP (Version 11103) using NED 1/3 Arc Second resolution elevation data fro m USGS’s Seamless Data Server. Refer to ENVIRON’s modeling report ( Appendix D ) for additional aerial photos of the receptors and property boundary.30 Figure 9 - Exide’s Modeling Receptors



### 5.8 Model Input, Output, and Results All AERMOD model system input and im pact output files are included in Appendix F

. The input files include background concentration for all receptors 24 hours and monthly lead concentrations. The monthly lead concentr ations were post-processed using LEADPOST
program.


### 5.9 Background Lead Concentration

Per EPA’s Guideline on Air Quality Models [40 CFR 51 Appendix W] background concentrations must be considered when de termining compliance with the NAAQS. Background concentrations include impacts attributable to natural sources, nearby sources (excluding the dominant source(s)), and unide ntified sources. This calcul ated background concentration includes all sources of lead not already explicitly included in the model. However, the assumption that emissions from the plant do not contribute to background concentrations is not entirely correct. Contributors to the background concentration are distant sources of lead, which may have originally derived from the plant, m obile and nonpoint sources, or naturally occurring lead in the atmosphere. Nonpoint and mobile sources from the 2011 NEI were reviewed. The data indicates that 2011 nonpoint and mobile so urces combined make up approximately 0.08%31 of the point source emissions tota l in 2012, and as such are not included in the modeling exercise as discreet sources but may infl uence the background concentration.

In general, the background value is calculated by averaging the monitored concentrations at one or more monitoring sites outside the area of immediate dominant source impact and on days when the predominant wind direction was not blowing from the dominant source to the monitor(s). In this case all monitored days were reviewed to identify days with no measured one-hour average wind direction co ming from the facility. This was accomplished by excluding days when any one-hour wind average was from th e Exide property to the Forest City levee monitoring site. The monitor was examined in conjunction with an acceptable wind fan and the concentrations were averaged on days with no predominant winds from the facility. The resultant concentration from a ll the monitors in the evaluatio n is the background concentration for the area.

Ambient monitoring for lead near the Exide Technologies-Canon Hollow facility began in May 2012 for low-volume lead-in-PM10 sampling (Pb-PM10) and in August 2012 for hi-volume lead-in-TSP sampling (Pb-TSP). The Air Progr am calculated Exide’s background concentration by averaging the hi-volume ambien t monitoring data near the facility on days in which the monitor was upwind of the facility and there was a minimum of 2 m/s wind speed to preclude the inclusion of calm conditions. The monitor would be upwind of the facility on days in which there were no one-hour wind averages blowing from the facility toward the monitor. Therefore, monitored values that include d corresponding winds from the 90 degree sector upwind of the monitor location were excluded from consideration as a repr esentative background value (40 CFR 51 Appendix W Section 8.2.2(b)). Winds from this sector were defined as those between 350 degrees and 80 degrees, where zero degree was defined as true no rth. However, this sector included days with high concentrations that were suspected to be coming from the facility. These days with their correspondi ng concentrations are 09/18/2012 (1.33  g/m 3 ), 10/06/2012 (0.8  g/m 3 ) and 12/17/2012 (  g/m 3 ). The resulting calculated background concentration from this sector was 0.195  g/m 3 which is higher than the lead NAAQS.

To reduce Exide’s influence on the monitor during th is background concentr ation analysis, the Air Program evaluated the sector from 300 degrees to 80 degrees ( Figure 10 ). This excluded HWY 11 and Canon Hollow road from considera tion in the background, which required these emission sources to be included in the model. In addition, HWY 111 along the facility fence and Canon Hollow Road section leading to the facility’s gate were modeled as area sources to make sure any dust blown by truck traffic in these tw o roads is accounted for in the overall lead concentration from the facility. Figure 10 shows ambient monitor, th e facility, and the proposed wind directions to exclude fr om the background calculation.

Six concentrations resulted fr om this sector as shown in Table 14 . The average of these six concentrations, 0.023  g/m 3 , is the background concentration.

Table 14 - TSP Monitoring Data for Days Exide had no Contribution Date 11/17/2012 01/4/2013 02/09/2013 06/21/2013 08/20/2013 08/26/2013 Average Concentration 0.021 0.020 0.016 0.034 0.027 0.019 0.02332 The estimation of background is conservative and provides a margin of safety when combined with the modeled maximum receptor concentration. The conservative nature for this method of background determination is due to the potenti al for some double-acc ounting: the background inclusion zones are very gener ous and could also include non -predominant periods of winds from the direction of the facility or modeled sources within the hourly averaging period. In other words, the chosen hourly wind averages do not elim inate all wind directions and influences from the plant to the monitor.

Figure 10 - Exclusion Zone for Calcul ating Background Concentration



### 5.10 Post Processing in LEADPOST The averaging period chosen fo r this model was monthly as recommended by EPA (2009d) for use with EPA’s LEADPOST software program. The POST files were processed through the LEADPOST program to calculate three month av erage lead concentra tions for each receptor location. The software created output text f iles corresponding to to tal receptor average concentrations across all source groups (a Sour ce Group ALL was created to represent facilitywide emissions).33 

### 5.11 Description of Modeling Results The LEADPOST output file of modeled maxi mum three month rolling average lead concentrations for all source groups were a dded to the background concentration (that was determined according to the steps described in section 5.8 of this document), to determine the cumulative impact at each receptor. Table 15 shows the maximum impacted receptor located northwest of the facility with a concentration of 0.1498  g/m 3 . No receptors violated the lead NAAQS as shown in the table. Figures 11 and 12 show the location of the highest impacted receptor and the lead concentrations contour plot around Exide, respectively.

