APPENDIX B 

Sanders Modeling Protocol and Correspondence 
SANDER'S LEAD SIP MODELING PROTOCOL IN 

ACCORDANCE WITH ADEM PSD AIR QUALITY ANALYSIS 

AERMOD MODELING GUIDELINES (MAY 2008) 

July 28,2011 

Revision 1 January 20, 2012 

Sanders Lead Company 

Troy, Alabama 

1000 Corporate Centre Drive 

Suite 250 

Franklin, Tennessee 37067 

(615) 771-2480 

URS Project No. 20499427.00001 
1.0 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 of the 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 Source Review Workshop Manual will be followed when applicable. 

1.2 Problem Dermition 

On September 30, 2009, ADEM provided EPA input regarding the extent of potential 

nonattainment areas in Alabama for the new Lead National Ambient Air Quality 

Standards (NAAQS). The monitoring data indicated that a small portion of Pike County, 

Alabama did not meet the new lead NAAQS. 

As a result of the NAAQS violation of the 2008 lead standards, EPA designated the area 

0.8 miles surrounding Sanders Lead located in Troy, AL as "nonattainment" in the first 

round of designations. 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 of the 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 on data from 2008-2010. 

Sanders Lead developing mitigation measures for achieving compliance with the new 

lead NAAQS, and anticipate that with the implementation of these 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 (refer to Appendix A), Troy is located in southeastern Alabama, in Pike County. 

Troy is located 70 kilometers southeast of Montgomery, Alabama. Figure I displays the 

plant site on a 7.5 minute USGS map along with a depiction of current company owned 

plant boundaries. The city population of Troy is approximately 13,935. According to the 

United States Census Bureau, the city has a total area of26.3 square miles (68.2 km2), of 

which, 26.2 square miles of it is land and 0.1 square miles of it (0.36%) is water. 

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2.1 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 Gulf of Mexico 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 of the Troy area. In late August and in September, summer 

conditions of temperature and humidity persist as air continues to drift in from the Gulf, 

but local thunderstorms become less frequent because of the shortening of the 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 of rain, 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, terrain has gentle undulations. 

The approximate UTM coordinates of the 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 recognized by EPA, the facility is located in a 

rural section of the state. EPA guidance shows two alternative procedures to determine 

whether the character of an area is predominately urban or rural: (1) land use typing or 

(2) population density. The area classification system as described by Auer in the Journal 

of Applied Meteorology, Vol. 17, pg. 636-643, 1978, Correlation of Land Use and Cover 

with Meteorological Anomalies, is frequently used to classify the area. URS used the 

new EPA AERSURF ACE program to also confitm what the USGS maps indicated. That 

is the area surrounding the facility is largely rural in nature with greater than 50 percent 

of the area made up of trees and vegetation. For the 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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3.0 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 of choice for 

this particular modeling exercise; such features include the capability to model point, area 

and volume sources; inclusion of building down wash of effluent; and most importantly, 

AERMOD was recently identified as the "preferred" model in the U.S. EPA Guideline on 

Air Quality Models. 

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 conducting refined 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 

be used include the following: 

• Calculation of average concentrations for each applicable averaging period; 

• Non-Urban dispersion conditions; 

• Regulatory default options; 

• Final plume rise; 

• Stack-tip downwash; 

• Buoyancy-induced dispersion; 

• Calms processing routine; 

• Default wind profile exponents; 

• Default vertical potential temperature gradients; 

• "Upper Bound" values for supersquat buildings; 

• No exponential decay; and 

• Terrain included. 

4.2 Meteorological Data 

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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to 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 of the atmosphere. As such, the determination of representativeness should 

include comparison of the surface characteristics, Bowen ratio and albedo, between the 

NWS measurement site and the 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 AERSURF ACE 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 AERSURF ACE 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 of maximum impact, URS will provide the air dispersion results for 

both surface characteristics (Montgomery airport and Sanders Lead site). 

4.2.2 AERSURFACE Landuse Analysis for AERMET 

One of the more important inputs to an air quality 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 of useful 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 if shown to be reasonably representative of conditions 

at the modeling site. This test of representativeness 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 of representativeness was originally intended in the Guideline on Air Quality Models 

to include both a spatial and temporal component together with 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 appropriate for a specific application. " The meteorological 

monitoring guidance continues to say that " .. for use in air quality modeling applications, 

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meteorological data should be representative of conditions affecting the transport and 

dispersion of pollutants in the area of interest as determined by the locations of the 

sources and receptors being modeled. " Establishing representativeness balances the 

requirements of the modeling assessment with the reasonableness of meteorological 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. 

4.2.3 AERSURFACE Landuse Analysis 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 

AERSURF ACE 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 of vegetation 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 

a population density greater than 750 people per square kilometer determines whether the 

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 included tenain heights generated from the AERMAP. 

AERMAP has been revised (beginning with version 9.84) to support processing of terrain 

elevations from the National Elevation Dataset (NED) developed by the U.S. Geological 

Survey (USGS, 2002) (http://scamless.usgs.gov/website/seamless/viewer.htm). An important 

component of the 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 of the 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 in the modeling rep01t when submitted. 

