Texas Commission on Environmental Quality

INTEROFFICE MEMORANDUM

To: David Brymer

Air Quality Planning Division

Date: June 3, 2009

Thru: Robert Opiela, P.E., Technical Specialist

Technical Program Support Section

Air Permits Division

From: Matthew Kovar, Megan Cox

Air Dispersion Modeling Team

Air Permits Division

Subject: Modeling Analysis of Lead for Exide Technologies, Frisco Battery Recycling Plant 

(RN100218643)

1.0 Project Identification Information. 

On November 12, 2008, the U.S. Environmental Protection Agency (EPA) finalized the new 

0.15 microgram per cubic meter (g/m

3

) NAAQS for lead based on a rolling three-month 

average (73 Federal Register 66964). In general, the rule requires source-oriented ambient air 

lead monitoring by January 1, 2010, at sites with actual annual lead emissions of one or more 

tons per year. Exide Technologies, Frisco Battery Recycling Plant was identified as having 

emissions at or above this level based on the reported 2007 TCEQ Emissions Inventory and/or 

2006 Toxics Release Inventory. The rule further requires that this monitoring be conducted at or 

near the maximum off-site ambient air lead concentration, as predicted by modeling, that results 

from sources with annual lead emissions of one or more tons.

The TCEQ conducted air dispersion modeling of all the lead emission sources at the site using 

the most current modeling parameters and associated permitted allowable emissions rates. The 

TCEQ will use the dispersion modeling results to determine the optimal location of any required 

source-oriented monitors.

Since monitoring already exists at and near the Exide Technologies site, and monitored values 

exceeding the new lead standard have been recorded, the dispersion modeling results will also

be used to determine the proposed boundaries of a lead non-attainment area.

ArcReader Published Map:

\\Msgiswrk\apd\MODEL PROJECTS\Lead NAAQS 

Analysis_2009\Lead_NAAQS_Analysis_Results.pmf

2.0 Report Summary. The predicted maximum ground level concentration (GLCmax) is 1.42 

g/m3for a rolling three-month average. The location of the GLCmax is the same as the 

location of monitor 480850009 on the north property line of the Exide Technologies site. 

Predicted concentrations exceeding the NAAQS extended approximately 1.3 kilometers (km) to 

the north, 0.8 km to the south, 0.8 km to the west, and 0.4 km to the east of the site property 
David Brymer

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June 3, 2009 

Modeling Analysis of Lead for Exide Technologies, Frisco Battery Recycling Plant

line. All predicted concentrations greater than the NAAQS are located within Collin County. 

Table 1 lists the predicted concentrations at the current monitor locations and proposed monitor 

location near the intersection of 1st Street and Ash Street.

Table 1. Modeling Results for Lead

Monitor ID Averaging 

Time 

GLC 

(μg/m3)

Standard

(μg/m3)

480850009 rolling three-month 1.42 0.15

480850003 rolling three-month 0.81 0.15

480850007 rolling three-month 0.49 0.15

Proposed rolling three-month 0.52 0.15

3.0 Land Use and Terrain. A land use/land cover analysis was performed using AERSURFACE

consistent with guidance given in the AERMOD Implementation Guide (March 19, 2009). The 

recommended input data, the National Land Cover Data 1992 archives (NLCD92), were used 

for this analysis.

Terrain elevations within the modeling domain were determined using AERMAP (Version 

09040). The input data used for this analysis were United States Geological Survey (USGS) 

digital elevation models (DEMs) for Little Elm, Frisco, Lewisville East, and Hebron data sets.

4.0 Modeling Emissions Inventory. The modeled emission source parameters and emission rates 

were provided by Exide Technologies. The source locations were validated by ADMT using 

aerial photography. The source emission rates modeled were consistent with the maximum 

allowable emission rates authorized through permits 3048A and 1147A. The emission source 

coordinates are in the UTM Zone 14 North, North American Datum of 1927 (NAD27) 

coordinate system.

