Bryan W. Shaw, Ph.D., Chainnan Buddy Garcia, Commissioner Carlos Rubinstein, CommiSsioner 

## RECEIVED

Mark R. Vickery, P.G., Executive Director 

## II SEP I**~** 

## PH I :**~**

## 7 TEXAS COMMISSION ON ENVIRONMENTAL QuMfHNAL AffAIRS DIVISION 6RAJ

.. f.'t\', \.••....6EN

...........PrfJJ•Gting Texas byReducing andPreventing Pollution

### 6DRA.~~-l ....6WQ.

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### September 8, 2011 6PD.U

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### ••.••••••**C'c"-~1** 

### Alfredo Armendariz, Ph.D. Regional Administrator U.S. Environmental Protection Agency

- Region 6 1445 Ross Avenue Dallas, Texas 75202-2733 

### Dear Dr. Armendariz: 

### Docket No. 2011-oo6s-SIP Project No. 2011-005-SIP-NR

On August 17, 2011, 

### theTexas Commission on Environmental Quality (Commission) adopted a revision to the state implementation plan (SIP) for Lead Transport for the 2008 

### Lead National AmbientAir Quality Standard (NAAQS). The Commission adopted a SIP revision demonstrating thatTexas is not contributing significantly to nonattainment ofthe lead NAAQS for areas in other states; not interfering with the maintenance ofthe lead NAAQS in any other state; not interfering with measures required to meet an implementation plan for any other state related to prevention of significant deterioration (PSD); and not interfering with measures required to meet the implementation planfor any other state related to regional haze and visibility. Enclosed are the proposedrevision to the SIP, a public hearing certification, a complete record ofthe public hearing, andthe accompanying order. I lookforward to your expeditious approval ofthese SIP revisions. Sincerely,

# ~~~ 1rm 

### BWS/ab Enclosures

cc: The Honorable Rick Perry, Governor ofTexas Mr. Toby Baker, Office ofBudget, Planning and Policy, Office ofthe Governor Mr. Mark R 

### Vickery, P.G., Executive Director, Texas Commission on Environmental Quality P.O. Box 13087 Austin, Texas 78711-3087 512-239-1000 Internet address: www.tceq.state.tx.us

### TEXAS CoMMISSION ON ENVIRONMENTAL QuALITY

THE STATE OF TEXAS COUNIT OF TRAVIS Docket No. 2011-0065-SIP Project No. 2011-005-SIP-NR



### This is to certifythat the attached are true and correct copies ofdocuments for revisions to the Texas State Implementation Plan, adopted on August 17, 2011, 

### pursuant to 40 

### Code ofFederal Regulations § 

### 51.104. I am the records administrator for the Air Quality Division ofthe Texas Commission on Environmental Quality (Commission).

<

### O.,~u**~mer-;"Di** 

### ctor \)--Air Quality Division Texas Commission on Environmental QualityTexas Commission on Environmental Quality Public Hearing May 17, 2011 Concerning Revisions to the State Implementation Plan concerning Lead Transport for the 2008 Lead National Ambient Air Quality Standard Project No. 2011-005-SIP-NRINTRODUCTION

The Texas Commission on Environmental Quality (commission) held a public hearing in Austin

on May 17, 2011, to receive testimony regarding revisions to the state implementation plan.

The revision incorporates a plan to address lead transport for the 2008 lead National Ambient Air Quality Standard (NAAQS). The revision meets the requirements ofthe Federal Clean Air Act, §110 (a)(2)(D)(i), that relates to the interstate transport of lead under the 2008 NAAQS. The revision references existing control strategies to reduce the concentration of lead, as well as dispersion modeling of major lead sources in Texas. Additionally, the revision verifies that Prevention of Significant Deterioration and Nonattainment New Source Review permitting programs are being implemented in Texas and that lead is not considered a visibility-impairing pollutant.

The comment period closed on May 23, 2011. All testimony and comments have been reviewed and seriously considered. This hearing record contains a complete record of the public hearing and is divided into the following four sections:

o Public Notification and Proposal

o Written and Oral Testimony

o Evaluation of Testimony

o Staff Recommendations/Order

Additional copies of this hearing record are maintained in the TCEQ central office at 12100 Park 35 Circle, Austin, Texas 78753. For further information, please contact Shelley Naik at (512) 239-1536.

# PUBLIC NOTIFICATION AND PROPOSALPUBLIC NOTIFICATION

Notification to the public of the proposed revisions was conducted by the following procedures:

1. Publication of notice of public hearing in the following newspapers on the date listed: Austin Amencan-Statesman: April 15, 2011 Houston Chronicle: April 15, 2011 Ft. Worth Star- Telegram: April15, 2011

2. Publication ofthe Notice of Public Hearings in the April22, 2011, issue of the Texas Register (36 TexReg 2623).

3. Correspondence forwarding the notice of public hearings to the following officials and agencies: Speaker ofthe House Lieutenant Governor Alamo Area Council of Governments Capital Area Planning Council City of Dallas, Department of Environmental Quality City of Dallas, Department of Aviation City of El Paso, Environmental Services City of Fort Worth, Environmental Management Department City of Houston, Department of Health and Human Services East Texas Council of Governments El Paso Metropolitan Planning Organization Federal Highway Administration Galveston County Health District Harris County Public Health and Environmental ServicesNorth Central Texas Council of Governments Houston-Galveston Area Council South East Texas Regional Planning Commission Texas Department ofTransportation, Environmental Affairs Division Texas Department ofTransportation, Systems Planning Section Victoria Metropolitan Planning Organization Arkansas Department of Pollution Control and Ecology Louisiana Department of Environmental Quality New Mexico Environmental Department Oklahoma Department of Environmental Quality United States Environmental Protection AgencyExample of Newspaper Classified Ad Austin American-Statesman, April15, 2011

NO'IICEDPPUIUCHMRINGBY1

.. TEXAS'toMMISSION ON ENVIRONMIIII'AI.

QUAUrYON PROPOSED REVISIOIIS1D**~STAlE** IMPLEMINTAnOf-1 PLAit The Teas Commission on-Envlionmental Quality (J'CEQ) WID'conduct 1: publk hearing to receive comments concerning revisions to the state:-implemematlon.plarl (SIP). under ,the**~Uirements** ofTexas-Heatth**and~** Code, §382.012 and·§382.01-3; and40 Coda of**Feder~~**IRegulations §51,102 ofthe United States Envffonml!ntai Protet:tlan Agency regtilatlons concerning SIPs. The p10posed revision would Incorporate a pllnto. addresslnd·transport:furthe 2001 lead-National Ambient Air Quality Standarel (NAAQSJ. Thtproposal.would meet therequirements. ofthli'Federai Clean Air Act, §11 O{a){2)(D)(I}, relatingtothelnterstm transport oflead underthe 20081ead NAAQS. These revtslons**re~** 0dstin9 control Jll'iltegles to rei::luce tlieconcenmstlan of lud,as Well as**~ion** modeling ofmajor lead sources lnTela.AdditiOnally, therevision verifies thatthe Prev.ntion ofSignificant Dc!ter.ioratlon !md NOnilitalnm'eot New Source Review**permlttin§(prt~glims** are beIng imple""'nted,lri Texas and that lead Is oot**consid~** a**vlllblllty-in~irlng·poJiutlrtt** A public hHringon this pmposal wiJI Ill! held In Austin on May 17',2(11l,lt 10:00 a.m., atthe TtEQ headquarun; 12100 Part 35Clrde.

. Building F, Room 2210. The hearing wiD be ttructured·forthe receipt ofcral cr writml ccmments bylnteruted.perlons.lndlvlduab may prese_ntoral satemcntsVYhen ailed upon In order.of reglstrltl_cn. There wiD be no open dlscwslon durlr!gthe.huring;**Ito~, ~**  staff.will beBVIillble ttldlsc;USSthe propcui'3D,\'111Jjute;s.Jll1ortD the-hearing.

. Pei'SOIVwhcohaVi spectal·communlcatlon or other ac:Cotnmodationneeds who are pllnnlng to**;~ttend** the hurlng shaukl CCII)tact**Shel~** Nalkwiththe Air Quality Division ;Jt · (512) 23g..1 536; Requests should·be made as far in advanceas possible.· · Comments miybesubmttted toShelley Natk. MC 206. Air**Qua~** Division, Chief Engineer's Office, TunCommlulon on EnvlronrnenDI QuiUty, P.O."Boi' 13087,-Austln, Texas 7871 1· ¥.'67, orfaxedtcCl12) 239-51587. Elettnric comments maybesubm!tted ItwwwS.tc2q. tms.gOV/nlleste:om'memsl. FMe size restrlc·

..tlons may applytocomments being submit-·

. tad vla.the ecammentsl)'Stem.**~.1** com- ' ments pertaining-to-the LedTraRsportpt.,

.ferthe l008 Lead NAAOS SIP rwlilon should Rm.nce**PrDjed"Numbei'"2D1.1~P-Nfl;.** The comment perioddoses. on May 2312011. Copies ofthe prcpastdSIP !"!!vision anbe**·o~ed** from theTCEQ's Web stce ItHttp'i/ www.tceq.texas.gayllmplemaotatluio/rk/tip/ texas-slplcriterilt-pollutantslsip-lead.Forfurtheritdc:ii 1 nalkJti, ,.._contactSbtlleyNID:,. AttQuaflty PlanningSection,**(51~** 239-1536.

..birds, insects and heavy air cont!minants; 30 TAC §290.46(m), by failing to initiate maintenance and housekeeping practices to ensure the good working condition and gdneral appearance ofthe facility and its equipment; PENALTY: $1.02l; ENFORCEMENT COORDINATOR: Stephen Thompson, (512) 239-2558; REGIONAL OFFICE: 3870 Eastex Freeway, Beaumont, exas 77703-1892, (409) 898-3838_ (28) COMPANY: USGreentech, .L.C. dba USGreentech; DOCKET NUMBER: 2010-1894-IHW-E; IDENTIFIER: RNI04360144; LOCATION: Brady, McCulloch unty; TYPE OF FACILITY: manufacture of infill material and/or lored sand; RULE VIOLATED: 30 TAC §335.4, by failing to man ge industrial hazardous waste in a manner to prevent the discharge imminent threat of discharge into or adjacent to water in the state; 0 TAC §335.9(a)(l), by failing to maintain records of industrial h dous waste activities; PENALTY: $2,100; ENFORCEMENT CO RDINATOR: Mike Pace, (817) 588-5933; REGIONAL OFFICE 622 South Oakes, Suite K, San Angelo, Texas 76903-7013, (325) 55-9479. (29) COMPANY: Vopak Term nal Galena Park, Incorporated; DOCKET NUMBER: 201 -1843-IWD-E; IDENTIFIER: RN!03137790; LOCATION: Galena Park, Harris County; TI'PE OF FACILITY: special arehousing and storage; RULE VIOLATED: TWC, §26.12I(a), 0 TAC §305.125(1), and Texas Pollutant Discharge Elimination ystem (TPDES) Permit Number WQ0001662000, E:ffiuent Limita 'on and Monitoring Requirements Number I for Outfall 002, by ailing to comply with permitted effluent limits; TWC, §26.12l(a), 30 TAC §305.125(1), and TPDES Permit Number WQ0001662000, ffiuent Limitation and Monitoring Requirements Number I for Ou 11 002, by failing to comply with permitted effluent limits; PEN TY: $!7,640; ENFORCEMENT COORDINATOR: Jeremy Escob , (361) 825-3422; REGIONAL OFFICE: 5425 Polk Avenue, Sui H, Houston, Texas 77023-!486, (713) 767-3500. TRD-201101381 Kathleen C. Decker Diredor, Litigation Division Texas Commission on Environmen I Quality Filed: April12, 2011 

# • Correction ofError The Texas Commission on Enviro amendment to 30 TAC §IOI.J in Tuas Register (36 TexReg !294) inition text for paragraph (115). compound" that appears on page 1 paragraph that was superseded in language was incorporated into th The definition in paragraph (115) "(115) Volatile organic compound Regulations §51.1 OO(s), except §5 uary 21, 2009 (74 FR 3441)." 

# •

ental Quality (TCEQ) adopted an February 25,2011, issue ofthe TCEQ submitted the wrong defe definition of ''Volatile organic 04 reflects an earlier version ofthe 10. In consequence, that incorrect Texas Administrative Code.

