## APPENDIX B Sanders Modeling Protocol and CorrespondenceSANDER'S LEAD SIP MODELING PROTOCOL IN ACCORDANCE WITH ADEM PSD AIR QUALITY ANALYSIS AERMOD MODELING GUIDELINES (MAY2008)

July28,2011 Revision 1January 20, 2012



# Sanders Lead Company Troy, Alabama

1000 Corporate Centre Drive Suite 250 Franklin, Tennessee 37067 (615) 771-2480 URS Project No. 20499427.000011.0 INTRODUCTION
1.1 Background Sanders Lead Company (Sanders Lead) has retained URS Corporation (URS) to prepare a modeling analysis for lead emissions released from their facility located in Troy Alabama. The purpose of this document is to present to the Alabama Department of Environmental Management (ADEM) a detailed protocol ofthe modeling procedures that will be used to conduct the air quality dispersion modeling analyses. The modeling procedures used to conduct analysis were based on recommendations given in the ADEM PSD Air Quality Analysis AERMOD Modeling Guidelines (May 2008). Also, modeling guidance contained in the U.S. EPA Guideline on Air Quality Models and the U.S. EPA New SourceReview Workshop Manual will be followed when applicable.
1.2 Problem Dermition On September 30, 2009, ADEM provided EPA input regarding the extent ofpotential nonattainment areas in Alabama for the new Lead National Ambient Air Quality Standards (NAAQS). The monitoring data indicated that a small portion ofPike County, Alabama did not meet the newleadNAAQS.

As a result ofthe NAAQS violation ofthe 2008 lead standards, EPA designated the area 0.8 miles surrounding Sanders Lead located in Troy, AL as "nonattainment" in the first round ofdesignations. It should be noted that the EPA completed lead designations in two rounds. In the first round, the EPA designated as "nonattainment" any area that violated the 2008 lead standards based on data from 2007-2009. The EPA took an additional year to make final designations decisions for all other areas ofthe country to allow additional lead air quality data to be collected and evaluated. In the second round, the EPA designated those remaining areas as meeting or not meeting the 2008 lead standards based ondata from 2008-2010.
Sanders Lead developing mitigation measures for achieving compliance with the new lead NAAQS, and anticipate that with the implementation ofthese measures that ambient lead concentrations in the area will be significantly reduced and the new lead NAAQS will be attained.
2.0 SITE DESCRIPTION The Sanders Lead facility is located at 1 Sanders Road, in Troy, Alabama. As shown in Figure 1 (referto Appendix A), Troyis located in southeastern Alabama, in Pike County. Troy is located 70 kilometers southeast ofMontgomery, Alabama. Figure I displays the plant site on a 7.5 minute USGS map along with a depiction ofcurrent company owned plant boundaries. The citypopulation ofTroyis approximately 13,935. According to the United States Census Bureau, the cityhas a total area of26.3 square miles (68.2 km2), of which, 26.2 square miles ofitis land and 0.1 square miles ofit (0.36%) is water.

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_Consulting\01_Air\Pb Modeling\Protocol\Modeling Protocol_Rev !.doc2.1 Site Characteristics As shown in Figure 2 (refer to Appendix A), Troy is located in a gently rolling area of Alabama with no local topographic features which appreciably influence weather and climate. During the months of June through September, inclusive, temperature and humidity conditions generally show little change from day to day. During the coldest months, December, January, and February, there are frequent shifts between mild and moist air from the GulfofMexico and dry, cool continental air. From late June through the first half of August, nearly all precipitation is from local, mostly afternoon, thunderstmms, and there are apt to be considerable differences in day-to-day amounts of rainfall in different parts ofthe Troy area. In late August and in September, summer conditions oftemperature and humidity persist as air continues to drift in from the Gulf, but local thunderstorms become less frequent because ofthe shortening ofthe days and the decrease in heat received from the sun. As this late summer season progresses, the local climate gives way to thunderstorms which occur with cold fronts and occasional general rains associated with storms on the Gulf. All types and intensities ofrain, except the local thunderstorms of summer, may occur at any time from December through March or early April. Floods in the rivers are correspondingly most frequent during this period. Most rain from late April through early June is in the form of showers or thunderstorms occurring in advance of approaching cool fronts, which become weaker and less frequent as summer approaches. It is during this spring season, and during the late summer and early autumn, that droughts sometimes occur. Snow in Troy is important only as a curiosity. Near the facility, terrainhas gentleundulations.

