MEMORANDUM 

To: Nathan Topham, U.S. Environmental Protection Agency, OAQPS 

From: Mike Burr, Donna Lazzari, and Danny Greene, ERG 

Date: December 16, 2011 

Subject: Summary of the Technology Review for the Secondary Lead Smelting Source 

Category 

This memorandum summarizes the results of an analysis to identify developments in 

practices, processes, and control technologies for emissions sources of hazardous air pollutants 

(HAP) from the Secondary Lead Smelting source category. This analysis is part of the EPA’s 

review efforts in accordance with section 112(d)(6) of the Clean Air Act (CAA). The EPA has 

reviewed this memorandum and it reflects the agency’s analysis and consideration. The EPA is 

therefore adopting this memorandum as its own. 

This memorandum is organized as follows: 

1.0 Background 

1.1 Requirements of Section 112(d)(6) of the CAA 

1.2 Description of the Secondary Lead Smelting Source Category and 

Requirements of the 1997 NESHAP 

2.0 Developments in Practices, Processes and Control Technologies 

2.1 Stack Emissions 

2.2 Fugitive Emissions 

3.0 Recommended Revisions Based on Developments in Practices, Processes and 

Control Technologies 

3.1 Stack Emissions 

3.2 Fugitive Emissions 

4.0 Conclusions 

1.0 BACKGROUND 

1.1 Requirements of Section 112(d)(6) of the CAA

Section 112 of the CAA requires the EPA to establish technology-based standards for 

sources of HAP. These technology-based standards are often referred to as maximum achievable 
control technology, or MACT, standards. CAA Section 112 also contains provisions requiring 

the EPA to periodically revisit these standards. Specifically, paragraph 112(d)(6) states: 

(6) REVIEW AND REVISION. – The Administrator shall review, and revise as 

necessary (taking into account developments in practices, processes, and control 

technologies), emissions standards promulgated under this section no less often 

than every 8 years. 

1.2 Description of the Secondary Lead Smelting Source Category and Requirements of 

the 1997 NESHAP

The current National Emissions Standards for Hazardous Air Pollutants (NESHAP) for 

the Secondary Lead Smelting source category was promulgated on June 13, 1997 (62 FR 32216) 

and codified at 40 CFR part 63, subpart X. As promulgated in 1997, the NESHAP applies to 

affected sources of HAP emissions at secondary lead smelters. The 1997 NESHAP (40 CFR 

63.542) defines “secondary lead smelters” as “any facility at which lead-bearing scrap material, 

primarily, but not limited to, lead-acid batteries, is recycled into elemental lead or lead alloys by 

smelting.” The secondary lead smelting process consists of: (1) pre-processing of lead bearing 

materials, (2) melting lead metal and reducing lead compounds to lead metal in the smelting 

furnace, and (3) refining and alloying the lead to customer specifications. The NESHAP for the 

Secondary Lead Smelting source category does not apply to primary lead smelters, lead 

remelters, or lead refiners. 

Today, there are 15 secondary lead smelting facilities that are subject to the NESHAP 

and one facility currently under construction. One existing facility is currently in the process of 

expanding their operations. Table 1-1 lists the secondary lead smelters currently in operation or 

under construction in the United States and Puerto Rico. 

Table 1-1. Secondary Lead Smelters in the U.S. and Puerto Rico 

FACILITY NAME PARENT COMPANY CITY STATE 

Facility 

Abbreviation 

East Penn 

Manufacturing Co., Inc. 

East Penn Manufacturing 

Co., Inc. 

Lyon Station Pennsylvania East Penn 

EnviroFocus 

Technologies, LLC Gopher Resources, LLC Tampa Florida EnviroFocus 

Gopher Resources, LLC Gopher Resources, LLC Eagan Minnesota Gopher Eagan

Quemetco, Inc., City of 

Industry, Ca 

Eco-Bat Technologies, LTD 

(Quemetco West, LLC) 

City of 

Industry 

California Quemetco CA 

Quemetco, Inc., 

Indianapolis, In 

Eco-Bat Technologies, LTD 

(Eco-Bat Indiana, LLC) Indianapolis Indiana Quemetco IN 

Revere Smelting and 

Refining Corporation 

(RSR) 

Eco-Bat Technologies, LTD 

(Eco-Bat New York, LLC) Middletown New York RSR 

Sanders Lead Company Sanders Lead Company Troy Alabama Sanders Lead
Table 1-1. Secondary Lead Smelters in the U.S. and Puerto Rico 

FACILITY NAME PARENT COMPANY CITY STATE 

Facility 

Abbreviation 

Exide Technologies, 

Baton Rouge, La Exide Technologies, Inc. Baton Rouge Louisiana 

Exide Baton 

Rouge 

Exide Technologies, 

Cannon Hollow 

Recycling Facility 

Exide Technologies, Inc. Forest City Missouri Exide Forest City 

Exide Technologies, 

Frisco, Tx 

Exide Technologies, Inc. Frisco Texas Exide Frisco 

Exide Technologies, 

Muncie, In 

Exide Technologies, Inc. Muncie Indiana Exide Muncie 

Exide Technologies –

Reading Recycling 

Exide Technologies, Inc. Reading Pennsylvania Exide Reading 

Exide Technologies, 

Vernon, Ca 

Exide Technologies, Inc. Vernon California Exide Vernon 

Buick Resource 

Recycling Facility, LLC 

The Doe Run Resources 

Corporation 

Boss Missouri Buick RRF 

The Battery Recycling 

Company 

The Battery Recycling 

Company 

Arecibo Puerto Rico TBR 

Johnson Controls 

Battery Group, Inc. 