Table 15 - Maximum 3-Month Average Lead Concentration
XCoordinate (m) Y-Coordinate (m) Modeled Concentration (  g/m 3 ) Background Concentration (  g/m 3 ) Total Concentration (
 g/m 3 ) NAAQS for Lead (  g/m 3 ) 309169.66 4434082.50 0.126837 0.023 0.149837 0.15

Figure 11 - Location of Maximum Mode led Concentration Receptor34 Figure 12 - Contour Plot of Lead Concentrations around Exide



## 6. CONTINGENCY MEASURES As part of this plan, a conti ngency strategy has been developed that will be implemented in the event that the area has failed to attain and maintain the 2008 Lead NAAQS 180 days after the effective date of the Consent Judgment and the implementation of the new control measures. The contingency plan is detailed in Para graph V. 9. of the Consent Judgment ( Appendix A ). The department shall notify Exide of any violations of the NAAQS and to start implementation of any necessary contingency measures.

The contingency measure strategy consists of two pa rts. The first part is a measure that may be implemented immediately after a ny rolling three-month average vi olates the 2008 lead standard. The second part is a study to identify likely causes contributin g to the violation followed by implementation of a proposed action plan of the most effective control measures.

Immediately after notifica tion that the lead air quality monitori ng results for the Forest City area show a violation of the 0.15 μ g/m 3 three-month rolling average lead standard, Exide shall increase the in-plant road cleaning to 10 hours e ach working day. Currently, plant roadways and parking lots are cleaned with wet wash or vacu um cleaning at least twice a day between 7 am35 and 7 pm [Exide Fugitive Dust Source SOP Manual, pg. 2, Appendix B ]. The implementation of this contingency measure is expected to preven t the re-entrainment of at least 7 pounds of lead dust per year into the air. Exide may cease this increased road cleaning schedule only after a more effective replacement contro l measure has been identified and implemented as a result of the fugitive dust control study in the second phase of the contingency strategy as outlined below.

There are few other remaining effective lead em ission reduction techniques to be used as contingencies remaining at this facility. The limite d control options that were still available form the basis of the main control strategy used to dem onstrate attainment within this plan. Therefore, the second phase of this plan’s contingency stra tegy involves a study or revi ew of best practices and best available technologies at facilities with similar fugitive emissions control challenges. The purpose of this contingency project is to help pinpoint the source of the errant fugitive emissions and to implement the identified measures in the future (if needed) as close as possible to the time the contingency measure triggering even t occurs. This project’s concept is the same as the contingency project adopted as part of the EPA-approved 2007 Herculaneum Lead SIP revision. Missouri asserts that a comprehensive evaluation of all known lead emissions sources has already been accomplished and that sufficient levels of controls wi ll be implemented by the control measures section of this plan to at tain the lead standard. However, any ongoing violations of the NAAQS (triggering this contin gency measure) would indicate that another evaluation of fugitive emissions would be need ed. This contingency project will allow additional strategies to be identi fied to meet the 2008 lead standa rd in light of the new conditions created after the implementation of all required contro ls as part of this atta inment demonstration.

Furthermore, the Consent Judgment allows for the submission of additional new contingency measures when other contingency measures (ide ntified by the fugitive control study contingency project) have been exhausted.



## 7. PUBLIC PARTICIPATION In accordance with Section 110(a)(2) of the C AA, the Missouri Air Conservation Commission is required to hold a public hearing prior to adoption of this plan and the subsequent submittal to the EPA. The department will notify the public and ot her interested par ties of an upcoming public hearing and comment period thirty (30) da ys prior to holding such hearing for this SIP revision as follows:

 Notice of availability of the SIP revisi on was posted on the Department of Natural Resources’ Air Pollution Control Program website on July 28, 2014: http://www.dnr.mo.gov/env/apcp /stateplanrevisions.htm

 The public hearing was held on August 28, 2014 be ginning at 9:00 a.m. at the Elm Street Conference Center, in Bennett Springs C onference Room, 1730 East Elm Street, Jefferson City, MO 65101.

 The public comment period for the plan opened when it was posted on the Department of Natural Resources’ Air Pollution Control Prog ram website on July 28, 2014, and closed on September 4, 2014, seven days after the public hearing.36 

## 8. CONCLUSION The department hereby asserts that the State has met its CAA Secti on 110 obligations to attain and maintain the 2008 Lead NAAQS in all areas of the State (not designated as nonattainment) including, specific ally through this plan, the ar ea in the vicinity of Forest City, MO. The near by Exide Technologies–Canon Holl ow secondary lead smelting facility has added emission co ntrols pursuant to the Seco ndary Lead Smelting NESHAP [40 CFR 63 Subpart X revised as of January 5, 2012] and in conjunction with this plan, has agreed, through a court-lodged consent judgment, to additional emission reductions to include emission limitations and work practic es. These control strategies combine to demonstrate attainment of the 2008 Lead NAAQS in the area though air dispersion modeling included in this plan. Furthermore, this plan contains a contingency strategy to act as a backstop in case of a continued NAAQS violation after implementation of the control measures.

