Mr. Karl Brooks 

Regional Administrator 

U.S. EPA, Region VII 

11201 Renner Boulevard 

Lenexa, KS 66219 

Dear Mr. Brooks: 

The Missouri Department ofNatural 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 ofthe 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 ofthe comments received 

and our responses are attached. 

In order to comply with Attachment A ofthe "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 Paper 
Mr. 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 ofNatural 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 ofthe appendices are not included) 

Copy ofthe 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 ofNatural 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 Exide

i 

Table of Contents 

1. PURPOSE ........................................................................................................... 1

2. BACKGROUND AND AIR QUALITY MONITORING ............................. 1

3. EMISSIONS INVENTORY ............................................................................. 6

4. CONTROL STRATEGY .................................................................................. 7

4.1 MACT Controls ........................................................................................................................................... 9

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

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

5.1 Model Selection and Settings .................................................................................................................... 15

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

5.3 Modeled Sources and Their Release Parameters ....................................................................................... 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 Downwash .................................................................................................................................. 27

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

5.7 Receptors ................................................................................................................................................... 29

5.8 Model Input, Output, 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 MEASURES ..................................................................... 34

7. PUBLIC PARTICIPATION ........................................................................... 35

8. CONCLUSION ................................................................................................ 36

 
List of Appendices 

Appendix A – Consent Judgment 

Appendix B – Standard Operating Procedures 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 Files 
1 

1. PURPOSE

As required by Section 110(a) of the federal 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 site is located near the Exide Technologies-Canon 

Hollow plant, a secondary lead smelter which recycles lead from lead-acid automobile batteries. 

This SIP revision contains a demonstration of NAAQS compliance through air dispersion 

modeling and a consent judgment detailing control projects, record keeping, new work practices, 

provisions for public access preclusion to non-ambient areas, as well as a contingency measure 

plan in case lead NAAQS violations continue. Furthermore, a margin of safety was built into the 

entire attainment modeling analysis by using conservative assumptions in the establishment of an 

ambient background concentration and the fact that emissions were modeled as being worst-case 

rather than typical facility 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 other criteria pollutants are ozone, 

particulate matter (including PM10 and PM2.5), nitrogen dioxide, carbon monoxide, and sulfur 

dioxide. The CAA also requires EPA to periodically review the standards and the latest 

scientific information to ensure they provide adequate health and environmental protection, and 

to update those standards as necessary. 

Lead is a metal found naturally in the environment, 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 emissions, 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 since the U.S. Environmental Protection Agency 

(EPA) first issued a lead standard in 1978. Lead can be emitted into the air in the form of 

particles small enough to stay suspended in the air. Lead emitted into the air can be inhaled 

directly or ingested after it settles onto surfaces or soils. Once in the body, lead is rapidly 

absorbed into the bloodstream and accumulates in the bones. Lead exposure is associated with 
2 

several health effects that have an adverse impact on the cardiovascular system, central nervous 

system, kidneys, and immune system. 

Children are more susceptible to the damaging effects of airborne lead than adults because they 

breathe in more air per minute, typically spend more time outdoors, and exhibit greater hand-tomouth activity than adults. Children are also more vulnerable to the health effects of lead 

because their minds and bodies are developing rapidly. 

For information on lead as a criteria pollutant, including more details on the NAAQS revision, 

the health effects of lead and other useful links, please see the 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/m3

), 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 previous 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 necessary to implement the 2008 standard at the same time that 

they revised the standard. These regulations required the state to operate a monitoring station 

near facilities estimated to emit 1.0 tons of lead per year. The monitor provisions were later 

modified to require monitoring near 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 Smelters. 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 monitoring network at Forest 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 (PM10) 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 PM10 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 standard. Compliance with the lead standard is based on averaging the 
3 

every-sixth-day monitored concentrations of lead the ambient air over a 3-month period and 

comparing that average to 0.15 μg/m3

 [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 concentrations 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 two (overlapping) 3-month periods– December 2012 

through March 2013 (0.151 μg/m3 would meet the standard, because it rounds to 0.15) and for 

the four most recent (overlapping) 3-month periods for which data are available, November 2013 

through April 2014. The PM10 lead concentrations show violations 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. PM10 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, because three years of monitoring results at or 

below the level of the standard are required 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 current 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– ENVIRON, and EPA Region VII staff for the purpose of coordinating 

the development of this compliance plan to address the measured violation of the Lead NAAQS. 

Since that initial meeting there have been numerous 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 vicinity of Forest City, Missouri 

through air dispersion modeling. This plan was developed with the consensus and cooperation 

of the Air Program, Exide Technologies, EPA Region VII and the Missouri Attorney General. 

