From: Chuck French/RTP/USEPA/US 

 To: "Steinwurtzel, Robert N." <rsteinwurtzel@bakerlaw.com> 

Cc: "DeLaquil, Mark" <mdelaquil@bakerlaw.com>, "Russell Kemp" <rkemp@environcorp.com>, 

"Steinwurtzel, Robert N." 

 Date: 02/07/2011 03:52 PM 

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

Hi Russell, Robert, and Mark, 

 Sorry for the delay with sending you additional documentation. Subsequent to the emails that I 

sent you on 1/31 and 2/1, we have continued to evaluate the estimates of fugitive lead emissions for 

the facilities over the past few days. We have reviewed further the ICR responses and other 

information and revised the draft emissions estimates a bit. Anyway, attached is a draft document 

describing the draft estimates of fugitive lead emissions for the 14 Secondary Lead facilities. Also 

attached is a table comparing the estimates that I sent to you on 1/31 and 2/1 compared to the draft 

estimates provided in the attached document (dated 2/7/2011). Please review the attached documents 

and let us know if you have any comments or suggestions on these draft estimates or the 

documentation. If you suggest alternative estimates, please provide complete documentation and 

explanation of the basis of such alternatives. If you would like to provide comments, additional 

information, or alternative estimates and documentation, please send those to us no later than 

February 10 th , 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 

(See attached file: DRAFT-estimates-Fugitive Metal Emissions-2-7-11 .docx)(See attached file: Draftcomparison-of-estimates of fugitive lead-emissions.doc) 
DRAFT for Review – Under Development - Do Not Cite Or Quote – (2/7/2011) – 

Draft Section of Emissions Technical Document for Secondary Lead RTR 

February 7, 2011 

Draft Estimates of Fugitive Lead Emissions for the 

Secondary Lead Smelting Facilities 

1.0 Fugitive Metal Emissions

Because they cannot be captured or directly measured, fugitive emissions are the most 

challenging emission type to estimate. In 2010, as part of an information collection request 

(ICR), EPA asked the Secondary Lead industry to provide their best estimate of the emissions 

from fugitive sources (e.g., building openings, raw material storage piles, roadways, parking 

areas) at their facilities and to provide a description of the basis for the estimates (e.g., test data, 

emissions factors, mass balance calculations, engineering judgment). For our analysis of fugitive 

emissions for the source category, we first reviewed and evaluated the estimates of fugitive lead 

emissions that were submitted by each of the facilities in response to the 2010 ICR to determine 

the reliability and appropriateness of those estimates as an input to our risk analyses and other 

assessments. Based on that evaluation we concluded that some facilities reported estimates that 

were relatively complete, seemed within the range of expected estimates, and were supported 

with documentation. However, we concluded that there were significant gaps and incomplete 

documentation for a number of other facilities, a large amount of variability in estimates between 

the facilities, and various significant uncertainties. For example, five facilities provided no 

estimate of fugitive emissions, several facilities provided quite incomplete estimates (e.g., for 

roadways only), and other estimates were not sufficiently documented. A summary of the 

responses are shown in Attachment #1. 

Based on this review and evaluation, we concluded that estimates for four facilities 

appeared to be reliable estimates of total fugitive emissions that we believe are reasonable 

estimates that we could use as input for our risk analysis. For the remaining 10 facilities, we 

searched for other sources of information (such as the EPA’s Toxics Release Inventory) to try to 

find reliable estimates of fugitive emissions. Based on that search, we found estimates for three 

other facilities that appeared to be adequate estimates of total fugitive emissions to serve as 

inputs to our risk analyses. Thus, we identified reasonable estimates for seven facilities either 
DRAFT for Review – Under Development - Do Not Cite Or Quote – (2/7/2011) – 

Draft Section of Emissions Technical Document for Secondary Lead RTR 

from the ICR responses or the TRI. The emissions estimates for these seven facilities are shown 

in table 1. 

Table 1. Summary of DRAFT fugitive lead emission estimates for seven of the secondary 

lead smelting facilities. 

For the other seven facilities, we concluded that the estimates in the ICR were far too 

incomplete to be reliable estimates of total fugitive emissions for the facilities and we did not 

identify adequate estimates in the TRI. Therefore, we decided to calculate estimates for these 

seven facilities using the approach and method described in the following paragraphs. 

For these seven facilities, we determined that it was appropriate to estimate emissions for 

each facility using a consistent methodology that utilized the best available emissions estimate 

for any one of the 14 facilities as a starting point to establish estimates for the other facilities by 

applying various correction factors and modification factors to reflect characteristics and 

differences across the facilities. Thus, a model facility was chosen (among the 14 facilities in 

our dataset) due to the superior documentation and completeness of their estimates as a basis for 

estimating fugitive emissions at all the other facilities. 