As defined in 40 Code of Federal IOO(s)(2)- (4), as emended on JanThe correct definition will be restor dtothe Texas Administrative Code on-line. TRD-201101405 

# • • Notice ofa Public Hearing on Proposed Revisions to the State Implementation Plan The Texas Commission on Environmental Quality (TCEQ) will conduct a public hearing to receive comments concerning revisions to the state implementation plan (SIP), under the requirements of Texas Health and Safety Code, §382.012 and §382.Dl3; and 40 Code ofFederal Regulations §51.102 ofthe United States Environmental Protection Agency regulations concerning SIPs. The proposed revision would incorporate a plan to address lead transport for the 2008 lead National Ambient Air Quality Standard (NAAQS). The proposal would meet the requirements ofthe Federal Clean Air**Ac~** §IIO(a)(2)(D)(i), relating to the intemate transport of lead under the 2008 lead NAAQS. These revisions reference existing control strategies to reduce the concentration of lead, as well as dispersion modeling ofmajor lead sources in Texas. Additionally, the revision verifies that the Prevention of Significant Deterioration and Nonattainment New Source Review permitting programs are being implemented in Texas and that lead is not considered a visibility-impairing pollutant. A public hearing on this proposal will be held in Austin on May 17, 2011, at !0:00a.m., at the TCEQ headquarters, 12!00 Park 35 Circle, Building F, Room 2210. The hearing will be structured for the receipt of oral or written comments by interested persons. Individuals may present oral statements when called upon in order ofregistration. There will be no open discussion during the hearing; however, TCEQ staff will be available to discuss the proposal30 minutes priorto thehearing. Persons who have special communication or other accommodation needs who are planning to attend the hearing should contact Shelley Naik with the Air Quality Division at (512) 239-1536. Requests should be made as far in advance as possible. Comments may be submitted to Shelley Naik, MC 206, Air Quality Division, Chief Engineer's Office, Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas 78711-3087, or faxed to (512) 239-5687. Electronic comments may he submitted at www5.tceq.texas.gov/rules/ecomments/. File size restrictions may applyto commentsbeing submitted via the eComments system. All commentspertaining totheLead Transport Plan for the 2008 Lead NAAQS SIP revision should reference Project Number 2011-005-SIP-NR. The comment period closes on May 23, 2011. Copies of the proposed SIP revision can be obtained from the TCEQ's Web site athttp://wv.rw.tceq.texas.gov/implementationlair/sipltexas-sip/criteria-pollutants/sip-lead. For further information, please contact Shel1ey Naik, Air Quality Planning Section, (512) 239-1536. TRD-2011 01382 Robert Martinez Director, Environmental Law Division Texas Commission on Environmental Quality Filed: Aprll12, 2011 

# • • Notice ofOpportunity to Com ent on Agreed Orders of Administrative Enforcement A The Texas Commission on Enviro ental Qua1ity (TCEQ or commission) staffis providing an oppo ty for written public comment on the listed Agreed Orders (AOs) in cordance with Texas Water Code (TWC), §7.075. TWC, §7.075 re uires that before the commission may approve the AOs, the commis ion shall a11ow the public an opportunity to submit written comm ts on the proposed AOs. TWC, §7.075 requires that notice ofthe op rtunity to commentmust be published in the Texas Register no late than the 30th day before the date on which the public commentperio c]oses, which inthis case is May 23, 2011. TWC, §7.075 also requi s that the commission promptly consider any written comments rece ed and that the commission may



### INADDITION April22, 2011 36 TexReg 2623Bryan W. Shaw, Ph.D., Chairman Buddy Garcia, Commissioner Carlos Rubinstein, Commissioner Mark R. Vickery, P.G., Executive Director



### TEXAS COMMISSION ON ENVIRONMENTAL QUALI'IT Protecting Texas by Reducing andPreventing Pollution



### NOTICE OF PUBLIC HEARING BYTHE TEXAS COMMISSION ON ENVIRONMENTAL QUALITY ON PROPOSED REVISIONS TO THE STATE IMPLEMENTATION PLAN


### The Texas Commission on Environmental Quality (TCEQ) will conduct a public hearing to receive comments concerning revisions tothe state implementation plan (SIP), under the requirements ofTexas Health and Safety Code, §382.012 and §382.013; and 40 Code ofFederal Regulations §51.102 ofthe United States Environmental ProtectionAgency regulations concerning SIPs. The proposed revision would incorporate a plan to address leadtransportfor the 2008 lead National AmbientAir Quality Standard (NAAQS). The proposal would meet the requirements of the Federal Clean Air

### Act, §11o(a)(2)(D)(i), relating to the interstate transport ofleadunderthe 2008 lead NAAQS. These revisions reference existing control strategies to reduce the concentration oflead, as well as dispersion modeling ofmajor lead sources inTexas. Additionally, the revision verifies thatthe Prevention ofSignificant Deterioration and Nonattainment New Source Review permitting programs arebeing implemented in Texas and thatlead is 

### not considered a visibility-impairing pollutant. A public hearing onthis proposal will be held inAustin on May 17, 2011, at 10:00 a.m., atthe TCEQ headquarters, 12100 Park 35 Circle, Building F, Room 2210. The hearing will be structured for the receipt oforal or written comments byinterested persons. Individuals may present oral statements when called upon in order ofregistration. There will be no open discussion during the hearing; however, TCEQ staff

### will be available to discuss the proposal30 minutes prior to the hearing. Persons who have special communication or other accommodation needs who are planning to attend the hearing should contact Shelley Naik with theAir 

### Quality Division at (512) 239-1536. Requests shouldbe made as far in advance as possible. Comments maybe submitted to Shelley Naik, MC 206, Air 

### Quality Division, ChiefEngineer's Office, Texas Commission on Environmental Quality, P.O. Box 13087,Austin, Texas 78711- 3087, or faxed to (512) 239-5687. Electronic comments may be submitted at www5.tceq.texas.gov/rules/ecomments/. File size restrictions may apply to commentsbeing submittedvia the eComments system. All comments pertaining to the Lead Transport Plan for the 2008 Lead NAAQS SIP revision should reference Project Number 2011-005-SIP-NR The comment period closes on May 23, 2011. Copies ofthe proposed SIP revision can be obtained from the TCEQ's Web site at http:/fwww.tceq.texas.gov/implementationjair/sip/texassip/criteria-pollutants/sip-lead. Forfurther information, please contact Shelley Naik, Air 

### Quality Planning Section, (512) 239-1536.

P.O. Box 13087 • Austin, Texas 78711-3087 • 512-239-1000 • www.tceq.state.tx.us How is our customer service? www.tceq.state.tx..usjgotojcustomersurvey printed an recycled paperREVISIONS TO THE STATE OF TEXAS AIR QUALTIY IMPLEMENTATION PLAN CONCERNING TRANSPORT EMISSIONS

LEAD TRANSPORT

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY P.O. BOX 13087 AUSTIN, TEXAS 78711-3087

LEAD TRANSPORT PLAN FORmE 2008 LEAD NATIONAL AMBIENTAIR QUALTIY STANDARD

PROJECT NUMBER 2011-005-SIP-NR

Proposal April6, 2011Thispage intentionally left blankEXECUTIVE SUMMARY This revision to the State Implementation Plan (SIP) for lead transport sets forth how theTexas Commission on Environmental Quality (TCEQ) will meet the Federal Clean AirAct (FCAA), §no(a)(1) requirement for states to submit SIP revisions within three years after the promulgation ofnew or revised NationalAmbientAir Quality Standards (NAAQS) to meet the requirements ofFCAA, §uo(a)(2),including FCAA, §uo(a)(2)(D)(i), relating tointerstate transport. On October 15, 2008, theUnited States Environmental ProtectionAgency (EPA) substantially strengthened theNAAQS for lead. The new standard, set at 0.15 micrograms per cubic meter (j.1g/m3) measured as a rolling three-month average, is tentimes more stringent than the previous standard of 1.5 j.lg/m3 measured as a quarterly average. Thepurpose ofthis SIP revision is to document that any emissions from sources in Texas do not interfere with attainment or maintenance ofthe 20o8leadNAAQS in another state. Section uo(a)(2)(D)(i) also contains a requirementfor all states to submit SIP revisions that contain adequate provisions prohibiting emissions thatwill interfere with measures required to be included in the applicable implementation plan in any other state to prevent significant deterioration of air quality or to protectvisibility. The EPA's September 25, 2009, "Guidance on SIP Elements Required Under Sections uo(a)(1) and (2) for the 2006 24-Hour Fine Particle (PM2.s) National AmbientAir QualityStandards" indicates thatthese requirements are satisfied ifa state's SIP includes New Source Review (NSR) and Prevention ofSignificant Deterioration (PSD) programs. This SIP revision includes verification that the PSD and NSRpermitting programs arebeing implemented inTexas. According tothe EPA's July 6, 2005, regional haze regulations and guidelines for BestAvailable RetrofitTeclmology (BART) determinations, lead is not included as a visibility-impairing pollutant andtherefore is notexpectedto interfere with measures to protect visibility. The October 15, 2008, final rule for the 20o8lead NAAQS (73 FR 66964) included a requirement for monitors tobe placed in areas with sources, sucll as industrial facilities, that emit 1.0 ton peryear (tpy) or more oflead andin urban areas with more than soo,ooo people. The EPA maywaive the source-oriented monitoring requirements ifthe monitoring agency demonstrates that emissions from the source would not contribute to maximum air lead concentrations greater than so% ofthe revised standard or 0.075 11g/m3. On December 14, 2010, theEPArevised the ambientmonitoring requirements for measuring leadin the air. The EPA cllanged theemission thresholdfor industrial facilities to 0.5tpy, reduced from the previous threshold of 1.0 tpy. TheTCEQ hascompleted modeling forthe facilities thatemit 1.0 tpy or more and is in the process ofcompleting modeling for thefacilities that emit 0.5 tpy or more. There are six facilities in Texas thatemit 1.0 tpy ormore oflead into the 

### air: theUnited States Army Fort Hood installation near Killeen (Fort Hood), Oxbow Carbon in PortArthur (Oxbow), the 

### Red RiverArmy Depot nearTexarkana (Red River), theAmerican Smelting and Refining Companyfacility nearAmarillo (ASARCO), the ECS Refining plant in Terrell (ECS), and the Exide Technologies, Incorporatedlead batteryrecycling facility in Frisco (Exide). Modeled lead emissions from FortHood and Oxbow eacll result in ambient concentrations oflessthan 15% of thelevel ofthe 2008 lead NAAQS. Additionally, the September 8, 2005, Defense Base Closure and Realignment Commission reportpursuantto Sections 2903 and 2914 oftheDefense Base Closure and Realignment Act of 1990 requires the munitions demilitarization activities at Red

ES-1River to be relocated to anotherfacility.' These demilitarization activities are scheduled to cease by September 30, 2011. The TCEQ has submitted waiver requests for the source-oriented lead monitoring requirements for these three facilities, since emissions from these sources are not expected to contributeto an ambient air concentration oflead greaterthan so% ofthe NAAQS. Source-oriented lead monitors have been installed for ASARCO, Exide, and ECS. Modeling of thefive• operational facilities indicates that lead emissions do not transport overlong distances and will therefore not impact surrounding nonattainment areas, maintenance areas, or states. Modeling for facilities that emitbetween 0.5 and 1.0 tpy is being conducted to determine the need for monitoring. This modeling is expected to give similar results to theprevious modeling andindicate that there will be no impact on surrounding areas or states. Fort Hood and Oxbow model results predictlevels ofless than 15% ofthe NAAQS. For Exide, ECS, and ASARCO the predicted concentrations dropped to belowhalfthelevel ofthe NAAQS within 2 kilometers of thepropertyline. To further validate this modeling, there are currently no lead nonattainment or maintenance areas in any ofthefour states thatborderTexas: Louisiana, Oklahoma, Arkansas, and New Mexico. Texas has only one nonattainment area underthe 2008 lead NAAQS. OnNovember 16, 2010, the EPA designated a portion ofCollin County, located in Frisco, Texas, as a lead nonattainment area, effective December 31, 2010 (75 FR. 71033). This nonattainment area surrounds the Exide lead batteryrecycling facility. An area surrounding Exide was originally designated nonattainment for the 1978leadNAAQS onNovember 6, 1991. On November 29, 1994, the EPA approvedthe Collin Countylead attainment demonstration SIP revision. OnAugust 31, 1999, the governor ofTexas submittedto the EPA a requestto redesignate the nonattaimnentportion ofCollin County to attainment andto approve a ten-year maintenanceplan for the area. The EPA redesignatedthe areato attainment and approved the ten-year maintenanceplan effective December 13, 1999 (64 FR. 55421). In 2009, the governor ofTexas submittedto the EPA the final ten-yearmaintenanceplan for the 1978lead NAAQS. This SIP revision included contingencymeasures set in place to promptly correct any violations ofthe 1978leadNAAQS. The attainment demonstration for the 2008leadNAAQS will be dueto the EPA byJune 30, 2012. Based onthe control strategies already in placeto reduce lead emissions inthe Collin County nonattainment area, modelingthatpredicts that lead emissions from Texas will not impact surrounding states, and lack ofnonattainment ormaintenance areas in thefour surrounding states, Texas has adequately addressed interstate transport oflead.

