UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IX AIR DIVISION

Technical Support Document 

For

EPA’s Proposed Rulemaking

For the

California State Implementation Plan

South Coast Air Quality Management District, Rule 1420.1, 

Emissions Standard for Lead from Large Lead-acid Battery Recycling Facilities

Prepared by: Adrianne Borgia

Reviewed by: Andrew Steckel

June 2012
2

Agency: South Coast Air Quality Management District 

(SCAQMD)

Subject of this TSD: Rule 1420.1 - Emissions Standard for Lead from 

Large Lead-acid Battery Recycling Facilities

Adopted – November 5, 2010

Submitted – September 27, 2011

BACKGROUND - On November 22, 2011, the EPA designated the Los Angeles 

County portion of the South Coast Air Basin, excluding the high desert areas, 

San Clemente and Santa Catalina Islands, as nonattainment for the 2008 lead

National Ambient Air Quality Standard (NAAQS).

1 CAA §§ 172(c)(1) and 191(a) 

require areas that are classified as moderate or above for lead non-attainment to 

implement reasonably available control measures (RACM) and reasonably 

available control technology (RACT), and to submit a plan within 18 months of 

the designation. 

According to SCAQMD, lead-acid battery recycling facilities are the largest lead 

emission sources in the Basin.2 Rule 1420.1 currently applies to two battery 

recycling facilities, Exide Technologies in the City of Vernon and Quemetco, Inc. 

in the City of Industry.

RULE SUMMARY - SCAQMD Rule 1420.1, Emissions Standard for Lead from 

Large Lead-acid Battery Recycling Facilities, is a new rule designed to reduce 

exposure and emissions of lead from large lead-acid battery recycling facilities. 

Definitions are included in section (c); general emission limits, including specific 

dates of compliance, are covered in section (d); and the applications of total 

enclosures are set forth in section (e). Requirements for control devices are 

included in section (f) and requirements for compliance plans if ambient air 

concentrations of lead exceed 0.12 micrograms per cubic meter averaged over 

30 consecutive days, is set forth in section (g). Sections (h) and (i) include 

housekeeping and maintenance requirements and sections (j) and (k) define air 

monitoring, sampling procedures and source testing methods. Section (l) 

specifies requirements for new large lead-acid battery recycling facilities and 

sections (m) and (n) specify recordkeeping, reporting and notification 

requirements. Section (o) addresses the content of a study required when a 

facility’s emissions exceed 0.12 micrograms per cubic meter over 30 consecutive 

days. Appendix 1 outlines the content of the initial facility status report required 

in subsection (n) (3) (A).

EPA EVALUATION CRITERIA - The following criteria were used to evaluate the 

submitted rule. 

 

1. Air Quality Designations for the 2008 Lead (Pb) NAAQS, 76 FR 72097, November 22, 2011.

2. Staff Report, Proposed Rule 1420.1 – Emissions Standard for Lead from Large Lead-Acid 

Battery Recycling Facilities, November, 2010, at 2-2.
3

1. Enforceability - The Bluebook (Issues Relating to VOC Regulation 

Cutpoints, Deficiencies, and Deviations, EPA, May 25, 1988) and the Little 

Bluebook (Guidance Document for Correcting Common VOC & Other 

Rule Deficiencies, EPA Region 9, August 21, 2001) were used to evaluate 

compliance with the CAA §110(a)(2)(A) requirement for enforceability.

2. Stringency – EPA’s 2008 Lead NAAQS, 1997 Lead NESHAP, 2012 Lead 

NESHAP, 2008 Lead NAAQS Implementation Questions and Answers 

Memorandum (Scott Mathias, July 8, 2011), and the Implementation of the 

2008 NAAQS Guide to Developing RACM for Controlling Lead Emissions 

(EPA-457/R-12-001), were used to help evaluate the RACM/RACT 

requirements of CAA §172(c)(1). 

3. Rule Relaxation – We have evaluated this SIP rule to determine whether it 

would interfere with any applicable requirement concerning attainment and 

reasonable further progress (RFP) or any other applicable requirement of 

the Act (CAA §110(l)) or modify, in a nonattainment area, any SIPapproved control requirement in effect before November 15, 1990 (CAA 

§193).

EPA EVALUATION

Enforceability - Rule 1420.1 is generally clear in defining compliance with 

emission limits, recordkeeping, housekeeping, annual source testing, and 

monitoring and sampling requirements. 

In addition, section (j) requires ambient monitoring and sampling at a minimum of 

four sampling sites at or near the property line of facilities subject to the rule. The 

exact locations of the ambient monitors must be approved by the District and are 

to be based on maximum expected ground level lead concentrations. Sampling is 

to be conducted once every three calendar days. If ambient air concentrations of 

lead exceed 0.12 micrograms per cubic meter, facilities must begin daily 

monitoring for a period of 60 days. Section (n) requires submittal of all ambient 

monitoring results to the District on a monthly basis. 