Concurrent to the development of this plan, the Exide Technology-Canon Hollow facility 

(Exide) installed, and is operating, 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 requirements, 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 purpose, 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 projects were completed and operating by January 6, 

2014. 
4 

In addition to the revised MACT, other requirements 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 judgment among the department, the Missouri 

Attorney General, and Exide Technologies. 

Lastly, though an attachment to this plan, Exide voluntarily agrees to collect complete, accurate 

onsite weather data for trend analysis or in case an additional air dispersion modeling analysis 

becomes necessary. (For this plan, air dispersion modeling used meteorological data obtained 

from the nearby Brenner, Nebraska airfield because no onsite meteorological existed during the 

development of this plan.) 

 

Figure 1. Aerial photograph of the Exide-Canon Hollow 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 lead concentrations (μg/m3) measured at the Forest City, Exide 

Levee site. Note: 3-month averages are calculated from monthly averages of concentrations originally reported 

by the department and retrieved from the EPA’s Air Quality System (AQS), except for the February-March-April 

2014 average, which uses preliminary data for April. 

3-Month Period PM10 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 average lead concentrations measured at the 

Forest City, Exide Levee site. 

3. EMISSIONS INVENTORY 

The Air Program creates air emission inventories for criteria pollutants and hazardous air 

pollutants to meet federal reporting requirements under EPA’s Air Emissions Reporting Rule to 

provide data that supports the functions of the Air Program, including 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 county 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 lead inventory for the area, but other smaller 

(nonpoint) sources are also described for completeness. Nonpoint sources are too numerous to 

inventory at the individual source level; nonpoint lead sources include aviation gasoline 

distribution and human cremation. Mobile sources of lead emissions are also considered 
7 

including piston-driven aircraft, commercial marine vessels, and diesel locomotives. Both the 

nonpoint and mobile source inventory included below are for all of Holt County. 

Large emitters with Part 70 (P70) operating permits, 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 Inventory (NEI), a dataset prepared triennially 

through state, tribal, and EPA cooperation. Exide Technologies submitted their 2012 inventory 

data to the state of Missouri, and that data was quality assured prior to forwarding to EPA for 

further review. The 2012 lead emission totals for Exide Technologies are 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) 5.0045a 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 facility near Forest City, 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 batteries into pieces. The plastic, spent acid, and 

lead-bearing materials are then separated. Lead-bearing 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 added as a result of the revised Secondary lead 

MACT and this plan. 
8 

Figure 3 
9 

There are three types of emission sources at secondary lead facilities. This plan proposes 

controls at each of these emissions 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 the 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 filtered 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 haul routes and wind-blown re-entrainment. 

Total enclosure of the process buildings and work practices such as haul route sweeping 

and truck frequency restrictions help control fugitive dust sources. 

4.1 MACT Controls 

The development of this plan coincides with the implementation of the revised Secondary Lead 

Smelting NESHAP or MACT Subpart X promulgated 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 from 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 standards for lead as a criteria pollutant. The 

MACT regulation is designed to control emissions 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 the revised MACT that are used by 

this plan to demonstrate compliance with the lead NAAQS include– 

 Requiring facilities to fully enclose all 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 with these requirements by January 6, 2014 through 

a capital improvement and construction campaign that includes the following projects: 

 Improvements to lead process building enclosures; 

 Construction of two new baghouses, each with 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 improve 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 naming 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 and 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 maintained by Exide pursuant to the Fugitive Dust 

SOP is found on page 2 of the manual. Exide must clean all in-plant roadways 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 the 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 SOP of Appendix B that describes in detail 

procedures for inspection, maintenance, bag leak detection and corrective action plans for all 

baghouses that are used to control process, process fugitive or fugitive dust emissions from any 

applicable source including those 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 lodged with the court. This Consent Judgment 

was developed in conjunction with this plan and is included in this plan as Appendix A. The 

enforceable provisions for these lead emission 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 the 
11 

department, the Missouri Attorney General and Exide technologies. The parties shall sign and be 

bound by the Consent Judgment once it has been adopted by the Missouri Air Conservation 

Commission after appropriate opportunities has been made by the public or any interested parties 

during the 37-day public hearing and comment process as discussed in chapter 7 of this 

document. 

The MACT prescribes a plant-wide stack emission limitation of below 0.20 milligrams of lead 

per dry standard cubic meter. This is an aggregate flow-weighted average concentration of all 

the lead process stacks at the facility. To translate this aggregated average 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 limit 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, frequency and hours of operation on the plant roads 

to the schedules outlined in Table 4 below [Paragraph V.7.F. of the Consent Judgment]. For 
12 

more information on truck haul route emissions, see paragraph 5.3.3 Area Sources of this 

document. 

