1

MEMORANDUM

To: Nathan Topham, U.S. Environmental Protection Agency, OAQPS

From: Donna Lazzari and Mike Burr, ERG 

Date: December 16, 2011

Subject: Cost Impacts of the Revised NESHAP for the Secondary Lead Smelting Source 

Category

The purpose of this memorandum is to describe the methodology used to estimate the 

costs, emissions reductions, and secondary impacts of the final revisions to the National 

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

source category. These impacts were calculated for existing units and new units projected to be 

operational by the year 2014, two years after the rule is expected to be promulgated and the 

anticipated year of implementation of the revised NESHAP. The results of the impacts analyses 

are presented for the most stringent regulatory options considered in addition to the regulatory

options that were ultimately chosen for promulgation. The development of the baseline 

emissions estimates and the maximum achievable control technology (MACT) floors for this 

source category are discussed in other memoranda1,2. The organization of this document is as 

follows:

1.0 Summary of Cost Estimates and Emissions Reductions for the Regulatory Options 

Chosen for Proposal 

2.0 Regulatory Options Considered for Proposal

3.0 Methodology for Estimating Control Costs

4.0 Methodology for Estimating Emissions Reductions

5.0 Testing and Monitoring Cost Impacts

6.0 Summary of Cost by Facility

A list of secondary lead smelters currently in operation or under construction in the 

United States and Puerto Rico that were considered in this analysis is presented in the table 

below.

 

1 ERG. Development of the RTR Emissions Dataset for the Secondary Lead Smelting Source Category, December 

16, 2011.

2 ERG. MACT Floor Analysis for the Secondary Lead Smelting Source Category, December 16, 2011.
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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

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 Battery Recycling

Johnson Controls 

Battery Group, Inc. 

Johnson Controls 

International Florence South Carolina JCI

1.0 SUMMARY OF COST ESTIMATES AND EMISSIONS REDUCTIONS FOR THE 

REGULATORY OPTIONS CHOSEN FOR PROPOSAL

Regulatory options were considered for control of emissions of metal hazardous air 

pollutants (HAP), organic HAP, and dioxins and furans (D/F) from stacks and metal HAP from 

fugitive sources. For all options, total hydrocarbons (THC) are considered a surrogate for organic 

HAP (other than dioxins and furans) and lead a surrogate for metal HAP. A brief description of 

the options selected for the revisions to the NESHAP and the associated costs and emissions 

reductions are summarized in Table 1-1. The most stringent options considered in this analysis 

are summarized in Table 1-2. A more detailed description of all the regulatory options 

considered for proposal and their associated cost and emissions reductions estimates are 

presented in section 2.0 of this memorandum.
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Table 1-1: Summary of the Estimated Costs and Emissions Reductions of Regulatory 

Options Selected for Final Rule

Option Description

COST IN $ MILLIONS (2009 DOLLARS)

Total HAP 

Emissions 

Reductions 

(tons per 

year)

Cost per 

ton HAP 

reduction 

($MM)

Capital 

Cost

Annualized 

Capital 

Cost

Annual 

Operation 

and 

Maintenance 

Cost

Total 

Annualized 

Cost

3S Stack lead 

concentration 

limit of 1.0 

mg/dscm any 

stack, and 0.2 

mg/dscm 

facility 

average

$11.5 $1.1 $1.7 $2.7 8.2 $0.33 

1D D/F 

Concentration 

based limit

$0 $0 $0.26 $0.26 30 $0.01

3F Fugitive 

enclosure + 

work practice

$38 $3.6 $5.8 $9.4 7.1 $1.3 

Test, 

Monitor, 

Report

Additional 

Testing, 

Monitoring

$0.10 $0.01 $0.79 $0.80 

Total $49.7 $4.7 $8.5 $13.2 45.0 $0.29

*Tons of total organic HAP (3 grams/yr D/F reduction)

Table 1-2: Summary of the Estimated Costs and Reductions for the Most Stringent Options

Considered

Option Description

COST IN $ MILLIONS (2009 DOLLARS)

Total HAP 

Emissions 

Reductions 

(tons per 

year)

Cost per 

ton HAP 

reduction 

($MM)

Capital 

Cost

Annualized 

Capital 

Cost

Annual 

Operation 

and 

Maintenance 

Cost

Total 

Annualized 

Cost

4S

Stack lead 

concentration 

<0.01 

mg/dscm 

(WESP)

$365 $34 $12 $46 19.5 $2.37

2D

Beyond the 

floor D/F 

limits for 

blast 

furnaces

$5.9 $0.6 $2.4 $2.9 303 $0.01

1F and 2F

Enclosures, 

work 

practices, 

$38 $3.6 $6.2 $9.8 7.1 $1.37
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Option Description

COST IN $ MILLIONS (2009 DOLLARS)

Total HAP 

Emissions 

Reductions 

(tons per 

year)

Cost per 

ton HAP 

reduction 

($MM)

Capital 

Cost

Annualized 

Capital 

Cost

Annual 

Operation 

and 

Maintenance 

Cost

Total 

Annualized 

Cost

monitoring

Test, 

monitor, 

report

Additional 

testing and 

monitoring

$0.10 $0.0 $0.8 $0.8

Total $409 $38.6 $21.1 $18.8 330 $0.06

2.0 REGULATORY OPTIONS CONSIDERED FOR PROMULGATION

This section provides a detailed description of all regulatory options that were considered 

for the revisions to the Secondary Lead Smelting NESHAP and their associated costs and 

secondary impacts.

2.1 Stack Emissions – Metal HAP

The four regulatory options considered for control of metal HAP emissions from stacks 

are presented in the following sections.

a. Option 1S

Regulatory option 1S represents a scenario of reducing the existing lead emissions 

concentration limit from 2.0 milligrams per dry standard cubic meter (mg/dscm) to 0.5 mg/dscm.