### The Missouri Air Conservation Commission 

### ADOPTS the following action

on this 25th day of September, 2014:

Missouri State Implementation Plan Revision

- 2008 Lead National Ambient Air Quality Standard Compliance Plan

- Exide Technologies Canon Hollow Facility

# ,,z!; / '0

# )**"' ""** **~:4 -1** **--, RL=·**  == ======= ==----, Chairman

_________________ , Vice Chairman

_________________ ,Member

__________________ ,Member

__________________ ,Member

__________________ ,Member----------------------------------

---------------------------------- 

### The Missouri Air Conservation Commission 

### ADOPTS the following action

on this 25th day of September, 20] 4:

Missouri State Implementation Plan Revision

- 2008 Lead National Ambient Air Quality Standard Compliance Plan

- Exide Technologies Canon Hollow Facility

, Chairman

, Vice Chairman

, Member

__________________________________ ,Member

__________________________________ ,Member

__________________________________ ,Member

__ ________________________________ ,Member

### The Missouri Air Conservation Commission 

### ADOPTS the following action

on this 25th day of September, 2014:

Missouri State Implementation Plan Revision

- 2008 Lead National Ambient Air Quality Standard Compliance Plan

- Exide Technologies Canon Hollow Facility

_________________ " Chairman

__________________ , Vice Chairman

_________________ ,Member

# e(;A**~:,** Member

# ----=--**'t--f-**

_________________ ,Member

____________________ ,Member

_ ____________ .

____ :, Member1 Bechtel, Cheri

From: Missouri DNR <MODNR@public.govdelivery.com> Sent: Saturday, July 26, 2014 8:10 AM To: Bungart, Renee; Archer, Larry; Lovejoy, Victoria ; Moore, Kyra; Vit, Wendy; Bechtel, Cheri; Crawford, Betsy; Terlizzi, Gena Subject: Courtesy Copy: Air Public Notices Update - Missouri Air Conservation Commission Public Hearing, August 28, 2014

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MISSOURI AIR CONSER VATION COMMISSION WILL HOLD PUBLIC HEARING
JEFFERSON CITY, MO -- The Missouri Air Conser vation Commission will hol d a public hearing on Thursday, August 28, 2014 beginning at 9 a.m. at the Elm Street Conference Cent er, 1730 East Elm Street, Lower Level, Bennett Springs Conference Room, Jefferson City, Missouri. The commission will hear testimony related to the fo llowing proposed action(s):
* Missouri State Implementation Plan – 2008 Lead NAAQS Compliance Plan – Exide Technologies Canon Hollow Facility

As required by Section 110(a) of the Clean Air Act, Missouri’s Stat e Implementation Plan (SIP) must ensure attainment and maintenance of all National Ambient Air Quality Standards (NAAQS). The Missouri Department of Natural Resources’ Air Pollution Control Pr ogram is proposing to amend and strengthen the Missouri SIP to address violatio ns of the 2008 Lead (Pb) NAAQS of 0.15 micrograms per cubic meter ( μ g/m 3 ), based on a rolling three-month average. These violations are located in the vicinity of Forest City in Holt County, MO near the Exide Technologies Canon Hollow Secondary Lead Smelting Facility. This plan was developed in conjunction with the revised National Emission Standards for Secondary Lead Smelters [40 CFR 63 Subpart X] which took effect on January 6, 2014. The SIP revision includes an attainment demonstrat ion using air dispersion modeling and a consent judgment containing emission limita tions and contingency measures.

If the Commission adopts th e action, it will be the Department’s inte ntion to submit the action to the U.S. Environmental Protection Agency to be includ ed in Missouri’s State Implementation Plan.2 Documents for the above item(s) will be av a ilable for review at the Misso uri Department of Natural Resources, Air Pollution Control Pr ogram, 1659 Elm Street, Jefferson Cit y, (573) 751-4817 and in the Public N otices section of the program web site http://dnr.mo.gov/env/ap cp/public-notices.htm . This information will be available at least 30 days pr ior to the public hearing date.
The Department will accept written or email comments for the record until 5 p.m. on September 4, 2014. Please send written comments to Chief, Air Quality Planning Section, Air Polluti on Control Program, P.O. Box 176, Jefferson City, MO 65102-0176. Email comments ma y be submitted via the program web site noted above. All written and email comments and public hearing testimony will be equally considered.

Citizens wishing to speak at the public hearing should notify the secretary to th e Missouri Air Conservation Commission, Missouri Department of Natural Resour ces, Air Pollution Control Program, P.O. Box 176, Jefferson City, Missouri 65102-0176, or telephone ( 573) 526-3420. The Department requests persons intending to give verbal presenta tions also provide a wr itten copy of their testimony to the commission secretary at the time of the public hearing.