Johnson Controls 

International Florence South Carolina JCI 

HAP are emitted from secondary lead smelting as stack releases (i.e., process emissions, 

and process fugitive emissions) and as fugitive dust emissions. Process emissions include 

exhaust gases from feed dryers and from blast, reverberatory, rotary, and electric furnaces. The 

HAP in process emissions are comprised primarily of metals (mostly lead compounds, but also 

some arsenic, cadmium, and other metals) and also may include organic compounds that result 

from incomplete combustion of coke that is charged to the smelting furnaces as a fuel or fluxing 

agent, combustion of natural gas or other fuels, or combustion of small amounts of plastics or 

other materials that get fed into the furnaces along with the lead-bearing materials. Process 

fugitive emissions are released from various sources throughout the smelting process, including 

smelting furnace charging and tapping points, refining kettles, agglomerating furnace product 

taps, and drying kiln transition equipment. Process fugitive emissions are comprised primarily of 

metal HAP. Fugitive dust emissions are emissions that are not associated with a specific process 

or process fugitive vent or stack. Fugitive emissions are comprised of metal HAP and result from 

the entrainment of HAP in ambient air due to material handling activities, vehicle traffic, wind, 

and other activities. 

The 1997 NESHAP applies to process emissions from blast, reverberatory, rotary, and 

electric smelting furnaces, agglomerating furnaces, and dryers; process fugitive emissions from 

smelting furnace charging points, smelting furnace lead and slag taps, refining kettles, 

agglomerating furnace product taps, and dryer transition equipment; and fugitive dust emissions 

from roadways, battery breaking areas, furnace charging and tapping areas, refining and casting 
areas, and material storage areas. For process sources, the 1997 NESHAP specifies numerical 

emissions limits for total hydrocarbons (THC) and lead compounds for blast furnaces and 

collocated blast and reverberatory furnaces. Additionally, emissions limits for lead are specified 

for reverberatory, electric, and rotary furnaces. Lead compound emissions from all smelting 

furnace configurations are limited to an outlet concentration of 2.0 milligrams per dry standard 

cubic meter (mg/dscm) (0.00087 grains per dry standard cubic foot (gr/dscf)) (40 CFR 

63.543(a)). THC emissions from collocated blast and reverberatory furnaces are limited to an 

outlet concentration of 20 parts per million volume (ppmv) (expressed as propane) corrected to 4 

percent carbon dioxide (CO2). THC emissions are limited to 360 ppmv (as propane) at 4 percent 

CO2 from existing blast furnaces and 70 ppmv (as propane) at 4 percent CO2 from new blast 

furnaces (40 CFR 63.543(c)). The 1997 NESHAP does not specify limits for THC emissions 

from reverberatory furnaces not collocated with blast furnaces, rotary furnaces, or electric 

furnaces. 

The 1997 NESHAP requires that process fugitive emissions sources be equipped with an 

enclosure hood meeting minimum face velocity requirements or be located in a total enclosure 

subject to general ventilation that maintains the building at negative pressure (40 CFR 

63.543(b)). Ventilation air from the enclosure hoods and total enclosures are required to be 

conveyed to a control device. Lead emissions from these control devices are limited to 2.0 

mg/dscm (0.00087 gr/dscf) (40 CFR 63.544(c)). Lead emissions from all dryer emissions vents 

and agglomerating furnace vents are limited to 2.0 mg/dscm (0.00087 gr/dscf) (40 CFR 

63.544(d)). The 1997 NESHAP also requires the use of bag leak detection systems for 

continuous monitoring of baghouses in cases where a high efficiency particulate air (HEPA) 

filters are not used in series with a baghouse (40 CFR 63.548(c)(9)). 

For fugitive dust sources, the 1997 NESHAP requires that facilities develop and operate 

according to a standard operating procedures (SOP) manual that describes, in detail, the 

measures used to control fugitive dust emissions from plant roadways, battery breaking areas, 

furnace areas, refining and casting areas, and material storage and handling areas. 

