Primary Lead Smelting NESHAP Technical Support Document



## Risk and Technology Review

National Emission Standards for Hazardous Air Pollutants (NESHAP) for the Primary Lead Smelting Source Category

Technical Support Document



# DRAFT 12/28/10

Docket No. EPA-HQ-OAR-2004-0305

January 31, 2011Primary Lead Smelting NESHAP Technical Support Document

i 

### Table of Contents

1.0 Residual Risk Analysis - Development of the Emissions Dataset for the Primary Lead Smelting Source Category ............................................................................................................... ................ 1

1.1 Emissions Data Sources .................................................................................................... .. 2

1.2 Risk Analysis Emissions Data Set ...................................................................................... 2

1.2.1 Actual Emissions ................................................................................................... 3

1.2.2 Allowable Emissions ............................................................................................. 4

2.0 Calculation of Proposed Emission Limi ts Based on Modeled Concentrations ................................ 7

3.0 Estimated Costs of Proposed Revisions to the Primary Lead Smelting NESHAP ........................ 10

3.1 Emission Control Costs for Acceptability Reductions ..................................................... 10

3.2 Emission Control Costs for Ample Margin of Safety Reductions .................................... 11

3.3 Additional Testing and Monitoring Costs ......................................................................... 13

Tables

Table 2.1 Calculations of Emission Li mits Based on Modeled Concentrations Table 2.2 Calculation of Proposed Refinery Operation Emission Limit based on Modeled Concentrations Table 3.1 Cost Effectiveness of Upgrading Baghouses to Membrane Bags for Baghouses 7, 8 and 9 Table 3.2 Cost Effectiveness of Adding A dditional Baghouses to Control Emissions for Baghouses 7, 8 and 9 Table 3.3 Cost Effectiveness of Upgrading Baghouses to Membrane Bags for Main Stack Table 3.4 Cost Effectiveness of Adding A dditional Baghouses to Control Emissions for Main Stack Table 3.5 Additional Testing and Monitoring CostsPrimary Lead Smelting NESHAP Technical Support Document

1 

### 1.0 Residual Risk Analysis ­ Development of the Emissions Dataset for

the Primary Lead Smelting Source Category

This memo describes the development of the data set used to conduct the residual risk analysis under Section 112 (f)(2) of the Clean Air Act (CAA) for the Primary Lead Smelting source
category.

Section 112 of the Clean Air Act (CAA) establishe s a two-stage regulatory process to address emissions of hazardous air pollutants (HAP) from st ationary sources. In the first stage, after EPA has identified categories of sources emitting one or more of the HAP listed in section 112(b) of the CAA, section 112(d) of the CAA ca lls for us to promulgate a National Emission Standard for Hazardous Air Pollutants (NESHAP) for those sources. These technology-based standards must reflect the maximum degree of emission reductions of HAP achievable (after considering cost, energy requirements, and non- air quality health and environmental impacts) and are commonly referred to as maximum achieva ble control technology (MACT) standards. The NESHAP for the Primary Lead Smelting sour ce category was promulgated on June 4, 1999.

The EPA is then required to review these te chnology-based standards and to revise them “as necessary (taking into account de velopments in practices, proce sses, and control technologies)” no less frequently than every 8 years, under CAA section 112(d)(6). In conducting this review, EPA is not obliged to completely recalc ulate the prior MACT determination. NRDC v. EPA

, 529 F.3d 1077, 1084 (D. C. Cir., 2008).

The second stage in standard-setting focuses on reducing any remaining “residual” risk according to CAA section 112(f)(2) and requires EP A to determine for source categories subject to certain MACT standards, whether the emission s standards provide an ample margin of safety to protect public health. If the MACT standa rds apply to a source category emitting a HAP that is “classified as a known, proba ble, or possible human carcin ogen do not reduce lifetime excess
cancer risks to the individual mo st exposed to emissions from a source in the category or subcategory to less than one-in-one million,” EPA must promulgate residual risk standards for the source category (or subcategory) as necessary to provide an ample margin of safety to protect public health. CAA section 112(f)(2)(A). In doing so, EPA may adopt standards equal to existing MACT standards if EPA determines that the existing standards are sufficiently protective.