The approximate UTM coordinates ofthe facility are NAD27 Zone 16, 596.744 krn east and 3517.284 krn north, at an elevation of approximately 160 meters above mean sea level. Based on area classification systems recognizedbyEPA, the facility is located in a rural section ofthe state. EPA guidance shows two alternative procedures to determine whether the character ofan area is predominately urban or rural: (1) land use typing or (2) population density. The area classification system as described byAuerinthe Journal ofApplied Meteorology, Vol. 17, pg. 636-643, 1978, Correlation ofLand Use and Cover with Meteorological Anomalies, is frequently used to classify the area. URS used the
new EPA AERSURFACEprogram to also confitm what theUSGS maps indicated. That is the area surrounding the facility is largely rural in nature with greater than 50 percent ofthe area made up oftrees and vegetation. Forthe landuse analysis, URS used a 3 krn distance to evaluate surface roughness. URS understands that for developing surface boundary layer parameters for AERMET processing (stage 3) a one kilometer distance is required. Results using a one kilometer radius have been presented in a recent landuse protocol submittal to the ADEM. Results fi_-om the 3-krn analysis indicate that urban dispersion adjustments based on population will not be needed for the lead modeling submittal.

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_Consulting\0 1_ Air\Pb Modeling\Protocol\Modeling Protocol_Rev !.doc3.0 MODEL SELECTION
3.1 AERMOD Overview The American Meteorological Society/Environmental Protection Agency Regulatory Model (AERMOD) modeling system shall be employed for the proposed Sanders Lead modeling analysis. AERMOD is a steady-state line Gaussian plume model that considers the effects of nighttime planetary boundary layer effects and daytime convective activities. AERMOD has many features that make it the preferred model ofchoice for this particularmodeling exercise; such features includethe capabilityto model point, area and volume sources; inclusion ofbuilding downwash ofeffluent; and most importantly, AERMOD was recently identified as the "preferred" model in the U.S. EPA Guideline on Air QualityModels.
4.0 MODELING INPUT
4.1 Dispersion Model The modeling analysis will be performed using the most current version of the EPA AERMOD model (version 9.84). Currently, AERMOD is the prefen·ed computer dispersion model for conductingrefined dispersion modeling. The AERMOD model will be used to model the individual point, area and volume sources in order to predict maximum ambient lead concentrations from the facility. The modeling options that will beused include the following:

• Calculation ofaverage concentrations for each applicable averagingperiod;
• Non-Urban dispersion conditions;
• Regulatorydefault options;
• Final plumerise;
• Stack-tip downwash;
• Buoyancy-induced dispersion;
• Calms processingroutine;
• Default wind profile exponents; • Default vertical potential temperature gradients;
• "UpperBound" values for supersquatbuildings;
• No exponential decay; and
•Terrain included.

4.2 MeteorologicalData National Weather Service data from the regional airport located in Montgomery, Alabama will be used for the modeling analysis. As recommended by ADEM, NWS 1- minute meteorological data from 2006 through 2010 shall be processed for this attainment demonstration.

In the following sections, Section 4.2.1 describes why the data is considered "representative" for the modeling analysis; and Section 4.2.2 describes the process used

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_Consulting\0l_ Air\Pb Modeling\Protocoi\Modeling Protocol_Rev !.docto make the determination that the area surrounding the facility should be considered "rural".

4.2.1 Data Representativeness Prior to conducting the modeling analysis, it is essential that the Meteorological data be representative of the meteorological conditions at Sanders Lead. ADEM AERMOD Modeling Guidelines define representativeness as "constructing a realistic planetary boundary layer (PBL) similarity profiles and adequately characterizing the dispersive capacity ofthe atmosphere. As such, the determination ofrepresentativeness should include comparison of the surface characteristics, Bowen ratio and albedo, between the NWSmeasurementsite andthe source location". Coincidentally, in August 2009, URS provided ADEM with a Landuse Protocol (August 2009) which evaluated the site "representativeness" between Montgomery airport and the Sanders Lead facility. Sanders Lead duplicated the AERMET processing for one year (2005) but used boundary layer parameters generated by AERSURFACE based on land
use patterns around the facility. The first quarter or first three months, of 2005 was modeled in AERMOD using the two meteorological data sets to understand the relative importance of these changes in AERSURFACE processing to predicted ambient concentrations.