2.0 DEVELOPMENTS IN PRACTICES, PROCESSES, AND CONTROL 

TECHNOLOGIES 

For the purposes of this technology review, a “development” was considered to be a(n): 

• add-on control technology or other equipment that was not identified during the 

development of the 1997 NESHAP for the source category; 
• improvement in add-on control technology or other equipment that was identified 

and considered during development of the 1997 NESHAP for the source category 

that could result in significant additional HAP emissions reductions; 

• work practice or operational procedure that was not identified during development 

of the 1997 NESHAP for the source category; or 

• applicable process change or pollution prevention alternative that was not 

identified and considered during the development of the 1997 NESHAP for the 

source category. 

We investigated developments in practices, processes, and control technologies for three 

categories of HAP emissions sources from secondary lead smelters: (1) stack emissions of lead 

and other metal HAP, (2) stack emissions of organic HAP, and (3) fugitive emissions of lead and 

other metal HAP. To identify developments, we conducted searches of the EPA’s 

RACT/BACT/LAER (Reasonably Achievable Control Technology/Best Available Control 

Technology/Lowest Achievable Emissions Rate) clearinghouse and the Internet for information 

on secondary lead smelting and similar processes, examined the Section 114 information 

collection request (ICR) responses from 15 secondary lead smelting facilities, reviewed 

technologies employed by similar industries, and reviewed new or updated NESHAPs for other 

source categories. The results of these analyses are presented in the following sections. 

2.1 Stack Emissions

The 1997 NESHAP specifies emissions limits for metal HAP (using lead as a surrogate) 

and organic compounds (using THC as a surrogate) from stacks. This section of the technology 

review will focus on developments in practices, processes, and control technologies applicable to 

emissions of metal HAP and organic compounds from stacks. 

a. Metal HAP Emissions from Stacks 

Based on a review of the ICR responses, the most common control technology employed 

by the industry to control emissions of metal HAP from stacks is fabric filtration (baghouses). 

Several types of baghouses are currently used by the industry, including shaker, pulse jet, and 

reverse pulse jet bag filters. One facility uses a wet electrostatic precipitator (WESP) 

downstream of a baghouse to further reduce emissions of metal HAP from stacks. Two other 

facilities have plans to install similar WESP units. Several facilities also reported using HEPA 

filters as an add-on control downstream of their baghouses. Additionally, some facilities reported 

using cartridge collectors; however these types of controls are generally suited to reduce metal 

HAP emissions from sources that have lower inlet concentrations and are typically not used to 

control metal HAP in smelting furnace exhaust. 

The first part of our analysis included attempting to determine which control technology 

(e.g., fabric filter, WESP, HEPA filter, cartridge collectors) achieves the greatest control 
efficiency for metal HAP. We could not directly calculate control efficiencies due to lack of inlet 

concentration data; however, we compared the outlet lead concentrations from the different 

control technologies based on emissions data that we received in the ICR. 

As displayed in Figure 2-1, the average stack outlet lead concentration from the baghouse 

and WESP combination was almost 50 times lower than the outlet concentration achieved by 

using baghouses alone. On average, units that employed HEPA filters downstream of a baghouse 

achieved approximately 20 percent lower outlet lead concentrations than baghouses alone, 

however we have no information for the actual reduction from the HEPA filter. Additionally, 

there were sources without HEPA filters that had lower outlet concentrations than sources with 

HEPA filters. An analysis of the stack emissions for the best 50% of all stacks that employed 

fabric filtration (the 50% with the lowest outlet concentration) revealed that over 40% of these 

stacks do not have HEPA filters. The data indicates that cartridge collectors appear to achieve 

outlet lead concentrations approximately three times lower than baghouses; however, as 

mentioned, cartridge collectors are generally limited to emissions points from building 

ventilation systems that have much lower inlet loading concentrations and should not be 

compared to devices employed to control a process source. 

Figure 2-1. Comparison of Control Device Outlet Lead Concentrations from Different Technologies. 

Based on emissions data received in the ICR, we also compared the relative performance 

of each baghouse across facilities and attempted to determine the factors that correlate best with 

low outlet lead concentrations. The factors that we considered include baghouse type (e.g., 

shaker, pulse jet, reverse bag pulse), filter material, and age of the unit. Figure 2-2 shows the 

results of these analyses. Based on our analysis, the most significant factor affecting baghouse 

performance is the age of the unit. We found that units installed prior to 1989 generally had 

significantly higher outlet lead concentrations than the newer units. Shaker baghouses appear to 

have higher outlet lead concentrations than those of the pulse jet or reverse bag pulse type. 

0.00

0.02

0.04

0.06

0.08

0.10

0.12

0.14

0.16

Fabric Filter HEPA Filter Cartrige 

collectors

WESP P

b

Con

centration (m

g/dscm)

AverageOutlet Lead Concentrationby Control Technology
Figure 2-2. Comparison of Baghouse Outlet Lead Concentrations Based on Type (Upper Left), Filter Media (Upper Right), and Installation Year 

(Bottom). 