Persons with disabilities requiring special services or accommodations to attend the meeting can make arrangements by calling the Program di rectly at (573) 751-4817, the Divisi on of Environmental Quality's toll free number at (800) 361-4827, or by writing two weeks in advance of the meeting to: Missouri Department of Natural Resources, Air Conservation Commissi on Secretary, P.O. Box 176, Jefferson City, MO 65102. Hearing impaired persons may contact the program through Relay Missouri, (800) 735-2966.

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.Jay Nixon, Governor Sara Parker Pauley, Director 

## Air Pollution Control Program

State Plan Actions

On Public Notice | Proposed fo r Adoption

On Public Notice

Missouri State Implementation Plan Revisi on – 2008 Lead NAAQS Compliance Plan – Exide Technologies Ca non Hollow Facility

As required by Section 110(a) of the Clean Ai r Act, Missouri’s State Implementation Plan (SIP) must ensure attainment and maintena nce of all National Ambient Air Quality Standards (NAAQS). The Missouri Department of Natural Resources’ Air Pollution Control Program is proposing to amend and strengthen th e Missouri SIP to address violations of the 2008 Lead (Pb) NAAQS of 0.15 mi crograms per cubic meter ( μ g/m 3 ), based on a rolling three-month average. These violations are lo cated in the vicinity of Forest City in Holt County, MO near the Exide Te chnologies Canon Hollow Second ary Lead Smelting Facility. This plan was developed in conjunction with the revised National Emission Standards for Secondary Lead Smelters [40 CFR 63 Subpart X] which took effect on January 6, 2014. The SIP revision includes an atta inment demonstration using ai r dispersion modeling and a consent judgment containing emission limitations and contingency measures.

2008 Lead NAAQS Compliance Plan – Exide

Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F

Submit Comments Now

A public hearing is scheduled for th is plan action on August 28, 2014. Comments about this plan action will be accept ed through the close of business on September 4, 2014. Pa g e 1 of 3 State Plan Actions on Public Notice - DN R

7/28/2014 htt p ://dnr.mo. g ov/env/a p c p /state p lanrevisions.htmProposed for Adoption

Missouri State Implementation Plan Revision – Regional Haze Plan 5-Year Progress Report

The federal Clean Air Act establishes requirements for the protection of visibility in Class I areas, consisting of national parks and wilderness areas. States are required to submit state implementation plans (SIPs) that demo nstrate reasonable prog ress toward meeting the national goal of a return to natural visibility condit ions in Class I areas by 2064. There are two Class I areas in Missouri: Hercules Glades Wilderness Area and Mingo National Wildlife Refuge. Missouri’s regional haze SIP, which was submitted to the U.S. Environmental Protection Agency in August 2009, established vi sibility goals for the year 2018 for each of the state’s Class I areas in or der to make reasonable progress toward the 2064 goal. The purpose of this report is to asse ss progress made toward the 2018 visibility goals in Hercules Glades and Mingo in the five years since Missouri’s regional haze SIP was submitted to EPA. This 5-year progress report demonstr ates that both of Missouri’s Class I areas are expected to meet their 2018 visibility goals based on contro l strategies currently in place, which largely consist of sulfur di oxide and nitrogen oxides emission reduction measures for utilities, industri al boilers, and other sources.

Regional Haze Plan 5- Year Progress Report Appendices

A public hearing for this plan action was held on May 29, 2014. Comments about this plan action were accepted through the close of business on June 5, 2014.

Missouri State Implementation Plan Revision – Marginal Area Plan for the Missouri Portion of the St. Louis Nonattainment Area for the 2008 8-Hour Ground Level Ozone National Ambient Air Quality Standard

The purpose of this State Implementation Plan (SIP) revision is to address the emissions inventory and other marginal ozone nonattainme nt area requirements pursuant to Clean Air Act Section 182(a) for the Mi ssouri portion of the St. Louis nonattainment area under the 2008 8-hour ozone national ambient air quality standard (NAAQS). The Missouri portion of the St. Louis nonattainment area includes the City of St. Louis and the Counties of St. Louis, St. Charles, Franklin, and Jefferson , which were designated as a marginal nonattainment area under the 2008 8-ho ur ozone NAAQS on May 21, 2012.

Marginal Area Plan for the Missouri Portion of the St. Louis Nonattai nment Area for the 2008 8-Hour Ground Level Ozone Nation al Ambient Air Quality Standard

Appendix A Appendix B

Appendix B-1 Appendix B-2 Appendix B-3 Appendix B-4 Appendix B-5 Pa g e 2 of 3 State Plan Actions on Public Notice - DN R

7/28/2014 htt p ://dnr.mo. g ov/env/a p c p /state p lanrevisions.htmAppendix B-6 Appendix B-7

A public hearing for this plan action was held on May 29, 2014. Comments about this plan action were accepted through the close of business on June 5, 2014.