In order to estimate costs and emission reductions for this option, we assumed that individual 

stacks with concentrations more than half the standard of 0.5 mg/dscm would replace baghouses 

or improve the maintenance and change the filtration media. Based on emissions data received in 

an information collection request (ICR) sent to the industry, twenty emissions points at six 

facilities reported concentrations above 0.25 mg/dscm; estimates of cost and emissions 

reductions were made for 15 of these stacks. Three facilities are currently undergoing an upgrade 

to their emissions control equipment with plans to replace existing baghouses or add additional 

filtration capacity, and thus, we assumed this would reduce the lead concentration at these five 

stacks below 0.25 mg/dscm. For 12 of the stacks reporting concentrations above 0.25 mg/dscm, 

we assumed that a replacement baghouse would be installed. For three stacks that were near the 

evaluated limit of 0.25 mg/dscm we assumed that lead concentrations below 0.25 mg/dscm could 

be achieved through replacement bags and performance of additional maintenance on the unit.

The total estimated capital cost for the 12 new baghouses that would likely be necessary to 

achieve concentrations below 0.25 mg/dscm is $14.8 million, resulting in an annualized capital 

cost of $1.4 million. Additional annual operational and maintenance costs, including more 

frequent bag changes for the 15 baghouses, are estimated at $2.0 million above the costs of 

operating the current air pollution control devices. The total estimated annualized cost above 
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current cost for the 15 baghouses is $3.4 million (2009 dollars). The estimated emissions 

reductions of Option 1S are 7.1 tons per year of lead and 9.0 tons per year of total metal HAP. 

b. Option 2S

Option 2S considers a production-based lead emissions limit. A limit of 0.009 pounds of 

lead emissions per ton of lead production (lbs/ton Pb) was calculated as a facility-wide emissions 

limit using a methodology similar to a MACT floor analysis. We estimate that new or improved 

baghouses would likely be necessary at 18 emissions points at six facilities to meet the limit 

considered in this option. For facilities that were estimated to be above the limit considered in 

this option, we sequentially selected stacks for a baghouse replacement or upgrade (based on 

reported concentration) until the facility was estimated to have emissions below 0.009 lbs/ton Pb. 

Two of the stacks selected had relatively newer baghouses, and thus, we estimated the cost of 

changing all the existing bags to a new upgraded filter media and performing additional 

maintenance for these units. One selected stack had a baghouse that was less than 10 years old; 

we estimated 25 percent of the cost of a new unit to represent additional filtration media or 

substantial upgrade to this unit. For the remainder of the selected stacks, we assumed 

replacement baghouses would be needed. The total estimated capital cost for this regulatory

option is $21.5 million, resulting in an annualized capital cost of $2.0 million. Additional annual 

operational and maintenance costs, including more frequent bag changes for the baghouses, are 

estimated at $2.5 million above current costs. The total annualized cost above current air 

pollution control device operating costs for the 18 baghouses is $4.5 million (2009 dollars). Total 

anticipated emissions reductions of lead and other metal HAP in this option are estimated at 9.6 

tons per year.

c. Option 3S

Option 3S is the regulatory option that was selected by the EPA for promulgation in the 

Secondary Lead Smelting NESHAP. This option represents an overall facility-wide flowweighted average lead concentration limit of 0.2 mg/dscm and a limit of 1.0 mg/dscm for any 

individual stack. In order to estimate costs and emission reductions for this option, we assumed 

that individual stacks with concentrations more than half the standard of 1.0 mg/dscm would 

replace baghouses or improve the maintenance and change the filtration media. We then 

reviewed the facility-wide flow-weighted average concentration from all the stacks after these 

improvements to determine if additional reductions were necessary. We determined that all the 

secondary lead facilities would be in compliance with the flow-weighted average after the 

upgrades described. In order to estimate costs and emission reductions for this option, we 

assumed that individual stacks with concentrations more than half the standard of 1.0 mg/dscm 

would replace baghouses or improve the maintenance and change the filtration media. Eleven 

emissions points at six facilities reported concentrations above 0.5 mg/dscm; estimates of cost 
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and emissions reductions were made for ten of these stacks. A baghouse at one facility is 

currently undergoing an upgrade, and we assumed this would reduce the lead concentration 

below 0.5 mg/dscm. Three stacks had outlet concentrations near the evaluated limit, and we 

assumed an outlet concentration of less than 0.5 mg/dscm could be achieved through 

replacement bags and performance of additional maintenance on the unit. The total estimated 

capital cost for this regulatory option is $11.5 million, resulting in an annualized capital cost of 

$1.1 million. Additional annual operational and maintenance costs, including more frequent bag 

changes for the baghouses, are estimated at $1.7 million above current costs. The total 

annualized cost above current air pollution control device operating costs for the 11 baghouses is 

$2.7 million (2009 dollars). Total anticipated emissions reductions of lead and other metal HAP 

in this option are estimated at 8.2 tons per year.

d. Option 4S

Option 4S is a regulatory option that considers requiring installation of a wet electrostatic 

precipitator (WESP) or equivalent technology at each facility to control stack emissions of metal 

HAP. One facility in this source category currently utilizes a WESP to control metal HAP 

emissions from stacks (i.e., Quemetco CA). Based on emissions data received in the ICR, this 

facility is the lowest emitting facility in terms of stack emissions of metal HAP. In this option, 

the other 15 facilities in the source category would be required to install technology with 

equivalent performance to a WESP. Based on the configuration of the existing WESP reported in 

the ICR, we assumed that facilities that would need to install a WESP under this option would 

use the WESP to control metal HAP emissions from process and process fugitive emissions 

sources only. Additionally, we assumed that the process fugitive vents would be optimized to 

minimize the airflow from these sources. We also assumed that baghouses installed on building 

vents would not be routed to the WESP. The total estimated capital cost for installation of a 

WESP at 15 facilities is $365 million, resulting in an annualized capital cost of $34 million. 