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TABLE 1 - Source of Emissions 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 Slag Treatment Building 

Roadway I Volume Material from breaker to main building (Bld.2) 

Roadway2 Volume Material to Slag Treatment building 

Roadway3 Volume Raw material (coke, limestone, scrap iron) to main building (Bld.2) 

Roadway4 Volume Delivery of raw coke, limestone and scrap iron 

RouteS Volume Delive1y of batteries 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 be modeled unless the ADEM specifically identifies an off-site 

source in response to this modeling protocol. 

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: 

Using EPA's Air Quality System's (AQS) database, speciated PM2.5 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 data for this monitor 

was collected every 6'" day throughout the year. This data was then used to calculate 

monthly averages for the entire period. These monthly averages were then used to 

create 3-month rolling averages and from that the maximum 3-month rolling average 

for the entire period of data was determined and set as the background for lead. 

Based on results from the speciated PM2.5 data, ADEM has determined that 0.009 ug/m3 

provides a representative background concentration of lead for the area. 

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4.7 Good Engineering Practice Stack Height Analysis 

For point sources located at the facility, a good engineering practice (GEP) stack height 

evaluation was conducted to determine if building 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 of 65 meters or GEP = Hb + 1.5L (where Hb is the building height, 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 of Good 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 stack height 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 of five times L (the lesser of the maximum projected width 

or height of the building) directly downwind from the leeward side of the building. Wake 

effects were assumed to occur if the emission source was located within a rectangle 

composed of two lines perpendicular to the wind direction, one at 5L downwind of the 

building and the other at 2L upwind of the 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 of influence changes and is combined to 

form a GEP 5L region of influence in all wind directions. Any emission source within 

the region of influence 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 of the 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 of influence, 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 of the building causing the maximum GEP height. The prime 

equations reduce plume rise due to initial plume dilution, enhance plume spread. 

The GEP analysis was conducted using the Building Profile Input Program -Prime 

(BPIPPRIME) program to demonstrate compliance with stack height regulations ( 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 FORTRAN program designed to read monthly 

concentrations output from AERMOD and calculate the maximum rolling 3-month 

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average 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 of control technology that 

is reasonably available considering technological 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 technology to apply: 

1. The process, operating procedures, and raw materials used by the source can 

affect the feasibility of carrying out process changes that reduce emissions and the 

selection of add-on emission control equipment. 

2. The operation of and longevity of control equipment can be significantly 

influenced by the raw materials used and the process to which it is applied. 

3. The feasibility of modifying processes or applying control equipment is also 

influenced by the physical layout of a particular plant. 

4. The space available in which to cany out such changes may limit the choices of 

control. 

5. Determinations of technological feasibility also consider adverse impacts on other 

resources. If a control technology increases pollution of bodies of water, creates 

additional solid waste disposal, or exacerbates worker exposure problems; the 

technology may not be considered reasonably 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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Description of Measure 

Enclose Baghouse Hoppers and 

Transport of Dust 

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 

Outdoor Traffic 

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 be provided by ducting to existing baghouses. 

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 by the new hoods and building enclosure. 

Sanders Lead is proposing to enclose the refining building, 

including the elimination of sidewall fans. As part of enclosing the 

refining building, fast acting rollup doors will be installed. Area 

ventilation will be provided by negative on building provided by 

the additional baghouse 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 raw mate1ial storage building. 

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 runoff from the shredder group pile. 

Sanders Lead is proposing the install transfer points 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 

watering plan will include an improved 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 of the CAA, a set of contingency measures has been prepared 

that could be implemented if required by a finding of the 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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deadline, or c) monitoring shows that the nonattainment area has failed to attain the 

NAAQS by the statutory deadline. 

7.0 SUBMITTAL INFORMATION 

The Air Quality Impact analysis will include the following information as recommended 

by the 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 be used to facilitate data input and process output. 

2) Description of the meteorological input data used, with an explanation of any 

modification(s) will be provided. 

3) A detailed analysis to demonstrate that the surface characteristics in the vicinity of the 

meteorological collection site (furnished by ADEM) are representative of the surface 

characteristics in the vicinity of the facility. This information has be previously submitted 

and approved in a separate Landuse protocol. 

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 be used for comparison with and ambient air quality standards if needed. 

5) Tables identifying the maximum ambient levels (including receptor locations and year 

of meteorology) for quarterly averaging periods including the contribution of the facility 

to the maxima. 

6) Figures of isopleths that illustrate the aerial extent of ambient levels. Location of 

maximum predicted concentrations will be clearly noted for comparison to 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 easy orientation. 

7) Appropriate model output files substantiating points of concern, as described in the 

text, will be submitted. 

8) Source input parameters for all sources modeled will be reported. 

9) Identification of the meteorology used will be described. 

1 0) List of options used in the patticular model run will be provided. 

11) Concentration tables for the "rolling" quarterly averaging period will be rep01ted. 

12) List of options used in the patticular model run will be provided. 

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13) 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 utility preprocessors such as AERSURF ACE, BPIP and LEAD POST. 

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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APPENDIX A 
PLANT 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 in the 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 Sources at 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 Practice Stack 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 include downwash 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. When EPA 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 .