Table 2. On-Property Point Source Parameter Information

ID Easting 

(meters)

Northing 

(meters)

Stack 

Height 

(meters)

Stack 

Temp

(K)

Stack Exit 

Velocity 

(meters/sec)

Stack

Diameter 

(meters)

11 702713.06 3668796.5 16.764 369.26 12.0396 0.3048

12 702713.25 3668793.75 16.764 369.26 8.5039 0.3048

13 702713.25 3668791.5 15.8496 391.48 13.1674 0.3048

14 702721 3668792.75 16.764 327.59 27.9624 0.5334
David Brymer

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June 3, 2009 

Modeling Analysis of Lead for Exide Technologies, Frisco Battery Recycling Plant

Table 2. On-Property Point Source Parameter Information

ID Easting 

(meters)

Northing 

(meters)

Stack 

Height 

(meters)

Stack 

Temp

(K)

Stack Exit 

Velocity 

(meters/sec)

Stack

Diameter 

(meters)

15 702725.31 3668807.5 16.764 349.82 14.1732 0.381

16 702717.88 3668803 17.3736 369.26 13.4722 0.253

17 702728.88 3668779.5 16.764 355.37 14.0208 0.381

18 702628.13 3668767.75 30.6324 303.71 5.1206 1.6154

21 702626.88 3668739.25 31.242 304.82 16.5811 1.521

22 702685.69 3668804.25 22.86 0 15.1486 0.8108

23 702637.38 3668764.5 6.096 0 1.8288 0.3048

24 702721.88 3668782.5 16.4592 369.26 11.491 0.381

25 702721.75 3668777.75 16.4592 358.15 9.4488 0.381

26 702736.31 3668782.75 9.144 355.37 11.5824 0.1524

37 702682.56 3668810 22.86 298.15 19.6901 1.6764

38 702620.19 3668771.75 33.8328 315.37 16.7945 1.3716

39 702544.5 3668727.75 10.668 0 0.0009 1.524

45 702623.06 3668713.75 32.1564 0 14.0238 1.8044

48 702585 3668771 11.2776 0 1.6764 0.1707

Table 3. Area Source Parameter Information

ID

Easting

(meters)

Northing

(meters)

Release 

Height

(meters)

Easterly 

Length

(meters)

Northerly 

Length

(meters)

Degrees from 

north

( )

10 702642.65 3668770.8 4.572 28.956 24.384 -2

27 702733.81 3668767.5 4.572 0.9144 0.9144 0

28 702756.31 3668782 4.572 0.9144 0.9144 0

35 702654.26 3668740.35 4.572 22.86 30.48 -2

36 702645.75 3668754.8 4.572 32.004 15.24 -2

41 702518.28 3668768.73 0.3048 94.488 21.336 40
David Brymer

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June 3, 2009 

Modeling Analysis of Lead for Exide Technologies, Frisco Battery Recycling Plant

Table 3. Area Source Parameter Information

ID

Easting

(meters)

Northing

(meters)

Release 

Height

(meters)

Easterly 

Length

(meters)

Northerly 

Length

(meters)

Degrees from 

north

( )

42 702625.1 3668693.38 0.3048 80.772 44.196 -2

43 702702.77 3668745.25 0.3048 62.484 39.624 -2

44 702590.79 3668760.22 3.9929 24.384 41.148 -2

52 702631.81 3668765.63 4.572 21.336 16.764 -2

53 702615.56 3668762.28 1.8288 16.764 19.812 -2

Table 4. On-Property Source Allowable Emission Rates

Scenario

ID

Pollutant Averaging

Time

Emission Rates

(lb/hr)