Back to top Pa g e 3 of 3 State Plan Actions on Public Notice - DN R

7/28/2014 htt p ://dnr.mo. g ov/env/a p c p /state p lanrevisions.htmPUBLIC HEARING 8/28/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334 MIDWEST LITIGATION SERVICES Page 1

1 BEFORE THE MISSOURI AIR CONSERVATION COMMISSIO N

2

3

4 IN RE:
Missouri State Implementation Plan - 2008 Lead Nati onal
5 Ambient Air Quality Standard Compliance Plan - Exide
Technologies Canon Hollow Facility

6

7 PUBLIC HEARING
8 August 28, 2014
Lewis and Clark State Office Building

9 1101 Riverside Drive
LaCharrette and Nightingale Conference Room
10 Jefferson City, MO 65101

11

12 Before:
13 Gary Pendergrass - Chair

Jack Baker - Member

14 Mark Garnett - Member

David Zimmermann - Member

15

16

17 THE COURT REPORTER:

18 Jenna Petree

MIDWEST LITIGATION SERVICES

19 401 Locust Street

Columbia, MO 65201

20 573-449-0561

21

22

23

24

25PUBLIC HEARING 8/28/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334 MIDWEST LITIGATION SERVICES Page 2

1 PROCEEDINGS

2 MR. PENDERGRASS: The hearing will co me to

3 order. Let the record show the following commissi oners are

4 present: Jack Baker, Mark Garnett, Gary Pendergras s, and

5 David Zimmermann. The Air Conservation Commission of the

6 State of Missouri has called this public hearing p ursuant

7 to Section 643.070, Revised Statutes of Missouri; EPA

8 promulgated Rule 40 CFR 51.102, for the purpose of hearing

9 testimony relating to: Missouri State Implementati on Plan

10 Revision - 2008 Lead NAAQS Compliance Plan Exide

11 Technologies Canon Hollow Facility.

12 The hearing record will close at 5:0 0 p.m. on

13 September 4, 2014. Anyone who has not been sched uled to

14 appear but who wishes to be heard should indicate that you

15 wish to speak on the sign-in sheets available at the door.

16 Section 643.100 of the Missouri Stat utes

17 provides that all oral testimony be given under o ath.

18 Accordingly, when you called to testify, please p resent

19 yourself to the court reporter first to be sworn in. When

20 you testify, please state your name, business add ress, and

21 your occupation or affiliation. If are you have a prepared

22 a statement, it will be helpful if you will provi de a copy

23 to the Staff Director, court reporter, and member s of the

24 Commission.

25 Ms. Kyra Moore.PUBLIC HEARING 8/28/2014

www.midwestlitigation.com Phone: 1.800.280.3376 Fax: 314.644.1334 MIDWEST LITIGATION SERVICES Page 4
1 MR. WINKELMANN: Mr. Chairman, member s of the

2 Commission. My name is Joe Winkelmann. I am empl oyed as

3 an Environmental Engineer with the Missouri Depart ment of

4 Natural Resources' Air Pollution and Control Progr am. I

5 work at 1659 East Elm Street, Jefferson City, Miss ouri.

6 I am here today to present testimony on the

7 proposed Missouri State Implementation Plan or SIP revision

8 entitled 2008 Lead National Ambient Air Quality St andard

9 (NAAQS) Compliance Plan for the Exide Technologies -Canon

10 Hollow Facility. The summary for the plan starts on page

11 77 of the briefing document.

12 As required by Section 110(a) of the federal

13 Clean Air Act, Missouri's SIP must ensure attainm ent and

14 maintenance of all NAAQS. The purpose of this co mpliance

15 plan is to amend and strengthen the Missouri SIP to address

16 violations of the 2008 lead NAAQS, which is 0.15 micrograms

17 per cubic meter averaged over three months. The violations

18 occurred at the Forest City levee lead air qualit y

19 monitoring site in Holt County, Missouri near the Exide

20 Technologies-Canon Hollow Secondary Lead Smelting Facility.

21 This plan was developed with the consensus and co operation

22 of the Missouri Department of Natural Resources' Air

23 Pollution Control Program, Exide Technologies, U. S.

24 Environmental Protection Agency Revion VII and th e Missouri

25 Attorney General.RECOMMENDATION FOR ADOPTION

PROPOSED REVISION TO

MISSOURI STATE IMPLEMENTATION PLAN –

2008 LEAD (PB) NATIONAL AMBIENT AIR QUALITY STANDARD (NAAQS) COMPLIANCE PLAN

– EXIDE TECHNOLOGIES-CAN ON HOLLOW FACILITY

On August 28, the Missouri Air Conservation Commi ssion held a public hearing for a revision to the Missouri State Implementation Plan (SIP) titled

– 2008 Lead (Pb) National Ambient Air Quality Standard (NAAQS) Compliance Plan – Exide Technologies-Canon Hollow Facility . A summary of comments received and the Air Pr ogram’s corresponding responses is included on the following page. Revisions were made to the proposed plan as a result of comments received.

The revised plan has not been reprinted in the briefing document due to its volume. The entire revised plan is available for review at the Missouri Departme nt of Natural Resources’ Air Pollution Control Program, 1659 East Elm St reet, Jefferson City, Missouri, 65101, (573)751- 4817. It is also available online at http ://dnr.mo.gov/env/apcp/stateplanrevisions.htm.

