IDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

We Protect Hoosiers and Our Environment. 

100 N. Senate Avenue • Indianapolis, IN 46204 

{800) 451-6027 • (317) 232-8603 • www.idem.IN.gov 

Michael R. Pence 

Ms. Susan Hedman 

Regional Administrator 

U.S. Environmental Protection Agency 

Region 5 

77 West Jackson Boulevard 

Chicago, IL 60604-3950 

Dear Ms. Hedman: 

October 31 , 2013 

Thomas W. Easterly 

Commissim1er 

Re: Technical Addendum for the Attainment 

Demonstration and Technical Support 

Document for the Muncie, Delaware 

County, Indiana Lead Nonattainment Area 

The Indiana Department of Environmental Management (IDEM) has prepared 

this technical addendum to the Attainment Demonstration and Technical Support 

Document for the Muncie, Delaware County, Indiana Lead Nonattainment Area 

(Attainment Demonstration) to provide modeled emission limits for Exide Technologies 

(Exide) proposed plans to construct and install two new bag houses to existing 

processes. IDEM submitted the Attainment Demonstration to the United States 

Environmental Protection Agency (U.S. EPA) for review on June 11, 2012 and a final 

submission on March 14, 2013, to demonstrate how the area will attain the National 

Ambient Air Quality Standard (NAAQS) for lead by the attainment date (i.e. December 

31,2015). 

Exide submitted a significant permit modification application to their Title V permit 

to IDEM in May, 2013. Exide plans to construct and install an additional bag house in 

the refinery area, where two pig casting machines and 11 pot furnaces are located (i.e. 

Refinery Bag House #2). This new bag house will have its own exhaust stack separate 

from the existing refinery bag house stack (i.e. Refinery Bag House #1 ). Exide will 

maintain the lead Prevention of Significant Deterioration (PSD) minor limit combined for 

both of these bag houses. 

The second new bag house (i.e. Bin Room Bag House #2) will be installed in the 

bin room area, where lead containing material storage and slag crushing are contained. 

This new bag house will have its own exhaust stack separate from the existing bin room 

bag house stack (i.e. Bin Room Bag House #1). Exide will maintain the lead PSD minor 

limit combined for both of these bag houses. 

An Equal Opportunity Employer 0 <i} Recycled Paper A State that~ 
Ms. Hedman 

Page 2 

The most recent version of AERMOD (BE EST Version 1 0.07) was used to 

conduct the updated air quality analysis. Pre-processed meteorological data from 

Indianapolis International Airport and upper air data from Wright-Patterson Air Force 

base in Dayton, OH were used for the analysis. The data include 1-rninute readings 

from 2006 through 2010. All elevations for the buildings, sources, and receptors were 

calculated using the AERMAP program. Building downwash from the Exide facility was 

considered in the analysis. No fugitive sources were considered for this analysis. 

Receptors were placed at 100 meter intervals along the fenceline. Receptors were also 

placed at 100 meter intervals to 2,000 meters away from Exide's fenceline and at 500 

meter intervals up to 10,000 meters away from the fenceline. Monthly concentrations at 

3,751 receptors were calculated. 

Table 1 lists each unit's permitted allowable maximum lead emission's rate in 

tons per year (tpy) under the national emission standards for hazardous air pollutants 

(NESHAP) for secondary lead smelters at 40 Code of Federal Regulations (CFR) 

635.44. The emission limits for the two existing bag houses and two new bag houses 

are divided equally into the existing source permitted limit. 

Table 1- Exide Modeled Point Sources 

Description Proposed NESHAP Lead 

Emission Limits (tpy) 

Lead Battery Crusher/Breaker 0.29 

Lead Reverberatory Furnace 0.48 

Material Handling 0.13 

Refinery Bag House #1 0.37 

Refinery Bag House #2 0.37 

Bin Room Bag House #1 0.045 

Bin Room Bag House #2 0.045 

Total Lead Emissions 1.73 

After the modeling was completed, LEADPOST was used to calculate the threemonth rolling average. This tool calculates and outputs the rolling cumulative (all 

sources) three-month average concentration at each modeled receptor with source 

group contributions and the maximum cumulative (all sources) rolling three-month 

average concentration by receptor. 

Analysis Results 

LEADPOST calculated the maximum three-month rolling average at 0.09 

micrograms per cubic meter (1Jg/m3

) for the period ending July 2008. The maximum 

impact is located on the northern fenceline of Exide's property. The three-month rolling 

average for the Mount Pleasant Road monitor (Site ID# 18-035-0009) ending February 

2012 was 0.34 1Jg/m3

. This design value is greater than the NAAQS of 0.15 1Jg/m3

. As a 

result, once the calculated modeling results are added to the monitored design value, 

the value suggests that Exide would still exceed the 2008 lead NAAQS with the 

installation and operation of the two new bag houses. 
Ms. Hedman 

Page 3 

However, since February 2012, the monitored design value at the Mount 

Pleasant Road monitor has steadily decreased to 0.03 1Jg/m3 for the last three 

consecutive three-month rolling averages. Therefore, the application of the modeling 

analysis estimates to more current monitoring data indicate that the proposed 

installation of the two new bag houses should not contribute to an exceedance of the 

NAAQS in the future. As such, this project will not interfere with Indiana's State 

Implementation Plan for lead or the attainment demonstration for the Muncie, Delaware 

County, Indiana Lead Nonattainment Area. 

IDEM believes that this technical addendum in conjunction with the Attainment 

Demonstration satisfies Indiana's obligation under Section 172(c) of the 1990 

Amendments to the Clean Air Act to demonstrate how the area will attain the 2008 lead 

NAAQS by the attainment date (i.e. December 31, 2015) and provide for an ample 

margin of safety. 

This submittal consists of one (1) hard copy of the required documentation. An 

electronic version of the submittal in PDF format that is identical to the hard copy has 

been sent to Doug Aburano, Chief of U.S. EPA Region 5's Attainment Planning and 

Maintenance Section. 

If you have any questions or need additional information concerning this matter, 

please contact Scott Deloney, Chief, Air Programs Branch, at (317) 233-5694 or 

sdeloney@idem.IN.gov. 

KB/sad/ghf 

cc: Doug Aburano, U.S. EPA Region 5 

Andy Chang, U.S. EPA Region 5 

Fred Ganster, Exide Technologies 

Keith Baugues, IDEM 

Scott Deloney, IDEM 

Gale Ferris, IDEM 

File Copy 

Sincerely, 

r,,.:;L s~a' 

Keith Baugues 

Assistant Commissioner 

Office of Air Quality