'"2005 Defense Base Closure and Realignment Commission Report," September 8, 2005, http:/fwww.brac.gov/docs/final/BRACReportcomplete.pdf. 2 Red River was not modeled because it will be shut down in 2011.

ES-2SECTION V: LEGAL AUTHORI'IY A General The Texas Commission on Environmental Quality (TCEQ) has thelegal authorityto implement, maintain, and enforce the NationalAmbient Air Quality Standards (NAAQS) and to controlthe quality ofthe state's air, including maintaining adequate visibility. Thefirst air pollution control act, known as the Clean Air Act ofTexas,.was passedbythe Texas Legislature in 1965. In 1967, the Clean AirAct ofTexas was supersededby a more comprehensive statute, the Texas CleanAir Act (TCAA), found in Article 4477-5, Vernon's Texas Civil Statutes. The legislature amended the TCAA in 1969, 1971, 1973, 1979, 1985, 1987, 1989, 1991, 1993, 1995, 1997, 1999, 2001, 2003, 2005, 2007, and 2009. In 1989, the TCAA was codified as Chapter 382 ofthe Texas Health and Safety Code. Originally, the TCAA stated that the Texas Air Control Board (TACB) was the state air pollution control agency and was the principal authority inthe state on matters relating to the quality of air resources. In 1991, the legislature abolished the TACB effective September 1, 1993, and its powers, duties, responsibilities, and functions were transferredto the Texas Natural Resource Conservation Commission (TNRCC). With the creation ofthe TNRCC, the authority over air quality is found in both the Texas Water Code and the TCAA Specifically, the authority ofthe TNRCC is found in Chapters 5 and 7. Chapter 5, SubchaptersA- F, H- J, and L, include the general provisions, organization, and general powers and duties ofthe TNRCC, and the responsibilities and authority ofthe executive director. This chapter also authorizes the TNRCC to implement action when emergency conditions arise and to conducthearings. Chapter 7 gives the TNRCC enforcement authority. In 2001, the 

### 77th Texas Legislature continued the existence ofthe TNRCC until September 1, 2013, and changed the name ofthe TNRCC to the Texas Commission on Emironmental Quality (TCEQ). In 2009, the 81st Texas Legislature, during a special session, amended section 5.014 ofthe Texas Water Code, changing the expiration date of the TCEQ to September 1, 2011, unless continuedin existenceby the Texas SunsetAct. TheTCAA specifically authorizes the TCEQ to establish the level ofqualityto be maintained in the state's air and to control the quality ofthe state's airbypreparing and developing a general, comprehensive plan. TheTCAA, SubchaptersA- D, also authorize the TCEQ to collect informationto enable the commissionto develop an inventory ofemissions; to conduct research and investigations; to enterproperty and examine records; to prescribe monitoring requirements; to institute enforcement proceedings; to enterinto contracts and execute instruments; to formulate rules; to issue orders taking into consideration factors bearing upon health, welfare, social and economic factors, and practicability and reasonableness; to conduct hearings; to establish air quality control**re~ions;** to encourage cooperation with citizens' groups and other agencies and political subdivisions ofthe state as well as with industries and the federal government; and to establish and operate a system ofpermits for construction or modification offacilities. Local government authority is found in Subchapter E ofthe TCAA Local governmentshave the same power as the TCEQ to enter property and make inspections. They also may make recommendations to the commission concerning any action ofthe TCEQ that affects their territorialjurisdiction, maybring enforcement actions, and mayexecute cooperative agreements with the TCEQ or other local governments. In addition, a cityortown may enact and enforce ordinances for the control and abatement of air pollution not inconsistent with the provisions of the TCAA and the rules or orders ofthe commission.Subchapters G and H oftheTCAA authorize the TCEQ to establish vehicle inspection and maintenance programs in certain areas ofthe state, consistent with the requirements ofthe Federal Clean AirAct; coordinate with federal, state, andlocal transportationplanning agencies to develop and implement transportation programs and measures necessaryto attain and maintainthe NAAQS; establish gasoline volatility and low emission diesel standards; and fund and authorizeparticipating counties to implement vehicle repair assistance, retrofit, and accelerated vehicle retirement programs. 

### B. Anniicable Law Thefollowing statutes and rules provide necessary authorityto adopt and implement the state implementationplan (SIP). The rules listed below havepreviouslybeen submitted as part ofthe SIP. Statutes 

### All sections ofeach subchapter areincluded, unless otherwise noted. TEXAS HEALTH & SAFElY CODE, Chapter 382 TEXAS WATER CODE Chapter 5: Texas Natural Resource Conservation Commission SubchapterA:. General Provisions September 1, 2009 September 1, 2009

Subchapter B: Organization oftheTexas Natural Resource Conservation Commission Subchapter C: Texas Natural Resource Conservation Commission Subchapter D: General Powers and Duties ofthe Commission Subchapter E: Administrative Provisions for Commission SubchapterF: Executive Director (except §§5.225, 5.226, 5.227, 5.2275,5.231, 5.232, and 5-236) Subchapter H: Delegation ofHearings Subchapter 1: Judicial Review SubchapterJ: Consolidated Permit Processing SubchapterL: Emergency andTemporary Orders (§§5.514, 5.5145, and 5.515 only) Subchapter M: Environmental Permitting Procedures (§5.558 only) Chapter 7: Enforcement SubchapterA: General Provisions (§§7.001, 7.002, 7.0025, 7.004, and7.005 only) SubchapterB: CorrectiveAction and Injunctive Relief(§7.032 only) SubchapterC: Administrative Penalties SubchapterD: Civil Penalties (except §7.109) SubchapterE: Criminal Offenses and Penalties (§§7.177, 7.179-7.183) Rules All ofthe following rules are found in 30 TexasAdministrative Code, as ofthefollowing latest effective dates: Chapter7: Memoranda ofUnderstanding, §§7.110 and7.119 Chapter 19: Electronic Reporting Chapter 35: Subchapters A-C, K: Emergency andTemporary Orders and Permits; Temporary Suspension orAmendment ofPermit Conditions ii May2, 2002 March 15,2007

July 20, 2006Chapter 39: Public Notice, §§39.201; 39.401; 39-403(a) and (b)(8)-(10); 39-405(0(1) and (g); 39.409; 39.411 (a), (b)(1)-(6), and (8)-(10) and (c)(1)-(6) and (d); 39-413(9), (11), (12), and (14); 39.418(a) and (b)(3) and (4); 39.419(a), (b), (d), and (e); 39.420(a), (b) and (c)(3) and (4); 39.423 (a) and (b); 39-601-39-605 Chapter 55: Requests for Reconsideration and Contested Case Hearings; Public Comment, §§55.1; 55.21(a)- (d), (e)(2), (3), and (12), (f) and (g); 55.101(a), (b), and (c)(6)- (8); 55.103; 55.150; 55.152(a)(1), (2), and (6) and (b); 55.154; 55.156; 55.200; 55.201(a)- (b); 55.203; 55.205; 55.209, and 55-211 Chapter 101: General Air Quality Rules June 24, 2010

June 24, 2010 March 3, 2011 Chapter 106: Permits by Rule, SubchapterA Decentber 11, 2002 Chapter 111: Control ofAir Pollution from Visible Emissions and Particulate Matter July 19,2006 Chapter 112: Control ofAir Pollution from Sulfur Compounds July 16, 1997 Chapter 113: Standards ofPerformance for HazardousAirPollutants and for Designated Facilities and Pollutants May 14, 2009 Chapter 114: Control ofAirPollution from MotorVehicles December 13, 2010 Chapter 115: Control ofAir Pollution from Volatile Organic Compounds February 17, 2011 Chapter u6: Permits for New Construction or Modification March 3, 2011 Chapter 117: Control ofAir Pollution by Control ofAir Pollution from Nitrogen Compounds February4, 2010 Chapter 118: Control ofAirPollution Episodes May 14, 2004 Chapter 122: §122.122: Potential to Emit December 11, 2002 Chapter 122: §122.215: Minor Permit Revisions June 3, 2001 Chapter 122: §122.216: Applications for Minor Permit Revisions June 3, 2001 Chapter 122: §122.217: Procedures for Minor Permit Revisions December 11, 2002 Chapter 122: §122.218: Minor Permit Revision Procedures for Permit Revisions Involving the Use ofEconomic Incentives, Marketable Permits, and Emissions Trading

iii June3, 2001SECflON VI: CONTROL STRATEGY A. Introduction (No change) B. Ozone (No change) 

### C. Particulate Matter (No change) 

### D. Carbon Monoxide (No change) 

### E. Lead (No change) 

### F. Oxides ofNitrogen (No change) 

### G. Sulfur Dioxide (No change) 

### H. Conformity with the National Ambient Air Quality Standards (No change) 

### I. Site Specific (No change) J. Mobile Sources Strategies (No change) 

### K Clean Air Interstate Rule (No change) L. Transport (Revised) M. Regional Haze (No change)

ivTABLE OF CONTENTS Executive Summary Section V: Legal Authority Section VI: Control Strategy Table ofContents List ofAcronyms List ofTables List ofAppendices Chapter 1: General 1.1 Background 1.2 Introduction 1.3 Health Effects 1.4 Public Hearing and Comment Information 1.5 Social and Economic Considerations 1.6 Fiscal andManpower Resources 1.7 Coordination with Local Agencies 1.8 Organizations Responsible for Development, Implementation, and Enforcement 1.9 Data Availability Chapter 2: Required Control Strategy Elements 2.1 Background 2.2 Control Strategy Overview 2.2.1 Significant Contribution to Nonattainment and Interference with Maintenance Elements 2.2.1.1 Dispersion Modeling 2.2.1.2Monitoring Sites 2.2.2 Collin County SIP Revisions 2.2.2.11993 Lead SIP 2.2.2.2 1999 Redesignation Request andMaintenance Plan 2.2.2.3 2009 Second Ten-Year Maintenance Plan 2.2.2-4Nonattainment Designation Underthe 2008 Lead NAAQS 2.2.3 Prevention ofSignificant Deterioration andNonattainmentNew Source Review Elements

v2.2-4 Protection ofVisibility Element Chapter 3: Future Attainment Plans

vi

### USTOFACRONYMS BART Best Available Retrofit Technology EPA United States Environmental Protection Agency FCAA Federal Clean AirAct FR Federal Register IQ Intelligence Quotient NAAQS NationalAmbientAir Quality Standard NSR New Source Review PSD Prevention ofSignificant Deterioration PM

..5 Fine Particulate Matter SIP State Implementation Plan TAC Texas Administrative Code TACB Texas Air Control Board TCAA Texas Clean AirAct TCEQ Texas Commission on Environmental Quality (commission) TNRCC Texas Natural Resource Conservation Commission tpy tons peryear J.ig/m3 micrograms per cubic meter

viiUST OF TABLFS

Table 1-1: Public Hearing Information

viiiAPPendix Appendix A AppendixB LIST OF APPENDICES AppendixName Lead Modeling Analyses TCEQ Lead MonitoringNetwork

ix

### CHAPTER 1: 

### GENERAL 1.1 BACKGROUND "The History ofthe Texas State Implementation Plan (SIP)," a comprehensive overview ofthe SIP revisions submitted to the United States Environmental Protection Agency (EPA) bythe State ofTexas, is available at the following Web site at: htto://www.tceg.texas.gov/implementation/air/sip/sipintro,html 1.2 INTRODUCTION This SIP revision for the transport oflead descnbes how theTexas Commission on Environmental Quality (TCEQ) will meet the requirements of §uo(a)(2)(D)(i) Federal Clean Air Act (FCAA), which requires states to submit a SIP that contains adequate provisions that prohibit any source or other type ofemissions activity within the state from emitting any air pollutants in amounts that will:

• contribute significantly to nonattainment ofthe National Ambient Air Quality Standards (NAAQS) for areas in other states; • interfere with maintenance ofthe NAAQS by any other state; • interfere with measures required for any other state to meet an implementation plan related to Prevention ofSignificant Deterioration; or • interfere with measures required for any other state to meet the implementationplan related to regional haze andvisibility. Based on the control strategies already in place to reduce lead emissions in the Collin County nonattainment area, modeling thatpredicts that lead emissions from Texas will not impact surrounding states, and lack ofnonattainment ormaintenance areas in the four surrounding states, this SIP revision demonstrates that Texas has adequately addressed the FCAA §uo(a)(2)(D)(i) requirements. 1.3 HEALTH EFFECTS On October 15,2008, the EPA substantially strengthened theNAAQS for lead. The new standard, set at 0.15 micrograms percubic meter (j.!g/m') measured as a rolling three-month average, is ten times more stringent than theprevious standard of 1.5 j.!g/m' measured as a quarterly average. According to the EPA, scientific evidence about lead andhealth has expanded dramatically since the EPA issued theinitial standard of 1.5 j.!g/m' in 1978, and more than 6,ooo new studies on lead health effects, environmental effects, and lead in the air have been published since 1990. Evidence from health studies shows that adverse effects occur at much lowerlevels oflead in blood than previously thought. Lead that is emitted into the air can be inhaled directly oringested after it settles onto surfaces or soils. However, for the general population, exposure to lead occurs primarily via ingestion through contact with contaminated soils or other surfaces. Once taken into thebody, lead distributes throughout thebody intheblood and accumulates in the bones. Depending on the level ofexposure, lead can adversely affect the nervous system, kidney function, immune system, reproductive and developmental systems, and the cardiovascular system. Lead exposure also affects the oxygen-carrying capacity oftheblood. The lead effects most ·commonly encountered in current populations are neurological effects in children and cardiovascular effects (e.g., high blood pressure andheart disease) in adults. Children are at a relatively higher risk ofexposure to lead when compared to adults. The risk of 1-1exposure is higher because children tend to put theirhands and other objects which may contain lead into their mouths (e.g., lead-basedpaint chips from older homes). Children also have a higher risk ofadverse effectsbecause their brains are still developing. Infants andyoung children are especially sensitive to low levels oflead, which may contributeto behavioral problems, learning deficits, and lowered intelligence quotient (IQ). 