Operating costs were estimated at $12 million. The total annualized cost above current cost is 

estimated at $46 million. Lead emissions reductions for this option are estimated at 15.4 tons per 

year with total estimated metal HAP emissions reductions of 19.5 tons per year. The cost of 

installation and projected emissions reductions from a facility currently under construction were 

included in this estimate. 

e. Option 5S

Option 5S is a regulatory option that was considered after proposal of the revised 

secondary lead NESHAP. This option was considered based on comments received that the 

emission controls proposed would not require a significant amount of emissions reduction, and 

the limits proposed did not represent advances in control technology. 
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Regulatory option 5S represents a scenario of reducing the existing lead emissions 

concentration limit from 2.0 milligrams per dry standard cubic meter (mg/dscm) to 0.2 mg/dscm

for all stacks. Based on emissions data received in an information collection request ( ICR) sent 

to the industry, 80 percent of the stacks in this source category reported concentrations below 0.2

mg/dscm. In order to estimate costs and emission reductions for this option, we assumed that 

individual stacks with concentrations more than half the standard of 0.2 mg/dscm would replace 

baghouses or improve the maintenance and change the filtration media. There are 30 emissions 

points at six facilities that reported concentrations above 0.1 mg/dscm; estimates of cost and 

emissions reductions were made for 29 of these stacks. One facility is currently undergoing an 

upgrade with plans to replace an existing baghouse, and thus, we assumed this action would 

reduce the lead concentration in three stacks at this facility to below 0.1 mg/dscm. 

For 29 of the stacks reporting concentrations above 0.1 mg/dscm, we assumed that a 

replacement baghouse with an additional HEPA filter would be installed. The total estimated 

capital cost that would likely be necessary to achieve concentrations below 0.1 mg/dscm is $36

million, resulting in an annualized capital cost of $3.1 million. Additional annual operational and 

maintenance costs, including more frequent bag changes for the baghouses, are estimated at $4.1

million above the costs of operating the current air pollution control devices. The total estimated 

annualized cost above current cost for the 29 baghouses is $7.5 million (2009 dollars). The 

estimated emissions reductions of Option 5S are 9.8 tons per year of lead and 12.4 tons per year 

of total metal HAP. 

f. Summary

A summary of the costs and emissions reductions associated with the five regulatory

options described above for stack emissions are summarized in Table 2-1.

Table 2-1: Estimated Costs and Emissions Reductions for the Regulatory Options 

Considered for Stack Emissions of Metal HAP.

Option Description

COST IN $ MILLIONS (2009 DOLLARS)

Total HAP 

Emissions 

Reductions 

(tons per 

year)

Cost per 

ton HAP 

reduction 

($MM)

Capital 

Cost

Annualized 

Capital 

Cost

Annual 

Operation 

and 

Maintenance 

Cost

Total 

Annualized 

Cost

1S

Concentration 

limit of 0.5 

mg/dscm

$14.2 $1.3 $2.0 $3.4 9.0 $0..38 

2S

0.009 lb Pb / 

Ton Pb 

produced $21.5 $2.0 $2.5 $4.5 9.6 $0.52

3S Concentration 

limit of 1.0 $11.5 $1.1 $1.7 $2.70 8.2 $0.33 
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Option Description

COST IN $ MILLIONS (2009 DOLLARS)

Total HAP 

Emissions 

Reductions 

(tons per 

year)

Cost per 

ton HAP 

reduction 

($MM)

Capital 

Cost

Annualized 

Capital 

Cost

Annual 

Operation 

and 

Maintenance 

Cost

Total 

Annualized 

Cost

mg/dscm any 

stack, and 0.2 

mg/dscm 

facility 

average

4S

Concentration 

limit <0.01 

mg/dscm 

WESP

$365 $34 $12 $46 19.5 $2.37

5S

Concentration 

limit of 0.2 

mg/dscm

$36 $3.4 $4.1 $7.5 12.4 0.0.60

2.2 Stack Emissions – Organic HAP and D/F

The two regulatory options considered for control of stack emissions of organic HAP and 

D/F are presented in the following sections.

a. Option 1D

Option 1D is the regulatory option that EPA chose for the revised NESHAP for the 

Secondary Lead Smelting source category. This option represents calculating a MACT floor for 

D/F emissions from various furnace groupings that were formed based on similar operating 

characteristics. In addition to the D/F MACT floors, new MACT floors for THC were calculated 

for furnace types that are not regulated in the existing NESHAP. These include reverberatory

furnaces not collocated with blast furnaces, and electric arc furnaces. Sufficient data was not 

available to calculate MACT floors for the rotary furnace category. The THC MACT limits for 

blast furnaces and collocated blast and reverberatory furnaces in the existing NESHAP would 

remain unchanged under the proposed revisions. We do not anticipate that this regulatory option 

will require installation of additional controls at any facilities. We do anticipate, however, that 

four facilities operating blast furnaces will likely increase the temperature of their afterburners to 

ensure continuous compliance with the new MACT floors for D/F. The cost of the natural gas 

required to raise the temperature 100 degrees Fahrenheit (°F) at afterburners was estimated at 

$260,000 per year (2009 dollars). Under this regulatory option, we estimate D/F emissions 

reductions of about 2.9 grams per year and organic HAP emissions reductions of about 30 tons 

per year.

b. Option 2D
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Option 2D represents a beyond-the-floor option for D/F emissions from blast furnaces 

that are not collocated with reverberatory furnaces. This option was considered because based on 

emissions data submitted in the ICR, blast furnaces that are not collocated with reverberatory

furnaces contribute approximately 78 percent of the total D/F emissions from the source 

category. In this option, a Toxic Equivalency Quotient (TEQ) based concentration limit of 17 

nanograms per dry standard cubic meter (ng/dscm) (corrected to 7 percent oxygen (O2)) was 

considered for blast furnaces. This concentration represents an approximate 90 percent reduction 

in total D/F emissions from blast furnaces in this source category. 