0.00

0.05

0.10

0.15

0.20

0.25

0.30

Shaker Reverse Air Pulse

P

b

Con

centration (m

g/dscm)

AverageOutlet Lead Concentrationfrom Baghouses by Type

0.00

0.05

0.10

0.15

0.20

Teflon Other Polyester

P

b

Con

centration (m

g/dscm)

AverageOutlet Lead Concentrationfrom Baghouses by 

Filter Material

0.00

0.20

0.40

0.60

0.80

1.00

1.20

1.40

1960 1970 1980 1990 2000 2010 2020

P

b

Con

centration (m

g/dscm)

AverageOutlet Lead Concentrationsfrom Baghouses by 

Installation Year
8 

However, the majority of the older units appear to be shaker types, and thus the age of the 

baghouse may be the controlling factor. We did not find a significant correlation between the 

outlet lead concentration and the filtration media used in the baghouses, although one company 

in the industry suggested, based on its experience, that Teflon (polytetrafluoroethylene) bags 

specifically supplied by Gore-Tex© performed better than other bag types. The company also 

suggested that the most critical factors influencing baghouse performance are proper installation 

and maintenance practices. They mentioned specific practices such as ensuring proper 

installation of the bags and properly sealing all ducts and dust conveyance devices. Additionally, 

they claim that replacing torn bags, rather than repairing them, can significantly improve 

baghouse performance. 

Based on our analyses, we believe that the most important development in the control of 

stack emissions of metal HAP from this source category has been improvement in the 

performance of baghouses throughout the industry. An indicator of such improvements is the 

difference between stack test results performed prior to the publication of the 1994 NESHAP and 

stack tests performed in the last 5 years. The average lead concentration in stacks from secondary 

lead facilities prior to 1994 was 0.94 mg/dscm. For tests conducted in the last 5 years, the 

average concentration is 0.16 mg/dscm. If building ventilation systems are removed from the 

analysis the average concentration is 0.21 mg/dscm. An analysis of the stack emissions for the 

best 50% of all stacks that employed fabric filtration (the 50% with the lowest outlet 

concentration) showed an average concentration of 0.0123 mg/dscm. Of these stacks that 

contained emissions from furnace sources (building ventilation systems not included), the 

average concentration is 0.0135 mg/dscm. These concentrations are levels that were not achieved 

on any source tested prior to 1994. Figure 2-3 shows the lead concentrations reported by the 

industry in the ICR compared to the lead concentration limit in the 1997 NESHAP. As illustrated 

by Figure 2-3, the outlet lead concentrations currently being achieved by the industry are far 

below, and in most cases orders of magnitude below, the concentration limit specified in the 

1997 NESHAP. The average reported stack lead concentration was 0.16 mg/dscm with a median 

of 0.04 mg/dscm. This large discrepancy between actual and MACT-allowable stack lead 

concentrations is likely a result of improvements in practices, processes, and control technologies 

that have significantly improved the performance of baghouses employed by this industry since 

the promulgation of the 1997 NESHAP. We also believe that the concentration data presented in 

Figure 2-3 clearly show that improvements in baghouse technology and operation have occurred 

that resulted in the capability of achieving significantly lower stack lead emissions than what is 

required by the 1997 NESHAP. 
9 

Figure 2-3. Comparison of Stack Lead Concentrations Reported by the Industry with the 1997 MACT 

Standard. 

b. Organic HAP and Dioxin and Furan Emissions

Based on our review of the ICR responses, we found that emissions of organic HAP from 

smelting furnaces vary substantially among the different furnace types. In general, emissions of 

organic HAP from blast furnaces are much higher than those from other furnace types. 

Information collected in the ICR indicates that this is likely due to the much lower exit 

temperature of the blast furnace exhaust relative to the other furnace types. The majority of 

facilities that operate blast furnaces use afterburners to control emissions of organic HAP. The 

exhaust of reverberatory furnaces is sufficiently hot that the use of an afterburner is generally not 

needed to meet the 1997 NESHAP limit for THC. Some facilities that operate both blast and 

reverberatory furnaces comingle the hotter reverberatory furnace stream with the cooler blast 

furnace stream to control organics in the blast furnace stream. We did not identify new control 

technologies that would achieve reductions in organic HAP emissions beyond the limits 

established in the 1997 NESHAP. 

However, we do believe it is possible to further reduce organic HAP emissions from blast 

furnaces by designing and operating an afterburner with a higher temperature and residence time. 

A blast furnace afterburner temperature as high as 2100 degrees Fahrenheit was reported in the 

ICR. This blast furnace exhaust gas was cooled and then mixed with reverberatory furnace 

exhaust, and therefore it was not possible to determine the exact concentration of THC resulting 

from the blast furnace alone. However, the THC concentration in the mixed exhaust was low; 

therefore we estimated that the THC concentration in the blast furnace exhaust must have been 

0

0.5

1

1.5

2

2.5

Con

centration (m

g/dscm)

Individual Stack Test Results

Reported Stack Lead Concentrations

Reported Lead Concentrations Current MACT
10 

below approximately 5 ppmv @ 4% O2. This is a considerably lower THC concentration than 

reported for other blast furnace exhausts and other mixed blast and reverberatory furnaces 

exhausts. Because of the many different furnace configurations, it was not possible to establish a 

significant correlation between temperature of the exhaust gas and THC concentration. Average 

exhaust THC concentrations for the various furnace types are summarized in Table 2-1. 