### 1.4 PUBLIC HEARING AND COMMENT INFORMATION The commission will hold a public hearingfor this proposed SIP revision atthe following time and location: 

### Table 1-1: 

### Public Hearing Information City Date Time Location Texas Commission on Austin, TX May 17,2011 10:00am Environmental Quality, 12100 Park 35 Circle, Building F, Room 2210

The public comment period will open on April 22, 2011, and close on May 23, 2011. Written comments will be accepted**'~a** mail, fax, orthrough the eComments system. All comments should reference the "Lead Transport Plan for the 2008 Lead NationalAmbient Air Quality Standard" and Project Number 2011-005-SIP-NR. Comments maybe submitted to Shelley Naik, MC 206, StateImplementation Plan Team, ChiefEngineer's Office, Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas 78711-3087 orfaxed to (512) 239-5687. Electronic comments maybe submitted at http://wwws.tceq.texas.gov/rules/ecomments. File size restrictions may apply to commentsbeing submittedvia the eComments system. Comments mustbe received by May 23, 2011. Copies ofthe proposed SIP revision and its appendices can beobtained from the TCEQ Web site at: http:/{www.tceq.texas.gov/implementation/air/sip/texas-sip orupon request to: Texas Commission on Environmental Quality Air Quality Division P.O. Box 13087 Mail Code 206 Austin, Texas 78711-3087 Re: Lead Transport SIP Information 

### 1.5 SOCIALAND ECONOMIC CONSIDERATIONS Because rulemaking is not a part ofthis SIP revision, there are no changes that would have an impact on society or the economy. 1.6 FISCALAND MANPOWERRESOURCFS TheTCEQ has determined that its fiscal and manpower resources are adequate and 

### will notbe adversely affectedthrough the implementation ofthisplan. 1.7 COORDINATIONWITH LOCALAGENCIFS TheTCEQ has determined thatthere will be no assignment to local agencies. However, preexisting assignments to local agencies regarding various enforcement activities remain in effect and couldbeutilized ifenforcement activities are delegated to the TCEQ from the EPA.

1·21.8 ORGANIZATIONS RESPONSIBLE FORDEVELOPMENT, IMPLEMENTATION, AND ENFORCEMENT The TCEQ is the agency delegated authoritybythe Texas Legislature regarding the protection of air quality in the State ofTexas. Other local government entities have limited authority regarding 

### air quality matters in the State ofTexas. 

### 1.9 DATAAVAILABILITY The TCEQ affinns that it will retain all dataused in the preparation ofthis SIP revision. All supportingdocuments and data are publicly available via the TCEQ Web site at: htto://www.tceg.texas.gov/implementation/air/sip/texas-sip or are available from theTCEQ upon request.

1·3CHAPTER 2: REQUIRED CONTROL STRATEGY ELEMENTS 

### 2.1 BACKGROUND There are currently six facilities inTexas that emit 1.0 ton peryear (tpy) ormore oflead. Dispersion modeling oflead emissions from the five operational facilities (the Red River Army Depot was not modeled because it willbe shut down in 2011) indicates that lead does not transport over long distances and will therefore not impact the four surrounding states: Louisiana, Arkansas, New Mexico, and Oklahoma. There are currently no lead nonattainment or maintenance areas in any ofthese four states. Texas has only one nonattainment area underthe 2oo8leadNational AmbientAir Quality Standard (NAAQS). On November 16, 2010, the United States Environmental Protection Agency (EPA) designated a portion ofCollin County, located in Frisco, Texas, as a lead nonattainment area, effective December 31, 2010 (75 FR 71033). This nonattainment area surrounds the Exide Technologies, Inc. lead battery recycling facility. An area surrounding Exide is currently a maintenance area underthe 1978leadNAAQS. Control measures are in place underthis maintenance plan. The attainment demonstration for the 2008 lead NAAQS is due to the EPA byJune 30, 2012, andwill include additional control measures, ifnecessary, to meet the attainment deadline ofDecember 31, 2015. Texas has existing control strategies inplace in Collin County and modeling that indicates that lead emissions from sources that emit 1.0 tpy ormorewill not transport to surrounding states. Therefore, interstate transport oflead emissions inTexas has been adequately addressed. 2.2 CONTROL STRATEGY OVERVIEW Federal 

### Oean AirAct (FCAA) §uo(a)(2)(D)(i) requires states to submit a stateimplementation plan (SIP) revision that contains adequate provisions to prohibit any source orothertype of emissions activity within the statefrom emitting any 

### air pollutants in amounts that will:

• contribute significantly to nonattainment oftheNAAQS for areas in other states; • interfere with maintenance ofthe NAAQS in any other state; • interfere with measures for any other state required to meet an implementation plan related to Prevention ofSignificant Deterioration (PSD); or • interfere with measures required for any other state to meetthe implementation plan related to regional haze andvisibility. 

### 2.2.1 Significant Contribution to Nonattainment and Interference with 

### Maintenance IDements 2.2.1.1 Disnersion Modeling The October 15, 2008, final rule for the lead NAAQS included a requirement for monitors to be placed in areas with sources such as industrial facilities that emit 1.0 ormore tpy oflead and in urban areas with more than soo,ooo people. The EPA may waive the source-oriented monitoring requirements ifthe monitoring agency demonstrates that emissions from the source would not contnbute to maximum air lead concentrations greater than 50% ofthe revised standard, or 0.075 micrograms percubic meter**(~g/m').** On December 14, 2010, theEPA revised the ambient monitoring requirements for measuring lead in the 

### air. The EPA changed the emission threshold for industrialfacilities to 0.5 tpy, reduced from theprevious threshold of 1.0 tpy. The Texas Commission on Environmental Quality (TCEQ) has completed modeling for the facilities thatemit 1.0 tpy ormore and is inthe process ofcompleting modeling for the

2·1facilities that emitbetween o.s tpy and 1.0 tpy to determine the need for monitoring near those facilities. Six facilities in Texas emit 1.0 tpy or more oflead into the air: the United States Army Fort Hood installation near Killeen (Fort Hood), Oxbow Carbon in Port Arthur (Oxbow), the Red River Army Depot near Texarkana (Red River), theAmerican Smelting and Refining Company facility nearAmarillo (ASARCO), the ECS Refining plant in Terrell (ECS), and the Exide Technologies, Incorporated lead battery recycling facility in Frisco (Exide). Modeled lead emissions from Fort Hood and Oxbow result in predicted concentrations oflessthan 15% ofthe 2008leadNAAQS. Additionally, the September 8, 2005, Defense Base Closure and Realignment Commission report pursuantto Sections 2903 and 2914 ofthe Defense Base Closure and Realignment Act of 1990 requires the munitions demilitarization activities atRed River to be relocated to another facility. These demilitarization activities are scheduled to cease by September 30, 2011. The TCEQ has submittedwaiver requests for the source-oriented lead monitoring requirements for these three facilities since emissions from these sources are not expected to contribute to an ambient air concentration ofleadgreaterthan so% ofthe NAAQS. Source-oriented lead monitorshave been installed for ASARCO, Exide, and ECS. Modeling ofthe five3 operational facilities indicates that lead emissions do nottransport overlong distances and will therefore not impact surrounding areas or states. Fort Hood and Oxbow model results predict levels of less than 15% ofthe NAAQS. For Exide, ECS, andASARCO thepredicted concentrations dropped to belowhalfthe level ofthe NAAQS within 2kilometers oftheproperty line. Thefinding thatlead does nottransport over long distances is supportedby the EPA in the December 14, 2010, "Revisions to Lead Ambient Air Monitoring Requirements." Inthat final rule, the EPA indicated when selecting airports for an airport monitoring study, "We selected a maximum distance to ambient air from thelocation ofmaximum emissions of 150 meters because the available information indicates that ambient lead concentrations drop offquickly with distance, and it is less likely that an exceedance ofthelead NAAQS 

### will occur at greater distances. "4 To further validate this finding, there are currently no lead nonattainment or maintenance areas in any ofthe four states surroundingTexas: Louisiana, Oklal10ma, Arkansas, and New Mexico. Details ofthe dispersion modeling conducted bytheTCEQ canbefound in Appendix A: 

### LeadModeling Analyses. 2.2.1.2 Monitoring Sites The TCEQ currently operates ulead monitoring sites inAmarillo, Frisco, Terrell, Houston, Laredo, and Brownsville. These sites are listed inAppendix B: 

### TCEQ LeadMonitoring Network. This list includes the EPA-required source-oriented monitors for lead sources which emit 1.0 tpy or more, except for those for which theTCEQ has submittedwaiver requests. Changes to the lead monitoring requirements published by the EPA on December 14, 2010, require sourceoriented lead monitors for industrial sources that emit 0.5 tpy ormore and operation ofone lead monitor ateach site that is part ofthe multi-pollutant sitenetwork known asthe National Core monitoring network. Modeling for the sources meeting these criteria 

### will be conductedbythe TCEQ, andmonitors will be installed orwaiver requests 

### will be submitted accordingly. The final rule also requires monitors to 

### be installed at Stinson MunicipalAirport in Bexar County and Northwest Regional Airport in Denton County for an airport monitoring study.

3Red Riverwas not modeled, because it will be shutdown in 2011. 4 EPA, "Revisions to Lead AmbientAir Monitoring Requirements," December 14, 2010, http:/ jwww.epa.govjairjleadjpdfs/PbRevision-ForPublication.pdf 2-22.2.2 

### Collin County SIP 

### Revisions 2.2.2.1 1993 Lead SIP On November 6, 1991, the EPA published the notice ofnonattainment designation for lead in the FederalRegister (56 FR56694) for the portion ofCollin County that essentially encompassed theplant boundaries ofthe GouldNational Battery, Incorporatedfacility, laterknown as GNB Technologies, Incorporated (GNB), and now known as Exide Technologies, Incorporated (Exide). The effective date ofthe nonattainment designation was January- 6, 1992. Underthe federal guidelines, the Texas Air Control Board, a predecessor agency to the TCEQ, responded by submitting a site-specific SIP revision to the EPA onJune 18, 1993· Under the FCAA, the Collin County nonattainment area was required to attain the 1978leadNAAQS byJanuary- 6, 1997· The 1993 SIP revision includes an air quality analysis through thefourth quarter of 1992, a 1992 emissions inventory-, dispersion modeling that demonstratedNAAQS attainment for the area, control measures in Board OrderNumber 92-09(k), contingencymeasures in Board Order Number 93-12, and state New SourceReview (NSR) provisions for lead sources. The EPA approved the SIP revision on November 29,1994 (59 FR60930). The approval became effective January 30, 1995. 2.2.2.2 1999 Redesignation Request and Maintenance Plan OnAugust 31, 1999, Texas submittedtotheEPA a request that Collin Countybe redesignated from a nonattainment to an attainment area and a maintenanceplan that meets FCAA §175A requirements. The maintenance plan contained an agreed orderwith GNB (now Exide), making emissions reductions that had occurred since 1993 permanentandenforceable. Thepermanence ofthese reductions was tobe maintainedthrough pennit restrictions, emissions limits, and standardoperatingprocedures for controlling emissions from process sources, process fugitive sources, andfugitive dust sources from National Emissions Standards for Hazardous Air Pollutants mandated maximum achievable control technology for secondary- lead smelters. The plan also included contingencymeasures thathadbeenincludedin the 1993 attainment demonstration andthat GNB had alreadyimplemented. For example, the company added a supplementalventilationbaghouseto its metallurgical furnace operation, enclosed areas that hadpreviously notbeen enclosed and improved maintenance and operatingprocedures. The plan also included new contingencymeasures, their associated triggers, and a description ofthe monitoring networkthat wouldbe usedto detennine when an exceedance ofthe leadNAAQS occurred for the purpose oftriggering contingency measure notification during the ten-year maintenanceperiod. Thecontingencymeasures would require GNB to (1) install a new wheel washing facility; (2) install a scale and automatic tuyere punching device at theblast furnace; and (3) install an alternative measurethatwill provide, at a minimum, emissions reductions equivalent tothose listed previously. The EPA approved the redesignation request and maintenanceplan on October 13, 1999, effective December 13, 1999 (64 FR 55421). · 2.2.2.3 2009 SecondTen-Year Maintenance Plan FCAA §175A requires submission ofan additional SIP revision to provide for maintenance ofthe 1978 NAAQS for lead for the secondten-year period following redesignation ofthe nonattainment area to attainment. On August 26, 2009, the commission approved this maintenance plan for the Collin County area. The 2009 maintenance plan included new contingencymeasures set in place topromptlycorrect anyviolations ofthe 1978leadNAAQS.