In order to conduct the risk analysis of sources in the Primary Lead Smelting source category, a dataset was developed that included estimates of individual HAP emi ssions from each HAP emitting source as well as source characteristics. The dataset used includes both actual and allowable facility emissions and would be used in the emissions modeling exercise to determine
concentrations of various HAPs at the modeled receptor locations. Those concentrations would be compared to the established risk-based thre shold for each HAP to determine the potential forPrimary Lead Smelting NESHAP Technical Support Document

2 residual risk from the emissions. The methods, thresholds, and results of risk analysis and modeling are described in the “Residual Risk As sessment for the Primary Lead Smelting Source Category” memorandum included in this docket. Below is a discussion of the sources of the
actual and allowable emissions data and source ch aracteristics used in the risk analysis and modeling exercise.

1.1 Emissions Data Sources

The preliminary sources used to gather emissions and source characteristic data included the 2002 National Emissions Inventory (N EI) Final Inventory, Version 1 (made publicly available on February 26, 2006), and the 2005 National Emi ssions Inventory (NEI), version 2.0 (made publicly available in October 2008). The 2005 NEI was updated to develop the 2005 National Air Toxics Assessment (NATA) Inventory. NATA inventory updates for the primary lead smelting category included SIP da ta provided by the state of MO to EPA. These data sets
include information about sources that emit criter ia air pollutants, their precursors, and HAP.
The NEI database includes estimates of annual air pollutant emissions from point and volume sources, emission release characteristic data such as emission release he ight, temperature, and velocity, and location latitude/longitude coordina tes. We reviewed the NEI datasets, checked geographic coordinates, and made ch anges based on available information.

The sole remaining facility in this source category is the Doe Run Company in Herculaneum, Missouri. The Doe Run facility has been the su bject of many compliance and regulatory actions by the State of Missouri and by EP A Region 7 due to efforts to co mply with the lead National Ambient Air Quality Standard (NAAQS). The controls applicable to the faci lity in order to meet the NAAQS are codified in the Lead State Impl ementation Plan. In 2007 a SIP demonstration was conducted which included modeling of facility emissions to determine compliance with the
SIP. EPA also reviewed the emissions data us ed for that demonstra tion to update the risk analysis data set. Since many improvements in emissions controls have been implemented from 2001 through 2007 due to the 2001 SIP and the 2007 SIP revision, EPA determined that more recent data would be necessary to conduct an appropriate risk assessment of the current emissions impacts. EPA requested emissions a nd source control informa tion through a section 114 information collection request (ICR) in October, 2009. The February, 2010 Doe Run ICR response included copies of the emissions inve ntories that were provi ded to the Missouri Department of Natural Resources (MDNR) for the CY 2000 through 2008.

1.2 Risk Analysis Emissions Data Set

The analysis performed considers HAPs that ar e regulated by the existing MACT standard, and also considers any other HAPs that have the potential to present ri sk. The risk analysis considers both actual emissions of the facility and the em issions that would be allowable under the MACT rule. Once the analysis is complete, EPA de termines if any furthe r emission reductions arePrimary Lead Smelting NESHAP Technical Support Document

3 necessary to assure that an accep table level of risk is achieved. For the Doe Run facility, we
determined the actual and allowable emissions as described below.

1.2.1 Actual Emissions
We reviewed the NEI datasets, checked geograp hic coordinates, and made changes based on
available information. We also reviewed the emi ssions and other data to identify data anomalies
that could affect risk estimates. Since the 2008 emissions inventory is th e most recent emissions data source available, and reflects the implem entation of the numerous SIP emission reduction requirements (as evidenced by the ICR response), EPA determined that the emissions reported for the facility in the CY2008 emissions inventor y report would be the most representative of current facility operations and would also be appropriate for use in the risk analysis.