The initial modeling results indicate there would be about a 22 percent change in predicted concentrations using the different data sets. Although both data sets produce the same location ofmaximum impact, URS will provide the air dispersion results for both surface characteristics (Montgomeryairport and Sanders Lead site).

4.2.2AERSURFACELanduseAnalysis forAERMET One ofthe more important inputs to an airquality dispersion model is the meteorological data. The meteorological data will dictate where emitted compounds will be transported based on information such as wind speed, wind direction, ambient temperature, and atmospheric surface boundary layer parameters which help define atmospheric stability and mixing height development. The more meaningful the meteorological inputs, the greater the likelihood ofuseful results. Recognizing that not all locations have access to meteorological data, EPA developed methods whereby data obtained not at the site, but from another locale, could be used ifshown to be reasonably representative ofconditions at the modeling site. This test ofrepresentativeness has been described in EPA guidance (Guideline on Air Quality Models) (40 CFR 51 Appendix W) and AERMOD/AERMET implementation guidance, including the most recent version issued March 19, 2009. The test ofrepresentativeness was originally intended in the Guideline on Air QualityModels to include both a spatial and temporal component togetherwith a suitability component.

In the EPA Meteorological Monitoring Guidance for Regulat01y Modeling Applications, representativeness has been defined as "the extent to which a set of measurements taken in a space-time domain reflects the actual conditions in the same or different space-time domain taken on a scale appropriatefor a specific application. " The meteorological monitoring guidance continues to saythat "

..for use in air quality modelingapplications,
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_Consulting\01_Air\Pb Modeling\Protocol\Modeling Protocol_Rev !.docmeteorological data should be representative ofconditions affecting the transport and dispersion of pollutants in the area ofinterest as determined by the locations ofthe
sources and receptors being modeled. " Establishing representativeness balances the requirements ofthe modeling assessment with the reasonableness ofmeteorological data acquisition. Due to the fact that surface characteristics for both the Montgomery airport
as well as the Sanders Lead site, it is believed that URS will satisfy the requirements of data representativeness, as results from both data sets will used in the following air dispersion modeling analyses.

4.2.3AERSURFACELanduseAnalysis for Urban/Rural Selection The ADEM requires an Auer land use analysis which uses USGS maps to make a rural/urban determination. From this review it was apparent the area within a 3-km radius of the facility is rural using Auer techniques. To confirm this conclusion, the AERSURFACE program was also used using a 3-km radius and the land use distribution
was calculated and plotted. The plot clearly shows the large amount ofvegetation in the
area. EPA modeling guidance provided in the AERMOD Implementation Guide (January 9, 2008) and the Guidelines on Air Quality Models (Appendix W) indicate that
apopulation density greaterthan 750 people per squarekilometer determines whetherthe urban dispersion option is selected in AERMOD. An initial population density value based on 2009 census data for Troy, Alabama obtained from http://en.wikipedia.org/wiki/Troy,_Alabama indicates a**~opulation** density of 204.3 people/km2• Since the EPA trigger of 750 people/km value is not exceeded, urban AERMOD options will not selected.
4.3 Receptors A Cartesian grid system shall be implemented with a 100 meter spacing receptor grid, in addition, a 300m x 300m grid will be included around each monitor. The grid system was centered at a location that was in the middle of company owned property. All receptors includedtenainheights generated from theAERMAP.

AERMAP has been revised (beginning withversion 9.84) to supportprocessing ofterrain elevations from the National Elevation Dataset (NED) developed bythe U.S. Geological Survey (USGS, 2002) (http://scamless.usgs.gov/website/seamless/viewer.htm). An important component ofthe NED data is that it is being actively supported and checked for quality; therefore, NED represents a more up-to-date and improved resource for tenain elevations for use with AERMAP. The NED data used for this modeling exercise included the following domains: Troy, Ansley, Banks, Brundidge, Brundidge NW, Goshen, Needmore, Saco and Youngblood.
4.4 Lead Emission Sources at Facility Table 1 is a list ofthe current stack parameters for the lead point sources located at the facility, as well as the fugitive lead emission sources. All emission rates used in the modeling will be clearly identified inthemodelingrep01t when submitted.