For this option, we assumed that additional afterburner capacity would be needed at five 

blast furnaces. Two of the blast furnaces have afterburners currently installed that meet the 

requirements of this considered regulatory option. The total estimated capital cost for installation 

of the additional afterburners is $5.9 million, which results in an estimated annualized capital 

cost of $0.56 million. Annual operational and maintenance costs increases, including additional 

natural gas fuel, are estimated at $2.4 million above current control device operating costs. The 

total annualized cost above current cost for the afterburners is estimated to be $2.9 million (2009 

dollars). Under this scenario, we anticipate D/F emissions reductions of 31 grams per year, with 

a co-reduction of 200 tons per year of all other organic HAP. We also estimate that this option 

would result in a significant increase in fuel use along with increased emissions of carbon 

dioxide (CO2) and oxides of nitrogen (NOx) associated with operation of the additional 

afterburners.

c. Summary

A summary of the costs and emissions reductions associated with the two regulatory

described above for D/F and organic HAP emissions are summarized in Table 1-4.

Table 2-2: Cost Estimates and Emissions Reductions for Regulatory Options Considered 

for Stack Emissions of D/F and Organic HAP.

Option Description

COST IN $ MILLIONS (2009 DOLLARS)

Total HAP 

Emissions 

Reductions 

(tons per 

year)

Cost per 

ton HAP 

reduction 

($MM)

Capital 

Cost

Annualized 

Capital 

Cost

Annual 

Operation 

and 

Maintenance 

Cost

Total 

Annualized 

Cost

1D Concentration 

based MACT 

limit

$0 $0 $0.26 $0.26 30a$0.009

2D Beyond the 

floor for Blast 

furnaces $5.9 $0.56 $2.4 $2.9 200a

$0.01

a

based on total organic HAP
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2.3 Fugitive Emissions – Metal HAP

Three regulatory options were considered for control of fugitive metal HAP emissions. 

Because these emissions cannot be directly measured, a numerical emissions limit was not 

calculated. Instead, regulatory options were considered that prescribed specific controls or lead 

compliance monitoring at the property boundary as a means of demonstrating compliance. The 

three options considered are as follows:

1. Option 1F: This option requires facilities to conduct ambient lead monitoring at or near 

the property boundary to demonstrate compliance with the National Ambient Air Quality

Standard (NAAQS) for lead. 

2. Option 2F: This option requires facilities to keep all lead-bearing materials and processes 

enclosed in permanent total enclosures that are vented to a control device. Additional 

fugitive control work practices would also be required. Compliance with this regulatory

option would be demonstrated by ensuring full enclosure plus work practices and ambient 

lead monitoring at or near the property boundary. 

3. Option 3F: This is the regulatory option selected by EPA for the revised NESHAP for 

the Secondary Lead Smelting source category. This option is identical to option 2F with 

the exception that ambient lead monitoring at or near the boundaries of the facilities 

would not be required. Instead, compliance would be demonstrated through construction 

of total enclosures and operation according to a standard operating procedures (SOP) 

manual detailing how the required fugitive control work practices will be implemented.

In options 2F and 3F, facilities would be required to have all lead manufacturing 

processes within total enclosures under negative pressure with conveyance to a control device. 

Although option 1F requires only monitoring at the property boundary, and does not explicitly

require total enclosures, we assumed for cost purposes that facilities would need to operate all 

lead-bearing processes under negative pressure enclosures in order to comply with this option. 

Based on information submitted in the ICR, the facilities that are currently achieving ambient 

lead concentrations near the lead NAAQS at or near their property’s boundaries are facilities that 

already have their processes totally enclosed. Therefore, we assumed facilities that do not have 

all of their lead manufacturing processes in total enclosures will construct the appropriate 

enclosures and reconfigure their facilities to reduce their overall footprint as described in section 

3.3 of this memorandum.

Costs were estimated for enclosures and associated control devices at 7 facilities. One of 

these facilities is currently under construction (JCI), but an examination of the permit for the 

facility indicated that the battery breaking area enclosure was not vented to a control device; 

costs were estimated at the facility for this one process. One additional facility (Exide Frisco)

does not currently have enclosures for their secondary lead processes, but is under an agreed 

order with the state to install enclosures; this rule will not trigger additional costs. Another 

facility (EnviroFocus) is in the process of enclosing all of their process areas as a permit 
11

requirement for expansion. No costs for additional enclosures were estimated for these two 

facilities. 

The total estimated capital cost for the total enclosures, ventilation systems, and 

associated control devices is $38 million, which results in an annualized capital cost of $3.6

million. The total annual operation and maintenance cost, which includes building and baghouse 

maintenance, is estimated at $2.8 million above current cost. The total annualized cost of new 

enclosures and associated control devices for seven facilities is $6.4 million. Costs associated 

with the additional work practices are estimated at $250,000 per facility for 12 facilities at a total 

cost of $3 million. The total estimated annualized cost of reducing fugitive emissions for the 

primary regulatory option selected by the EPA (Option 3F) is $9.4 million (2009 dollars). For 

option 1F and 2F, the cost of operating two compliance monitors at or near the property 

boundary of each facility is estimated at $23,000 per facility for a total additional annualized cost 

of $347,000. We estimate reductions in fugitive emissions of 6.4 tons per year of lead and 7.2

tons per year of metal HAP. 

The estimated costs and emissions reductions associated with the regulatory options 

considered for fugitive emissions of metal HAP are summarized in Table 1-5.