The dataset derived from the review of th e 2002 and 2005 NEI/NATA data was then updated to
include the emissions for all sources from the CY2008 emissions inventory report. Any
differences in the data between the NEI a nd the CY2008 emission inventory were noted and analyzed. If data found in the NEI was not included in the CY2008 emi ssion inventory, but was found to be pertinent, then it wa s included in the data set used for the risk analysis. Any discrepancies found between the NEI and the CY2008 emission inventory was discussed with the facility.

One specific change to the data set derived from the combination of the NEI data and the CY2008 emission inventory pertained to organic HAP em issions. The 2005 NEI file included several sources that emitted trace levels of 25 organi c HAP from natural gas and other combustion sources primarily through the main stack. The current VOC emission levels as reported in the ICR response are well below the level which can be addressed by current controls. In addition, the levels are low enough to preclude effectively modeling for risk assessment (i.e. the dispersion
from the 500 foot stack would eff ectively put any modeled emissions at zero at rece ptor sites). Therefore, the organic HAP emi ssions sources were removed from the modeling dataset and not considered during the risk analysis.

The final dataset included emissions of lead compounds and other metal HAP (i.e. antimony, arsenic, cadmium, chromium, c obalt, and nickel) which are th e HAP currently regulated under
the MACT standard.

“Lead compounds” is the primary HAP emitted from the Doe Run facility and accounts for approximately 99 percent of the total HAP emitted. Of the lead compound emissions, approximately 86 percent is emitted through stacks ( point or vertical sources) with the remainder being fugitive emissions. The point or vertic al sources include stacks that discharge from baghouses, heat stacks and roof vents. The MA CT emission limit applies to operations that discharge through 2 stacks, the main and baghous e #7 stacks which account for 15.1 of the total 17.9 TPY stack lead compound emissions. Since pr omulgation of the MACT rule, the facilityPrimary Lead Smelting NESHAP Technical Support Document

4 has captured and controlled all refining operations with two additional baghouses (baghouse #8 which vents to a stack and baghouse #9 which vents to a common stack with baghouse #7).
These emissions are included in the table below. Fugitive sources include material handling and plant yard and roadway dust. Table 1.1 summarizes the types and volumes of HAP and the types
of sources included in the dataset for the Doe Run Company facility. Total actual lead emissions including fugitive emissions are 20.7 tons per year (TPY). It should be noted that non-volatile
metal HAP other than lead ar e reported by Doe Run based on sp eciation tests c onducted for the
various sources.

Table 1.1 - Summary of Doe Run Comp any Risk Dataset Emission Sources Fugitive Stack Total

HAP Number of Sources TPY Number of Sources TPY Number of Sources TPY

Lead 115 2.8053 22* 17.9030 137 20.7083 Antimony 6 0.0028 4 0.0252 10 0.0280

Arsenic 10 0.0005 6 0.0210 4 0.0215

Cadmium 12 0.0296 7 0.0823 19 0.1118

Chromium 0 0.0000 3 0.0056 3 0.0056

Cobalt 6 0.0005 6 0.0049 12 0.0054

Nickel 8 0.0019 7 0.0154 15 0.0172 *Of the 22 stack sources, 2 are included within the MACT emission limit which account for 17.6 of the 17.9 TPY.

The actual emissions dataset for this facility repr esents the entire source category. Likewise, all HAP emission points for this sour ce are included in the risk anal ysis dataset; therefore, the facility-wide emission dataset for this source categor y is the same as the risk analysis dataset.

1.2.2 Allowable Emissions

Allowable emissions are emissions that woul d be allowed under the current NESHAP for primary lead smelters. For the Primary Lead Smelting source category and NESHAP, lead is the regulated HAP and other non-volatile metal HAP ar e regulated using lead as a surrogate. Therefore, allowable emissions would only apply for the lead compound emissions. For the Doe Run facility, allowable lead compound emissions are summarized in Table 1.2.