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_Consulting\0l_Air\Pb Modeling\Protocol\Modeling Protocol_ Rev !.docTABLE 1 - Source ofEmissions at Sanders Lead Source ID Type Description Stack I Point Blast Furnaces I, 2 and Reverberatory Furnace Stack 5 Point Blast Furnaces 3, 4 and Alloying Kettles Stack 4 Point Sanitmy Baghouse for Furnaces I and 2 Stack 4a Point Sanitary Baghouse for Furnaces 3 and 4 Stack 10 Point SlagTreatment Building Roadway I Volume Material from breaker to main building (Bld.2) Roadway2 Volume Material to Slag Treatmentbuilding Roadway3 Volume Raw material (coke, limestone, scrap iron) to main building (Bld.2) Roadway4 Volume Delivery ofraw coke, limestone and scrap iron RouteS Volume Delive1y ofbatteries to Breaker Source A Volume Shredding and Separation Fugitive Source B Volume Decasing ofindustrial Batteries Source C Volume Raw Material Storage Building Operations SourceD Volume Furnace/Refining Building Operations

4.5 Off-Site Emissions Inventory Since lead emissions from Sanders Lead are expected to produce the largest concentration gradients for lead in the area, the value of modeling very small contributions from other, more distant lead sources it very limited. Therefore, other "offsite" lead sources will not bemodeled unless the ADEM specifically identifies an off-site
sourceinresponse to this modelingprotocol.
4.6 Background Air Quality Data An ambient background concentration for lead will be added to the maximum predicted concentrations from all modeled sources to determine a final maximum ambient concentration. ADEM has provided a representative background concentration, based on PM2.5 speciated data from the Montgomery airport monitor-based on the following protocol:
UsingEPA'sAir QualitySystem's (AQS) database, speciatedPM2.5 data specifically for lead was obtained for the years 2006-2010 and the last 2 months of 2005. The monitor used was the Montgomety site (01-101-1002) and the datafor this monitor
was collected every

## 6'" day throughout the year. This data was then used to calculate monthly averagesfor the entireperiod. These monthly averages were then used to create 3-month rollingaverages and from that the maximum 3-month rollingaverage for the entireperiodof data was determinedandsetas the background for lead.

Based on results from the speciated PM2.5 data, ADEM has determined that 0.009 ug/m3 provides a representativebackground concentration oflead for the area.

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_Consulting\0I_Air\Pb Modeling\Protocol\Modeling Protocol_ Rev ].doc4.7 Good Engineering Practice StackHeightAnalysis For point sources located at the facility, a good engineering practice (GEP) stack height evaluation was conducted to determine ifbuilding wake effects allow a point source to be modeled at a height greater than 65-meters. The GEP formula stack height is expressed
as the greater of65 meters or GEP 

### =Hb 

### + 1.5L (where Hb is the buildingheight, and L is the lesser of the building's height or maximum projected width). The procedures followed guidance given in the EPA Guideline for Determination ofGood Engineering Practice Stack Height (Technical Support Document for the Stack Height Regulations) Revised (EPA- 450/4-80-023R) and the User's Guide to the Building Profile Input Program. BEEST software was utilized to detennine calculated GEP stack heights and to develop direction specific building dimensions for use in the dispersion model. There are no stacks with a stackheight greater than 65 meters.
The building wake and downwash effect analysis was applied to each point source that released lead emissions. For each building, an area of wake and downwash effects extends outward to a distance offive times L (the lesser ofthe maximum projected width
orheight ofthe building) directly downwind from the leeward side ofthebuilding. Wake effects were assumed to occur if the emission source was located within a rectangle composed oftwo lines perpendicular to the wind direction, one at 5L downwind ofthe building and the other at 2L upwind ofthe building, and by two lines parallel to the wind direction, each at 0.5L away from each side of the building. As the wind direction rotates, the wake and downwash effect region ofinfluence changes and is combined to form a GEP 5L region ofinfluence in all wind directions. Any emission source within the region ofinfluence can be affected by wake and downwash effects. For buildings close to an emission source, wake and downwash effects were considered where the distance between the emission source and the nearest part ofthe building is less than or equal to 5L.
When an emission source height is less than the calculated GEP height and is located within the region ofinfluence, direction-specific building and dispersion parameters are required in the modeling analysis. The AERMOD model uses downwash and cavity equations developed by the Electric Power Research Institute (EPRI) and this methodology is referred to as the "Prime" method when the physical stack height is less than 1.5 times the height ofthe building causing the maximum GEP height. The prime equations reduce plumerise due to initial plume dilution, enhance plume spread.