Table 2-1. Summary of Exhaust THC Concentrations by Furnace Type. 

Furnace Type Average THC (ppmv@4% O2) 

Reverberatory furnaces not collocated with blast furnaces, and reverberatory 

furnaces mixed with electric furnaces 

5.8 

Blast Furnaces 372 

Collocated Blast and Reverberatory Furnaces 3.7 

Rotary Furnaces* 257 

Blast and Reverberatory Furnace Mixed, not collocated 45 

*Based on one test with only two runs. 

Although dioxin and furan (D/F) emissions limits are not specified in the 1997 NESHAP, 

we investigated technologies available for prevention and/or control of D/F emissions from the 

smelting furnaces. Based on data submitted by the industry in the ICR, D/F emissions from blast 

furnaces are one to three orders of magnitude higher than emissions from reverberatory and 

electric furnaces. The key conditions typically associated with higher D/F emissions, listed in 

order of relative importance

1

, are: 

• Poor combustion conditions, 

• High particulate concentration in the flue gases of a combustion process, 

• Increased residence time for particulate in critical temperature window (150 - 450 

degrees Celsius), 

• Particulate matter containing metals that can catalyze formation to dioxin, 

• Waste or fuel that is comprised of complex organic or lignin-like structure, and 

• Sufficient chlorine. 

We believe the controlling factor for D/F formation in blast furnaces is the relatively low 

exit temperature of the exhaust stream in comparison to other furnace types. 

We identified two technologies employed by this source category that have demonstrated 

effective control of D/F emissions from blast furnaces: (1) incineration of the furnace exhaust, 

 

1 Gullett, Brian (EPA) and Seeker, Randy (EER Corporation), Chlorinated Dioxin and Furan Formation 

Control and Monitoring. Presentation at the Industrial Combustion Coordinated Rulemaking Meeting.

September 17, 1997.
11 

and (2) comingling of the blast furnace exhaust with the hotter reverberatory furnace exhaust. 

These technologies are the same as those described above for control of THC. D/F is a 

chlorinated form of hydrocarbon and so it is understandable that combustion may be effective at 

reducing emissions of these compounds. However, a higher temperature may be required for 

significant destruction of these compounds than other organic material. Based on information 

submitted in the ICR and information in the literature on dioxin destruction efficiency, operating 

an afterburner at sufficient temperature (approximately 1,600 degrees Fahrenheit) with adequate 

residence time (approximately 2.0-2.5 seconds) can achieve significant reductions in D/F 

emissions from blast furnaces

2

. Additionally, emissions data submitted in the ICR indicate that 

D/F emissions from collocated blast and reverberatory furnaces are generally lower than 

emissions from a blast furnace alone (presumably reflecting the higher temperatures of the 

exhaust from the collocated furnaces). Average exhaust D/F concentrations of the various 

furnace types are summarized in Table 2-2. 

Table 2-2. Summary of Exhaust D/F Concentrations by Furnace Type. 

Furnace Type 

Average D/F 

(nanograms/dscm) 

Reverberatory furnaces not collocated with blast furnaces, and reverberatory 

furnaces mixed with electric furnaces 

0.10 

Blast Furnaces 38.83 

Collocated Blast and Reverberatory Furnaces 0.19 

Rotary Furnaces* 0.14 

*Based on one test with only two runs. 

Because the presence of chlorine is necessary for D/F formation, we also examined the 

potential sources of chlorine in the feed materials charged to the smelting furnaces. Historically, 

the plastic battery casings used in the construction of automotive batteries contained polyvinyl 

chloride (PVC). Although battery casings are no longer made of PVC, the battery casings can 

sometimes contain small amounts of chlorinated flame retardants. This material may be 

introduced into the furnace through incomplete separation of the battery casing material from the 

lead-bearing material in the feed preparation process. Moreover, we believe that occasionally 

some older batteries that still contain PVC casings could be processed. 

Based on our review, control of D/F emissions occurs due to measures initially 

implemented to control organic HAP emissions (i.e., incineration and co-mingling of furnace 

exhaust streams). 

 

2

Ficarella, Antonio and Laforgia, Domenico, Numerical Simulation of Flow-Field and Dioxins 

Chemistry for Incineration Plants and Experimental Investigation, Waste Management, 20 

(2000) 27-49. http://www.bvsde.paho.org/bvsacd/cd43/antonio.pdf
12 

2.2 Fugitive Emissions

As outlined in section 1.2 of this memorandum, the pollutants emitted from fugitive 

emissions sources in this source category are metal HAP. Therefore, we focused on identifying 

advancements in practices, processes, and control technologies related to fugitive emissions of 

metal HAP. Sources of fugitive emissions at secondary lead smelters include dust from plant 

roadways, battery breaking operations, material storage areas, and process fugitives that are not 

captured by a control device. 