Under the NESHAP, an emission limit of 1.0 pound of lead per ton of lead produced (lb/ton) applies to the following nine sources:

1) Sinter machine 2) Blast furnace 3) Dross furnace 4) Dross furnace charging location 5) Blast furnace and dross furnace tapping location 6) Sinter machine charging locationPrimary Lead Smelting NESHAP Technical Support Document

5 7) Sinter machine discharge end 8) Sinter crushing and sizing equipment 9) Sinter machine area

Applying the allowable emissions rate of 1.0 lb/ton to the Do e Run’s 2008 lead production of 149,564 tons, the allowable emissions from the a bove nine sources would be 74.8 TPY. All emissions from the source’s nine emission poin ts listed above are cap tured and controlled by baghouses, which vent to the main stack or the furnace area stack. The total allowable emissions were prorated between the two stacks based on th e ratio of actual emissi ons reported for the two
stacks.

Note that refining operations are not listed above and ar e not subject to the 1.0 lb/ton limit in the original MACT. At the time the NESHAP was promulgated, refining operations were a fugitive emissions source, however, these emissions under the current facility configuration are now captured, controlled by a baghouse, and vented through two stacks. As the emissions are no longer fugitive, and the MACT emission limit does not apply to the operation, we were unable to
calculate an allowable emission le vel for refining operations.

Under the NESHAP, fugitive emissions are governed by work practices, which under §63.1544
are defined as the measures that will be “put into place to contro l fugitive dust emissions.” Thus, the actual fugitive emissions, which reflect the meas ures that have been put in place, would be equivalent to the allowable emissions. Fugitiv e emissions levels were taken from Doe Run’s 2008 Emissions Inventory that is submitted annually to the MDNR.

Table 1.2 Summary of Actual and Allowable Lead Emissions for the Doe Run Primary Lead Smelter, 2008 1

Emission Point Processes Actual Emissions

(TPY) Allowable Lead Emissions

(TPY) Main Stack (BH # 3, 5, 6) Sintering, blast furnace, dross furnace 13.31 65.8

Furnace Area (BH # 7) Smelter building 1.81 8.94 Refining (BH # 8, 9) Refining kettles and building N/A N/A Fugitives Roadways, storage piles, materials handling and transport 2.85 2.85

As shown above, we estimate that MACT-allowabl e emissions from this source category are about four times greater than th e actual emissions, based on the MA CT limit (1 lb/ton) applied to 2008 production data and compared to 2008 actual em issions. The modeling file for this risk analysis can be reviewed in the EXCEL spreadsheet

“ PrimLead_RTR_ModelingFile_102110_2008_DOE_RUN.xls ” available in the docket.Primary Lead Smelting NESHAP Technical Support Document

6 References:

1. Curran, D., Stinson Morrison Hecker, for The Doe Run Company, to Nizich, S., US EPA, Response to Section 114 Information Collection Request, February 5, 2010.Primary Lead Smelting NESHAP Technical Support Document

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### 2.0 Calculation of Proposed Emission Limits Based on Modeled

Concentrations

The risk analysis process included modeling of ac tual and allowable emissions to determine the anticipated concentration at individual recept or locations. For this source category, the emissions for the lead emissions sources were individually modeled fo r each receptor location and the results were compared to the Primary National Ambient Air Standard (NAAQS) for lead (0.15 μ g/m 3 ). If the modeled emissions exceeded the lead NAAQS, those locations were considered to be exposed to unacceptable risk. The results indicated multiple locations exceeded the level of the NAAQS to various degrees.

Our modeling results indicated that emissions from the main stack did not exceed NAAQS within the 50 km radius modeled. The highest concentration location wa s a point on the property boundary. Emissions contributing to this exceeda nce were found to be cumulative fugitive dust emissions from various emission points. Other em ission points that resulted in exceedance of the lead NAAQS were the furnace area stack and th e Baghouse #9 stack for the refinery building, both at various census block locations.

Each emission point (with fugitive dust emissi ons being treated as one emission point) were analyzed to determine what emission levels woul d be necessary to reduce risk to an acceptable level. EPA determined that if the emissions from each emission point were reduced below the NAAQS level based on the worst-ca se or highest location concentr ation, then all risk for that emission point at any location w ould be reduced to acceptable levels. Therefore, a roll-back calculation was conducted to determ ine what percentage reduction in concentration was required for each of the highest concentration locations. Since the relationship betw een level of emissions and modeled concentrations is linear, a percen tage reduction could be applied to the actual emissions from the CY 2008 emissions inventory for a given emission point that would reflect the same reduction in modeled concentration.

