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 under construction in the 

U.S. and Puerto Rico to comply with the final revisions to the Secondary Lead Smelting 

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 Frisco
2

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 lowering the current lead-based concentration limit of 2.0 

milligrams per dry standard cubic meter (mg/dscm) applicable to all stacks in the source category 

to 1.0 mg/dscm. Additionally, the EPA is adding a facility-wide flow-weighted average lead 

concentration limit 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 are 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 any standards 

promulgated under 112(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 facilities 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 emissions limit of 0.2 

mg/dscm. However, we expect that three of these facilities will come into 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 further 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 

more details).

Based on the analyses described above, we 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 more details). An additional 3 control devices will require 

additional maintenance or replacement of bags in baghouses. We estimate that a replacement 

control device will require 21 to 24 months 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 testing is conducted. These

facilities will also likely have several other ongoing projects to comply with the revisions to the

fugitive emissions standards.

3.0 FUGITIVE EMISSION 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 exist. Based on information submitted by each facility in the ICR, compared with 

the requirements in the revised NESHAP, table 3-1 presents a summary of the actions that we 

expect will be taken by the facilities to comply with the revised 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 Revisions to the Fugitive 

Emissions Standards in the Secondary Lead Smelting NESHAP.

Number of 

Facilities 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 practices to control 

fugitive emissions. We estimate that development and implementation of the additional work 

practices will require a minimum of 6 months. We 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, all facilities will need to develop 

standard operating procedures (SOPs) and submit those draft SOPs to the Administrator 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 this overall process could 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 projects 

necessary for compliance. With regard to the steps that will be taken during the period to assure 
5

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 measures 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.