The GEP analysis was conducted using the Building Profile Input Program -Prime (BPIPPRIME) program to demonstrate compliancewith stack heightregulations (40 CFR Part 51).
4.8 Quarterly Lead Concentration Calculation Procedure Since the dispersion model AERMOD does not provide the ability to directly compute the 3-month rolling averages, results must go through a post-processing procedure. EPA's "LEADPOST" program which is a FORTRANprogram designed to read monthly concentrations output from AERMOD and calculate the maximum rolling 3-month

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_Consulting\0l_Air\Pb Modeling\Protocol\Modeling Protocol_Rev !.docaverage concentration for each receptor and overall maximum concentration (across all receptors and source groups).

5.0 REASONABLY AVAILABLE CONTROL TECHNOLOGY EPA defines Reasonably Available Control Technology (RACT) as the lowest emission limitation that a particular source can meet by the application ofcontrol technology that is reasonably available consideringtechnological and economic feasibility.

The technology feasibility of applying an emission reduction method to a particular
source considers the source's process and operating procedures, raw materials, and physical plant layout. The following items were considered when determining the control technologyto apply: 1. The process, operating procedures, and raw materials used by the source can affect the feasibility ofcarrying outprocess changes that reduce emissions and the selection ofadd-on emission control equipment. 2. The operation of and longevity of control equipment can be significantly influencedbythe raw materials used and the process to whichitis applied. 3. The feasibility of modifying processes or applying control equipment is also influencedbythephysical layout ofaparticularplant. 4. The space available in which to cany out such changes may limit the choices of control. 5. Determinations oftechnological feasibility also consider adverse impacts on other
resources. Ifa control technology increases pollution ofbodies ofwater, creates additional solid waste disposal, or exacerbates worker exposure problems; the technologymaynotbe consideredreasonably available.

The implementation of RACT by the Sanders Lead facility provides enforceable and permanent emissions reductions needed to attain and maintain the lead NAAQS at this time. The following information details the cmTently anticipated measures to be employed, as well as a brief explanation of the control measures. Sanders Lead has developed a detailed "Lead Compliance hnplementation Schedule" which details the installation timeline of the proposed measures in order to meet the implementation deadline.

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_Consulting\0I_ Air\Pb Modeling\Protocoi\Modeling Protocol_ Rev !.docDescription of Measure

Enclose Baghouse Hoppers and Transport ofDust

Control and Enclose Furnace Operations

Control and Enclose Refining Operations

Relocate Industrial Battery Decasing and Enclose Raw Material Handling Operations

Improve Process Material Transport to Eliminate Leaded OutdoorTraffic

Relocate and Contain Leaded Vehicle Maintenance

Improved Watering Explanation

Sanders Lead is proposing to enclose the base ofbaghouses #1 and #5, including the access doors and removable panels on the units. Ventilation will beprovided by ducting to existingbaghouses.

Sanders Lead is proposing to install canopy hoods over each blast furnace with supply air to reduce worker lead exposures. A new hood will be installed over the reverb feed hopper. Additionally, the furnace building will be enclosed. A new approximately 318,000 CFM baghouse will be installed to control emissions captured bythe new hoods and buildingenclosure.

Sanders Lead is proposing to enclose the refining building, including the eliminationofsidewall fans. As partofenclosing the refining building, fast acting rollup doors will be installed. Area ventilation will be provided by negative on building provided by the additionalbaghouse capacity.

Sanders Lead is proposing to relocate the industrial battery decasing operations to the inside of the existing raw material storage building. A new raw material receiving dock will also be constructed to connect with the east side of the raw material building. Sanders Lead is also proposing to install an enclosed vehicle washing system which will enclose the vehicle entrance to and from the storage building. Fast acting rollup doors will also be installed at the rawmate1ial storagebuilding.

In order to eliminate leaded outdoor traffic, Sanders Lead is proposing to enclose the shredder building and the transport of group to shredder from raw material storage building. Sanders Lead is also proposing to enclose the collection and handling of water and lead runofffrom the shreddergroup pile.

Sanders Lead is proposing the install transferpoints at the refining, smelting and raw material storage vehicle exits to maintain "leaded" vehicles inside the building. Sanders Lead is proposing to relocate leaded vehicle maintenance to a newly enclosed constructed area.
Sanders Lead is proposing to develop an updated watering plan based on the new vehicle patterns and facility layout. The wateringplan will include animproved floor wetting system inside and outside the building, as well as purchasing new wet sweepers for the outside buildings.