The minimum requirements for control of fugitive emissions in the 1997 NESHAP for 

the following specified fugitive sources are: 

• Plant roadways – must be cleaned twice per day; 

• Battery breaking area – partial enclosure of storage piles and wet suppression with 

twice daily pavement cleaning; 

• Furnace and refining and casting areas – partial enclosure and pavement cleaning; 

and 

• Material Storage and Handling Areas – partial enclosure, wet suppression, and 

vehicle wash at exits. 

Based on our analysis of information received in the ICR, we grouped the facilities into 

three categories that describe the level of fugitive emissions control implemented. Table 2-2 

defines these categories and Table 2-2 summarizes our categorization for each facility. 

Table 2-3. Enclosure Category Definitions. 

Enclosure Category Description 

Level 1 Enclosure

Facilities described as having Level 1 enclosure meet the enclosure 

requirements in the 1997 NESHAP. The facilities rely primarily on 

enclosure hoods to capture process fugitive emissions and partial 

enclosures with wet suppression for process units and storage areas.

Level 2 Enclosure

Facilities described as having Level 2 enclosure generally employ, in 

addition to enclosure hoods for process fugitive sources, a 

combination of negative pressure total enclosures and partial 

enclosures with wet suppression for process units and storage areas.

Level 3 Enclosure

Facilities described as having Level 3 enclosure generally employ, in 

addition to enclosure hoods for process fugitive sources, negative 

pressure total enclosures for all process units and storage areas.

Table 2-4. Enclosure Category Assigned to the 15 Secondary Lead Smelting Facilities. 

Facility Enclosure Category 

Exide Baton Rouge Level 1

Exide Forest City Level 2
13 

Facility Enclosure Category 

Exide Frisco Level 23

Exide Muncie Level 3

Exide Technologies – Reading, PA Level 2

Exide Vernon Level 3

RSR Level 3

Quemetco CA Level 3

Quemetco IN Level 3

Sanders Lead Level 1

EnviroFocus Level 2

Gopher Eagan Level 3

Buick RRF Level 1

East Penn Level 3

TBR Level 1

As displayed in Table 2-3, our analysis concludes that 11 of the 15 facilities are 

controlling fugitive emissions beyond the levels required by the 1997 NESHAP. Additionally, 

seven of the 15 facilities have placed all of their process areas in total enclosures under negative 

pressure with ventilation to a control device. EnviroFocus has a current project to implement 

level 3 enclosures due to a permit requirement. Exide Frisco is in the process of implementing 

level 3 enclosures due to a consent order with the state of Texas and the state’s lead NAAQS SIP 

implementation. After completing these projects, nine of the 15 secondary lead smelters will be 

classified as level 3 enclosure facilities. 

Of the seven facilities that are currently level 3 enclosures, several facilities perform 

additional work practices (beyond the enclosures) beyond those required by the 1997 NESHAP 

to further limit the formation of fugitive dust in other areas of their facilities. Examples of these 

work practices include: 

• more complete vehicle washing inside buildings; 

• improved roadway cleaning techniques and frequency; 

• pavement of entire facility grounds; 

• cleaning of building roofs and exteriors; 

 

3 Exide Technologies at Frisco, TX operates a total enclosure for only the raw material storage area. Fugitive 

emissions from this facility therefore may be more typical of a level 1 enclosure facility. 
14 

• use of daily ambient monitoring to diagnose plant activities that lead to 

exceedances of the National Ambient Air Quality Standards (NAAQS) for lead; 

• timely cleaning of accidental releases; 

• inspection of outside battery storage areas for broken batteries; and 

• performance of all maintenance activities inside total enclosures operated under 

negative pressure. 

Our analysis of ambient lead concentration data measured near the facilities indicates that 

facilities with level 3 enclosure that implement the work practices described above are generally 

achieving much lower lead concentrations near their property boundaries (see Figure 3-2). For 

this reason, we believe that developments in practices, processes, and control technologies with 

regard to fugitive emissions of metal HAP have occurred that can result in reduced metal HAP 

emissions from fugitive sources beyond the standards contained in the 1997 NESHAP. 

3.0 RECOMMENDED REVISIONS BASED ON DEVELOPMENTS IN PRACTICES, 

PROCESSES, AND CONTROL TECHNOLOGIES 

Based on the analyses presented above, we are recommending the following revisions to 

the 1997 NESHAP with regards to stack and fugitive emissions from the Secondary Lead 

Smelting source category. 

3.1 Stack Emissions

As described in section 2.1 of this memorandum, the concentrations of lead in stacks 

reported by this industry in the ICR are far below the level specified in the 1997 NESHAP, 

indicating improvements in the control of metal HAP emissions since promulgation of the 1997 

NESHAP. Our analysis indicates that this is primarily a result of improved performance of 

baghouses. Therefore, we recommend revising the 1997 NESHAP to reflect the level of 

performance currently being achieved by facilities that implement well-performing baghouses to 

control emissions of metal HAP from stacks. 