10 Lead 1-hr 0.27

11 Lead 1-hr 0.05

12 Lead 1-hr 0.03

13 Lead 1-hr 0.05

14 Lead 1-hr 0.03

15 Lead 1-hr 0.05

16 Lead 1-hr 0.02

17 Lead 1-hr 0.05

18 Lead 1-hr 0.12

21 Lead 1-hr 0.25

22 Lead 1-hr 0.08

23 Lead 1-hr 0.03

24 Lead 1-hr 0.006

25 Lead 1-hr 0.004

26 Lead 1-hr 0.001

27 Lead 1-hr 0.001
David Brymer

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June 3, 2009 

Modeling Analysis of Lead for Exide Technologies, Frisco Battery Recycling Plant

Table 4. On-Property Source Allowable Emission Rates

Scenario

ID

Pollutant Averaging

Time

Emission Rates

(lb/hr)

28 Lead 1-hr 0.001

35 Lead 1-hr 0.27

36 Lead 1-hr 0.01

37 Lead 1-hr 0.16

38 Lead 1-hr 0.29

39 Lead 1-hr 0.12

41 Lead 1-hr 0.07

42 Lead 1-hr 0.07

43 Lead 1-hr 0.07

44 Lead 1-hr 0.03

45 Lead 1-hr 0.35

48 Lead 1-hr 0.06

52 Lead 1-hr 0.01

53 Lead 1-hr 0.32

5.0 Building Wake Effects (Downwash). Input data to Building Profile Input Program Prime 

(BPIP-PRM Version 04274) were provided by Exide Technologies. The building locations were 

validated by ADMT using aerial photography.

6.0 Meteorological Data.

Surface Station and ID: Dallas/Fort Worth, TX (Station #: 03927)

Upper Air Station and ID: Stephenville, TX (Station #: 13091)

Meteorological Dataset: 1985, 1987, 1988, 1989, 1990

Profile Base Elevation: 551 feet

The AERSURFACE analysis conducted of the area surrounding the Exide Technologies site 

resulted in a calculated roughness length of 0.129 meters. Since the AERSURFACE analysis 

used land cover data from 1992 and since the area near the site has become more developed and 

urbanized since 1992 based on comparing the land cover data to 2008 aerial photography, a 

representative roughness length for the area would be approximately 0.5 meters. For this reason, 
David Brymer

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June 3, 2009 

Modeling Analysis of Lead for Exide Technologies, Frisco Battery Recycling Plant

the meteorological data set used for this analysis was developed using a roughness length of 0.5 

meters.

7.0 Receptor Grid. The receptor grid used in the modeling analysis consisted of receptors with 100 

meter spacing and extended approximately 5 kilometers (km) from the Exide Technologies site 

property line in all directions. Discrete receptors were used for the locations of the three existing 

monitoring stations and the location of a proposed monitoring station near the intersection of 1st 

Street and Ash Street. The purpose of the receptor grid was to determine a representative 

maximum ground-level concentration and the extent of ground-level concentrations at or above 

half of the lead NAAQS standard.

8.0 Model Used and Modeling Techniques. AERMOD (Version 07026) was used in a refined 

screening mode. For refined screening, National Weather Service (NWS) meteorological raw 

input data are used with generalized surface characteristics of the application site. Since the 

current version of AERMOD is not capable of calculating rolling three-month average 

concentrations, the EPA post processor LeadPost was used. The input values to LeadPost are 

monthly average values at each receptor in the POSTFILE output format from AERMOD.

For this analysis, only emission sources at the Exide Technologies site were considered. The 

nearest source of lead emissions outside the modeling domain is approximately 20 km from the 

Exide Technologies site with reported 2007 lead annual emissions approximately one percent of 

the annual lead emissions reported by Exide Technologies. The largest nearby source of lead 

emissions is approximately 50 km from the Exide Technologies site with annual reported 

emissions approximately ten percent of the annual emissions reported by Exide Technologies. 

Due to the great distance to the Exide Technologies site and the small reported emission, no 

other sources of lead emissions would have a significant contribution near the Exide 

Technologies site or the modeling domain used for this analysis.