The Air Program recommends the commission adopt the plan as revised. If the commission adopts this plan, it will be the department’s in tention to submit it to the U.S. Environmental Protection Agency for inclusion in th e Missouri State Implementation Plan.COMMENTS AND RESPONSES ON

PROPOSED REVISION TO

MISSOURI STATE IMPLEMENTATION PLAN –

2008 LEAD (PB) NATIONAL AMBIENT AIR QUALITY STANDARD (NAAQS) COMPLIANCE PLAN – EXIDE TECHNOLOGIES-CAN ON HOLLOW FACILITY

The public comment period for the proposed revisi on to the Missouri State Implementation Plan (SIP) titled 2008 Lead (Pb) National Ambient Air Qua lity Standard (NAAQS) Compliance Plan – Exide Technologies-Canon Hollow Facility opened on July 28, 2014 and closed on September 4, 2014. Revisions to the proposed plan we re made as a result of comments.

The following is a summary of comments recei ved and the Missouri Department of Natural Resources’ Air Pollution Control Program’s (A ir Program’s) corresponding responses. Any changes to the proposed plan are in cluded in the response to comments.

SUMMARY OF COMMENTS: During the public comment period for the proposed plan, the Air Program received comments from 3 s ources: Dr. Rex McAliley, U.S Environmental Protection Agency (EPA) and Exide Technologies (Exide). Dr. McAliley submitted written comments in addition to his verbal testimony.

COMMENT #1: Both EPA and Exide commented in support of the proposed plan. EPA noted the high level of coordination involve d in the plan’s development a nd emphasized that the plan came together without the Federal issuance of a nonattainment designation or SIP call.

RESPONSE: The Missouri Departme nt of Natural Resources’ Air Pollution Control Program (Air Program) appreciates the comment ers’ support and cooperation duri ng the development of this plan. As noted by EPA, this compliance plan was developed proactively, pursuant to Section 110 of the federal Clean Air Act (CAA), to attain and maintain the 2008 lead NAAQS in the vicinity of Forest City and prior to the i ssuance of a formal nonattainment designation by EPA. Since the area has not been designated nona ttainment, certain provisions of CAA Section 172, such as a formal attainment demonstration, are not required of this plan. None theless, to make this plan as robust as possible and to be consis tent with the State’s other lead SIPs, this plan demonstrates attainment using air dispersion modeling based on the most conservative assumptions (worst-case scenarios) and the best available data. The plan includes a continge ncy measure strategy in case of any further violations of the lead standard. No ch anges to the plan were made as a result of this
comment.

The remaining comments were all made by Rex McAliley, Ph.D.:

COMMENT #2: Dr. Rex McAliley, a university professor and form er environmental consultant, having an interest in regional air quality expresses general concerns about the Exide-CanonHollow secondary smelter in Holt County as a resident of nearby Nodaway County. One concern is that the company’s Ch apter 11 bankruptcy last year may affect Exide’s ability to fund pollution control measures.

RESPONSE: The Air Program encourages public participation and appreciates the commenter’s concerns about air quality.

All the control projects used to demonstrate attain ment in this plan have already been installed including those required by the revised fede ral Maximum Achievable Control Technology (MACT) regulation for secondary lead smelte rs promulgated on January 5, 2012. The monitored values have so far not recorded a viol ation of the 2008 lead air quality standard since the implementation of the control strategy of this plan. Furthermore, Exide has expressed its commitment to maintaining environmental complia nce throughout the bankruptcy process. The Consent Judgment portion of this SIP revi sion makes that commitment permanent and enforceable for the controls relevant to this plan.

No changes to the plan were made as a result of this comment.

COMMENT #3: The commenter raises several concerns ab out the location of Forest City levee monitoring site. He notes reasons why the site is not ideal because of the direction of the prevailing wind, topography, and other siting criteria. Because of the location of the plan’s maximum modeled result, he suggests a monitor location to the Northw est of the facility.

RESPONSE: The Missouri ambient air monitoring network is designed by the State of Missouri and approved by US EPA Region VII consistent with 40 CFR 58 through the annual Monitoring Network Plan proposal and approval process cited in 40 CFR 58.10. The Air Program’s 2011 Monitoring Network Plan [ http://dnr.mo.gov/env/apcp/docs/2011monitoringnetwork.pdf ] describes the rationale for resuming monitori ng in the area surrounding the Exide Canon Hollow facility and the 2012 Monitoring Network Plan [ http://dnr.mo.gov/env/apcp/doc s/2012monitoringnetwork.pdf ] discusses the monitoring site selection process. Both monitoring network plans are approved by EPA.

Although the plan’s modeling results suggest that the estimated area of maximum airborne lead impact from the facility’s current emission sources is to the Northwest of the smelter, this area is densely forested and close to the facility fence line. Based on EPA’s network design requirements for lead ambient air monitoring, 40 CFR 58 Appendix D, paragraph 4.5, the State can take into account the logistic s and potential for population expos ure. The logistical issues related to installing a monitoring station in this area include the removal of a wide tract of trees and other land disturbance activ ities to facilitate appropria te monitoring siting criteria, installation of electrica l power, and potential construction of gravel roads to access the site. Additionally, population exposure in this area appears unlikely now and for the foreseeable future since this property is owned by the Exide facility. Relying on regulatory dispersion modeling to characterize airborne lead impacts is appropriate for this area where monitoring is logistically difficult

.The Exide Levee ambient air monitoring site [EPA’s Air Quality System (AQS) Site ID: 29-087- 0008] is located approximately southwest of the sm elter facility in an area that is subject to public access and considered in the ambient air. Analyses conducted by Air Program staff indicates that calm wind conditions tend to correlate with increasing airborne lead concentrations which suggests fugitive emissions are likely to be monitored at the Levee site despite the predominant wind direction. See Chart 1 below. This weight of evidence supports the continued use of the levee site as an indicator of how effective the new emission controls and management practices are at cont rolling fugitive airborne lead emissions and provide airborne lead data for demonstrating that the area meets the lead NAAQS.