2-3The contingencymeasures would require Exide to (1) automate the scale and feed for the reverberatory furnace; (2) expand the existing water misting dust suppression system; and (3) utilize an alternative measure that will provide, at a minimum, emissions reductions equivalent to thoselisted previously. The contingency measures were made legally enforceable under an agreed order adopted concurrently with the maintenance plan. 2.2.2.4 NonattainmentDesignation Under the 2008 Lead NAAOS Texas has one nonattainment area under the 2008lead NAAQS. On November 16, 2010, the EPA designated an area surrounding the Exide lead recycling facility inCollin County, Texas as a lead nonattainment area. The attainment demonstration for the 2008 lead NAAQS is due tothe EPA byJune 30, 2012, and will include control measures necessaryto meetthe attainment deadline ofDecember 31, 2015. 

### 2.2.3 Prevention ofSignificant Deterioration andNonattainment New Source Review Elements FCAA §no(a)(2)(D)(i)(II) contains a requirement for states to submit SIP revisions that contain adequate provisions to prohibit any source ortype ofemissions activity within the statefrom emitting airpollutants in amounts thatwill interfere with another state's SIP measures for preventing significant deterioration ofair quality. The EPA's September 25, 2009, "Guidance on SIP Elements Required Under Sections no(a)(1) and (2) for the 2006 24-Hour Fine Particle (PM•.s) NationalAmbientAir Quality Standards" indicates that these requirements are satisfied if a state's SIP includes NSR and PSD programs. All major sources inTexas are subjectto PSD and nonattainrnent NSRpermitting programs, implementedin 30Texas Administrative Code (TAC) Chapter 116. Major sources are defined in 30 TAC §116.12(17) in relationto the federal classification ofan area for nonattainment permitting andby reference to 40 Code ofFederal Regulations §51.166 for PSD. 

### 2.2.4 Protection ofViSioility Element Section no(a)(2)(D)(i)(Il) also contains a requirementfor all statesto submit SIPsthat contain adequate provisions prohibiting"

... any source orothertype ofemission activity within the state from emitting any airpollutant in amounts which will interfere with measures requiredto be included in the applicable implementationplanfor any other state

.... to protectvisibility." On July 6, 2005, the EPA publishedregional haze regulations and guidelines for BestAvailable Retrofit Technology (BART) determinations in the

### Federal Register. The BART guidelines include thefollowing list ofvisibility-impairing pollutants: sulfur dioxide, nitrogen oxides, particulate matter, volatile organic compounds, and ammonia. Lead is not included as a visibility-impairing pollutant and therefore is notexpectedto interfere 

### with measures to protect visibility in any other state.

2-4CHAPTER 3: FUIURE ATI'AINMENT PLANS Federal Clean AirAct (FCAA), §uo(a)(l) requires states to submit state implementationplans within three years after the promulgation ofnew or revised National Ambient Air Quality Standards (NAAQS) to meet the requirements ofFCAA, §uo(a)(2), including FCAA, §uo(a)(2)(D)(i), relating to interstate transport. Therefore, ifthe NAAQS are revised in the future, theTexas Commission on Environmental Quality

### will need to take the adequate steps relating to the interstatetransport of air pollution.

3-1APPENDIXA: LEAD MODEUNGANALYSES

# Texas Commission on Environmental Quality INTEROFF1CE MEMORANDUM

To:
Thru:

From: David Brymer Date: Air QualityPlanning Division Robert Opiela, P.E., Technical Specialist Technical Program Support Section Air Permits Division Matthew Kovar, Megan Cox Air DispersionModeling Team Air Permits Division June 22,2009

Subject: ModelingAnalysis ofLead for Asarco LLC (RN101701654) 1.0 Project Identification Information. On November 12, 2008, the U.S. Environmental Protection Agency (EPA) finalized the new 0.15 microgram per cubic meter (J.ig/m3) NAAQS forleadbased on a rolling threemonth average (73 Federal Register 66964). In general, the rule requires sourceoriented ambient air lead monitoringbyJanuary 1, 2010, at sites with actual annual lead emissions ofone ormore tons per year. Asarco LLC was identified ashaving emissions at or above this level based onthe reported 2007TCEQ Emissions Inventory and/or 2006Toxics Release Inventory. The rule further requires that this monitoring be conducted at or near the maximum off-site ambient air lead concentration, as predictedbymodeling, that results from sources with annual lead emissions ofone or more tons. TheTCEQ conducted air dispersion modeling ofall the lead emission sources at the site using the most current modeling parameters and associated permitted allowable emissions rates. TheTCEQ 

### will use the dispersion modeling results to determine the optimallocation ofany required source-<Jriented monitors. ArcReader Published Map: \\Msgjswrk\and\MODEL PROJECIS\LeadNAAOS Analvsis 2009\Lead NMOS Analvsis Results.pmf 2.0 Report Summary. The predictedmaximum ground level concentration (GLCrnax) is 0.21 J.lg/m3 for a rolling three-month average. The location ofthe GLCmaxis along the southeastern propertyline. Ail predicted concentrations exceeding the NAAQS are locatedto the southeast oftheAsarco LLC site and extendedless than 150 meters from the site propertyline. Table 1lists the location ofthe predicted GLCrnax. Thelocation coordinates are inthe UTM Zone 14 North, North American Datum of 1927 (NAD27) coordinate system. ·David Brymer Page 2 of4 June 22, 2009 Modeling Analysis ofLead for Asarco LLC Table 1. Modeling Results for Lead Location Location Averaging Easting Northing Time (meters) (meters) 252500 3906900 rolling three-month 3.0 Land Use and Terrain. 

### GLC Standard (1181m')**(~g,lm')**

0.21 0.15

A land use/land cover analysis was performed using AERSURF ACE consistent with guidance given in the AERMOD Implementation Guide (March 19, 2009). The recommended input data, the National Land Cover Data 1992 archives (NLCD92), were used for this analysis. Terrain elevations within the modeling domain were determined usingAERMAP (Version 09040). The input data usedfor this analysis were United States Geological Survey (USGS) digital elevation models (DEMs) for Pullman, Amarillo East, Mayer, and Pleasant Valley data sets. 4.0 Modeling Emissions Inventory. The modeled emission sourceparameters and emission rates were providedbyAsarco LLC. The source locations werevalidated by ADMT using aerial photography. Only source 7A has a listed maximum allowable emission rate for lead. Forthe other three sources, emissions estimates were submittedbyAsarco LLC and then validated byAPD permit reviewing stafffor use in this analysis. The emission rates represent worst case 1-houraverage emission rates and maybe more conservative than 24-hour ormonthly average emission rates. The emission source coordinates arein the UTM :l<me 14 North, NorthAmerican Datumof 1927 (NAD27) coordinate system. Table 2. On-Property Point Source ParameterInformation
Stack Stack Stack Exit Stack ID Easting Northing Height Temp Velocity Diameter (meters) (meters) (meters) (K) (meters/sec) (meters) 7A 251881.8 3907527.8 24.99 456.48 1.19 5.49 4B 251554.8 3907622.8 38.71 310.37 12.31 1.22 6A 251623.8 3907942.8 30.48 388.71 0.65 5.49 60 251732.8 3907896.8 30.48 408.15 0.87 5.49David Brymer Page 3 of4 June 22, 2009 Modeling Analysis ofLead for Asarco LLC Table 3. On-Property Source Modeled Emission Rates

Source Averaging Emission Rates Pollutant ID Time (lb/hr) 7A Lead 1-hr 4.27 48 Lead 1-hr 0.48 6A Lead 1-hr 0.02 6D Lead 1-hr 0.04 5-0 Building Wake Effects (Downwash). Input data to Building Profile Input Program Prime (BPIP-PRM Version 04274) were provided by Asarco LLC. Thebuilding locationswere validatedbyADMT using aerial photography. 6.o Meteorological Data. Surface Station and ID: Amarillo, TX (Station#: 23047) Upper Air Station and ID: Amarillo, TX (Station#: 23047) Meteorological Dataset: 1987, 1988, 1989, 1990, 1991 Profile Base Elevation: 3591 feet The AERSURFACE analysis conducted ofthe area surroundingthe Asarco LLC site resulted in a calculated roughness length of0.155 meters. The vast majority ofthe area considered industrial andurbanized (and with a higher roughness length) is concentrated ncar the emission sources. The dispersion ofemissions from the sources will behighly influencedby this higher roughness length- Arepresentative roughness length for the area wouldbe approximately 0.5 meters. For 

### this reason, the meteorological data set used for this analysis was developed using a roughness length of0.5 meters. 7.0 Receptor Grid. The receptor grid used in the modeling analysis consisted ofreceptorswith 100 meter spacing and extended approximately 2 kilometers (km) from the Asarco LLC site propertyline in all directions. The purpose ofthe receptor grid was to determine a representative maximum ground-level concentration and the extent ofground-level concentrations at or above halfofthelead NAAQS standard.David Brymer Page4 of4 June 22, 2009 Modeling Analysis ofLead for Asarco LLC 8.0 Model Used and Modeling Techniques. AERMOD (Version 07026) was used in a refined screening mode. For refined screening, National Weather Service (NWS) meteorological raw input data are used with generalized surface characteristics ofthe application site. Since the current version ofAERMOD 

### is not capable ofcalculating rolling three-month average concentrations, the EPA postprocessor LeadPost was used. The input values to LeadPost are monthly average values at each receptor in the POSTFILE outputformat from AERMOD.

# Texas Commission on Environmental Quality

To:
Thru:

From: INTEROFFICE MEMORANDUM

David Brymer Date: Air Quality Planning Division Robert Opiela, P.E., Technical Specialist Technical Program Support Section Air Permits Division Matthew Kovar, Megan Cox Air Dispersion Modeling Team Air Permits Division June 29,2009

Subject: ModelingAnalysis ofLead for ECS Refining Texas LLC (RN10o8o4467) 1.0 Project Identification Information. On November 12, 2008, the U.S. Environmental Protection Agency (EPA) finalized the new 0.15 microgram percubic meter (J.Lg/m3) NMQS for lead based on a rolling threemonth average (73 FederalRegister 66964). In general, the rule requires sourceoriented ambient air lead monitoringbyJanuary 1, 2010, at sites with actual annual lead emissions ofone ormore tons peryear. ECS Refining Texas LLC was identified as having emissions at or above this level based onthe reported 2007TCEQ Emissions Inventory and/or 2006 Toxics Release Inventory. The rule further requires thatthis monitoring be conducted at ornearthe maximum off-site ambient airlead concentration, as predictedby modeling, that results from sources with annual lead emissions ofone or moretons. The TCEQ conducted 

### air dispersioR modeling ofall thelead emission sources at the site using the most current modeling parameters and associated permitted allowable emissions rates. The TCEQ will use the dispersion modeling results to determine the optimal location ofany required source-oriented monitors. ArcReader Published Map: \\Msgiswrk\apd\MODELPROJECf8\LeadNMOS Analvsis 2009\Lead NMOS 

### Ana!vsis Results.pmf 2.0 Report Summary. Thepredicted maximum groundlevel concentration (GLCmax) is 4.06 J.Lg/m3 for a rolling three-month average. The location ofthe GLCmax is along the northern propertyline. All predicted concentrations exceeding the NMQS are located within approximately 1.1 kilometers (km) to the north, 0.7 km to the west, 0.6 km to the south, and0.3 km to the east ofthe site propertyline. Table 1lists thelocation ofthepredicted GLCmax. The location coordinates are in the UTM Zone 14 North, North American Datum of 1927 (NAD27) coordinate system.David Brymer Page 2 of4 June 29, 2009 Modeling Analysis ofLead for ECS Refining Texas LLC Table 1. Modeling Results for Lead Location Location Averaging Easting Northing Time (meters) (meters) 7S1SOO 362440 rolling three-month 3.0 Land Use and Terrain. GLC Standard (118fm')**(~g!m')**