Table 4 – Truck Traffic Restrictions: Frequency and Hours of Operations 

Group Route 

Description 

Total Trips 

Per Month 

Unrestricted 

Trips Per 

Month* 

A Cores/Scrap 368 0 Industrials 

B 

Furnace Coke 

Lime (bulk) 87 4 

Furnace Fluxes 

C 

Trash 

Acid (bulk) 61 3 

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 the 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 the operation of local exhaust ventilation process hoods (LEV’s). 

The new secondary lead smelting NESHAP revised as of 2012 requires both total building 

enclosures and negative pressure differential filtered-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 kettles. [Paragraph 7.C. of the Consent Judgment] 

Section 5 of this document on Air Dispersion Modeling 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 modeled concentration of lead in the ambient air 

(including background concentration) is 0.1498 μg/m3 at a model receptor site located about 600 

yards northwest of the lead process buildings on the Exide property. Figure 1 above shows 

Exide’s property boundary at the Canon Hollow facility. 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 property 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. One 
13 

quadrant is west of Canon Hollow Road and north of Highway (HWY) 111 to a line about 

midway through their property. The other quadrant extends east of Canon Hollow Road and 

North of HWY 111 to surround their active processing 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 with 10-meter spacing are attached to the Consent 

Judgment. 10-meter spacing is appropriate because it represents the approximate distance 

between hypothetical “fence posts” that 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 (SIP) regulations found at 40 CFR 51.117 (entitled 

“Additional provisions for lead”) 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 sources. For pollutants emitted through a stack, it 

considers the emission rate, stack height, stack diameter, and stack gas temperature and velocity, 

as well as the effect of nearby buildings and terrain. Other emission sources like vehicle traffic 

or wind erosion from storage piles are represented as 2-dimensional 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 selected modeling receptor grids. Five years of 

National Weather Service (NWS) meteorological data is typically used for 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 meteorological data is used. 

Model results are compared to ambient air standards 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 dispersion modeling analyses are used. One is used to 

verify the accuracy of the modeled inputs by comparing the monitored data to the modeled results 

(base case). The second analysis examines the effectiveness of the proposed emission controls 

(future case) necessary to demonstrate attainment. In order to conduct a base case model, 

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 case scenario 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 standard may be achieved as expeditiously as 

possible, the Air Program moved forward with the plan using 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 become 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 construction projects related to the newly revised 

secondary lead MACT control measures that changed the facility’s “baseline.” Consequently, 

there was an inability to establish concurrent and correlative model inputs necessary for a base 

case evaluation. The decision to move forward with the plan without a base case modeling 

analysis was made in coordination with EPA Region VII staff. 

The Air Program is confident that all lead sources have been appropriately identified and 

characterized in the model because this plan uses the same source accounting analysis utilized by 
15 

the State in other recent SIP revisions for similar 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 International 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 current air quality modeling 

guidelines as contained in 40 CFR 51 Appendix W. The EPA’s recommended dispersion model 

for addressing lead is the AMS/EPA Regulatory Model (AERMOD). AERMOD can predict the 

concentration distribution of pollutants 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 calculations, 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 control 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 Pollutants and Averaging Periods 

The only pollutant that was modeled is lead (CAS 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 averaging times. To demonstrate 

agreement with the 2008 Lead NAAQS, the Air Program and ENVIRON executed the 

AERMOD model and generated POST files using a monthly averaging period. These POST 

files were processed through the EPA’s LEADPOST (Version 12114) FORTRAN based 

computer program to generate consecutive three-month rolling averages for comparison against 

the lead NAAQS. 

 

5.3 Modeled Sources and Their 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 baghouses share one stack (EP01) and it is called 

the Wheelabrator air pollution control system. Refining/Casting ventilations, Battery Breaker 
16 

area, Deminimis Storage area, Containment Building, Maintenance Building are routed to the 

Negative Pressure Baghouse #2, one of the newly constructed baghouses (CD006). Some of the 

Blast Furnace and Refining/Casting areas are routed to the other newly-constructed baghouse, 

Negative Pressure Baghouse #1 (CD005). Other areas that are controlled by the acid demister 

baghouse (CD007) are the Stabilization Unit, Blast Slag, and Mixing areas. The battery 

break/crushing area is routed to CD007. The source identifiers for the point sources used in this 

AERMOD modeling were chosen based on the designations 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 modeled. Any other small mobile or nonpoint 

sources of lead are contributors to background concentration which is discussed in section 5.9 of 

this document. The following sections describe 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 impacts less than the 2008 Lead NAAQS (0.15 g/m3

) and all 

relevant federal New Source Performance Standard (NSPS) and NESHAP standards applicable 

to the sources involved, the Wheelabrator Air Pollution 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 allowed 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 emission 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 included in this modeling exercise. Figure 5 shows the location of 

all point sources within the facility. The modeled stack velocities for the two new baghouses 

(CD005 and CD006) are corresponding to conservatively assumed flow rates 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 conservatively 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 m3/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-02 
17 

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 stack
18 

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 continuous ventilation of the total enclosure to 

ensure negative pressure values of at least 0.007 inches of water 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 inches water column. 

