## F LORIDA 

## D EPARTMENT OF 

## E NVIRONMENTAL 

## P ROTECTION

BOB MARTINEZ CENTER
2600 BLAIRSTONE ROAD TALLAHASSEE, FLORIDA 32399

- 2400 RICK SCOTT

GOVERNOR

CARLOS LOPEZ

- CANTERA

LT. GOVERNOR

CLIFFORD D. WILSON III

INTERIM SECRETARY

December 23 , 2014

Mrs. Heather McTeer Toney, Regional Administrator U.S. Environmental Protection Agency (EPA)

– Region 4 61 Forsyth Street SW Atlanta, Georgia 30303

- 8960

Re: State of Florida Department of Environmental Protection Proposed Contingenc y Measures for State Implementation Plan Submittal Number 2012

- 04 Lead (Pb) Nonattainment Area Plan (June 29, 2012, Amended June 27, 2013)

Dear Mrs. Toney,

On June 29, 2012, the Florida Department of Environmental Protection (DEP) submitted to the

U.S. Environmental Protection Agency (EPA) for review and approval a proposed revision to Florida’s State Implementation Plan (SIP) under the Clean Air Act (Submittal No. 2012

- 04). The proposed SIP revision consists of a Lead (Pb) Nonattainment Area Plan to e nsure the attainment and maintenance of the revised Pb National Ambient Air Quality Standard (NAAQS) in Florida’s one Pb nonattainment area, which is located in Hillsborough County, and which centers upon a single facility

– the EnviroFocus Technologies, L LC (EnviroFocus) lead recycling facility. On June 27, 2013, DEP amended its Pb Nonattainment Area Plan to incorporate the revised terms and conditions of a federally enforceable air construction permit for EnviroFocus, as it pertains to emissions of Pb.

Florida is pleased to report that the most recent monitoring data fo r the nonattainment area reflect the significant emissions controls and process improv ements undertaken at the

EnviroF ocus facility pursuant to the Plan

. For the period ending in November 2014 , the

reference monitor most proximate to the facility reports a three

- month rolling average of 0.05 μg/m 3 , which is one

- third of the standard. T he dry autumn season has historically produced the highest averages at this location, so this figure stron gly suggests that the facility’s control measures are yielding results.

By means of this letter, DEP seeks to supplement the “Contingency Measures” provisions of its pending Pb Nonattainment Area Plan to reflect additional procedures and controls at the EnviroFocus facility that would be implemented immediately upon the occurrence of various triggering events related to future monitored exceedances or violations of the Pb NAAQS. 1
While retaining the “Contingency Measures” provisions currently contained wi thin Florida’s

1 The existing “Contingency Measures” provisions of Florida’s pending Pb Nonattainment Area Plan are located on page 23 of the amended submittal dated June 27, 2013.

www.dep.state.fl.usMrs. Heather McTeer Toney

December 23 , 2014 Page 2 of 3

pending Pb Nonattainment Area Plan, DEP proposes to supplement these provisions as follows:

• If any one month period averages greater than 0.15 μg/m 3 at any one of the approved SIP Pb monitors in the vicinity of EnviroFocus, once notified by the Florida Department of Environmental Protection’ s Divi sion of Air Resource Management (DARM) or the Environmental Protection Commission of Hillsborough County (EPC), the facility will immediately initiate an enhanced Operation & Maintenance (O&M) Plan for Pb control. This enhanced O&M Plan shall include the following:

1. EnviroFocus shall conduct a twelve minute EPA Method #9 visible emission reading on each Pb source outlet by a certified reader every day effective immediately;

2. EnviroFocus shall complete a dye leak check on every filtration device which controls a Pb source within 14 days and cease operation of any emission unit connected to a filtration device that fails the dye leak check until such time as repairs are made and the unit passes a second

leak check.

3. EnviroFocus shall i ncrease the sprinkler frequency to 5 minutes every 30 minutes during daylight hours and 5 minutes every 60 minutes during nighttime hours twenty

- four hours a day every day, effective immediately;

4. EnviroFocus shall v acuum the entire paved yard three times a day, except during rain events or within two hours of a rain event, effective immediately;

5. EnviroFocus shall keep daily records for each of these measures and submit these records monthly by the third business day of the fol lowing month to EPC and DARM, and upon request.

Each of these contingencies shall continue for a minimum of 90 days or until such time as DARM has determined that they are no longer needed.

• If any three consecutive month period averages greater than 0.15 μg/m 3 at any one of the SIP

- approved Pb monitors in the vicinity of EnviroFocus, once notified by the Florida Department of Environmental Protection ’ s Division of Air Resource Management (DARM) or the Environmental Protection Commission of

Hillsbor ough Cou nty (EPC), the facility will continue with the measures detailed in the enhanced O&M Plan for Pb control listed above and, in addition, conform to the following:

1. EnviroFocus shall immediately cease any construction activities on site that disturb soils;

2. En viroFocus shall immediately restrict yard traffic only to essential vehicles;

3. DARM may require immediate restrict ion of the daily production of

www.dep.state.fl.usMrs. Heather McTeer Toney

December 23 , 2014 Page 3 of 3

lead from the blast and reverb furnaces. Any production restriction

shal l be a percent reduction from the faci l ity’s average production from the three

- month period during which the monitor exceeded the 0.15 μg/m3 standard , and shall be set by DARM based upon the facility’s anticipated stack emissions impact on the highest reading

ambient lead monitor in the immedi ate area

. 4. EnviroFocus shall keep daily records for each of these measures and submit these records monthly by the third business day of the following month to EPC and DARM, and upon request.

Each of these contingencies shall continue for a minimum of 90 da ys, or until such time as DARM has determined that they are no longer needed.

• If a fourth consecutive month is greater than 0.15 μg/m3 at any one of the SIP

approved Pb monitors in the vicinity of EnviroFocus, DARM may require further production restric tions and/or other contingencies as DARM deems necessary to

reduce ambient lead concentrations in the area. DARM shall transmit written descriptions of any such contingency measures by certified letter, and such measures will be effective immediately upon receipt by EnviroFocus, and remain in effect until such time as DARM has determined that they are no longer needed. All of the contingency measures detailed above shall continue to apply. Applicable lead emission abatement measures may be revisited each a nd every consecutive month during which a SIP

- approved Pb monitor averages above the

standard.

Thank you for your attention to this request. If you have any questions about these proposed additions to the Contingency Measures for Florida’s pending Pb Non attainment Area Plan, please contact me at any time at (850) 717

- 9000 or by e

- mail at Paula.Cobb@dep.state.fl.us.

Sincerely

,

Paula L. Cobb, Director Division of Air Resource Management

cc: Lynorae Benjamin, Chief, Regulatory Development Section,

Air P lanning Branch, EPA Region 4

Cindy Mulkey, Program Administrator, Office of Business Planning, Division of Air Resource Management

www.dep.state.fl.us