Each facility was compared to the model facility and an estimate of total lead fugitives 

was calculated based on a number of factors including relative size, degree of enclosure, and 

degree of work practices applied at each of the facilities. With regard to enclosure, information 

provided by each facility on building containment was used to categorize the facilities as 

enclosed, partially enclosed, or unenclosed. The facilities categorized as enclosed generally have 

Facility Is the facility enclosed, 

partially enclosed, or 

unenclosed? 

Fugitive Pb 

Emissions 

Estimate (tons/yr)

Source of the 

Estimate

Exide Frisco, TX Partially enclosed 1.03 ICR Response

Exide Muncie, 

IN 

Enclosed 0.22 ICR Response

Exide Vernon, 

CA 

Enclosed 0.103 ICR Response

Sanders Lead, 

AL 

Unenclosed 1.6 2009 TRI

EnviroFocus, FL Partially enclosed 0.213 2009 TRI

Gopher Eagan, 

MN 

Enclosed 0.35 ICR Response

East Penn, PA Enclosed 0.272 2009 TRI
DRAFT for Review – Under Development - Do Not Cite Or Quote – (2/7/2011) – 

Draft Section of Emissions Technical Document for Secondary Lead RTR 

complete enclosures with negative pressure for all their process activities. The facilities 

designated as partially enclosed generally had specific parts of their process in negative pressure 

enclosures (e.g., raw materials storage, furnace activities) while those facilities designated as 

unenclosed generally did not have any of their major processes under a negative pressure 

enclosure. We assumed that facilities that are totally enclosed would have about 1⁄4 the amount 

of fugitive emissions compared to an unenclosed facility given all other factors being equal. We 

assumed that a partially enclosed facility would have about 3⁄4 the amount of fugitive emissions 

compared to a fully enclosed facility. Thus, a factor of 0.25 (for totally enclosed facilities) and 

0.75 (for partially enclosed facilities) were applied to the fugitive lead estimates at these facilities 

in order to reflect approximate reductions that we expect would occur due to the level of 

enclosure at each facility. 

A housekeeping factor was also developed in order to characterize the level of work 

practices in place at each facility to control fugitive emissions. Information reported by the 

industry in their surveys was used to determine the extent to which they implemented work 

practices that go beyond the current secondary lead smelting NESHAP. Factors ranging from 1 

(work practices consistent with the current NESHAP) to 0.2 (work practices far beyond the 

current NESHAP) were then applied to the fugitive lead estimates at these facilities in order to 

reflect reductions that may occur due to the work practices in place at each facility. The model 

plant chosen is Exide in Frisco, Texas, because in their ICR response it appears that they had the 

most complete, well documented and supported estimate of all the responses. They reported 

estimates based on engineering calculations for vehicle traffic, raw material storage, slag 

handling, material handling, blast & reverb fugitives, and refining and casting fugitives. The 

total estimated emissions for the facility were 1.03 tons per year of fugitive emissions of lead 

compounds, which we designated as the emissions factor for the model plant. The estimates for 

the other facilities were calculated by multiplying the emissions factor (1.03 tons/yr) by a size 

factor, an enclosure factor, and a housekeeping factor. For example, Exide Forest City, Mo is 

estimated to be roughly the same size as Exide Frisco (size factor = 1), and is partially enclosed 

(0.75), and does typical work practices (i.e., housekeeping factor = 1). Therefore, the estimated 

emissions for Exide Forest City, Mo are calculated as follows: 

1.03 tons/yr x 1.0 x 0.75 x 1.0 = 0.77 tons per year. 
DRAFT for Review – Under Development - Do Not Cite Or Quote – (2/7/2011) – 

Draft Section of Emissions Technical Document for Secondary Lead RTR 

Table 2 summarizes the enclosure and housekeeping factors used and lists the estimated 

fugitive lead emissions for each of the seven facilities. Table 3 presents an overall summary of 

the estimates for all 14 facilities. 

Table 2. Draft Estimates of Fugitive Lead Emissions for Seven Secondary Lead Facilities. 