However, measures will be put in place to ensure 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 include equipment door designs that minimize building 

inflow and the use of local exhaust ventilation (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 pressure or building inflow during occasional but 

necessary traffic. Exide intends to keep all doors closed during normal operation barring the 

protection of employee welfare. Exide will continue to operate and maintain LEV’s at the Blast 

Furnace (both charging and tapping) and at the refinery kettles to reduce process fugitive 
19 

emissions after installation of the new baghouses. EPA’s Secondary Lead Smelting Background 

Information Document for Proposed 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 effect 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 process 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 manufacturing area; therefore, those equipment 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 dimension 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 height divided by 2.15. Table 8 includes a 

listing of the fugitive volume sources and their 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 1.42 
20 

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 facility roads and contribute to these fugitive 

emissions. Vehicular fugitive emissions were modeled as ground level area sources with input 

parameters calculated according to the guidance provided in the EPA’s Haul Road Workgroup 

Final Report (March 2, 2012). All of the haul roads 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 and corresponding area sources that were included 
21 

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, frequency of trips, and hours of day are in Table 10. Table 11

includes a list of the haul road area sources and their 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 Heighta 4.11 3.66 3.44 3.81 2.13 

Vehicle Widtha 2.59 3.05 2.87 2.46 1.16 

Top of Plume Heightb 7.00 6.22 5.86 6.48 3.63 

Release Heightb 3.50 3.11 2.93 3.24 1.81 

Plume Widthb 8.59 9.05 8.87 8.46 7.16 

Sigma Zb 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 Configuration 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 day (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/sm2

) 

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 3.25 
23 

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 using the Paved Roads section of Chapter 13.2.1 from 

AP-42 (EPA 2011). The equations in AP-42 require site specific data including the fleet average 

vehicle weight, vehicle kilometers traveled, and a silt loading value for paved roads. The sitespecific silt and lead content sampling have recently been completed for a similar Exide facility 

in Vernon, California which is currently totally enclosed, consistent with the pending NESHAP. 

These parameters were used in the AP-42 equations to estimate the future traffic fugitive 

emissions on paved roads at the Canon Hollow facility when the enclosure project is completed. 

Exide conducted site-specific sampling for silt loading 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 throughout of a concrete-like substance that stabilizes and fixates 

the lead-bearing material contained within, preventing 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 Basisa 

ܧ௘௫௧ ൌ ݇ሺܮݏሻ଴.ଽଵ ൈ ܹଵ.଴ଶሿሺ1 െ

ܲ

4ܰሻ

Variable Description Value Units Roads Landfill 
24 

k particle size multiplier for particle size range and units of 

interest 3.23 g/VKTb 

sLc road surface silt loading 0.23 327 g/m2

W average weight of the vehicles traveling the road 24.30c 19.50d ton 

Pe 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 averaging period (e.g., 365 for annual, 

91 for seasonal, 30 for monthly) 365 day 

Eext

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 take into account truck weight by type 

e Based on weather data collected from the 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 the 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 (HROFDY) emissions scaling factor in AERMOD (Table 8 of the 

Modeling Report). An example of these scaling 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	ܾܲ

ݏ݉ଶቁൌܧ௘௫௧ 	ቀ ݃

ܶܭܸ൬ܺቁܶܭܸݎ1݄ ൬ܺ൰ ݎ݄

60݉݅݊൰ܺ൬1݉݅݊60ݏ ൰ܺ൬ 1ܽݎ݁ܽ	ሺ݉ଶሻ

൰ ܺ	%ܾܲ

Eext (g/VKT) = 20.40 

VKT/hr = 8.99E-02 for HR01

min/hr = 60 

seconds/min = 60 

Area (m2

) = 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-08 
25 

Figure 7- Modeled Area Sources (Haul Roads) 

5.4 Terrain Data 

Terrain elevations were incorporated into the model using version 11103 of AERMAP, 

AERMOD’s terrain preprocessor, as per EPA guidance (2009). Terrain 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 Server (http://seamless.usgs.gov). AERMAP was 

configured to assign elevations for all roadway 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, Battery 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 Rise Model Enhancements (BPIPPRM) model 

