1 MEMORANDUM

To: Docket No.: EPA

- HQ

- OAR

- 2011

- 0344

From: Nathan Topham , Project Lead Risk and Technology Review

– National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Secondary Lead Smelting

Date: December 16 , 2011

Subject: Summary of Compliance Time for the Revised NESHAP for the Secondary Lead Smelting Source Category

The purpose of this memorandum is to present the results of an analysis to estimate the time required for the 16 secondary lead smelting facilities operating or un der construction in the
U.S. and Puerto Rico to comply with the final revisions to the S econdary L ead S melting
NESHAP. The facilities identified that will be required to comply with the revised NESHAP are
summarized in the table below.

Secondary Lead Smelters in the U.S. and Puerto Rico

FACILITY NAME PARENT COMPANY CITY STATE Facility
Abbreviation
East Penn Manufacturing Co., Inc. East Penn Manufacturing Co., Inc. Lyon Station Pennsylvania East Penn

EnviroFocus Technologies, LLC Gopher Resources, LLC Tampa Florida EnviroFocus

Gopher Resources, LLC Gopher Resources, LLC Eagan Minnesota Gopher Eagan Quemetco, Inc., City of Industry, Ca Eco

- Bat Technologies, LTD (Quemetco West, LLC) City of Industry California Quemetco CA

Quemetco, Inc., Indianapolis, In Eco

- Bat Technologies, LTD (Eco

- Bat Indiana, LLC) Indianapolis Indiana Quemetco IN

Revere Smelting and Refining Corporation (RSR) Eco

- Bat Technologies, LTD (Eco

- Bat New York, LLC) Middletown New York RSR

Sanders Lead Company Sanders Lead Company Troy Alabama Sanders Lead

Exide Technologies,

Baton Rouge, La Exide Technologies, Inc. Baton Rouge Louisiana Exide Baton Rouge Exide Technologies,

Cannon Hollow Recycling Facility Exide Technologies, Inc. Forest City Missouri Exide Forest City

Exide Technologies, Frisco, Tx Exide Technologies, Inc. Frisco Texas Exide Frisco2 Secondary Lead Smelters in the U.S. and Puerto Rico

FACILITY NAME PARENT COMPANY CITY STATE Facility
Abbreviation Exide Technologies, Muncie, In Exide Technologies, Inc. Muncie Indiana Exide Muncie

Exide Technologies

–

Reading Recycling Exide Technologies, Inc. Reading Pennsylvania Exide Reading

Exide Technologies, Vernon, Ca Exide Technologies, Inc. Vernon California Exide Vernon

Buick Resource Recycling Facility, LLC The Doe Run Resources Corporation Boss Missouri Buick RRF

The Battery Recycling Company The Battery Recycling Company Arecibo Puerto Rico TBR

Johnson Controls Battery Group, Inc. Johnson Controls
International Florence South Carolina JCI

1.0 SUMMARY OF FINAL REVISIONS As part of the Risk and Technology Review (RTR) for the Secondary Lead Smelting
source category, the EPA is finalizing revisions to the stack and fugitive emissions standards in
the NESHAP

. For stack emissions, the EPA is lower ing the current lead

- based concentration limit of 2.0 milligrams per dry standard cubic meter ( mg/dscm ) applicable to all stacks in the s ource category to 1.0 mg/dscm. Additionally, the EPA is add ing a facility

- wide flow

- weighted average lead

conce ntration li mit of 0.2 mg/dscm. For fugitive emissions, the EPA is requiring that facilities operate all lead

- bearing processes within total enclosures that are maintained at negative pressure and a re vented to a
control device. The EPA is also requiring additional work practices to control fugitive emissions beyond those required in the existing NESHAP

. The EPA is finalizing these revisions under Sections 112(d)(6) and 112(f)(2) of the Clean Air Act (CAA). As outlined in the Act, existing sources must comply with an y standards promulgated under 11 2(f)(2) within 90 days of promulgation. However, the Administrator may grant a waiver allowing up to a two year compliance period if the Administrator finds that “ such period is necessary for the installation of controls and that steps will be taken during the period of the waiver to assure that the health of persons will be protected from imminent endangerment” (CAA Section 112(f)(4)(A)

- (B)). In this memorandum, we estimate the time that will be required for existing facilit ies in this source category to comply with the final revisions to the Secondary Lead Smelting NESHAP

. The results of our analyses are presented in the following
sections.3 2.0 STACK EMISSION STANDARDS