When considering the most appropriate form of a revised lead standard for this source 

category, the EPA considered alternatives to the current form (i.e., outlet lead concentration). 

However, the EPA analysis indicates that a concentration-based lead standard continues to be the 

most appropriate form for this industry. The EPA then determined the appropriate reduction to 

the lead concentration limit of 2.0 mg/dscm. As outlined in section 2.1, the average stack 

concentration of lead reported by the industry in the ICR was 0.16 mg/dscm with a median 

concentration was 0.04 mg/dscm. Over 96 percent of the reported concentrations were less than 

half the 1997 NESHAP limit of 2.0 mg/dscm and over 80 percent of the reported concentrations 

were at least an order of magnitude less than the 1997 NESHAP limit. Our analyses conclude 

that advancements in the performance of baghouses appear to be the controlling factors for these 

lower concentrations and that reducing the lead concentration limit from 2.0 to 0.2 mg/dscm 
15 

would reflect the level of control achieved in practice by facilities that implement wellperforming baghouses. 

Figure 3-1 compares the lead concentrations reported by the industry in the ICR with a 

potential revised lead concentration limit of 0.2 mg/dscm. Although the majority of stacks 

reported concentrations well below 0.2 mg/dscm, a limited number of stacks would need 

improvements, possibly in the form of improved maintenance practices on their existing 

baghouses or installation of newer, more efficient units. To provide the facilities flexibility in 

determining the best approach to meeting a revised concentration limit, the EPA proposed and is 

finalizing a facility-wide flow-weighted average lead concentration limit of 0.2 mg/dscm. For 

this limit, facilities would assign a weighting factor to each stack lead concentration based on the 

flow rate of the stack. They would then sum the flow-weighted concentration of all the stacks at 

their facility to get a facility-wide flow-weighted concentration. The final rule establishes an 

additional concentration limit on any one emission point of 1.0 mg/dscm. A limit in this form 

would reflect the level of metal HAP emissions control being achieved in practice by well 

performing baghouses while providing flexibility to the facilities in determining the most costeffective approach to achieving the necessary reductions. 

As required under section 112(d)(6), we considered the costs and other impacts 

associated with revising the lead concentration limit in the manner described above. As described 

in the Cost Impacts of the Revised NESHAP for the Secondary Lead Smelting Source Category, 

we estimate that ten baghouses at five facilities would need either to be replaced, or to undergo a 

significant maintenance upgrade as a result of the revised limit. Emission points were selected 

for improvement that had a lead concentration above 0.5 mg/dscm (one half the standard for any 

one emission point). After emissions reductions at these stacks, all the facilities would be in 

compliance with the 0.2 mg/dscm flow weighted average limit. The estimated total capital cost is 

$11.5 million with a total annualized cost of $2.7 million. We estimate that the revised limit 

would result in annual reductions of metal HAP of approximately 8.2 tons with co-reductions in 

emissions of particulate matter (PM) of approximately 82 tons. We do not anticipate additional 

energy use associated with this revised limit, as only replacement baghouses, as opposed to new 

additional units, are expected. Furthermore, we do not anticipate any adverse non-air 

environmental impacts associated with the implementation of this revised limit. 

For these reasons, we are recommending that a flow-weighted average lead concentration 

limit of 0.2 mg/dscm be applied to the sum of all stacks at each facility in this source category. 

To limit the potential impacts of any individual stack, we are also recommending that a 

maximum lead concentration limit of 1.0 mg/dscm be applied to individual stacks in this source 

category. This is warranted given the fact that, as described above, over 96 percent of stack lead 

concentrations reported in the ICR were less than 1.0 mg/dscm, these improvements are 
16 

achievable at reasonable total cost, are cost effective, and are not associated with adverse non-air 

environmental impacts or adverse energy implications.. 

Figure 3-1. Comparison of Stack Lead Concentrations Reported by the Industry with a Potential 

Revised Lead Concentration Limit. 

3.2 Fugitive Emissions

As outlined in section 2.2 of this memorandum, several facilities in this source category 

are currently implementing controls for fugitive emissions of metal HAP that exceed what is 

required in the 1997 NESHAP. Based on our analyses, we are recommending revising the 1997 

NESHAP to reflect the level of control currently being achieved by the better performing 

facilities in this source category with regards to fugitive emissions of metal HAP. 

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

limit is a work practice standard. Although lack of direct measurement makes comparisons of the 

efficiency of different control technologies challenging, analysis of ambient lead monitoring data 

near the facilities has generally been considered an accurate indicator of the level of fugitive 

emissions of metal HAP. The Residual Risk Assessment for the Secondary Lead Smelting 

Source Category presents dispersion modeling results for this source category indicating that 

fugitive emissions are overwhelmingly the most significant source contributing to ambient lead 

concentrations near the property boundaries of secondary lead smelting facilities. The same 

modeling results indicate that lead emissions from this source category could result in 

exceedances of the lead NAAQS at 9 of the 15 facilities. 