(incorporated into AERMOD) is used to determine 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 BPIPPRM 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 City, Nebraska about 22 miles west of the ExideCanon Hollow facility. For off-site met data, generally 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 City levee monitoring site and operating the met 

station under a Quality Assurance Project Plan (QAPP). That agreement is attached to this 
28 

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 the transport and dispersion of 

pollutants in the atmosphere. Surface and upper air meteorological data inputs 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 input files required by AERMOD. Details of 

AERMET and AERMOD meteorological data needs 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 dispersion modeling exercise (40 CFR Part 51 Appendix 

W (November 2005)). EPA’s Meteorological Monitoring Guidance for Regulatory Modeling 

Applications (EPA 2000) describes the criteria that should be considered when siting 

meteorological instruments for modeling purposes. 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 placement of wind instruments 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 and can result in non-representative, 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 representative 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 evaluation, and the collection of one year of on-site 

meteorological data is not feasible at this time. Instead, meteorological data collected at a 

representative airport was used for the SIP modeling analysis. 

The Air Program evaluated three airports’ meteorological data (Kansas City International 

Airport, Rosecrans Memorial Airport, and Brenner Field located near Falls City, Nebraska) to 

determine which data most closely represent conditions at the facility. These airports were 

selected due to their proximity to Exide. Other airports, located farther away, have weather 

patterns which were deemed different from that of the facility. 

By taking into account the distance from the site 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 pressure, 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 prepared using TD-3505 surface data and TD6805 AERMINUTE data. The data were processed using the AERMET meteorological data 
29 

processor (version 13350). Upper air data for the period of 2007 to 2011 was selected by the Air 

Program from the Topeka, KS Airport station (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 Road, 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 receptors 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 preclude 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 Cartesian 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 approximately 250 m to 500 m beyond the fence line. 

Lastly, a receptor grid with 200-m spacing was 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 was 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 from 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 impact 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 concentrations 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 determining compliance with the NAAQS. Background 

concentrations include impacts attributable to natural sources, nearby sources (excluding the 

dominant source(s)), and unidentified sources. This calculated 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, mobile 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 sources combined make up approximately 0.08% 
31 

of the point source emissions total in 2012, and as such are not included in the modeling exercise 

as discreet sources but may influence 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 coming from the facility. This was accomplished by excluding 

days when any one-hour wind average was from the 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 all the monitors in the evaluation 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 Program calculated Exide’s background concentration 

by averaging the hi-volume ambient 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 included corresponding winds from the 90 degree sector upwind of the 

monitor location were excluded from consideration as a representative 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 north. However, this sector 

included days with high concentrations that were suspected to be coming from the facility. 

These days with their corresponding concentrations are 09/18/2012 (1.33 g/m3

), 10/06/2012 

(0.8 g/m3) and 12/17/2012 (g/m3). The resulting calculated background concentration from 

this sector was 0.195 g/m3 which is higher than the lead NAAQS. 

To reduce Exide’s influence on the monitor during this background concentration analysis, the 

Air Program evaluated the sector from 300 degrees to 80 degrees (Figure 10). This excluded 

HWY 11 and Canon Hollow road from consideration 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 two roads is accounted for in the overall lead 

concentration from the facility. Figure 10 shows ambient monitor, the facility, and the proposed 

wind directions to exclude from the background calculation. 

Six concentrations resulted from this sector as shown in Table 14. The average of these six 

concentrations, 0.023 g/m3, 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 0.023 
32 

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 potential for some double-accounting: the background 

inclusion zones are very generous 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 eliminate all wind directions and influences from 

the plant to the monitor. 

Figure 10- Exclusion Zone for Calculating Background Concentration 

5.10 Post Processing in LEADPOST 

The averaging period chosen for 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 average lead concentrations for each receptor 

location. The software created output text files corresponding to total receptor average 

concentrations across all source groups (a Source Group ALL was created to represent facilitywide emissions). 
33 

5.11 Description of Modeling Results 

The LEADPOST output file of modeled maximum three month rolling average lead 

concentrations for all source groups were added 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/m3. 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/m3

) 

Background 

Concentration 

(g/m3) 

Total 

Concentration ( 

g/m3 ) 

NAAQS 

for Lead 

(g/m3) 

309169.66 4434082.50 0.126837 0.023 0.149837 0.15 

Figure 11- Location of Maximum Modeled Concentration Receptor 
34 

Figure 12- Contour Plot of Lead Concentrations around Exide 

6. CONTINGENCY MEASURES 

As part of this plan, a contingency 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 Paragraph 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 parts. The first part is a measure that may be 

implemented immediately after any rolling three-month average violates the 2008 lead standard. 