In addition, if section (j) fence-line monitors (or any District-installed monitor)

register concentrations over 0.12 microgram per cubic meter averaged over 30 

days, section (g) requires a facility to submit a compliance plan to the District that 

identifies additional lead emission reduction measures. Section (g)(4) requires 

implementation of the compliance plan if levels exceed 0.15 microgram per cubic 

meter averaged over 30 days. 

Stringency - EPA defined RACM/RACT nationally for secondary lead smelters in a 

document published in March 2012, well after adoption of Rule 1420.1.3 

 

3. Implementation of the 2008 Lead National Ambient Air Quality Standards Guide to 

Developing Reasonably Available Control Measures (RACM) for Controlling Lead Emissions, 

EPA-457/R-12-001, March 2012.
4

Nonetheless, Rule 1420.1 contains all RACM/RACT elements described as 

necessary in this guidance. A summary of these minimum elements and how 

they are fulfilled in Rule 1420.1 is provided below:

 RACM includes fabric filters controlling lead process emissions from 

stacks. By requiring 99.97% capture efficiency for 0.3 micron particles for 

the filter media in subsections (f)(4) and (i)(1)(B), and by requiring that 

filter bags be of polytetrafluoroethylene membrane type in subsection 

(f)(5), Rule 1420.1 essentially requires the replacement of old fabric filters. 

 RACM also includes negative pressure total enclosures and partial 

enclosures with wet suppression for process units and storage areas to 

capture fugitive process emissions. Rule 1420.1(e) requires total 

enclosures for battery breaking areas, storage areas, dryer areas, melting 

furnace areas, agglomerating furnace areas and refining and casting 

areas. Section (e) also requires that total enclosures be maintained at a 

negative pressure of a minimum 0.02 mm Hg (0.11 inches H2O). Each 

total enclosure must be vented to an emission collection system that ducts 

the entire stream to a lead control device that meets the requirements in 

subsection (f) for filters and baghouses. Wet suppression is recommended 

for maintenance in an enclosure under negative pressure in areas where 

fugitive lead dust generation is a potential, “barring safety issues” in 

subsection (i)(1)(B).

 RACM includes paving or chemical stabilization of unpaved roads, and 

vacuuming paved roads for fugitive dust sources. Rule 1420.1(h), 

Housekeeping Requirements, requires paving and cleaning of surfaces 

subject to vehicular traffic, cleaning of rooftop structures, monthly 

inspections of enclosures and other structures that contain fugitive dust 

and storage methods for fugitive dust.

The following are also considered RACM/RACT in EPA’s March 2012 guidance:

 Fabric filters with downstream add-on control devices, such as HEPA 

filters, to control uncontrolled lead process emissions from stacks. Rule 

1420.1(f)(3) specifically requires a secondary lead control device on dryer 

emissions. In addition, Rule 1420.1(g)(2)(A)(iv) provides that compliance 

plans may include the installation of multi-stage lead control devices as an 

additional emission reduction measures for the compliance plan. 

 Replacement of old fabric filters. The stringent requirements of Sections 

1420.1(f)(4) and (5) will result in the replacement of any filter bags that do

not meet those standards.

 Cleaning of vehicles and building exteriors. Requirements in Rule 

1420.1(h) include regular cleaning of rooftops, lead-containing waste 

storage or recovery areas, and requirements in section (i)(2) include 

general cleaning of lead-contaminated equipment and materials used for 

any maintenance activity.

EPA also published the final residual risk and technology review revisions to the 

National Emission Standard for Hazardous Air Pollutants from Secondary Lead 
5

Smelting (NESHAP) in 2012.4 The revised NESHAP requirements represent the 

maximum achievable control technology (MACT) under CAA Section 112. MACT 

requirements apply nationwide, regardless of whether an area attains the Lead 

NAAQS, so we expect that MACT requirements are also needed in order to fulfill

RACM/RACT. The revised NESHAP’s compliance deadline for existing sources 

is May 19, 2011. A summary of the MACT requirements and how they are 

addressed by Rule 1420.1 is provided below: 

 MACT for an existing source must maintain 1.0 milligrams of lead per dry 

standard cubic meter in any process vent gas and 0.20 milligrams of lead 

per dry standard cubic meter from a secondary lead smelting facility on a 

rolling 12-month average basis. Rule 1420.1(d) requires compliance with 

a facility-wide limit of 0.15 micrograms of lead per cubic meter over 30 

consecutive days.

 MACT for an existing source must meet the applicable emissions limits for 

hydrocarbons and dioxins and furans. Rule 1420.1 addresses lead 

emissions only.

 MACT requires that initial performance tests and annual compliance tests

be required unless a continuous emission monitoring system (CEMS) is 

installed. Rule 1420.1(k) requires an initial source test and annual source 

tests. 

 MACT requires separating plastic battery casings from all other 

automotive batteries prior to introducing feed to a furnace. This provision 

is germane to dioxins and furans and is not addressed by Rule 1420.1.

