# Texas Commission o n Environmental Quality INTEROFFICE MEMORANDUM
To: David Brymer

Air Quality Planning Division Date: Ju ne 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, 20 08, the U.S. Environmental Protection Agency (EPA) finalized the new 0.15 microgram per cubic meter ( g/m3 ) 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 mo nitored 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/m3 for 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 propertyDavid Brymer

Page 2 of 6 Ju ne 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 ( μ g/m3 ) Standard ( μ g/m3 ) 480850009 rolling three
- mo nth 1.42 0.15 480850003 rolling three
- mo nth 0.81 0.15 480850007 rolling three
- mo nth 0.49 0.15 Proposed rolling three
- mo nth 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

Tem p (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 .5334David Brymer

Page 3 of 6 Ju ne 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

Tem p (K) Stack Exit

Velocity (meters/sec) Stack

Diameter (meters) 15 702725.31 366880 7.5 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 3668 810 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 3668768.7 3 0 .3048 94.488 21.336 40David Brymer

Page 4 of 6 Ju ne 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 16.7 64 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 .001David Brymer

Page 5 of 6 Ju ne 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

Page 6 of 6 Ju ne 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 station s 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.