The second part is a study to identify likely causes contributing to the violation followed by 

implementation of a proposed action plan of the most effective control measures. 

Immediately after notification that the lead air quality monitoring results for the Forest City area 

show a violation of the 0.15 μg/m3

 three-month rolling average lead standard, Exide shall 

increase the in-plant road cleaning to 10 hours each working day. Currently, plant roadways and 

parking lots are cleaned with wet wash or vacuum cleaning at least twice a day between 7 am 
35 

and 7 pm [Exide Fugitive Dust Source SOP Manual, pg. 2, Appendix B]. The implementation 

of this contingency measure is expected to prevent 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 control 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 emission reduction techniques to be used as 

contingencies remaining at this facility. The limited control options that were still available form 

the basis of the main control strategy used to demonstrate attainment within this plan. Therefore, 

the second phase of this plan’s contingency strategy involves a study or review 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 event 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 will be implemented by the 

control measures section of this plan to attain the lead standard. However, any ongoing 

violations of the NAAQS (triggering this contingency measure) would indicate that another 

evaluation of fugitive emissions would be needed. This contingency project will allow 

additional strategies to be identified to meet the 2008 lead standard in light of the new conditions 

created after the implementation of all required controls as part of this attainment demonstration. 

Furthermore, the Consent Judgment allows for the submission of additional new contingency 

measures when other contingency measures (identified by the fugitive control study contingency 

project) have been exhausted. 

7. PUBLIC PARTICIPATION 

In accordance with Section 110(a)(2) of the CAA, 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 other interested parties of an upcoming 

public hearing and comment period thirty (30) days prior to holding such hearing for this SIP 

revision as follows: 

 Notice of availability of the SIP revision 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 beginning at 9:00 a.m. at the Elm Street 

Conference Center, in Bennett Springs Conference 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 Program 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 Section 110 obligations to 

attain and maintain the 2008 Lead NAAQS in all areas of the State (not designated as 

nonattainment) including, specifically through this plan, the area in the vicinity of Forest 

City, MO. The nearby Exide Technologies–Canon Hollow secondary lead smelting 

facility has added emission controls pursuant to the Secondary 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 practices. 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!;~:4/ '0-1) --,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 't--f- ~:, Member

_________________,Member 

____________________,Member 

_ ____________.____:, Member 






























1

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

This is a courtesy copy of an email bulletin sent by Cheri Bechtel.

This bulletin was sent to the following groups of people:

Subscribers of Air Public Notices (593 recipients) 

Having trouble viewing this email? View it as a Web page.

MISSOURI AIR CONSERVATION COMMISSION 

WILL HOLD PUBLIC HEARING 

JEFFERSON CITY, MO -- The Missouri Air Conservation Commission will hold a public hearing on 

Thursday, August 28, 2014 beginning at 9 a.m. at the Elm Street Conference Center, 1730 East Elm Street, 

Lower Level, Bennett Springs Conference Room, Jefferson City, Missouri. The commission will hear 

testimony related to the following 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 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 is proposing to amend and 

strengthen the Missouri SIP to address violations of the 2008 Lead (Pb) NAAQS of 0.15 micrograms 

per cubic meter (μg/m3

), 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 demonstration using air dispersion modeling and a consent 

judgment containing emission limitations and contingency measures. 

 

If the Commission adopts the action, it will be the Department’s intention to submit the action to the U.S. 

Environmental Protection Agency to be included in Missouri’s State Implementation Plan. 

 
2

Documents for the above item(s) will be available for review at the Missouri Department of Natural 

Resources, Air Pollution Control Program, 1659 Elm Street, Jefferson City, (573) 751-4817 and in the Public 

Notices section of the program web site http://dnr.mo.gov/env/apcp/public-notices.htm. This information will 

be available at least 30 days prior 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 Pollution Control Program, P.O. 

Box 176, Jefferson City, MO 65102-0176. Email comments may 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 the Missouri Air Conservation 

Commission, Missouri Department of Natural Resources, 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 presentations also provide a written 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 directly at (573) 751-4817, the Division 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 Commission Secretary, P.O. Box 176, Jefferson City, MO 65102. 

Hearing impaired persons may contact the program through Relay Missouri, (800) 735-2966. 

 

 

Celebrating 40 years of taking care of Missouri's natural resources. To learn more visit dnr.mo.gov.

 

Update your subscriptions, modify your password or email address, or stop subscriptions at any time on your 

Subscriber Preferences Page. You will need to use your email address to log in. If you have questions or 

problems with the subscription service, please contact subscriberhelp.govdelivery.com. 

