FLORIDA DEPARTMENT OF

ENVIRONMENTAL PROTECTION

BOB MARTINEZ CENTER

2600 BLAIRSTONE ROAD

TALLAHASSEE, FLORIDA 32399-2400

RICK SCOTT

GOVERNOR

CARLOS LOPEZ-CANTERA

LT. GOVERNOR

CLIFFORD D. WILSON III

INTERIM SECRETARY

December 23, 2014

Mrs. Heather McTeer Toney, Regional Administrator

U.S. Environmental Protection Agency (EPA) – Region 4 

61 Forsyth Street SW

Atlanta, Georgia 30303-8960

Re: State of Florida Department of Environmental Protection 

Proposed Contingency Measures for State Implementation Plan Submittal Number 2012-04 

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

Dear Mrs. Toney, 

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

U.S. Environmental Protection Agency (EPA) for review and approval a proposed revision to 

Florida’s State Implementation Plan (SIP) under the Clean Air Act (Submittal No. 2012-04). 

The proposed SIP revision consists of a Lead (Pb) Nonattainment Area Plan to ensure the 

attainment and maintenance of the revised Pb National Ambient Air Quality Standard 

(NAAQS) in Florida’s one Pb nonattainment area, which is located in Hillsborough County, and 

which centers upon a single facility – the EnviroFocus Technologies, LLC (EnviroFocus) lead 

recycling facility. On June 27, 2013, DEP amended its Pb Nonattainment Area Plan to 

incorporate the revised terms and conditions of a federally enforceable air construction permit 

for EnviroFocus, as it pertains to emissions of Pb. 

Florida is pleased to report that the most recent monitoring data for the nonattainment area 

reflect the significant emissions controls and process improvements undertaken at the 

EnviroFocus facility pursuant to the Plan. For the period ending in November 2014, the 

reference monitor most proximate to the facility reports a three-month rolling average of 0.05

μg/m3

, which is one-third of the standard. The dry autumn season has historically produced the 

highest averages at this location, so this figure strongly suggests that the facility’s control 

measures are yielding results.

By means of this letter, DEP seeks to supplement the “Contingency Measures” provisions of its 

pending Pb Nonattainment Area Plan to reflect additional procedures and controls at the 

EnviroFocus facility that would be implemented immediately upon the occurrence of various 

triggering events related to future monitored exceedances or violations of the Pb NAAQS.1

While retaining the “Contingency Measures” provisions currently contained within Florida’s 

1 The existing “Contingency Measures” provisions of Florida’s pending Pb Nonattainment Area Plan are located on 

page 23 of the amended submittal dated June 27, 2013.

www.dep.state.fl.us

 
Mrs. Heather McTeer Toney

December 23, 2014

Page 2 of 3

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

• If any one month period averages greater than 0.15 μg/m3 at any one of the 

approved SIP Pb monitors in the vicinity of EnviroFocus, once notified by the 

Florida Department of Environmental Protection’s Division of Air Resource 

Management (DARM) or the Environmental Protection Commission of 

Hillsborough County (EPC), the facility will immediately initiate an enhanced 

Operation & Maintenance (O&M) Plan for Pb control. This enhanced O&M Plan 

shall include the following:

1. EnviroFocus shall conduct a twelve minute EPA Method #9 visible 

emission reading on each Pb source outlet by a certified reader every 

day effective immediately;

2. EnviroFocus shall complete a dye leak check on every filtration device 

which controls a Pb source within 14 days and cease operation of any 

emission unit connected to a filtration device that fails the dye leak 

check until such time as repairs are made and the unit passes a second 

leak check.

3. EnviroFocus shall increase the sprinkler frequency to 5 minutes every 

30 minutes during daylight hours and 5 minutes every 60 minutes 

during nighttime hours twenty-four hours a day every day, effective 

immediately;

4. EnviroFocus shall vacuum the entire paved yard three times a day, 

except during rain events or within two hours of a rain event, effective 

immediately;

5. EnviroFocus shall keep daily records for each of these measures and 

submit these records monthly by the third business day of the following 

month to EPC and DARM, and upon request.

Each of these contingencies shall continue for a minimum of 90 days or until such 

time as DARM has determined that they are no longer needed.

• If any three consecutive month period averages greater than 0.15 μg/m3 at any 

one of the SIP-approved Pb monitors in the vicinity of EnviroFocus, once notified 

by the Florida Department of Environmental Protection’s Division of Air 

Resource Management (DARM) or the Environmental Protection Commission of 

Hillsborough County (EPC), the facility will continue with the measures detailed 

in the enhanced O&M Plan for Pb control listed above and, in addition, conform 

to the following:

1. EnviroFocus shall immediately cease any construction activities on 

site that disturb soils;

2. EnviroFocus shall immediately restrict yard traffic only to essential 

vehicles;

3. DARM may require immediate restriction of the daily production of 

www.dep.state.fl.us
Mrs. Heather McTeer Toney

December 23, 2014

Page 3 of 3

lead from the blast and reverb furnaces. Any production restriction 

shall be a percent reduction from the facility’s average production 

from the three-month period during which the monitor exceeded the 

0.15 μg/m3 standard, and shall be set by DARM based upon the 

facility’s anticipated stack emissions impact on the highest reading 

ambient lead monitor in the immediate area.

4. EnviroFocus shall keep daily records for each of these measures and 

submit these records monthly by the third business day of the following 

month to EPC and DARM, and upon request.

Each of these contingencies shall continue for a minimum of 90 days, or until 

such time as DARM has determined that they are no longer needed.

• If a fourth consecutive month is greater than 0.15 μg/m3 at any one of the SIPapproved Pb monitors in the vicinity of EnviroFocus, DARM may require further 

production restrictions and/or other contingencies as DARM deems necessary to 

reduce ambient lead concentrations in the area. DARM shall transmit written 

descriptions of any such contingency measures by certified letter, and such 

measures will be effective immediately upon receipt by EnviroFocus, and remain 

in effect until such time as DARM has determined that they are no longer needed. 

All of the contingency measures detailed above shall continue to apply. 

Applicable lead emission abatement measures may be revisited each and every 

consecutive month during which a SIP-approved Pb monitor averages above the 

standard.

Thank you for your attention to this request. If you have any questions about these proposed 

additions to the Contingency Measures for Florida’s pending Pb Nonattainment Area Plan, 

please contact me at any time at (850) 717-9000 or by e-mail at Paula.Cobb@dep.state.fl.us.

Sincerely,

Paula L. Cobb, Director

Division of Air Resource Management

cc: Lynorae Benjamin, Chief, Regulatory Development Section, 

Air Planning Branch, EPA Region 4

Cindy Mulkey, Program Administrator, Office of Business Planning, 

Division of Air Resource Management

www.dep.state.fl.us