As described in the Cost Impacts of the revised NESHAP for the Secondary Lead Smelting Source Category document available in the docket , we estimate that five facilities will not be in initial compliance with the flow weighted average stack emission s limit of 0.2 mg/dscm. However, we expect that t hree of these facilities will come in to compliance with the flow weighted average limit after installation of the total enclosures and associated control
devices that are required under the revisions to the fugitive emissions standards described in
section 1.0

. We furt her estimate that 6 facilities will need to reduce their stack emissions in order to ensure compliance with the concentration limit of 1.0 mg/dscm applicable to all stacks (see Cost Impacts of the Revised NESHAP for the Secondary Lead Smelting Source Category for

mor e details)

. Based on the analyses described above, w e estimate that 4 facilities will need to replace existing baghouses at 7 stacks (see Cost Impacts of the revised NESHAP for the Secondary Lead Smelting Source Category for mor e details). An additional 3 control devices will require additional maintenance or rep lacement of bags in baghouses. We estimate that a replacement
control device will require 21 to 24 m onths to be fully operational. This includes 2

- 4 months for
evaluation of existing control devices and development of an engineering plan to meet the revised emissions limits, 2

- 4 months for engineering of replacement control device(s), 2

- 3 months for capital approval, 5

- 7 months for delivery of the control device, 2

- 4 months for
construction and installation, and 2

- 3 months of operation until stack testi ng is conducted. The se facilities will also likely have several other ongoing projects to comply with the revisions to the fugitive emissions standards.

3 .0 FUGITIVE EM ISSION STANDARDS

Based on the revisions to the fugitive emissions standards described in section 1.0 , we estimate that 11 of the 15 operating secondary lead smelting facilities will be required to implement additional fugitive emissions control work

- practices (see Cost Impacts of the Revised
NESHAP for the Secondary Lead Smelting Source Category for more details)

. We also estimate
that 8 facilities will need to construct total enclosures for their lead

- bearing processes if they do

not currently e xist

. Based on information submitted by each facility in the ICR, compared with the requirements in the revised NESHAP, t able 3

- 1 presents a summary of the actions that we expect will be taken by the facilit ies to comply with the revis ed fugitive emissions standards. We estimate that construction of new enclosures for one or more of the specified fugitive
emissions sources will require 21 to 24 months. This includes an estimated 5

- 7 months for engineering analysis and design, 2

- 3 months for capital approval, and 12

- 16 months for construction of the enclosure, installing additional ventilation systems and duct work, and ensuring appropriate venting of gases to the control devices.4 Table 3

- 1. Summary of Required Actions for Compliance with the Revisi ons to the Fugitive Emissions Standards in the Secondary Lead Smelting NESHAP.

Number of Facilit ies that would need to do action Construct Total Enclosures Implement Additional Work Practices Develop an SOP, and submit the SOP for review and approval by the Administrator Furnace

Area Raw Materials

Storage

Area Refining and Casting

Area Battery Breaker

Area

Buick RRF      
East Penn  
EnviroFocus  
Exide Baton Rouge      

Exide Forest City      

Exide Frisco     
Exide Muncie   Exide Reading    
Exide Vernon  Gopher Eagan   Quemetco CA  Quemetco IN 
RSR 
Sanders      

TBR      
JCI   

Some facilities already have all of the specified fugitive emissions sources in total
enclosures and will only need to develop and implement additional work practice s to control fugitive emissions

. We estimate that development and implementation of the additional work practices will require a minimum of 6 months. W e believe that some facilities may need to hire additional employees to dedicate to the new work

- practices. Thus, an estimated 2

- 4 months may be required to hire and train new employees. Additionally, a ll faci lities will need to develop standard operating procedures (SOPs) and submit those draft SOPs t o the Admin is trator for review and approval (§63.545(a))

. They may potentially then need to revise those plans based on comments by the Administrator and resubmit the revised SOPs for further review and approval

. Finally , the facilities will need to implement those work practices pursuant to the approved SOP.
We estimate that t his overall process c ould take 6

- 9 months

.

4.0 CONCLUSIONS Based on our analysis, at least half of the secondary lead smelting facilities affected by
the revisions to the existing NESHAP will need 21 to 24 months to complete the proj ects necessary for compliance. With regard to the steps that will be taken during the period to assure5 that the health of persons will be protected from imminent endangerment , we conclude that the public will be protected from imminent endangerment during these extra months because reductions resulting from the meas ures described in this document will be phased in over the next two years with implementation of work practices possible within 6

- 9 months

. Furthermore, facilities will continue to comply with the existing 1997 NESHAP and various State programs (including implementation of the primary and secondary NAAQS for lead) which likewise will progressively reduce emissions from this source category. Therefore, we believe that a two year compliance period is appropriate for all existing secondary lead smelting facilities.