This service is provided to you at no charge by Missouri DNR. 
Jay Nixon, Governor 

Sara Parker Pauley, Director

Air Pollution Control Program

State Plan Actions                                                                    

On Public Notice | Proposed for Adoption

On Public Notice 

Missouri State Implementation Plan Revision – 2008 Lead NAAQS Compliance Plan – 

Exide Technologies Canon Hollow Facility 

As required by Section 110(a) of the Clean Air Act, 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 is proposing to amend and strengthen the Missouri SIP to address violations of the 

2008 Lead (Pb) NAAQS of 0.15 micrograms per cubic meter (μg/m3

), 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 demonstration using air 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 this plan action on August 28, 2014. Comments about this 

plan action will be accepted through the close of business on September 4, 2014.

State Plan Actions on Public Notice - DNR Page 1 of 3

http://dnr.mo.gov/env/apcp/stateplanrevisions.htm 7/28/2014
Proposed 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 demonstrate reasonable progress toward meeting 

the national goal of a return to natural visibility conditions 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 visibility goals for the year 

2018 for each of the state’s Class I areas in order to make reasonable progress toward the 

2064 goal. The purpose of this report is to assess 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 demonstrates that both of Missouri’s Class I 

areas are expected to meet their 2018 visibility goals based on control strategies currently 

in place, which largely consist of sulfur dioxide and nitrogen oxides emission reduction 

measures for utilities, industrial 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 nonattainment area requirements pursuant to Clean Air 

Act Section 182(a) for the Missouri 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-hour ozone NAAQS on May 21, 2012.

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

Appendix A 

Appendix B

Appendix B-1

Appendix B-2

Appendix B-3

Appendix B-4

Appendix B-5

State Plan Actions on Public Notice - DNR Page 2 of 3

http://dnr.mo.gov/env/apcp/stateplanrevisions.htm 7/28/2014
Appendix 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

State Plan Actions on Public Notice - DNR Page 3 of 3

http://dnr.mo.gov/env/apcp/stateplanrevisions.htm 7/28/2014
 PUBLIC 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 COMMISSION 

2

3

4 IN RE:

Missouri State Implementation Plan - 2008 Lead National

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

25
 PUBLIC 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 come to

3 order. Let the record show the following commissioners are

4 present: Jack Baker, Mark Garnett, Gary Pendergrass, and

5 David Zimmermann. The Air Conservation Commission of the

6 State of Missouri has called this public hearing pursuant

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 Implementation Plan

10 Revision - 2008 Lead NAAQS Compliance Plan Exide

11 Technologies Canon Hollow Facility.

12 The hearing record will close at 5:00 p.m. on

13 September 4, 2014. Anyone who has not been scheduled 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 Statutes

17 provides that all oral testimony be given under oath.

18 Accordingly, when you called to testify, please present

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

20 you testify, please state your name, business address, and

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

22 a statement, it will be helpful if you will provide a copy

23 to the Staff Director, court reporter, and members 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, members of the

2 Commission. My name is Joe Winkelmann. I am employed as

3 an Environmental Engineer with the Missouri Department of

4 Natural Resources' Air Pollution and Control Program. I

5 work at 1659 East Elm Street, Jefferson City, Missouri.

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 Standard

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 attainment and

14 maintenance of all NAAQS. The purpose of this compliance

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 quality

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 cooperation

22 of the Missouri Department of Natural Resources' Air

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

24 Environmental Protection Agency Revion VII and the 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-CANON HOLLOW FACILITY 

On August 28, the Missouri Air Conservation Commission 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 Program’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 Department of Natural Resources’ Air 

Pollution Control Program, 1659 East Elm Street, 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 intention to submit it to the U.S. Environmental 

Protection Agency for inclusion in the 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-CANON HOLLOW FACILITY 

The public comment period for the proposed 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 opened on July 28, 2014 and closed on September 

4, 2014. Revisions to the proposed plan were made as a result of comments. 

The following is a summary of comments received and the Missouri Department of Natural 

Resources’ Air Pollution Control Program’s (Air Program’s) corresponding responses. Any 

changes to the proposed plan are included in the response to comments. 

SUMMARY OF COMMENTS: During the public comment period for the proposed plan, the 

Air Program received comments from 3 sources: 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 involved in the plan’s development and emphasized that the plan came 

together without the Federal issuance of a nonattainment designation or SIP call. 