No changes to the plan were made as a result of this comment.0% 5% 10% 15% 20% 25% 30% 35%

0.000 0.200 0.400 0.600 0.800 1.000 1.200

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29PercentCalmWindConditions(Forthe24‐hoursamplingEvent)LeadConcentration(μg/m3)

24

‐ hour Sampling Event Rank Ordered by Increasing % Calm Wind Conditions (Note: Sample for sampling event 20 was void) 

## 24

‐ Hour Airborne PM 10 

## Lead Concentrations vs. % Calm Wind Conditions. Exide

‐ Forest City Levee Monitor

Lead Concentration ug/m^3 2008 Lead NAAQS % Calm Conditions (% < 3 mph)

Chart 1 24-Hour Airborne PM10 Lead Concentrations vs. % Calm Wind Conditions at the Exide- Forest City Levee MonitorCOMMENT #4: The commenter noted that the T oxic Release Inventory (TRI) data reported by this facility showed no information for arseni c despite other information from EPA showing 5.5 pounds per year of arsenic emissions.

RESPONSE: The TRI data is reported by the fa cility to the national TRI database which is maintained by EPA. The Air Program is not re sponsible for quality assurance of the TRI submissions, so we have no additional response re garding the TRI data. No changes to the plan were made as a result of this comment.

COMMENT #5: The commenter asks for a review of the modeling since it results in such a small margin of attainment and because Exide has updated the way it repo rts fugitive emissions in recent years.

RESPONSE: This comment is refe rencing Exide’s reported emi ssions on the Emission Inventory Questionnaire (EIQ). Exide is required by State rule 10 CSR 10-6.110 Reporting Emission Data, Emission Fees, and Process Information to submit actual emissions on an annual basis in the form of an EIQ. This plan demonstrates modeled at tainment with the lead NAAQS through conservative assumptions and worst-case scenario modeling, which includes a modeling inventory that was developed separately from the EIQ. The plan’s modeling effort is an independent accounting of potential emissions from all area, point and volume sour ces of lead at the facility. Therefore, Exide’s previous accounting and reporti ng of actual fugitive emissions for the EIQ was not used in the model development. Furthermore, the plan contains a cont ingency measure strategy to act as a backstop in case of any future vi olations of the 2008 lead NAAQS. No changes to the plan were made as a result of this comment.

COMMENT #6: Dr. McAliley commented that no baseline assessment or base case modeling analysis was conducted. He questions how we can be sure that all lead emission sources causing previous monitored violations have been properl y quantified. He notes that typically modeling underestimates impacts when compared to actual l ead monitoring data likely due to lack of proper accounting of the reentrainment of previ ously emitted and deposited particles.

RESPONSE AND EXPLANATION OF CHANGE: A ba se case modeling analysis verifies the accuracy of the modeled inputs by comparing the m onitored data to the modeled results. The Air Program is confident that all lead sources have be en appropriately identified and characterized in the model despite not having a base case for Exide. Because Missouri has been at the forefront of developing SIPs for lead since th e late 1970’s, we have develope d decades of in-depth knowledge and experience with lead’s characteristics as a pollutant, specifically in regards to modeling, fugitive source accounting and control techniques. This plan uses the same source accounting analysis utilized by the State in other recent SIP re visions for similar lead smelting facilities and by the EPA in their recent MACT lead residual risk assessment. The decision to move forward with the plan without a base case modeling analysis was made in coordination with EPA Region VII staff.

In addition, a base case evaluati on is typically driven by the need to evaluate the source of potential controls on the existing facility. Ea rly in the development of this plan, the Air Program, in consultation with EPA, decided to purs ue the implementation of controls in a timelyfashion in lieu of waiting for the collection of on-site data before beginning development of this plan. As a result, Exide started process change s and construction projects related to the newly revised secondary lead MACT c ontrol measures that changed the facility’s “baseline.” Consequently, there was an inability to establis h baseline emissions due to the commencement of process changes and construction projects related to the newly re vised secondary lead MACT. This proactive approach to early reductions at the fac ility removed the necessity for a base case evaluation.

Furthermore, in order to conduct a base case m odel, emissions, monitoring and meteorological data must all be representative, concurrent and correlative. For this plan, a representative corresponding period of matching data sets for establishing a base cas e scenario did not exist. At the start of the development of this plan in late 2012, on-site meteor ological data was not available. So that compliance with the lead air quality standard may be achieved as expeditiously as possible, the Air Program moved forward with the plan using meteorological data from a representative Nati onal Weather Service site despite its potential limitations due to terrain differences. Exide has agreed to c onduct on-site meteorological monitoring for trend analysis or in case future air dispersion m odeling should become necessary. The on-site meteorological station became operational in March 2014.

