From: <French.Chuck@epamail.epa.gov>

To: <Steve.Yates@grcmn.com>

CC: Donna Lazzari <Donna.Lazzari@erg.com>, <michael.burr@erg.com>, 

<Topham.Nathan@epamail.epa.gov>

Date: 1/31/2011 5:50 PM

Subject: Secondary Lead Smelters - Fugitive lead emissions and ICR responses

Dear Mr. Yates,

 Thank you for the information and data that you submitted to us in

response to the information collection request letters that we sent you

in June and July of 2010. The data and information are very helpful for

our Risk and Technology Review of the Secondary Lead Smelting source

category. We have been using much of the data and information in our

analyses as you reported.

 However, with regard to the estimates of fugitive lead emissions,

because of complexities of estimating these emissions, the data gaps and

incomplete information, and various uncertainties, we determined that it

was appropriate to gather additional information and conduct

supplemental analyses to calculate revised draft estimates of fugitive

emissions for some of the facilities.

 As you know, in the section 114 survey, we requested information

for stack and fugitive emissions from your facilities. We are now in

the process of conducting dispersion modeling of the emission estimates.

In some instances, we have found a discrepancy between the preliminary

results of the dispersion model and the values recorded at local ambient

monitors which cannot be accounted for by the stack and fugitive

emissions reported. EPA assumes the stack emissions are generally

reliable as they are based on actual test data, and the primary cause of

the discrepancy is due to releases of fugitive emissions. In your

surveys, it appears that you have provided stack emissions from process

and storage vents rather than estimates of fugitives which escape from

the process other than through a stack (such as roadway fugitives,

fugitives from storage piles or slag handling, or fugitives which escape

from buildings).

 Therefore, we have derived new or revised draft estimates of

fugitive emissions the Gopher Resources and Envirofocus facilities based

upon a review of the ICR responses and industry practices and

calculation methodologies. We have taken into account the size of the

facility, the degree to which facilities are contained within

enclosures, and the reported work practices described in your survey.

Moreover, we analyzed available ambient monitoring data near these

facilities in relation to initial preliminary modeling estimates.

 The draft estimates we have calculated for fugitive lead emissions

for your facility and the original estimate you provided in the survey

are provided in here:
 Gopher Resources, Eagan MN:

 1. estimate of fugitive lead emissions provided in your survey

response = 0.35 tons per year

 2. draft EPA estimate of total fugitive emissions of lead = 0.39

tons/yr

 Envirofocus, Tampa FL:

 1. estimate of fugitive lead emissions provided in your survey

response = 0.07 tons per year

 2. draft EPA estimate of total fugitive emissions of lead = 0.33

tons/yr

 Anyway, with this email we are providing you with an opportunity

to comment on our revised draft estimates, provide calculations and

documentation to support your original estimates, or provide alternative

estimates that you believe are more accurate. If you suggest

alternative estimates, please provide complete documentation and

explanation of the basis of such alternatives. If you would like to

comment or provide additional information or alternative estimates,

please send a response to this email by February 7th, 2011.

 Thank You,

 Chuck French, Environmental Scientist,

 U.S. EPA, Office of Air Quality Planning and Standards,

Sector Policies and Program Division

 Phone: 919-541-7912