6.0 CONTINGENCY MEASURES Pursuant to Section 1 72 ofthe CAA, a set of contingency measures has been prepared that could be implemented ifrequired by a finding ofthe EPA Regional Administrator that a) the nonattainment area has failed to make Reasonable Further Progress (RFP), b) there is a failure to implement a control strategy to attain the NAAQS by the statutory
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_Consulting\0l_Air\Pb Modeling\Protocoi\Modeling Protocol_Rev !.docdeadline, or c) monitoring shows that the nonattainment area has failed to attain the NAAQS bythe statutorydeadline.

7.0 SUBMITTAL INFORMATION The Air Quality Impact analysis will include the following information as recommended bythe ADEM:
1) Description of model used and any special assumptions or options employed. Justification will be included for any use of non-regulatory options. The BEEST proprietary software will beusedto facilitate datainput and process output. 2) Description of the meteorological input data used, with an explanation of any modification(s) will beprovided.
3) A detailed analysis to demonstrate that the surface characteristics in the vicinity ofthe meteorological collection site (furnished by ADEM) are representative of the surface characteristics inthe vicinity ofthe facility. This information has bepreviously submitted and approved in a separate Landuseprotocol.
4) Overall description of the methodology used in perfonning the analysis. This will include all steps necessary for identifying the maximum ambient lead impact values and could beused for comparisonwith and ambient air quality standards ifneeded.
5) Tables identifying the maximum ambient levels (including receptor locations and year ofmeteorology) for quarterly averaging periods including the contribution ofthe facility to themaxima.
6) Figures of isopleths that illustrate the aerial extent of ambient levels. Location of maximumpredicted concentrations will be clearly noted for comparisonto the air quality standard for lead as needed. Figures will have a background illustrating terrain or other identifiable features, such as a U.S.G.S. Map, for easyorientation.
7) Appropriate model output files substantiating points of concern, as described in the text, will be submitted.
8) Source inputparameters for all sources modeled will bereported.
9) Identification ofthemeteorologyused will be described.

1

0) List ofoptions used in thepatticularmodel run will beprovided.
11) Concentration tables for the "rolling" quarterly averagingperiod will berep01ted.
12) List ofoptions used inthepatticularmodel run will beprovided.

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_Consulting\0I_ Air\Pb Modeling\Protocol\Modeling Protocol_Rev !.doc13) All modeling results will be submitted electronically and include all model input and output files from the AERMOD, AERMAP, AERMET programs and input/output files from utilitypreprocessors such as AERSURFACE, BPIP and LEADPOST.

Sanders Lead request that these modeling procedures be approved so modeling can begin. Sander Lead looks forward to working with the ADEM on this impottant modeling study. Please contact Mr. Steve Lund at (919) 461-1361 (steve_lund@URSCorp.com) on any technical modeling issues or Mr. Billy Nichols at (615) 224-2135 (Billy_ Nichols@URSCorp.com) with respect to facility operations and emissions.

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_Consulting\0l_Air\Pb Modeling\Protocol\Modeling Protocol_ Rev !.doc

# APPENDIX APLANT SITE Sander's Lead Company, Inc.

Drawn By Checked B Scale NTS Troy, Alabama

### ~ Franklin. Tannassao JMB Date: BRN Date: 6/20/11 6/20/11 Project No. 20499427

FIGURE:

1

### ~ Franklin, Tennessee JMB Date: 6/20/11 BRN Date: 6/20/11 Project No. 20499-4-27

FIGURE:

2

### Air Modeling Review Comments Sanders Lead SIP Modeling Protocol Dated July 28, 2011 Sanders Lead Company, Troy, Alabama Comments prepared by: Rick Gillam Air Quality Modeling and Transportation Section U.S. EPA Region 4 November 14, 2011
General Comment: Overall, the modeling procedures proposed in the Sanders Lead SIP Modeling Protocol are acceptable. The proposed use of EPA’s AERMOD Modeling System to demonstrate attainment of the 2008 lead National Ambient Air Quality Standards (NAAQS) is appropriate. However, EPA Region 4 has some recommendations on specific procedures for applying AERMOD (and associated pre and post processors) and other procedures for demonstrating attainment. The following “Specific Comments” contain these recommendations. Additional guidance is also provided in a presentation made by Mr. James Thurman at the 2011 Regional/State/Local Modelers Workshop. The presentation materials are available on EPA’s SCRAM website at: http://www.cleanairinfo.com/regionalstatelocalmodelingworkshop/archive/2011/Presentations/5- Wednesday_PM/5-1_Pb_Designations_Implementation.pdf