Facility

Emissions factor 

(tons/yr) used to 

calculate 

emissions (based 

on model plant) 

Size Factor (rough 

estimate of the ratio of 

the size of the facility 

compared to size of 

the model plant)

Enclosure 

Factor

Housekeeping 

Factor

Fugitive Pb 

Emissions 

(tons/yr)

Exide Baton 

Rouge, LA 

1.03

1 1.00 1 1.03 

Exide Forest 

City, Mo 

1.03

1 0.75 1 0.77 

Exide Reading, 

PA 

1.03

1 0.75 1 0.77 

RSR, NY 1.03 1 0.25 0.25 0.064

Quemetco 

(CA) 

1.03

1 0.25 0.2 0.052 

Quemetco (IN) 1.03 1 0.25 0.25 0.064

Doe Run, 

Buick RRF, 

MO 

1.03

2 

1.00 

1 2.06 
DRAFT for Review – Under Development - Do Not Cite Or Quote – (2/7/2011) – 

Draft Section of Emissions Technical Document for Secondary Lead RTR 

Table 3. Summary of DRAFT Fugitive Lead Emission Estimates for the Secondary Lead 

smelting facilities. 

To estimate fugitive emissions for metals other than lead (i.e., arsenic, cadmium, 

chromium, manganese, mercury, and nickel), a ratio of these other metals to lead was developed 

based on total stack emissions of these pollutants from all the facilities (see Table 4). These 

ratios were then applied to the fugitive lead emissions at each facility. 

Table 4. Ratios used to estimate fugitive emissions of metals other than lead. 

HAP HAP/Pb Ratio

Arsenic 2.54E-02

Beryllium 1.73E-04

Cadmium 1.86E-02

Chromium 3.76E-03

Chromium (VI) 3.76E-05

Chromium +3 3.72E-03

Manganese 1.71E-02

Mercury 8.37E-03

Elemental Hg 6.70E-03

Divalent Hg 8.37E-04

Particulate Hg 8.37E-04

Nickel 7.07E-03

Facility Is the facility enclosed, 

partially enclosed, or 

unenclosed? 

Fugitive Pb 

Emissions Estimate 

(tons/yr)

Source of the 

Estimate

Exide Baton Rouge, 

LA 

Unenclosed 1.03 EPA estimate

Exide, Forest City, 

MO 

Partial enclosure 0.77 EPA estimate

Exide, Frisco, TX Partial enclosure 1.03 ICR Response

Exide, Muncie, IN Enclosed 0.22 ICR Response

Exide, Reading, PA Partial Enclosure 0.77 EPA estimate

Exide, Vernon, CA Enclosed 0.103 ICR Response

RSR, Middletown, 

NY 

Enclosed 0.064 EPA estimate

Quemetco (CA) Enclosed 0.052 EPA estimate

Quemetco (IN) Enclosed 0.064 EPA estimate

Sanders Lead, A Unenclosed 1.6 2009 TRI

EnviroFocus, FL Partial enclosure 0.213 2009 TRI

Gopher Eagan, MN Enclosed 0.35 ICR Response

Doe Run, Buick 

RRF, MO 

Unenclosed 2.06 EPA estimate

East Penn, PA Enclosed 0.272 2009 TRI
DRAFT – Under Development - Do Not Cite or Quote (2/7/2011) 

Table 5. Comparison of the DRAFT Fugitive Lead Emission Estimates for the Secondary Lead 

smelting facilities calculated on 1/31/2011 and 2/1/2011 compared to the revised draft estimates 

provided in the document* dated 2/7/2011. 

* Document titled: “Draft Estimates of Fugitive Lead Emissions for the Secondary Lead 

Smelting Facilities”, dated February 7, 2011. 

Facility Is the facility enclosed, 

partially enclosed, or 

unenclosed? 

DRAFT Fugitive Pb 

Emissions Estimate 

provided to companies 

by email on 1/31/2011 

or 2/1/11 (tons/yr)

Revised draft Fugitive 

Pb Emissions Estimate 

calculated in draft 

document dated 

2/7/2011 (tons/yr)

Exide Baton 

Rouge 

Unenclosed 0.84 1.03

Exide Forest City Partial enclosure 0.57 0.77

Exide Frisco Partial enclosure 1.03 1.03

Exide Muncie Enclosed 0.26 0.22

Exide Reading Partial Enclosure 0.75 0.77

Exide Vernon Enclosed 0.23 0.103

RSR Enclosed 0.09 0.064

Quemetco (CA) Enclosed 0.06 0.052

Quemetco (IN) Enclosed 0.08 0.064

Sanders Lead Unenclosed 1.4 1.6

EnviroFocus Partial enclosure 0.33 0.213

Gopher Eagan Enclosed 0.39 0.35

Buick RRF Unenclosed 3.13 2.06

East Penn Enclosed 0.33 0.272