4.06 0.1S

A land use/land cover analysis was performed using AERSURFACE consistentwith guidance given in the AERMOD Implementation Guide (March 19, 2009). The recommended input data, the National Land Cover Data 1992 archives (NLCD92), were usedfor this analysis. Terrain elevations within the modeling domain were determined using AERMAP (Version 09040). The inputdata used for this analysis was the United States Geological Survey (USGS) National Elevation Dataset (NED) for Terrell North, Terrell South, Forney North, and Forney South quadrangles. 4.0 Modeling Emissions Inventory. The modeled emission source parameters and emission rates were providedby ECS Refining Texas LLC. The source locations were validated byADMT using aerial photography. The sourceemissionrates modeled were consistent

### withthe maximum allowable emission rates authorized through permit 19430.The emission rates represent worst case 1-houraverage emission rates and maybe more conservative than 24-hour or monthly average emission rates. The emission source coordinates are in the UTM Zone 14 North, NorthAmerican Datum of 1927 (NAD27) coordinate system. Table 2. On-Property Point Source Parameter Information
Stack Stack Stack Exit Stack ID Easting Northing Height Temp Velocity Diameter (meters) (meters) (meters) (K) (meters/sec) (meters) P6 7S1S08.S 3624260.2 16.04 310.04 8.84 0.78 P12 7S1S14.S 36242S3.2 12.8S 303.87 16.74 1.07 P14 7S1488.S 3624262.2 17.63 30S.1S 12.93 1.12 P1S 7S1494.S 3624268.2 17.28 308.1S 13.47 0.66David Brymer Page 3 of4 June 29, 2009 ModelingAnalysis ofLead for ECS Refining Texas LLC

Stack ID Easting Northing Height (meters) (meters) (meters) P17 751464.5 3624251.2 11.4 Stack Stack Exit Temp Velocity

(K) (meters/sec) 312.32 6.1 Table 3· On-Property Source Modeled Emission Rates Stack Diameter (meters)

0.48

Source Averaging Emission Rates Pollutant ID nme (lb/hr) P6 Lead 1-hr 0.32 P12 Lead 1-hr 0.04 P14 Lead 1-hr 1.01 P15 Lead 1-hr 0.1 P17 Lead 1-hr 0.11 5.0 Building Wake Effects {Downwash). Input data to Building Profile Input Program Prime {BPIP-PRM Version 04274) were providedby ECS Refining Texas LLC. Thebuilding locations werevalidatedby ADMT using aerial photography. 6.o Meteorological Data. Surface Station and ID: Dallas/FortWorth, TX {Station#: 03927) UpperAir Station and ID: Stephenville, TX {Station#: 13091) Meteorological Dataset: 1985, 1987, 1988, 1989, 1990 Profile Base Elevation: 551 feet TheAERSURF ACE analysis conducted ofthe area surroundingthe ECS Refining Texas LLC site resulted in a calculated roughnesslength of0.109 meters. Since the AERSURF ACE analysis used landcover data from 1992 and since the area nearthe site hasbecome more developed andurbanized since 1992 based on comparing theland coverdata to 2004 aerial photography, a representative roughness length for the area wouldbe approximately 0.5 meters. Forthis reason, the meteorological data setused for this analysis was developed using a roughness length of0.5 meters.David Brymer Page4 of4 June 29, 2009 ModelingAnalysis ofLead for ECS Refining Texas LLC
7.0 Receptor Grid. The receptor gridused inthe modeling analysis consisted ofreceptors with 100 meter spacing and extended approximately 3 kilometers (km) from the ECS Refining Texas LLC sitepropertyline in all directions. Thepurpose ofthe receptor grid was to determine a representative maximum ground-level concentration and the extentof ground-level concentrations at or abovehalfofthe lead NAAQS standard 8.0 Model Used and Modeling Techniques. AERMOD (Version 07026) was used in a refined screening mode. Forrefined

. screening, NationalWeather Service (NWS) meteorological raw inputdata are used with generalized surface characteristics ofthe application site. Sincethe currentversion ofAERMOD is not capable ofcalculating rolling three-month average concentrations, the EPApost processorLeadPost was used. Theinputvalues to LeadPost are monthly average values at each receptor in the POSTFILE outputformat from AERMOD.

# Texas CommissiononEnvironmental Quality INTEROFFICE MEMORANDUM

To: Thru:

From: David Brymer Air Quality Planning Division Robert Opiela, P.E., Technical Specialist Technical Program Support Section Air Permits Division Matthew Kovar, Megan Cox Air Dispersion Modeling Team Air Permits Division Date: October 8, 2010

Subject: Modeling Analysis ofLead for Exide Technologies, Frisco Battery Recycling Plant (RN100218643) 1.0 Project Identification Information. On November 12, 2008, the U.S. Environmental ProtectionAgency (EPA) finalized the new 0.15 microgram percubic meter (J.Lg/m3) NAAQS forlead basedon a rolling threemonth average (73 FederalRegister 66964). In general, the rule requires sourceoriented ambient 

### air lead monitoringbyJanuary 1, 2010, at sites with actual annual lead emissions ofone ormoretons peryear. ExideTechnologies, Frisco Battery Recycling Plant was identified as having emissions at or above this level based on the reported 2007TCEQ Emissions Inventory and/or 2006Toxics Release Inventory. The rule further requires thatthis monitoringbe conducted at or nearthemaximum off-site ambient air lead concentration, as predicted bymodeling, that results from sources with annual lead emissions ofone or more tons. In 2009, theTCEQ conducted air dispersion modeling ofall the leademission sources at the siteusing the most current modeling parameters and associated permitted allowable emissions rates. In October 2010, ExideTechnologies submitted information to the TCEQ documenting a reduction inpermitted allowable emission rates for some sources. Some ofthese reductions will be validated through stacktesting at a future date. This modeling analysis addresses those emission reductions and supersedes the previous modeling analysis report (NSRG document #9136). TheTCEQ will use the dispersion modeling results to determine the optimal location ofanyrequired sourceoriented monitors. Since monitoring already exists at and nearthe Exide Technologies site, and monitored values exceeding the newlead standardhave been recorded, the dispersion modeling results will also beused to determinethe proposedboundaries ofa lead nonattainment area. ArcReader Published Map: \\Msgiswrk\aod\MODEL PRQJECTS\LeadNMOS Analysis 2010 reyjsed\Lead NMOS Analvsis Results 2010 reviseQ..pmfDavid Brymer Page 2 of? October 8, 2010 Modeling Analysis ofLead for Exide Technologies, Frisco Battery Recycling Plant 2.0 Report Summary. The predicted maximum ground level concentration (GLCmax) is 0.837 J.Lg/m3 for a rolling three-month average. The location oftheGLCmax is the same as thelocation of monitor 480850009 onthenorth propertyline ofthe Exide Technologies site. Predictedconcentrations exceeding the NAAQS extended approximately 0.8kilometers (km) to the north, o.s krn tothe south, 0.5 krn to the west, and 0.2 krn tothe east ofthe site propertyline. All predictedconcentrations greater thanthe NAAQS are located within Collin County. Table 1lists thepredicted concentrations atthe current monitor locations andproposed monitorlocation near the intersection of 1st Street andAsh Street. Table 1. Modeling Results for Lead Monitor ID Averaging GLC Standard Time (1181m') (1181m') 480850009 rolling three-month 0.837 0.15 480850003 rolling three-month 0.477 0.15 480850007 rolling three-month 0.292 0.15

Proposed rolling three-month 0.311 0.15 3.0 Land Use andTerrain. A land use/land cover analysis was performed using AERSURF ACE consistent with guidance given inthe AERMOD Implementation Guide (March 19, 2009).The recommended input data, the National Land Cover Data 1992 archives (NLCD92), were usedfor this analysis. Terrain elevations within the modeling domain were determined usingAERMAP (Version 09040). The inputdata used for this analysis were United States Geological Survey (USGS) digital elevation models (DEMs) for Little Elm, Frisco, Lewisville East, and Hebron data sets. 4.0 Modeling Emissions Inventory. The modeled emission sourceparameters and emission rates were providedby Exide Technologies. The source locations were validated by ADMT using aerial photography. The source emission rates modeled were consistent with the maximum allowable emission rates authorized through permits 3048A and 1147A. Several source emissions rates were revised through a permit alteration submitted October 2010. The revised emission rates are highlighted in Table 4· The emission source coordinates are inthe liTM Zone 14 North, North American Datum of 1927 (NAD27) coordinate system.David Brymer Page 3 of7 October 8, 2010 ModelingAnalysis ofLead for Exide Technologies, Frisco Battery Recycling Plant Table 2. On-Property Point Source ParameterInformation
Easting Northing Stack Stack Stack Exit ID Height Temp Velocity (meters) (meters) (meters) (K) (meters/sec) 11 702713.06 3668796.5 16.764 369.26 12.0396 12 702713.25 3668793.75 16.764 369.26 8.5039 13 702713.25 3668791.5 15.8496 391.48 13.1674 14 702721 3668792.75 16.764 327.59 27.9624 15 702725.31 3668807.5 16.764 349.82 14.1732 16 702717.88 3668803 17.3736 369.26 13.4722 17 702728.88 3668779.5 16.764 355.37 14.0208 18 702628.13 3668767.75 30.6324 303.71 5.1206 21 702626.88 3668739.25 31.242 304.82 16.5811 22 702685.69 3668804.25 22.86 0 15.1486 23 702637.38 3668764.5 6.096 0 1.8288 24 702721.88 3668782.5 16.4592 369.26 11.491 25 702721.75 3668777.75 16.4592 358.15 9.4488 26 702736.31 3668782.75 9.144 355.37 11.5824 37 702682.56 3668810 22.86 298.15 19.6901 38 702620.19 3668771.75 33.8328 315.37 16.7945 39 702544.5 3668727.75 10.668 0 0.0009 45 702623.06 3668713.75 32.1564 0 14.0238 48 702585 3668771 11.2776 0 1.6764 Stack Diameter (meters) 0.3048 0.3048 0.3048 0.5334 0.381 0.253 0.381 1.6154 1.521 0.8108 0.3048 0.381 0.381 0.1524 1.6764 1.3716 1.524 1.8044 0.1707David Brymer Page4 of? October 8, 2010 Modeling Analysis ofLead for Exide Technologies, Frisco Battery Recycling Plant

Table 3· Area Source Parameter Information Easting Northing Release Easterly Northerly Degrees 10 Height Length Length from north (meters) (meters) (meters) (meters) (meters) ( 0 ) 10 702642.65 3668770.8 4.572 28.956 24.384 -2 27 702733.81 3668767.5 4.572 0.9144 0.9144 0 28 702756.31 3668782 4.572 0.9144 0.9144 0 35 702654.26 3668740.35 4.572 22.86 30.48 -2 36 702645.75 3668754.8 4.572 32.004 15.24 -2 41 702518.28 3668768.73 0.3048 94.488 21.336 40 42 702625.1 3668693.38 0.3048 80.772 44.196 -2 43 702702.77 3668745.25 0.3048 62.484 39.624 -2 44 702590.79 3668760.22 3.9929 24.384 41.148 -2 52 702631.81 3668765.63 4.572 21.336 16.764 -2 53 702615.56 3668762.28 1.8288 16.764 19.812 -2 Table 4· On-Property Source Allowable Emission Rates
Scenario Averaging Emission Rates Pollutant 10 Time (lb/hr) 10 Lead 1-hr 0.08 11 Lead 1-hr 0.05 12 Lead 1-hr 0.03 13 Lead 1-hr 0.05 14 Lead 1-hr 0.03 15 Lead 1-hr 0.05 16 Lead 1-hr 0.02David Brymer Page 5 of7 October 8, 2010 Modeling Analysis ofLead for ExideTechnologies, Frisco Battery Recycling Plant