. Specific Comments:

1. Section 3.0, Episode Selection, Page 3: The proposed procedures of modeling specific “episodes” (as is done for ozone and PM2.5 attainment modeling) is not recommended for lead attainment modeling demonstrations. EPA recommends that the lead attainment modeling procedures follow more closely those for sulfur dioxide attainment demonstrations. These procedures are similar to National Ambient Air Quality Standard (NAAQS) compliance modeling that is done for New Source Review (NSR)/Prevention of Significant Deterioration (PSD) permitting. The following provides a brief summary of EPA’s recommended modeling procedures for demonstrating attainment with the lead NAAQS: Note that EPA recommends AERMOD be run with 5-years of representative National Weather Service meteorological data or at least 1-year of site-specific data, as is recommended for regulatory modeling applications in 40 CFR Part 51, Appendix W, Guideline on Air Quality Models(Appendix W). See the presentation materials referenced in the General Comment above for more details.

o Identify all significant lead emission sources inthe area that will be included in the cumulative impact modeling

### o Beginning with maximum allowable emissions or federally enforceable permit limits, apply control strategies to develop emissions inputs for modeling
o Conduct modeling with controlled emissions, 5-years of representative meteorology, representative background concentrations, and building downwash information to calculate design values for receptors based on cumulative concentrations (from all sources plus background). The design value should be calculated for the modeled period (e.g., the 5-years of NWS met data), not 3-year averages. o If no predicted exceedances, then the attainment demonstration is successful
o If exceedances are modeled, additional control strategies may need to be applied on sources and additional runs of the modeling may be necessary. Continue to apply additional controls until no exceedances are modeled.
2. Section 4.3 Receptors, Page 6: The protocol should indicate the extent of the 100-m spacing receptor grid. It is recommended that a map showing the proposed receptor grids be included in the protocol. Modeled exceedances from the cumulative impact modeling (including impacts from Sanders Lead sources, other significant s sources and background concentrations) as discussed in Comment #1 should be resolved to 100-m receptor grid spacing.
3. Section 4.4 Lead Emission Sourcesat the Facility, Page 6: The protocol should include additional information about how the emission rates for the modeling will be determined. As indicated in Comment #1, consistent with Section 8.1 of Appendix W, permitted “allowable” or “potential” emissions should be used for the modeling.
4. Section 4.5 Off-Site Emissions Inventory, Page 7:
Other sources of lead emissions in the vicinity of the Sanders Lead facility should be specifically identified in the protocol (both distance from the facility and magnitude of emissions). This information should be evaluated to decide whether additional significant lead emission sources should be modeled. If there is a question about whether a source is significant, screening modeling (e.g., AERSCREEN modeling) may be performed to evaluate the impact in the non-attainment area.
5. Section 4.6 Good Engineering PracticeStack Height Analysis, Page 7:
Please note that the latest version of AERMOD (v11103) includes a change which removed the comparison of stack height to the EPA formula height as a criterion for determining whether building downwash effects apply. This change means that the determination of whether building downwash effects apply is now based on the criterion implemented within the PRIME downwash algorithm. Therefore, depending on the sitespecific configuration of stacks and buildings, AERMOD may includedownwash effects for stacks at GEP height.

### 6. Section 4.7 Quarterly Lead Concentration Calculation Procedure, Page 8: A new version (v11237) of the LEADPOST post-processing tool has been posted on EPA’s SCRAM website (http://www.epa.gov/scram001/). This version should be used for the modeling demonstration.

7. Section 5.0 Modeling Performance Analysis, Page 8: Since the modeling attainment demonstration is being performed using EPA’s “preferred model,” AERMOD, a detailed “Model Performance Analysis” as described in this section of the protocol is not required. WhenEPA decided to promulgate AERMOD as a preferred modeling technique, rigorous model performance and evaluation testing was conducted. The documentation of the model performance testing is available on EPA’s SCRAM website: http://www.epa.gov/ttn/scram/dispersion_prefrec.htm#aermod

.