 MACT requires total enclosures maintained at negative pressure for 

process fugitive emissions for various sources. The total enclosure must 

be vented to ensure negative pressure and inspections for enclosure 

breaches should be routine. Rule 1420.1(e) requires total enclosures for 

battery breaking areas, storage areas, dryer areas, smelting furnace 

areas, agglomerating furnaces areas and refining and casting areas 

maintained at negative pressure. Venting of the total enclosures to 

maintain negative pressure is required in subsection (e)(3). The 

housekeeping provisions in subsection (h)(2) require inspections and 

repairs of all total enclosures.

 MACT requires that a standard operating procedures manual and fugitive 

dust control standard operating procedures be prepared and submitted.

While an operations manual is not explicitly required by Rule 1420.1, 

Appendix 1 to the rule requires a status report which is to include, among 

other things, a description of types of lead processes performed at the 

facility and operating schedules.

 MACT specifies EPA test methods 1, 2, 3A, 3B, 4, 12 or 29 to determine 

compliance for lead. Rule 1420.1 specifies EPA Method 12 and lists the 

other EPA-approved methods as optional test methods.

 MACT requires recordkeeping on site for 2 years and maintained for 5 

years. Rule 1420.1(m)(2) requires facility records be maintained for 5 

years and kept on site for 2 years.

 

4. NESHAP From Secondary Lead Smelting, 77 FR 556, January 5, 2012. 
6

Based on comparison above to the MACT and national RACM guidance, and 

based on additional analysis provided in SCAQMD’s staff report for this rule,5 we 

conclude that Rule 1420.1 adequately fulfills CAA RACM/RACT requirements. 

SIP Relaxation - We propose to determine that our approval of the submittal 

would comply with CAA section 193 because the submitted SIP rule is the first 

for this source category and would insure emission reductions of lead.

We propose to determine that our approval of the submittal would comply with 

CAA section 110(l), because the proposed SIP revision strengthens the SIP and 

would not interfere with the on-going process for ensuring that requirements for 

RFP and attainment of the NAAQS are met.

ADDITIONAL RECOMMENDATIONS FOR THE NEXT RULE REVISION –

1. For clarity, the term “worker receptor location” used in Appendix 1 should 

be defined in this rule or specific reference made to “Risk Assessment 

Procedures for Rules 1401 and 212.”

2. Consider strengthening the rule by making compliance plan requirements 

more specific. 

3. In section (f), Lead Point Source Emission Controls, consider adding 

additional requirements for secondary lead controls such as HEPA filters 

downstream of primary controls.

4. Consider adding bag leak detection systems as a facility requirement.

EPA ACTION - Rule 1420.1 fulfils the relevant CAA §110 and part D 

requirements. EPA staff recommends a full approval of Rule 1420.1 pursuant to 

CAA §110(k) (3) and §301(a).

 

5. Staff Report, Proposed Rule 1420.1 – Emissions Standard for Lead from Large Lead-Acid 

Battery Recycling Facilities, November, 2010.
7

ATTACHMENTS 

1. SCAQMD Rule 1420.1, Emissions Standard for Lead from Large Lead-acid 

Battery Recycling Facilities as adopted on November 5, 2010.

ADDITIONAL REFERENCES

1. SCAQMD Rule 1420, Emission Standard For Lead, Adopted Sept. 11, 

1992.

2. “Issues Relating to VOC Regulation Cutpoints, Deficiencies, and 

Deviations,” (a.k.a., Bluebook) EPA OAQPS, May 25, 1988.

http://www.epa.gov/ttn/naaqs/ozone/ozonetech/voc_bluebook.pdf

3. “Guidance Document for Correcting Common VOC & Other Rule 

Deficiencies,” (a.k.a., Little Bluebook), EPA Region 9, August 21, 2001.

http://www.epa.gov/Region09/air/sips/littlebluebook2001.pdf

4. Lead (Pb) NAAQS dated November 12, 2008 (73 FR 66964) 

http://www.gpo.gov/fdsys/pkg/FR-2008-11-12/pdf/E8-25654.pdf

5. NESHAP From Secondary Lead Smelting dated January 5, 2012 (77 FR 

556) http://www.gpo.gov/fdsys/pkg/FR-2012-01-05/pdf/2011-32933.pdf

6. NESHAP for Secondary Lead Smelting (40 CFR 63 Subpart X)

http://www.gpo.gov/fdsys/pkg/CFR-2011-title40-vol9/pdf/CFR-2011-title40-

vol9-part63-subpartX.pdf

7. Implementation of the 2008 Lead National Ambient Air Quality Standards 

Guide to Developing Reasonably Available Control Measures (RACM) for 

Controlling Lead Emissions, EPA-457/R-12-001, March 2012

http://www.epa.gov/airquality/lead/pdfs/2012ImplementationGuide.pdf

8. Memorandum from Scott L. Matthias, 2008 Lead (Pb) National Ambient Air 

Quality Standards (NAAQS) Implementation Questions and Answers, July 

8, 2011