 RESPONSE: The Missouri Department of Natural Resources’ Air Pollution Control Program (Air 

Program) appreciates the commenters’ support and cooperation during 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 issuance of a formal nonattainment designation by EPA. Since the 

area has not been designated nonattainment, certain provisions of CAA Section 172, such as a 

formal attainment demonstration, are not required of this plan. Nonetheless, to make this plan as 

robust as possible and to be consistent 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 contingency measure strategy in case of 

any further violations of the lead standard. No changes 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 former environmental consultant, 

having an interest in regional air quality expresses general concerns about the Exide-Canon 
Hollow secondary smelter in Holt County as a resident of nearby Nodaway County. One 

concern is that the company’s Chapter 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 attainment in this plan have already been installed 

including those required by the revised federal Maximum Achievable Control Technology 

(MACT) regulation for secondary lead smelters promulgated on January 5, 2012. The 

monitored values have so far not recorded a violation 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 compliance throughout the bankruptcy process. The 

Consent Judgment portion of this SIP revision 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 about 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 Northwest 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 monitoring in the area surrounding the Exide Canon Hollow 

facility and the 2012 Monitoring Network Plan

[http://dnr.mo.gov/env/apcp/docs/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 logistics and potential for population exposure. 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 activities to facilitate appropriate monitoring siting criteria, 

installation of electrical 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 smelter 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 controlling 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 29

Percent Calm Wind Conditions (For the 24‐hour sampling Event)

Lead Concentration (μg/m

3)

24‐hour Sampling Event Rank Ordered by Increasing % Calm Wind Conditions

(Note: Sample for sampling event 20 was void)

24‐Hour Airborne PM10 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 Monitor 
COMMENT #4: The commenter noted that the Toxic Release Inventory (TRI) data reported by 

this facility showed no information for arsenic despite other information from EPA showing 5.5 

pounds per year of arsenic emissions. 

RESPONSE: The TRI data is reported by the facility to the national TRI database which is 

maintained by EPA. The Air Program is not responsible for quality assurance of the TRI 

submissions, so we have no additional response regarding 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 reports fugitive emissions 

in recent years. 

RESPONSE: This comment is referencing Exide’s reported emissions 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 attainment 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 sources of lead at the facility. 

Therefore, Exide’s previous accounting and reporting of actual fugitive emissions for the EIQ was 

not used in the model development. Furthermore, the plan contains a contingency measure strategy 

to act as a backstop in case of any future violations 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 properly quantified. He notes that typically modeling 

underestimates impacts when compared to actual lead monitoring data likely due to lack of proper 

accounting of the reentrainment of previously emitted and deposited particles. 

RESPONSE AND EXPLANATION OF CHANGE: A base case modeling analysis verifies the 

accuracy of the modeled inputs by comparing the monitored data to the modeled results. The Air 

Program is confident that all lead sources have been 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 the late 1970’s, we have developed 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 revisions 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 evaluation is typically driven by the need to evaluate the source of 

potential controls on the existing facility. Early in the development of this plan, the Air 

Program, in consultation with EPA, decided to pursue the implementation of controls in a timely 
fashion in lieu of waiting for the collection of on-site data before beginning development of this 

plan. As a result, Exide started process changes and construction projects related to the newly 

revised secondary lead MACT control measures that changed the facility’s “baseline.” 

Consequently, there was an inability to establish baseline emissions due to the commencement of 

process changes and construction projects related to the newly revised secondary lead MACT. 

This proactive approach to early reductions at the facility removed the necessity for a base case 

evaluation. 

Furthermore, in order to conduct a base case model, 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 case scenario did not exist. At 

the start of the development of this plan in late 2012, on-site meteorological 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 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 become necessary. The on-site 

meteorological station became operational in March 2014. 

To address the concern about the underestimation 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 emissions 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 Dispersion 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 the method used to determine the background 

concentration. In light of prevailing wind data, 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 include 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, which 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 represent distant sources of lead but rather 

impacts from the facility by nearby sources. The wind zone first chosen to evaluate background 
influence included fugitive emissions from Highway 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 included as emission inputs to the model. Because there is still the 

possibility of some influences from the plant, the estimation of background concentration is 

conservative and lends to the attainment demonstration’s overall margin of safety. This rationale 

and method for determining the background is discussed 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 plan’s background concentration determination, it should be noted 

that the monitored average lead air quality concentration for the month of March 2014 is 

0.023μg/m3 . 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 the 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 SIP document, for the attainment demonstration 

model, the Air Program did run the modeling pre-processor software called AERMINUTE to 

develop 1-minute meteorological data for the purposes 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 SIP 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 intended to address the 

six criteria pollutants, including lead. Lead is the only pollutant that is both a criteria pollutant 

and a hazardous air pollutant (HAP). Arsenic and cadmium are HAPs. HAPs are regulated 

pursuant to CAA Section112 and are controlled by the federal MACT regulations. The revised 

secondary lead smelter MACT is a key 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 reducing 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 and emission limitations over and above those of 

the MACT, so we would expect similar additional 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 the 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 stabilizes 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 surface. 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 landfill and its fugitive emission characteristics.