The reduction necessary to address fugitive dust emissions risk was determined to be 98 percent. The reduction necessary to address the furnace area stack emissions was determined to be 52 percent.

The refinery emissions are vented through Baghouse #8 and Baghouse #9 stacks, and ten heat stacks. For the refinery operation, only one stack (Baghouse #9) showed exceedance of the NAAQS. The emission reduction found necessary from Baghouse #9 stack is 66 percent, which was applied to the total emissions from all of the refinery operation emissions points.

Table 2.1 summarizes the calculati ons and recommended limits for the total facility including furnace area stack, fugitive dust, and the refine ry operations. Table 2.2 summarizes just the refining operation calculation, consideri ng all contributing emission points.Primary Lead Smelting NESHAP Technical Support Document8Table 2.1 - Calculations of Emission Limits Based on Modeled ConcentrationsModeled Source2008 Emissions(tpy)Highest receptorlocation Concentration Roll back %Emissions afterrollback (tpy) NotesStacks- Main 13.31 0.007 0 13.31No risk impacts within 50 km- Baghouse #7, furnace area 1.81 0.314 520.86At census block #290997006014031- Baghouse #8 - refinery kettles 2.03 0.079 0 see below Included in refinery max calculation- Baghouse #9- refinery buiding 0.45 0.352 57 see below Included in refinery max calculationTotal of BHs 7+8+9 4.29 0.745 80 15.12Refinery stacks 2.74 0.4363 660.94BHs #8, #9 and heat stacks, see refinery maxcalculationSmelter Fugitives 2.55 6.94 980.06Fume, sinter and concentrate handlingPlantwide Fugitives 0.39 1.063 86 0.06 Roadays, plant yard, resuspensionAll Fugitives 2.94 7.289 98 0.061) Emission LimitAmbient lead concentration atproperty boundary*0.15 ug/m32) Emissions CapFurance Area stack (BH#7) 0.86 TPYRefinery stacks 0.94 TPY* To address 98% reduction needed from fugitive emissions, with receptor location at property boundary.Calculations Roll back % = (Actual concentration - 0.15)/actual concentrationEmissions after rollback = 2008 emissions * (1-(rollback%/100))RECOMMENDED ACTIONSAll Modeled SourcesPrimary Lead Smelting NESHAP Technical Support Document9Table 2.2 - Calculation of Proposed Refinery Operation Emission Limit based on Modeled ConcentrationsModeled SourceModeled values at the site of max.impact for refinery stack sources(ug/m3)*50007 Baghouse #8 Stack 0.070750008 Baghouse #9 Stack 0.315050011 Refinery Kettle Heat Stack 0.001050012 Refinery Kettle Heat Stack 0.001050013 Refinery Kettle Heat Stack 0.001050014 Refinery Kettle Heat Stack 0.001050015 Refinery Kettle Heat Stack 0.001050016 Refinery Kettle Heat Stack 0.001050017 Refinery Kettle Heat Stack 0.001050018 Refinery Kettle Heat Stack 0.0011Subtotal all refinery stacks 0.4363Ratio of NAAQS to refinery max 0.34 or 0.15/.4364Percent reduction required 0.66 or 1- 0.34TPY emission cap 0.94 or (NAAQS limit * TPY refinery current)/refinery maxlb /ton on rolling avg. 90 days 0.01 or (0.94 *2000 /149,500)Refinery Maximum CalculationPrimary Lead Smelting NESHAP Technical Support Document

10 

### 3.0 Estimated Costs of Proposed Revisions to the Primary Lead Smelting NESHAP

With regard to lead emissions, we are proposing to require most of the emission sources at the facility to implement all technically feasible contro ls in order to ensure that the ambient air meets the level of the lead NAAQS, which is the level we have determined will ensure an acceptable level of risk. EPA has determined that lead co mpound emissions must be reduced to allow for an acceptable level of risk for fugitive dust emissi ons, emissions from the furnace area stack, and the refining operation. As a result, the facility w ill need to implement emission controls or other actions that will reduce lead emissions to an acceptable level and to meet the new emission limits/caps in this proposed rule. In addition, in order to demonstrat e compliance with these limits, additional ambient lead contin uous monitoring is being required. This section summarizes the impacts analysis conducted on all addi tional emission control options that were considered technologically feasible for achie ving all necessary reductions as well as those monitoring costs necessary to comply with proposed requirements.