Scenario Averaging Emission Rates Pollutant ID Time (lb/hr) 17 Lead 1-hr 0.05 18 Lead 1-hr 0.07 21 Lead 1-hr 0.25 22 Lead 1-hr 0.02 23 Lead 1-hr O.Q3 24 Lead 1-hr 0.006 25 Lead 1-hr 0.004 26 Lead 1-hr 0.001 27 Lead 1-hr 0.001 28 Lead 1-hr 0.001 35 Lead 1-hr 0.08 36 Lead 1-hr 0.01 37 Lead 1-hr 0.09 38 Lead 1-hr 0.2 39 Lead 1-hr 0.12 41 Lead 1-hr 0.0388 42 Lead 1-hr 0.0388 43 Lead 1-hr 0.0388 44 Lead 1-hr 0.03 45 Lead 1-hr 0.25 48 Lead 1-hr 0.06 52 Lead 1-hr 0.01 53 Lead 1-hr 0.13David Brymer Page 6 of7 October 8, 2010 Modeling Analysis ofLead for Exide Technologies, Frisco Battery Recycling Plant

s.o Building Wake Effects (Downwash). Input data to Building Profile Input Program Prime (BPIP-PRM Version 04274) were providedby Exide Technologies. The buildinglocations were validatedbyADMT using aerial photography. 6.0 Meteorological Data. Surface Station and ID: Dallas/FortWorth, TX (Station #: 03927) UpperAir Station and ID: Stephenville, TX (Station #: 13091) Meteorological Dataset: 1985, 1987, 1988, 1989, 1990 Profile Base Elevation: 551 feet TheAERSURFACE analysis conducted ofthe area surroundingthe Exide Technologies site resulted in a calculated roughness length of0.129 meters. Since the AERSURFACE analysis used land cover data from 1992 and since the area near the site hasbecome more developed and urbanized since 1992 basedon comparing theland cover data to 2008 aerial photography, a representative roughness length for the area wouldbe approximately o.s meters. Forthis reason, the meteorological data set used for this analysis was developed using a roughness length ofo.s meters. 7.0 Receptor Grid. The receptor grid used in the modeling analysis consisted ofreceptors with so meter spacing and extended approximately 1.5 kilometers (km) from the Exide Technologies site propertyline in all directions. An additional grid consisted ofreceptors with 100 m spacing and extended 3·5 

### km beyond the first receptor grid in all directions. Discrete receptors were used for thelocations ofthethree existing monitoring stations and the location ofa proposed monitoring station neartheintersection of 1st Street and Ash Street. The purpose ofthe receptor grid was to determine a representative maximum ground-level concentration andthe extent ofground-level concentrations at or above halfofthe lead NAAQS standard. 8.0 Model Used and Modeling Techniques. AERMOD (Version 09292) was used in a refined screening mode. A new version of AERMOD was released on October 23, 2009. This version was used in the modeling analysis because it is thelatest approved EPA model version. Forrefined screening, National Weather Service (NWS) meteorological raw input data are used with generalized surface cllaracteristics ofthe application site. Since the current version of AERMOD is notcapable ofcalculating rolling three-month average concentrations, the EPA post processor LeadPost was used. The inputvalues to LeadPost are monthly average values at each receptor in the POSTFILE outputformat from AERMOD.David Brymer Page 7 of7 October 8, 2010 ModelingAnalysis ofLead for Exide Technologies, Frisco Battery Recycling Plant For this analysis, only emission sources atthe Exide Technologies site were considered. The nearest source ofleademissions outside the modeling domain is approximately 20 Ianfrom the Exide Technologies site with reported 2007lead annual emissions approximately one percentofthe annual lead emissions reportedby Exide Technologies. Thelargest nearby source oflead emissions is approximately

## so Ian from the Exide Technologies site with annual reported emissions approximately tenpercent ofthe annual emissions reportedbyExide Technologies. Due to the great distance to the Exide Technologies site and the small reported emission, no other sources oflead emissions wouldhave a significant contribution near the Exide Technologies site orthe modeling domain usedfor this analysis.

# Texas Commission onEnvironmental Quality

To: Thru:

From: INTEROFFICE MEMORANDUM

Jim Price Date: Air Quality Division Robert Opiela, P.E., Technical Specialist Technical Program Support Section Air Permits Division Matthew Kovar, Megan Cox Air Dispersion ModelingTeam Air Permits Division September 25, 2009

Subject: Modeling Analysis ofLead for Oxbow Calcining LLC (RN 100209287) 1.0 Project Identification Information. On November 12, 2008, the U.S. Environmental Protection Agency (EPA) finalized the new 0.15 microgram percubic meter (l!g/mJ) NAAQS for lead based on a rolling threemonth average (73 Federal Register 66964). In general, the rule requires sourceoriented ambient airlead monitoringbyJanuary 1, 2010, at sites with actual annual lead emissions ofone ormore tons peryear. Oxbow Calcining LLC was identified as having emissions at or above this level based on the reported 2007TCEQ Emissions Inventory and/or 2006 Taxies Release Inventory. The rule further requires thatthis monitoringbe conducted at or near the maximum off-site ambient air lead concentration, as predictedby modeling, that results from sources with annuallead emissions ofone or more tons. The TCEQ conducted air dispersion modeling of

### all thelead emission sources at the site using the most current modeling parameters and associated permitted allowable emissions rates. The TCEQ will use the dispersion modeling results to determine the optimal location ofany required source-oriented monitors. ArcReader Published Map: \ \Msgiswrk\apd\MODEL PROJEcrg\LeadNMQS Analvsis 20og\Lead NAAOS Analvsis Results.pmf 2.0 Report Summary. The predictedmaximum ground level concentration (GLCmax) is 0.016 11gfmJ for a rolling three-month average. The location ofthe GLCmax is approximately 70 meters from the northwest propertyline. Table 11ists the location ofthe predicted GLCmax. The location coordinates are in the UTM Zone 15 North, North American Datum of 1927 (NAD27) coordinate system.Jim Price Page 2 of4 September 25, 2009 Modeling Analysis ofLead for Oxbow Calcining LLC Table 1. Modeling Results for Lead location location Averaging Easting Northing Time (meters) (meters) 407000 3301300 rolling three·month 3.0 Land Use andTerrain. GlC Standard (1-l&'m') (ll8fm')

0.016 0.1S

A land use/land cover analysis was performedusingAERSURF ACE consistent with guidance given in the AERMOD Implementation Guide (March 19, 2009). The recommendedinput data, the National Land Cover Data 1992 archives (NLCD92), were usedfor this analysis. Terrain elevations within the modeling domain were determined using AERMAP (Version 09040). The input data used for this analysis was the United States Geological Survey (USGS) NationalElevation Dataset (NED) for the PortArthur South quadrangle. 4.0 Modeling Emissions Inventory. The modeled emission source parameters and maximum allowable emission rates were obtained from permits 45622 and 5421. The source locations were validated by ADMT using aerialphotography. The emission rates represent worst case 1-hour average emission rates and maybemore conservative than 24-hour or monthly average emission rates. The emission source coordinates areinthe UTM Zone 15 North, North American Datum of 1927 (NAD27) coordinate system. Table 2. On-Property Point Source Parameter Information
Stack Stack Stack Exit Stack ID Easting Northing Height Temp Velocity Diameter (meters) (meters) (meters) (K) (meters/sec) (meters) KS2 406942 3300668 38.1 1366.48 14.78 3.17 WHBS3 406991 3300709 45.72 477.59 23.13 2.07 WHB54 406935 3300796 45.72 477.59 23.13 2.07 WHBS5 406976 3300631 56.39 477.59 23.96 2.37Jim Price Page3 of4 September 25, 2009 Modeling Analysis ofLead for Oxbow Calcining LLC Table 3. On-Property Source Modeled Emission Rates

Source Averaging Emission Rates Pollutant ID Time (lb/hr) KS2 Lead 1-hr 0.13 WHBS3 Lead 1-hr 0.22 WHBS4 Lead 1-hr 0.22 WHBSS Lead 1-hr 0.31 5.0 BuildingWake Effects (Downwash). Input datato Building Profile Input Program Prime (BPIP-PRM Version 04274) were providedby Oxbow Calcining LLC. The building locations were validatedbyADMT using aerial photography. 6.0 Meteorological Data. Surface Station and ID: Port Arthur, TX (Station #: 12917) Upper

### Air Station and ID: Lake Charles, LA (Station#: 3937) Meteorological Dataset: 1987-1991 Profile Base Elevation: 16 feet TheAERSURF ACE analysis conducted ofthe area surrounding the Oxbow Calcining LLC site resulted 

### in a calculated roughness length of0.028 meters. Since the AERSURFACE analysis used landcover data from 1992 and since the area near the site hasbecome more developed andurbanized since 1992 basedon comparing the land cover data to 2004 aerial photography, a representative roughness length for the area wouldbe approximately 0.05 meters. For this reason, the meteorological data setused for this analysis was developed using a roughness length of0.05 meters. 7.0 Receptor Grid. The receptor grid used in the modeling analysis consisted ofreceptorswith 1 oo meter spacing and extended approximately 1.5 kilometers (km) from the Oxbow Calcining LLC site propertyline in all directions. The purpose ofthe receptor grid was to determine a representative maximum ground-level concentration and the extent of ground-level concentrations at or above halfofthe lead NAAQS standard.Jim Price Page4 of4 September 25, 2009 Modeling Analysis ofLead for Oxbow Calcining LLC 8.o Model Used andModeling Techniques. AERMOD (Version 07026) was used in a refined screening mode. For refined screening, National Weather Service (NWS) meteorological raw input data are used with generalized surface characteristics ofthe application site. Since the current version ofAERMOD is not capable ofcalculating rolling three-month average concentrations, the EPA postprocessor LeadPost was used. The input values toLeadPost are monthly average values at each receptor in the POSTFILE output format from AERMOD.

# Texas Commission on Environmental Quality

To: Thru:

From: INTEROFFICE MEMORANDUM

David Brymer Air Quality Planning Division Robert Opiela, P.E., Technical Specialist Technical Program Support Section Air Permits Division Matthew Kovar, Megan Cox Air Dispersion ModelingTeam Air Permits Division Date: July 24, 2009

Subject: ModelingAnalysis ofLead for U.S. Army (Fort Hood) (RN101612083) 1.0 Project Identification Information. On November 12, 2008, the U.S. Environmental Protection Agency (EPA) finalized the new 0.15 microgram percubic meter**(~g/m3)** NAAQS for lead based on a rolling threemonth average (73 Federal Register 66964). In general, the rule requires sourceoriented ambient air lead monitoring byJanuary 1, 2010, at sites with actual annual lead emissions ofone or more tons per year. The U.S. Army (Fort Hood) was identified as having emissions at or above this level based on the reported 2007 TCEQ Emissions Inventory and/or 2006 Toxics Release Inventory. The rule further requires thatthis monitoringbe conducted at or near the maximum off-site ambient airlead concentration, as predicted by modeling that results from sources with annual lead emissions ofone or more tons. The TCEQ conducted air dispersion modeling ofall the lead emission sources at the site using the most current modeling parameters. The TCEQ will use the dispersion modeling results to determine the optimal location ofany required source-oriented monitors. ArcReader Published Map: \\Msgjswrk\aod\MODEL PROJECTS\Lead NAAOS Analysis 2009\Lead NMOS Analysis Results.pmf 2.0 Report Summary. Thepredicted maximum groundlevel concentration (GLCmax) is 0.02**~g/m3** for a rolling three-month average. The location ofthe GLCmax is along the southern propertyline. Table 1lists the location ofthe predicted GLCmax. The location coordinates are in the UTM Zone 14 North, North American Datum of 1927 (NAD27) coordinate system.David Brymer Page 2 of4 July 24, 2009 ModelingAnalysis ofLead for U.S. Army (Fort Hood) Table 1. Modeling Results for Lead

Location Location Averaging Easting Northing Time (meters) (meters) 618000 3446900 rolling three-month 3.0 Land Use and Terrain. GLC Standard (ll&fm') (l!gfm')

0.02 0.15

A landuse/land cover analysis was performedusingAERSURF ACE consistent with guidance given in the AERMOD Implementation Guide (March 19, 2009). The recommended input data, the NationalLand Cover Data 1992 archives (NLCD92), were used for this analysis. Terrain elevations within the modeling domain were determined usingAERMAP (Version 09040). The input data used for this analysis was the United States Geological Survey (USGS) National Elevation Dataset (NED) for GatesvilleWest, Gatesville East, Shell Mountains, North Fort Hood, Fort Hood, and Post OakMountains quadrangles. 4.0 Modeling Emissions Inventory. The modeled emission source parameters and emission rates were providedby Fort Hood. The source locations were validatedby ADMT. The source emission rates modeledwerebased on air emissions estimates reported inthe Fort Hood 2007Toxic Release Inventory (TRI). Though the emissions were reported for many firing ranges at various locations around Fort Hood, for this demonstration all ofthe emissions were conservatively represented to be emitted only from the firing ranges nearest the areas ofpublic activity. Fromthe 2007TRI data and activitydata for 2008, the firing ranges with the highest emissions were the furthest away from publiclocations and largest in extent. Public activities are limited to the southern and the northern ends ofFort Hood. The central areas and areas on the east and west ofFort Hood are restricted from public access. The emission rates represent worst case 1-hour average emission rates and maybe more conservativethan 24-hour or monthly average emission rates. Table 2. On-Property SourceModeled Emission Rates