Table 2-3: The Estimated Costs and Metal HAP Reductions for Fugitive Sources

Option Description

COST IN $ MILLIONS (2009 DOLLARS)

Total HAP 

Emissions 

Reductions 

(tons per 

year)

Cost per 

ton HAP 

reduction 

($MM)

Capital 

Cost

Annualized 

Capital 

Cost

Annual 

Operation 

and 

Maintenance 

Cost

Total 

Annualized 

Cost

1F and 2F Enclosure, 

work 

practice, 

monitoring

$38 $3.6 $6.2 $9.8 7.2 $1.37

3 F Enclosure, 

work 

practice

$38 $3.6 $5.8 $9.4 7.2 $1.32

3.0 METHODOLOGY FOR ESTIMATING CONTROL COSTS

The following sections present the methodologies used to estimate the costs associated 

with the regulatory options considered for the revised NESHAP for the Secondary Lead 

Smelting source category.

3.1 Stack Emissions – Metal HAP

The primary technologies used to control stack emissions of metal HAP in the Secondary

Lead Smelting source category are filtration devices such as baghouses or cartridge collectors, 

some of which have high performance particulate air (HEPA) filters as a secondary filtration 
12

device. One facility uses a wet electrostatic precipitator (WESP) downstream of a baghouse as a 

polishing step to further reduce metal HAP emissions. Data collected in the ICR indicate that 

baghouses that are properly designed, installed, maintained and operated can meet all of the 

metal HAP stack emissions limits considered in this analysis except those under option 4S 

(which included a WESP).

In order to estimate the capital cost associated with a particular option, we first 

determined which stacks would be required to reduce emissions. For the concentration-based 

limits, we assumed that the baghouses at any stacks reporting concentrations in the ICR above 

the considered emissions limit would need to be repaired, improved, or replaced. If the reported 

concentration was more than 10 percent over the considered limit, we assumed the baghouse 

would need to be replaced. If the reported concentration was within 10 percent of the considered 

limit or the unit in question was relatively new (installed after the year 2000), we assumed that 

replacement bags or additional baghouse maintenance could sufficiently reduce the 

concentration. For options that included a flow-weighted average concentration limit or a 

production based emissions limit, control devices were chosen for replacement or upgrade one at 

a time, beginning with the highest reported lead concentration, until the facility’s emissions were 

below the considered limit.

In the ICR, the EPA requested information on costs of emissions control devices that 

have been installed in the last five years. Several facilities submitted cost information that was 

used as a basis for estimating the cost associated with installation of a new baghouse. We 

compared estimates submitted by all of the facilities and chose the highest of the estimates as the 

cost model for baghouse installations. We compared estimates using this methodology to 

estimates derived using techniques described in the sixth edition of the EPA Air Pollution 

Control Cost Manual 

(http://www.epa.gov/oaqps001/lead/pdfs/2002_01_cost_control_%20manual.pdf). While the 

estimates derived using the EPA’s manual were higher, we believe using data submitted directly

by the industry is likely more representative of actual costs incurred by this source category.

Our cost model included installation of the baghouse and any necessary fans, ductwork, 

screw conveyors, and site work for each scenario, as appropriate. All costs are based on 2009 

dollars. We did not consider the associated downtime for the unit in our costs. We estimated 

capital costs on the basis of dollars per unit of air flow (i.e., cubic foot per minute) into the 

device and assumed linearity of cost within the range of air flows considered in our analysis. The 

total installed capital cost of a typical baghouse designed for a flow-rate of 80,000 actual cubic 

feet per minute (acfm) was estimated at $1.4 million. This cost assumes a 20 year life expectancy

for the unit and, to be consistent with OMB Guidance in Circular A-4, a seven percent cost of 

capital as an estimate of the annualized capital cost. The design flow-rate for a baghouse was 
13

taken from information submitted in the survey, or the flow rate during a performance test if this 

flow was higher than design. If design information was not available, the flow was assumed to be 

20 percent higher than the flow-rate measured during a compliance test. 

The major operating cost of a baghouse is associated with routine replacements of the 

filter media (bags). The number of compartments in the baghouse and the number of bags per 

compartment were estimated using either data submitted in the ICR for the particular unit or data 

submitted for a similar sized unit if the former data were not available. The estimated number of 

bags was used to calculate the ongoing maintenance cost of replacing bags. We assumed that 

facilities would be required to replace bags every two years for the devices that reported 

emissions above the considered limit. The cost of a replacement bag was estimated at $200 based 

on information submitted in the ICR. Other operating and maintenance costs were developed 

using information submitted in the ICR.

For the WESP option, we used information submitted by Quemetco, Inc. in the ICR as a 

basis for estimating cost. We assumed that the configuration of the new WESP installations 

would be similar to that of Quemetco CA. More specifically, we assumed that facilities would 

use the WESP to control process and process fugitive emissions sources, but not general building 

ventilation sources. Additionally, we assumed that facilities would optimize the flow from 

process fugitive ventilation devices in order to reduce the overall airflow to the WESP. We used 

the rapid estimation exponential method described in Perry’s Chemical Engineers’ Handbook3to 

derive an equation representing the expected flow-rate into the WESP at each facility. Our 

estimate of annualized costs primarily includes electricity to operate the WESP and capital 

recovery.

3.2 Stack Emissions – Organic HAP and D/F

The formation of D/F occurs in the smelting furnaces and is highly dependent on the 

operating temperature of the furnace. Very small amounts of D/F were detected in the emissions 

streams of reverberatory furnaces; higher amounts were detected in the emissions streams of 

blast furnaces that were not collocated with reverberatory furnaces. Emissions data submitted in 

the ICR indicate that D/F emissions from collocated blast and reverberatory furnaces are lower 

than those from blast furnaces not collocated with reverberatory furnaces, indicating that 

comingling the flue gas streams of a blast furnace with the hotter stream of the reverberatory

furnace is an effective D/F control option. Based on information submitted in the ICR, 

temperatures of the reverberatory stream are typically around 2200°F, likely high enough to raise 

the overall temperature of the combined blast and reverberatory furnace stream to that typically 

achieved by an afterburner. Studies of D/F destruction indicate that properly designed and 

 

3

Perry, Robert H & Green, Don W. (1984). Perry’s Chemical Engineers’ Handbook, (6th ed.). McGraw-Hill.
14

operated afterburners with a sufficient residence time can achieve high destruction efficiency4. 