We note that the same controls for the three emission points to reduce lead emissions are the same controls that would reduce risks from cad mium and all other metal HAP; therefore we are not proposing additional, or other controls for control of other metal HAP.

For fugitive dust emissions, which are controlled by work practices, no additional controls were evaluated because all reasonable pr actices are currently being impl emented. Therefore, there are no additional controls and cost impacts considered for fugitive dust emissions however, based on our proposed concentration limit, we have evaluate d the costs for ambient monitoring to meet the requirement. For the four stack emission poi nts, we considered the upgrading of existing baghouses from use of cloth bags to membrane bags and addition of an in-series baghouse emission as emission reduction options.

3.1 Emission Control Costs for Acceptability Reductions
Emissions from the main stack did not trigge r unacceptable risk levels however; emission reductions were required from the furnace ar ea (baghouse #7), refining kettles (baghouse #8), refinery building (baghouse #9) and fugitive dust to meet acceptability requirements. Although costs are not considered under se ction 112(f)(1) (acceptability) in order to meet acceptable risk, EPA has estimated the cost impacts for these em ission controls for the furnace area and refining operation stacks, and has also estimated the cost s for the proposed ambient lead monitoring.

EPA estimates that replacing existing cloth bags in all baghouses will provide an approximately 95 percent reduction in emissions from the em ission points controlled by baghouses.

Table 3.1 summarizes the costs and cost-effec tiveness upgrading existi ng baghouses from cloth bags to membrane bags. Table 3.2 summarizes the costs and cost-effec tiveness of adding inseries baghouses. The calculatio ns supporting the costs reflected in the summary are included in EXCEL spreadsheet DRAFT ImpactsEst_PrimLeadRTR_122210.xls found in the docket.Primary Lead Smelting NESHAP Technical Support Document

11 3.2 Emission Control Costs for Ample Margin of Safety Reductions
Once we ensure that the risk is acceptable, we then determine whether further reductions are appropriate to ensure an ample ma rgin of safety. We investigated available and feasible control options that could be implemente d by the facility to attain the additional emissions reductions to provide an ample margin of safety.

Because all feasible controls will need to be adopted in order to meet the risk acceptability reductions, there are no additional controls to consider for fugitive dust emissions, the furnace area stack, and the refinery stacks. For the main stack, additional controls were evaluated and considered with regard to risk reduction and cost under the ample margin of safety analysis.

For the main stack, our risk anal ysis indicates that the main stack emissions do not result in ambient lead levels exceeding the NAAQS based on either actual or allowable emission levels. However, we determined that it is technologicall y feasible to reduce emissions from the main stack to a level well below the allowable level of the MACT, since thos e levels are currently being achieved. We evaluated ad ditional controls such as membrane bags or add-on baghouses as a means for achieving those reductions and redu cing associated risk. We determined that the additional controls would not provide an apprec iable risk reduction (emission reduction) for the associated cost. However, we have determined that emissions allowable under MACT should be reduced under the section 112(d )(6) technology review as descri bed in the technology review memorandum found in this docket.

