E4-1 ENCLOSURE 4

STATE OF CALIFORNIA SUPPLEMENTAL INFORMATION TO SUPPORT RECOMMENDED NONATTAINMENT AREA FOR THE 2008 FEDERAL LEAD STANDA RD

Los Angeles County - South Coast Air Basin

The presumptive boundary for a lead nonattainment a rea is the boundary of the county in which the violating monitor(s) is located . However, the Air Resources Board (ARB) recommends the Los Angeles County lead nonattainment area not be defined as the entire County, but be limited to the portion of the County within the South Coast Air Basin (South Coast). As descri bed below, this recommendation is based on the characteristics of l ead emissions, concentrations measured at other monitors in the su rrounding area, and existing jurisdictional boundaries and emissions control rul es.

The South Coast portion of Los Angeles County is ho me to several lead-related industrial sources. These facilities are Exide Technologies in the City of Commerce, Quemetco, Inc. in the City of Industry, T rojan Battery Company in Santa Fe Springs, and Exide Technologies in Vernon. The four facilities are located within a 20 mile radius in the southern portion of the County. In 1992, the South Coast Air Quality Management District (Distri ct) adopted Rule 1420: Emissions Standard for Lead. The purpose of Rule 1 420 is to reduce lead emissions from non-vehicular sources. It applies t o all facilities that use or process materials containing lead, including primar y or secondary lead smelters, foundries, and lead-acid battery manufacturers or r ecyclers, as well as facilities that produce lead-oxide, brass, and bronze. Under Rule 1420, facilities shall not discharge lead emissions into the atmosphere which cause ambient concentrations beyond the property line to exceed 1.5 micrograms per cubic meter (μg/m 3 ), averaged over 30 days. This concentration refle cts the current California ambient air quality standard for lead, a nd it is generally comparable with the level of the previous federal standard (1. 5 μg/m 3 averaged over a calendar quarter).

T he District operates a network of source-oriented m onitors around four separate facilities. In addition, Rule 1420 requires facilities with spe cific lead processing amounts or emissions to conduct monitoring at their fenceline. The District’s source-oriented monitors are located at or beyond the fence-line of the facility, and the District indicates they comply with U.S. EP A siting and operating criteria for a microscale monitoring site. While lead sampl es are generally collected on a 1-in-6 day schedule, samples may be collected more frequently at sites with high concentrations. Table 1 provides a summary of desi gn values for the District’s source-oriented monitors. Design values exceed the federal standard near two Deleted: Daelco Division of Quenell Inc.

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facilities: Trojan Battery Company and Exide Techn ologies in Vernon . The value for the Exide monitoring site is by far the highest

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TABLE 1 LEAD DESIGN VALUES FOR SOURCE-ORIENTED MONITORS

Facility Name City Monitor 3-Month Period Lead

Design Value* Exide Technologies City of

Commerce LA Paper Box, 61 st Street Jan-Mar 2006 0.14 μg/m 3 *

Quemetco, Inc. City of Industry Closet World, 500 S. 7

th Street Jan-Mar 2006 0.09 μg/m 3

Trojan Battery Co. Santa Fe

Springs Uddeholm,9331 Santa Fe

Springs Road May-Jul 2007 0.18 μg/m 3

Exide Technologies Vernon Rehrig-Pacific Street Jan-Mar 2008 2.49 μg/m 3

* * Data available for LA Paper Box monitor from Jan uary 2006 through May 2006 only. Data available fo r Closet World monitor from January through December 2006 and Octo ber through December 2008. Data available for Rehr ig-Pacific Street monitor from mid-November 2007 through mid-J uly 2009.

Exide Technologies is a lead-acid battery recycling facility. The most reliable estimate puts lead emissions from this facility at about 2 tons per year. The District currently maintains a network of three source-oriented lead monitors around Exide. All three are located beyond the fen ce-line, in publically accessible areas. In addition, the monitors are lo cated near points of modeled maximum concentration. Based on violations of the 1.5 μg/m 3 lead standard, as specified in their Rule 1420, the District issued v iolation notices to Exide for exceeding the limit during five consecutive months (December 2007 through April 2008). Concentrations during this time perio d also exceeded the 2008 federal standard. Since this time, District monito rs show concentrations that are much lower, although they still exceed the revised lead standard of 0.15 μg/m 3 calculated as a rolling three-month average.

Fugitive l ead particles are relatively large , and tend to settle out quickly after they are emitted. As a result, the highest concentratio ns occur in the immediate vicinity of an emission source. The U.S. EPA final lead rul e states that data from non

source-oriented monitors can be helpful in determin ing the appropriate nonattainment area boundary. In addition to the so urce-oriented monitors summarized above, the District maintains a network of six non

- source

- oriented lead monitors in Los Angeles County, two in Riversi de County, and two in San Bernardino County. Although data are not curre ntly available for 2008, data from these non

- source monitors are available for 2005 through 2007 . Table 2 provides a summary of design values for the non

- source-oriented sites. The design values range from 0.01 μg/m 3 to 0.03 μg/m 3 , demonstrating the significant difference in concentrations measured by the non

- source-oriented monitors versus the source-oriented monitors. This provides additi onal support for limiting the Deleted: Daelco Div,¶ Quenell Inc.

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geographic extent of the recommended nonattainment area.

TABLE 2 LEAD DESIGN VALUES AT SOUTH COAST NON

- SOURCE-ORIENTED MONITORS

Site Name County 2005-2007 Design Value Long Beach-East Pacific Coast Highway Los Angeles 0 .02 μg/m 3
Los Angeles-North Main Street Los Angeles 0.03 μg/m 3

Los Angeles-Westchester Parkway Los Angeles 0.01 μg /m 3 *

Lynwood Los Angeles 0.03 μg/m 3
North Long Beach Los Angeles 0.01 μg/m 3
Pico Rivera ** Los Angeles 0.03 μg/m 3 * Riverside-Magnolia Riverside 0.01 μg/m 3
Riverside-Rubidoux Riverside 0.02 μg/m 3

San Bernardino-4 th Street San Bernardino 0.02 μg/m 3 *

Upland San Bernardino 0.02 μg/m 3 * * Data are not complete for some months during the three-year period. ** Reflects data from two sites: Pico Rivera (Jan 2005-Apr 2005) and Pico Rivera-4144 San Gabriel (Sep 2005-Dec 2007).

In summary, ARB staff recommend s the South Coast portion of Los Angeles County be designated as nonattainment for the 2008 federal lead standard based on data from the Exide Rehrig-Pacific Street monito r. Although concentrations have dropped over the last year, they still exceed the 2008 federal lead standard. Design values for all non

- source-oriented monitors in Los Angeles County, as well as in the rest of the Air Basin, show complian ce with the revised standard. The District’s Rule 1420 provides a mechanism for r educing emissions from lead-related industrial sources. Although the conc entration limit currently specified in the Rule reflects the California lead standard, the District is planning to revise Rule 1420 to be more consistent with the level of the 2008 federal lead standard (0.15 μg/m 3 ). In addition, the District plans to propose Rule 142 0.1 which will apply to large lead-acid battery recycli ng facilities. The recommended nonattainment area falls under the jurisdiction of the South Coast Air Quality Management District, the agency responsible for adm inistrating and enforcing Rule 1420. Deleted: violate