The majority of the blast furnaces in this source category that are not collocated with 

reverberatory furnaces use afterburners as a means of controlling organic HAP emissions. 

However, based on information submitted in the ICR, the majority of these afterburners are not 

operated at temperatures necessary for efficient destruction of D/F. We estimated that an 

afterburner operating at 1600°F with a residence time of 2.5 seconds or longer would achieve a 

90 percent reduction in D/F emissions.

In order to estimate the capital cost of 90 percent control efficiency for D/F from blast 

furnaces, information contained in the ICR responses was used to determine the current furnace 

and afterburner temperature and residence time. We assumed that an existing afterburner would 

have the capability to increase the operating temperature 100°F without a major modification. 

Based on information submitted in the ICR, we determined that 5 of the 6 afterburners 

controlling blast furnaces (not collocated with reverberatory furnaces) in this source category

were not capable of achieving a temperature of 1600°F. Therefore, we estimated the capital and 

operating costs associated with installation of a new afterburner for these sources. Three facilities 

submitted cost data in the ICR for afterburner installations; the highest of the three estimates was 

chosen as the basis for our cost estimate. For the capital cost estimate, we assumed that the 

existing afterburner would remain in place and a new afterburner capable of increasing the 

temperature of the stream leaving the existing afterburner to a temperature of 1600°F would be 

installed. We used an equation modeled after equation 2.32 in the EPA Air Pollution Control 

Cost Manual to scale the size and cost of a thermal incinerator based on the reported flow-rates 

for each of the blast furnaces. The typical cost for an installed afterburner with a design flow-rate 

of 17,000 acfm was estimated at $1.2 million. 

The annual cost of operating an afterburner was estimated using the approach described 

in the EPA Air Pollution Control Cost Manual. The cost of additional fuel required to increase 

the operating temperature of the afterburners was estimated based on the estimated amount of 

required natural gas. Other operating and maintenance costs were estimated using an approach 

described in the EPA Air Pollution Control Cost Manual. The annual capital cost was estimated 

using a 20 year equipment life and a 7 percent interest rate.

3.3 Fugitive Emissions – Metal HAP

There are two general categories of fugitive emissions of metal HAP at a secondary lead 

smelting facility: process fugitive emissions and fugitive dust emissions from material handling 

operations and re-entrainment of deposited dust. Process fugitive emissions result from furnace 

 

4

Ficarella, Antonio and Laforgia, Domenico. Numerical simulation of flow-field and dioxins chemistry for 

incineration plants and experimental investigation, Waste Management 20 (2000) 27-49.
15

leaks and incomplete capture of emissions during tapping and charging of smelting furnaces. 

Charge materials contain fine lead-bearing particles that can be liberated during charging 

operations. Furnace upsets, particularly those caused by wet feed material, can result in 

overpressure of the smelting furnace. This may cause release of emissions that would normally

be contained by negative pressure occurring inside the smelting furnaces. Process fugitive 

emissions can also result from incomplete capture of emissions at battery breakers, dryers, and 

refining and casting operations. Fugitive dust emissions can be generated during material 

handling operations. Lead bearing materials are transported throughout the plant in areas that 

may be open to the atmosphere. During transport, the material can spill or leak from the transport 

vehicles and settle on the floors and yards of the facilities. Wind, vehicle traffic, and other forces 

can then re-entrain the deposited dust as fine airborne particles. Stack emissions containing lead 

and other metal HAP can also settle onto surfaces near the facility and can be subsequently reentrained as fine airborne particles.

The current MACT standard for control of fugitive emissions of metal HAP from 

secondary lead smelters requires process fugitive emissions sources to be captured by negative 

pressure enclosure hoods and vented to a control device. There is a minimum face velocity

requirement for the enclosure hoods that varies based on the emissions source. As an alternative 

to an enclosure hood requirement, the facility may operate the process fugitive emissions source 

in a building that is maintained at a lower than ambient pressure. The building ventilation air is 

required to be conveyed to a control device. Additional fugitive control work practice 

requirements in the current MACT standard include wetting of storage piles, cleaning of 

roadways, and washing of vehicles prior to leaving any areas where lead-bearing materials are 

handled. 

The EPA requested information in the ICR regarding the fugitive control techniques 

employed at each facility. Based on that information, we assessed the relative effectiveness of 

the controls implemented by each facility and estimated fugitive emissions at each facility based 

on that assessment (see Development of the RTR Emissions Dataset for the Secondary Lead 

Smelting Source Category for more details). The facilities achieving low ambient lead 

concentrations at nearby monitors were facilities that had total enclosures for their processes. 

Many implemented work practices that are more than that required by the 1997 NESHAP. We 

assumed that facilities that were not currently enclosed would install permanent total enclosures 

with ventilation to a control device and implement additional work practices to prevent the 

formation of fugitive dust in other areas of their facilities. For each facility, we estimated the area 

that is currently under a total enclosure ventilated to a control device. We then estimated the 

additional enclosure area necessary fully enclose the entire process. We assumed facilities that 
16

required a substantial area of new enclosures would re-configure their facility in a manner that 

reduces the overall footprint of the facility. 

Enclosure costs were estimated using the EPA Air Pollution Control Cost Manual. We 

used the 2008 version of the Air Compliance Advisor (ACA) program, a program developed by 

the EPA to facilitate the calculations required in the EPA Air Pollution Control Cost Manual, to 

estimate the cost of the building. The costs were then adjusted to 2009 dollars. The costs 

considered sheet metal walls, 30 feet high interior, automatic roll-up doors, louvers, make up air 

fans, ductwork, pressure monitors, and smoke detectors. We ran the ACA program for two 

model buildings. The average building capital cost based on these two runs was estimated at $40 

per square foot. This factor was used to the estimate the cost of the additional enclosure area 

required for all other facilities. 