To address the concern about the underestimati on of actual modeled emissions, the Air Program reiterates that the attainment demonstration model is based on an analysis using conservative assumptions of potential to emit not actual emissions. In addition, emissions due to reentrainment are accounted for in this plan ’s model through the addition of a background concentration to the source em issions modeled concentration. The estimation of background includes windblown fugitive emissions from lead dust previously deposited by the facility. [SIP document, section 5.9, pg. 29].

As a result of this comment, chapter 5 (Air Di spersion Modeling) of the SIP document has been amended to provide additional clarification on why a base case modeling scenario was not
necessary.

COMMENT #7: The commenter questioned th e method used to determine the background concentration. In light of prevailing wind da ta, he commented on why the wind compass points were modified to exclude three data appoints that averaged higher than the NAAQS and whether the use of meteorological data from a station 19 miles away in Nebraska represents localized weather for such evaluations as background concentrations.

RESPONSE: Background concentrations need to in clude all sources of lead from the facility that are not explicitly modeled. The monitor that was chosen to evaluate the background concentration was the Exide Levee monitor, wh ich collects data on a sampling period of 24 hours. To eliminate the impacts from the plant, the data points used corresponded to periods when the winds were not blowing from the plant for all 24 of the hourly wind values for that day regardless of the prevailing wind. This accounts for the few data points available in the background evaluation. The three data points referenced by the commenter were excluded from background determination because they did not re present distant sources of lead but rather impacts from the facility by nearby sources. Th e wind zone first chosen to evaluate backgroundinfluence included fugitive emissions from Hi ghway 111 and Canon Hollow. Subsequently, the wind zone was appropriately adjusted to exclude these impacts, and the fugitive emissions from these road sources were then incl uded as emission inputs to the model. Because there is still the possibility of some influences from the plan t, the estimation of background concentration is conservative and lends to the attainment demonstr ation’s overall margin of safety. This rationale and method for determining the background is di scussed in section 5.9 of the SIP document on pages 30-31.

To illustrate both the effectiveness of the plan ’s control strategy at attaining the 2008 NAAQS and the appropriateness of the pl an’s background concentration de termination, it should be noted that the monitored average lead air quality concentration for the month of March 2014 is 0.023 μ g/m 3 . This is the same concentration as the plan’s estimated background value despite the plant operations’ impact to the monitor during that month.

No changes to the plan were made as a result of this comment.

COMMENT #8: The commenter states that the impact from fugitive emissions is typically greater on calm or low wind velocity days and th e inclusion of 1-minute meteorological data is important for conducting an accurate evaluation to fill the hourly gaps caused by calm / missing data. He comments that the plan does not seem to indicate the inclusion of 1-minute meteorological data.

RESPONSE: As addressed by section 5.6 of the SI P document, for the attainment demonstration model, the Air Program did r un the modeling pre-pr ocessor software called AERMINUTE to develop 1-minute meteorological data for the purpos es of addressing missing or calm wind days. This is also explained in the Final Modeling Report (Appendix D), on page 8.

No changes to the plan were made as a result of this comment.

COMMENT #9: The commenter notes that the SI P revision does not address control measures for hazardous air pollutants like arsenic and cadmium. He urges that the plan should address these pollutants before being adopted to achieve the goal of protecting human health and the environment.

RESPONSE: State Implementation Plans pursuant to the CAA are plans in tended to address the six criteria pollutants, including lead . Lead is the only pollutant that is both a criteria pollutant and a hazardous air pollu tant (HAP). Arsenic and cadmium are HAPs. HAPs are regulated pursuant to CAA Section112 and ar e controlled by the federal MACT regulations. The revised secondary lead smelter MACT is a ke y building block of this plan so in that regard this plan does address arsenic emissions from the facility. EPA notes that the controls of this revised MACT cut arsenic emissions by 68% [ 77 Federal Register 575].

Since the control strategies and devices for reduc ing arsenic and cadmium are the same as that for lead, additional reductions in lead emission are expected to yield similar reductions in arsenic and cadmium. This plan adds work practices an d emission limitations over and above those of the MACT, so we would expect similar additiona l reductions in arsenic and cadmium as well.No changes to the plan were made as a result of this comment.

COMMENT #10: The commenter suggests that th e impact of fugitive emissions is further discounted because there are no windblown lead emissions from sources such as the landfill.

RESPONSE AND EXPLANATION OF CHANGE: The commenter is correct that the model identifies fugitive emissions from truck traffic on the paved surfaces and haul routes including the landfill but does not estimate any emissions from the landfill itself. The slag landfill at the ExideCanon Hollow facility is not typical of other landfills that might be characterized by loose fill that would lend itself to fugitive emissions from windblown erosion. This landfill is comprised throughout of a concrete-like substance that st abilizes and fixates the lead-bearing material contained within, preventing the surface from creating dust to be picked up by the wind. When the slag is brought to the landfill, it is completely mixed with this cement compound and deposited wet where it cures like concrete. The landfill’s only source of lead fugitive emissions is from the truck traffic over the hardened landfill su rface. Furthermore, the tires of all trucks are washed before exiting the landfill to prevent track-out.

In light of this comment, text has been added to chapter 5 (Air Dispersion Modeling) of the proposed plan to better describe the landf ill and its fugitive emission characteristics.