Table 3.3 summarizes the costs and cost-effec tiveness of upgrading existing baghouses from cloth bags to membrane bags. Table 3.4 summari zes the costs and cost-effectiveness of adding an in-series baghouse. The calculations suppor ting the costs reflected in the summary are included in EXCEL spreadsheet DRAFT ImpactsEst_PrimLeadRTR_122210.xls found in the docket.Primary Lead Smelting NESHAP Technical Support Document12Total CostInvestmentTotalAnnualizedCost2008 BaselinePb Emissions(tpy)Emission Reductionfrom upgrade*(tpy)CE($/ton)Furnace area, BH 7 81,548 27,5911.81 0.9529,043Refining, BH 8 102,032 17,048 0.45 0.21 81,179Refining BH 9 366,932 60,471 2.03 1.3 45,467*We estimate removal efficiency for membrane bag update to be between 50 and 70 percent.Cost of Upgrade toMembrane BagsTable 3.1 - Cost Effectiveness of Upgrading Baghouses to Membrane Bags for Baghouses 7, 8 and 9ImpactsSourcePb emissions (tpy)reported in 2008EIPb emission reductionwith additional BHassuming 50% RE (tpy)Pb emission reductionwith additional BHassuming 97% RE (tpy)Annualized cost ofadding extra BH's($/yr)Cost effectivenessassuming 50% RE($/ton)Cost effectivenessassuming97% RE($/ton)BH 7 1.81 0.9 1.8BH8 0.45 0.2 0.4BH 9 2.03 1.0 2.0Total 4.29 2.1 4.2 $849,750 $396,154 $204,2031Reflects costs for pulsejet baghouses2See DRAFT ImpactsEst_PrimLeadRTR_122210.xls for detail on cost analysis.RE = Removal efficiencyTable 3.2 - Cost Effectiveness of Adding Additional Baghouses to Control Emissions for Baghouses 7, 8 and 91,2Total CostInvestmentTotalAnnualizedCost2008 BaselinePb Emissions(tpy)Emission Reductionfrom upgrade*(tpy)CE($/ton)Main Stack 1,958,851 322,823 13.31 8.0 40,424*We estimate removal efficiency for membrane bag update to be between 50 and 70 percent.Cost of Upgrade toMembrane BagsTable 3.3 - Cost Effectiveness of Upgrading Baghouses to Membrane Bags for Main StackImpactsSourcePb emissions (tpy)reported in 2008EIPb emission reductionwith additional BHassuming 50% RE (tpy)Pb emission reductionwith additional BHassuming 97% RE (tpy)Annualized cost ofadding extra BH's($/yr)Cost effectivenessassuming 50% RE($/ton)Cost effectivenessassuming97% RE($/ton)Main Stack 13.31 6.7 12.9 $1,529,730 $229,862 $118,4851Reflects costs for pulsejet baghouses2See DRAFT ImpactsEst_PrimLeadRTR_122210.xls for detail on cost analysis.RE = Removal efficiencyTable 3.4 - Cost Effectiveness ofAdding Additional Baghouses to Control Emissions for the Main Stack1,2Primary Lead Smelting NESHAP Technical Support Document

13 3.3 Additional Testing and Monitoring Costs

Based on the elevated risk levels found for the furnace area stack and the refining operation stacks, EPA is proposing emission caps for those emission points. To demonstrate compliance with the new emission caps and the plant—wide emission limit, EPA is proposing to require quarterly stack testing. Although the method for te sting is the same as it was under the current MACT, the quarterly frequency requirement imposes additional impact with re gard to the cost of additional testing.

In addition, the risk analysis results indicate that modeled le ad concentrations exceed the NAAQS at several of the property boundary rece ptor locations. Since the impact at these locations is driven by fugitive dust emissions, EP A is proposing an ambient lead concentration limit at the property boundary. To demonstrate co mpliance with this limit, EPA is proposing to require ambient lead monitoring at four locations that would be most representative of the highest modeled emissions of lead.

The additional monitoring requirements will cause annual costs for the performance of additional testing and monitoring. Since EPA assumes that monitoring equipment will be leased and not purchased, there are no anticipated capital costs associated with th e new requirements. We have determined the cost for the additional testing and monitoring to meet these requirements as
summarized in Table 3.5 below.

Table 3.5 - Additional Testing and Monitoring Costs Type of Testing/Monitoring Notes Cost Annual Cost 1 Stack Testing Method 12 $13,000 per test $156,000 Ambient Lead Monitoring (lab analysis) Per required monitoring plan $127 per test $185,420

Ambient Monitoring Equipment A nnual Lease $2,500 per unit $10,000

1 Includes 12 additional stack tests (4 stacks x 3 more test s) and 4 ambient monitors, each tested 365 days per year

.