The capital cost of the control devices required to control the enclosure ventilation air 

was estimated based on the flow-rate required to maintain the building under sufficient negative 

pressure. Based on information submitted in the ICR, we estimated a flow-rate that would result 

in an air turnover rate of five per hour in a building maintained under sufficient negative 

pressure. We estimated the cost of the baghouse using the methodology described in section 3.1 

of this memorandum.

Annualized costs for the enclosures and associated baghouses were based on a 20 year 

life expectancy and 7 percent cost of capital. Annual operating costs for the baghouse were 

estimated based on data obtained in the ICR. We chose this methodology because we believed it 

to be more representative of actual operation and maintenance costs for this situation. Additional 

operating and maintenance costs were estimated for the enclosures using guidelines supplied in 

the EPA Air Pollution Control Cost Manual. 

We calculated annual costs for required installation of two compliance monitors at the 

property boundary for each facility under regulatory options 1F and 2F. The monitoring costs 

were obtained from estimates made for similar monitors in the proposed revisions to the Primary

Lead Smelting NESHAP, published February 17, 2011 (76 FR 94106). 

We anticipate that the work practices specified in the existing Secondary Lead Smelting 

NESHAP will not be adequate to maintain fugitive emissions from this source category at an 

acceptable level. We estimated that an additional three employees per facility at an annualized 

cost of $250,000 will be needed to implement the following additional fugitive control work 

practices: maintenance of negative pressure monitors in enclosures, weekly cleaning of all areas 

where waste generated by housekeeping activities are stored or disposed of, immediate cleaning 

after accidental releases, inspections of enclosures once per month, twice per week inspection of 
17

battery storage area and immediate processing of cracked batteries, and thorough cleaning and 

inspection of any vehicles leaving the process area.

4.0 METHODOLOGY FOR ESTIMATING EMISSIONS REDUCTIONS

This section discusses the methodology used to estimate emissions reductions associated 

with the control options presented in sections 1.0 and 2.0 of this memorandum.

4.1 Stack Emissions – Metal HAP

a. Option 1S

For Option 1S, the outlet lead concentration reported for each stack in the ICR was 

compared to the limit considered in this regulatory option (i.e., 0.5 mg/dscm ). If the reported 

concentration was significantly above one half the limit, we assumed that the facility would need 

to install a new baghouse at that emissions point. For stacks that were less than twenty percent 

above the limit, we assumed that additional maintenance and change out of filtration media 

would reduce the concentration to half the current concentration. We assumed that the outlet lead 

concentration from the newly installed baghouse would be equivalent to the average of all outlet 

lead concentrations reported in the ICR; we calculated this average to be 0.159 mg/dscm. We 

estimated the expected reduction in emissions as the difference between current stack emissions 

and the emissions that would occur after maintenance or replacement of the baghouse. Equation 

1 is an example calculation assuming an outlet lead concentration of 0.159 mg/dscm (see 

Equation 1).

  = [( × ) − (0.159 × )] ×  ×  (Eq. 1)

Where: 

Ci = outlet lead concentration reported in the ICR (mg/dscm),

F = flow rate (dscm/hr),

0.159 = expected outlet lead concentration of new baghouse (mg/dscm),

H = annual hours of operation, and

T = conversion factor for milligrams to tons (1.1 x 10-9).

b. Option 2S 

For option 2S, the stack lead emissions reported by each facility in the ICR were summed 

and divided by the annual lead production (average of 2008 and 2009) reported in the ICR. A 

statistical equation that considered variability in emissions was used to calculate a production 

based emissions limit of 0.009 lb/ton Pb. Based on emissions data received in the ICR, six 

facilities’ emissions were above 0.009 lb/ton Pb. We assumed that these six facilities would 

sequentially replace or improve their existing baghouses one-by-one, starting with the units 
18

reporting the highest lead concentrations, until the facility’s emissions were below 0.009 lb/ton 

Pb. Similar to option 1S, we assumed that a new baghouse could achieve an outlet lead 

concentration of 0.159 mg/dscm. We estimated that a total of 18 emissions points at six facilities 

would require reductions in lead emissions in this option. Total emissions reductions were 

calculated using Equation 1. We assumed emissions of other metal HAP would be reduced 

proportionally to lead emissions.

c. Option 3S

For Option 3S, we considered a facility-wide flow-weighted average lead concentration 

limit of 0.2 mg/dscm as well as a maximum lead concentration limit of 1.0 mg/dscm applicable 

to any individual stack. We calculated emissions reductions associated with the maximum 

concentration limit of 1.0 mg/dscm using a modified form of Equation 1. If the reported 

concentration was significantly above 0.5 mg/dscm, we assumed that the facility would need to 

install a new baghouse at that emissions point. For stacks that were less than twenty percent 

above 0.5 mg/dscm, we assumed that additional maintenance and change out of filtration media 

would reduce the concentration to half the current concentration. We assumed that the outlet lead 

concentration from the newly installed baghouse would be equivalent to the average of all outlet 

lead concentrations reported in the ICR; we calculated this to be 0.159 mg/dscm. We estimated 

the expected reduction in emissions as the difference between current stack emissions and the 

emissions that would occur after maintenance or replacement of the baghouse using Equation 1. 

Based on this analysis, we estimated that seven stacks would need replacement baghouses, and 

three baghouses needed additional maintenance. 

Additionally, each facility’s flow-weighted average lead concentration was calculated 

based on emissions data submitted in the ICR. We then compared that value to facility-wide 

flow-weighted average limit of 0.2 mg/dscm considered in this option. We estimate that five 

facilities currently have a flow-weighted average lead concentration above the considered limit. 