0

0.5

1

1.5

2

2.5

Con

centration (m

g/dscm)

Individual Stack Test Results

Reported Stack Lead Concentrations

Reported Lead Concentrations Potential Revised MACT
17 

We analyzed available ambient monitoring data to determine which facilities were 

implementing the most effective controls for fugitive emissions of metal HAP. Figure 3-2 

displays the annual average lead concentrations at ambient monitoring locations around facilities 

based on the enclosure category assigned to the facility in section 2.2 of this memorandum. The 

figure includes concentration data for 13 of the 15 facilities (monitoring data near Exide Baton 

Rouge and Exide Forest City were not available). All data in this figure were taken from 

http://www.epa.gov/airexplorer/monitor_kml.htm. The most recent year’s monitoring data 

available was selected for each facility. In cases where data were available at multiple 

monitoring locations around a facility, we chose the monitor with the highest annual lead 

concentration. 

Figure 3-2. Comparison of Annual Ambient Lead Concentrations for Each Enclosure Category. 

As the figure shows, facilities categorized as level 3 enclosures achieved significantly 

lower ambient lead concentrations than those classified as level 1 or 2 enclosures. As previously 

mentioned, seven of the 15 facilities are currently classified as level 3 enclosures, and two other 

facilities are planning to implement level 3 enclosures in the near future. Of the facilities 

classified as having level 3 enclosures, four facilities also implement some or all of the additional 

work practices mentioned in section 2.2 to further prevent the formation of fugitive dust in other 

areas of their facilities. Based on this analysis, we concluded that level 3 enclosure plus the 

implementation of additional fugitive control work practices reflects a development in practices 

and control technology which is necessary to adopt under section 112 (d)(6). (For purposes of 

section 112 (f), the EPA has also found that these controls are necessary to reduce risk from lead 

exposure to an acceptable level, using the lead primary NAAQS as the measure of risk 

acceptability.) 

0.00

0.20

0.40

0.60

0.80

1.00

1.20

1.40

1.60

Level 1 Level 2 Level 3

Con

centration (m

g/dscm)

Annual Ambient Lead Concentrations by Enclosure Category
18 

As with the revised stack lead concentration limit discussed in section 3.1 of this 

memorandum, we considered the potential cost impacts of revising the fugitive emissions 

standard in the 1997 NESHAP to include the controls mentioned above. As described in the Cost 

Impacts of the revised NESHAP for the Secondary Lead Smelting Source Category, we estimate 

that the total capital cost to implement level 3 enclosure and additional fugitive control work 

practices throughout the industry is approximately $38 million with a total annualized cost of 

approximately $9.4 million. We estimate reductions in metal HAP emissions of 7.2 tons per year 

resulting from this revised standard with co-reductions of PM of approximately 72 tons. The cost 

effectiveness of $1.3 million per ton of HAP reduction is reasonable considering that a large 

portion of the industry has already implemented controls that are at least as stringent as those 

required in this final rule. We do not anticipate any adverse non-air environmental impacts 

associated with this recommended standard. However, we do anticipate a minimal amount of 

additional energy use associated with the operation of the new total enclosure. After 

consideration of the costs, emissions reductions, and other potential impacts, we believe the 

revision of the fugitive emissions standard for this source category to include the control 

measures described in this memorandum is warranted and necessary. 

4.0 CONCLUSIONS 

This review identified several developments in practices, processes, or control 

technologies that have been implemented in this source category since promulgation of the 1997 

NESHAP. Our analysis indicates that several facilities have significantly reduced stack 

emissions of metal HAP, primarily though improved performance of baghouses. Additionally, 

several facilities have implemented fugitive emissions control practices that exceed the 

requirements of the 1997 NESHAP. Based on our review, we conclude that it is feasible and 

cost-effective for facilities to achieve a facility-wide, flow-weighted average lead concentration 

of 0.2 mg/dscm with a limit of 1.0 mg/dscm for any individual stack. We conclude that it is 

feasible for all facilities to fully enclose all process areas under negative pressure of and 

implement a prescribed list of work practices to limit fugitive emissions. Implementing these 

controls would achieve reductions in lead emissions of approximately 12.9 tons with total metal 

HAP reductions of approximately 15.4 tons. Additionally, we expect total co-reductions of PM 

emissions of approximately 130 tons. We estimate that between 39 and 63 tons of the total PM 

reductions will be reductions in particles with diameters less than 2.5 microns (PM2.5), depending 

on the nature of the particle size distribution of emissions from this source category. Since the 

controls being required are already employed by a significant portion of the industry, we believe 

that these controls and measures are cost-effective measures that reflect achievable performance 

for this industry. We conclude that a beyond the floor option is not warranted for THC or D/F 

emissions because there would be high costs, adverse energy impacts, and associated increased 
19 

emissions of NOx, CO2. Additionally, the risks estimated from organic emissions from secondary 

lead smelting facilities are negligible.