We also considered the impacts of the proposed fugitive control standards presented in section 

2.3 of this memorandum on the flow-weighted average concentration of each facility. Because 

we assumed that each facility will be required to have all processes under total enclosures with 

negative pressure and ventilation to a control device, we assumed that facilities needing 

additional enclosures would install one additional corresponding hygiene baghouse. Based on the 

average outlet lead concentration reported in the ICR for similar sources, we assumed that the 

outlet lead concentration from these hygiene baghouses would be 0.044 mg/dscm; the average of 

all building ventilation stacks. We estimated that three of the five facilities initially identified as 

having emissions above the limit considered in this option would meet the considered limit after 

installation of the additional enclosures required in the fugitive control options. Furthermore, we 

estimate that replacing or performing maintenance on all baghouses reporting concentrations 
19

above 0.5 mg/dscm in combination with the installation of additional enclosures will result in all 

facilities being in compliance with the limits considered in this option. The total emissions 

reductions for this option were calculated using Equation 1. 

d. Option 4S

For option 4S, we estimated emissions reductions of lead and other metal HAP using 

information submitted by Quemetco, Inc. regarding the efficiency of the WESP at their 

California facility. Based on this information, we assumed that emissions of lead and other metal 

HAP from any source expected to be controlled by the WESP would be reduced by 99.98 

percent.

e. Option 5S

For Option 5S, the outlet lead concentration reported for each stack in the ICR was 

compared to the limit considered in this regulatory option (i.e., 0.2 mg/dscm ). If the reported 

concentration was above one half the limit, we assumed that the facility would need to install a 

new baghouse at that emissions point. We assumed that a unit with a HEPA filter would be 

installed in order to reduce the concentration to below 0.1 mg/dscm. The emission reduction was 

estimated as the difference between current stack emissions and an outlet concentration of 0.1 

mg/dscm..

4.2 Stack Emissions – Organic HAP and D/F

a. Option 1D

Option 1D considers MACT floor emissions limits for D/F (TEQ) based on furnace type. 

This option also includes setting MACT floor emissions limits for THC for furnace types that are

not regulated in the existing NESHAP (i.e., reverberatory furnaces not collocated with a blast 

furnace, rotary furnaces, and electric furnaces). Based on our MACT floor calculation (see 

MACT Floor Analysis for the Secondary Lead Smelting Source Category), we do not anticipate 

significant D/F or organic HAP emissions reductions associated with this option. However, we 

assume that facilities operating afterburners will likely increase the operating temperatures to 

ensure continuous compliance with the considered D/F limit. We believe reduction in D/F and 

other organic HAP on the order of 10 percent are possible using this assumption. 

b. Option 2D

Option 2D is a beyond-the-floor option for D/F that establishes a TEQ concentration limit 

of 17 ng/dscm for blast furnaces not collocated with a reverberatory furnace. Based on the study

referenced in section 3.2 of this memorandum, the D/F destruction efficiency of an afterburner 

operating at 1600°F with a residence time of 2.0 – 2.5 seconds is between 90 and 94 percent. For 
20

the purposes of calculating emissions reductions associated with this option, we assumed a 90 

percent destruction efficiency of D/F and organic HAP for newly installed afterburners in this 

source category.

4.3 Fugitive Emissions – Metal HAP

For all the fugitive emissions control options considered, we assumed that all facilities 

would need to reduce their fugitive emissions to a level that would reduce ambient lead 

concentrations near their property boundary to levels below the lead NAAQS. 

We derived factors to estimate the reductions in fugitive emissions that are likely to occur 

as a result of enclosing all manufacturing processes material handling operations. Reductions in 

fugitive emissions of 77 percent from baseline levels were estimated if new total enclosures were 

installed at a facility where only partial enclosures currently exist. Additional reductions of 80 

percent (total reductions of 95 percent) were estimated as a result of implementation of the 

additional work practices described in section 3.3 of this memorandum. This methodology is 

described in detail in the Development of the RTR Emissions Dataset for the Secondary Lead 

Smelting Source Category.

5.0 TESTING AND MONITORING COST IMPACTS

The existing NESHAP requires annual stack testing for lead and allows for reducing 

stack testing to every two years if the measured lead concentrations are below 1.0 mg/dscm. The 

regulatory options chosen for the final rule in the revised NESHAP allows these same provisions

for reduced testing if the emissions are half of the regulatory limit. The final rule also requires 

annual stack testing for THC, with a reduced testing frequency if emissions are half of the 

regulatory limit. Stack testing is required once every six years for D/F. The additional costs 

associated with the stack testing requirements above current costs are anticipated to be $383,000

per year (an average of $24,000 per facility).

The capital cost associated with additional differential pressure monitors for total 

enclosures is $97,000. 

The total estimated annualized cost for additional testing, monitoring, recordkeeping, and 

reporting considering the first three years after the proposed revisions are implemented is 

$790,000. A detailed burden estimate is available in the docket for this rulemaking (Supporting 

Statement, National Emission Standards for Secondary Lead Smelting). 
21

6.0 SUMMARY OF COST BY FACILITY

Table 6-1 is a summary of estimated costs for each of the facilities in the secondary lead 

smelting source category. 

Table 6-1 Summary Cost Estimates by Facility

Facility Total Capital Cost Total Annual Cost

Buick RRF 18,490,000 3,600,000

East Penn 0 300,000

EnviroFocus 0 300,000

Exide Baton Rouge 7,250,000 1,930,000

Exide Forest City 2,560,000 720,000

Exide Frisco 0 460,000

Exide Muncie 0 300,000

Exide Reading 7,020,000 1,460,000

Exide Vernon 0 50,000

Gopher Eagan 0 300,000

Quemetco CA 0 50,000

Quemetco IN 0 50,000

RSR 0 50,000

Sanders Lead 11,690,000 2,490,000

TBR 1,990,000 700,000

JCI 610,000 420,000

Total 50,230,000 13,180,000