Source Averaging Emission Rates Pollutant 10 Time (lb/hr) NFHS Lead 1-hr 0.0056 NFHR Lead 1-hr 0.0079David Brymer Page 3 of4 July 24, 2009 Modeling Analysis ofLead for U.S. Army (Fort Hood)

Source Averaging Pollutant ID Time OBJID_8 Lead 1-hr OBJID_9 Lead 1-hr

IHSR Lead 1-hr HGQ Lead 1-hr PKGL Lead 1-hr BGRB Lead 1-hr BGPQ Lead 1-hr BGRC Lead 1-hr PKAT4 Lead 1-hr BWPA Lead 1-hr BWPB Lead 1-hr HGC Lead 1-hr NFHRB Lead 1-hr HGDA Lead 1-hr BWGL Lead 1-hr PKRZ Lead 1-hr PKRA Lead 1-hr BWMS Lead 1-hr

PSR Lead 1-hr 

## s.o Building Wake Effects (Downwash). Building downwash is not applicable for area source modeling. 6.0 Meteorological Data. Surface Station and ID: Waco, TX (Station#: 13959) Emission Rates (lb/hr) 0.0105 0.0062 0:0306 0.0026 0.0053 0.0113 0.0017 0.0255 0.0054 0.0018 0.0017 0.0025 0.0128 0.0023 0.0149 0.0068 0.0066 0.0411 0.0367David Brymer Page4 of4 July 24, 2009 Modeling Analysis ofLead for U.S. Army (Fort Hood) UpperAir Station and ID: Stephenville, TX (Station #: 13091) Meteorological Dataset: 1985, 1987, 1988, 1989, 1990 Profile Base Elevation: 499 feet TheAERSURF ACE analysis conducted ofthe area surroundingthe U.S. Army (Fort Hood) site resulted in a calculated roughness length of0.369 meters. Since the AERSURFACE analysis used land cover data from 1992 and sincethe area nearthe site has become more developed and urbanized since 1992based on comparing the land cover data to 2004 aerial photography, a representative roughness lengthfor the area wouldbe approximately 0.5 meters. For this reason, the meteorological data setused for this analysis was developed using a roughness length of0.5 meters. 7.0 Receptor Grid. The two receptor grids used in the modeling analysis consisted ofreceptors with 100 meter spacing. The larger receptor grid was locatedin close proximityto the southern firing ranges and extended approximately 2 kilometers (km) from these firing ranges to the south. The smallerreceptor grid was located in close proximityto the northern firing ranges and extended approximately 2 kmfrom these firing ranges to the northeast. Thepurpose ofthe receptor grid was to determine a representative maximum ground-level concentration and the extent ofground-level concentrations at or abovehalfofthelead NAAQS standard. 8.0 Model Used and Modeling Techniques. AERMOD (Version 07026) was used in a refined screening mode. For refined screening, NationalWeather Service (NWS) meteorological rawinput data are used with generalized surfacecharacteristics ofthe.application site. Since the currentversion ofAERMOD is not capable ofcalculating rolling three-month average concentrations, the EPA post processor LeadPostwas used. The inputvalues to LeadPost are monthly average values at each receptor in the POSTFILE outputformat fromAERMOD.APPENDIX B: TCEQ LEAD MONITORINGNE1WORK

### Table 1: 

### TCEQ LeadMonitoring Network AQS 1 CAMS' Region Site name

48-375-0024 24 1 AmarilloSH 136 48-085-0009 16 4 Frisco GNB
48-085-0007 NA 4 Frisco 7

48-085-0007 NA 4 Frisco 7 (collocated) 48-085-0007 NA 4 Frisco 7

48-085-0003 NA 4 Frisco 5th St

48-085-0029 29 4 Frisco Stonebrook 48-257-0020 20 4 Terrell Temtex 48-201-1034 1 12 Houston East
48-479-0016 44/144 16 Laredo Border 48-061-0006 80/180 16 Brownsville

•Air Quality System (AQS) ' Continuous Air Monitoring Station (CAMS) ' State and Local Air Monitoring Station (SLAMS) • Total Suspended Particles (TSP) Monitor Type SLAMS' SLAMS SLAMS

SLAMS QA' Collocated
SLAMS
NA SLAMSSLAMSSpecial Purpose SLAMS/ Border SLAMS/ Border

s Inductively Coupled Plasma Mass Spectrometry (ICP-MS) • QualityAssurance (QA) Monitoring Objective Highest Concentration Source Oriented Population Exposure Population Exposure Population Exposure Source Oriented NA Highest Concentration General/ Background Population Exposure Population Exposure Sampling Analysis Collection Sample Parameter Activated Frequency Duration code TSP4 for ICP-MS5 Every 6th 24 hours 14129 4/25/2010 Lead Day TSP for ICP-MS Every 6th 24 hours 14129 1/15/1995 Lead Day TSP for ICP-MS Every 6th 24 hours 14129 7/17/1999 Lead Day TSP for ICP-MS Every 6th 24 hours 14129 7/17/1999 Lead Day TSP for ICP-MS Every 6th 24 hours 14129 7/17/1999 Lead- Day Collocated TSP for ICP-MS Every 6th 24 hours 14129 1/1/1984 Lead Day TSP for ICP-MS NA NA NA 1/1/2011 Lead TSP for ICP-MS Every 6th 24 hours 14129 12/1/2010 Lead Day TSP for ICP-MS Every 6th 24 hours 14129 5/11/1999 Lead Day Spectated ICP-MS Every 6th 24 hours 14129 9/12/1996 Day Spectated ICP-MS Every 6th 24 hours 14129 11/11/1995 Day

# WRITTEN AND ORAL TESTIMONYReference Number W-1 

### INDEX OF WRITTEN TESTIMONY

Submitted by Steve SpacekFrom: To: Date: Subject: 04/1512011 12:04 PM <stevespacek.l@gmail.com> <stevespacek.l @gmail.com> 4/15/2011 11:59 AM 2011-005-SIP-NR

This email is a confinnation ofthe comment that was submitted for the referenced rulemaking. fiBt Name: S. Last Name: Spacek Company/Organization: E-ma.il Address: stevespacekl@gma.il.com Street Address: xx City: Washington State: DC Zip Code: 20001 Phone Number: Fax Number: Rule: 2011-005-SIP-NR Conunents: 

# W-1

The State ofTexas ranked as a bottom-ten "worst" state for public-property litter removal efforts in the United States, according to The 2011 American State Litter Scorecard, presented at last month's American Society for Public Administration national conference in Baltimore, MD. Littering, the illegal throwing ofman-made trash onto landscapes, breeds pests, diseases and harms wildlife. Each year, more than 80 Texans and over 800 Americans die in debrisl1itter attributed vehicle accidents, said Steve Spacek, Texas-born and Washington D.C.-based Scorecard Author. States were ranked for resulting environmental quality from their overall public space litter eradication activities (mostly focusing on roadside and adjacent properties) using multiple public performance indicators. The Scorecard tallied the frfty states objectively, using scientific data. and subjectively, using prior peer appraisals, to arrive at a final conclusive score. Spacek hopes the newest results might help his home state make a real difference in improving statewide ecological conditions, since public litter prevention and abatement remains mandated, important functions ofAmerican state governance.

### INDEX OF ORAL TESTIMONY



### NO ORAL TESTIMONYW AS RECEIVED PERTAININGTO THIS SIP REVISION.

# ~Pagel TEXAS COMMISSION ON ENVIRONMENTAL QLJAiJ'TY PUBLIC 

### HEARING REGISTRATION Location: TCEQ Headquarters, Building F, Room 2210 Date· ay 17, 2011, 10:00 a.m. Concerning: Proposed Lead Transport SIP Revision for the 20 Lead NAAQS

NAME

# /~ESENTING PRESENTING ORAL TESTIMONY? (CIRCLE ONE)

# ~0**A+ten;ee~** 

# sfn/UJtl 

# c

# ~/ Yes 

### No 

# /_ 

# v Yes 

### No 

# / Yes 

### No 

# / Yes 

### No 

# / Yes 

### No

Yes 

### No

### TEXAS COMMISSION ON ENVIRONMENTAL QUALITY

HEARING OFFICER REPORT



### I am the hearing officer assigned to conduct the public hearing regarding the proposed state implementation plan revision to incorporate the Lead Transport Plan for the 2008 Lead National Ambient Air Quality Standard (Project No. 2011-005-SIP-NR). A public hearing was scheduled for May 17, 2011, at 10:00 a.m., at the TCEQ headquarters, 12100 Park 35 Circle, Building F, Room 2210. At 10:00 a.m., the room was open, TCEQ staff and a court reporter were present and ready to open the hearing for public comment. After waiting for 15 minutes, no one had arrived to make comments on the record. Therefore, the public hearing was not formally opened for comment and no transcript was prepared.

Date

# ~l~J 

# !2-0 i (

# EVALUATION OF TESTIMONY

# Texas Commission on Environmental Quality Interoffice Memorandum To: 

### Commissioners Date: 

### July 29, 2011 Thru: 

### Melissa Chao, Acting ChiefClerk Mark R. Vickery, P.G., Executive Director

From: 

### Susana M. Hildebrand, P.E.,

## ChiefEngin~ Docket 

### No.: 2011-0065-SIP Subject: 

### Commission Approval for Lead Transport State Implementation Plan (SIP) Revision for the 2008 Lead National Ambient Air Quality Standard (NAAQS) Adoption Non-Rule Project No. 2011-005-SIP-NR Background and reason(s) for the SIP revision: 

### On October 15, 2008, the United States Environmental Protection Agency (EPA) substantially strengthenedthe lead NAAQS. The new standard, set at 0.15 micrograms per cubic meter (!lg/m3) measured as a rolling three-month average, is 10 times more stringent than the previous standard of 1.5 11g/m3 measured as a quarterly average. Section 110(a)(1) ofthe Federal Clean Air Act (FCAA) requires states to submit a SIP revision to provide for the implementation, maintenance, and enforcement ofthe NAAQS. States must adopt and submit new SIP revisions within three years after the promulgation ofa new or revised NAAQS. Section 110(a)(2) lists the elements that the new SIP revisions must contain. Among other things, each state's SIP must contain provisions adequate to prevent emissions that significantly contribute to violations ofthe NAAQS in any other state, interfere with maintenance in any other state, interfere with any other state's required measures to prevent significant deterioration ofits air quality, orinterfere with any other state's required measures to protect visibility. On August 15, 2006, the EPA issued its "Guidance for State Implementation Plan (SIP) Submission to Meet Current Outstanding Obligations Under Section 110(a)(2)(D)(i) for the 8-Hour Ozone and PM2.5 

### National AmbientAir Quality Standards" for states to use to address the §11o(a)(2)(D)(i) interstate transport requirements. The EPA Region 6 communicatedto the Texas Commission on Environmental Quality (TCEQ) on May 17, 2007, thatthe §11o(a)(2)(D)(i) submittal for 1997 eight-hour ozone and 1997fine particulate matter (PM2. 5) 

### shouldbe submitted as a SIP revision, and required notice, comment, and public hearingbythe state. Based onthis previous EPA guidance, the 2008 Lead NAAQS is also likely to require a SIP revision that has been opened to public notice and comment. The EPA has not yet issued additional guidance to address §11o(a)(1) and (2) requirements for the 2008 lead NAAQS.

### Commissioners Page 2 July 29, 2011 Re: Docket No. 2011-0065-SIP Scope ofthe SIP revision: A.) 

### Summary ofwhat the SIP revision will do: 

### The adopted SIP revision would meet the requirements ofthe FCAA, §no(a)(2)(D)(i), relating to the interstate transport oflead under the 2008 lead NAAQS. The SIP revision will reference existing control strategies to reduce the concentration oflead in Collin County, as well as dispersion modeling ofmajor lead sources in Texas. Additionally, the revision verifies thatthe Prevention of Significant Deterioration and Nonattainment New Source Review permitting programs are being implementedin Texas and that lead is not considered a visibility-impairing pollutant. B.) Scope required 

### byfederal regulations or state statutes:



### .Pursuant to FCAA, §no(a)(2)(D)(i), this SIP revision must contain several elements that

provide supporting information demonstrating that Texas is:

• not contributing significantlyto nonattainment ofthe lead NAAQS for areas in other states;

• not interfering with the maintenance ofthe lead NAAQS in any other state;

• not interfering with measures required to meet an implementation plan for any other state related to prevention ofsignificant deterioration; and

• not interfering with measures required to meet the implementation plan for any other state related to regional haze and visibility

.

.C.) 

### Additional staffrecommendations that are not required

### byfederal rule or state statute: 

### None Statutory authority: 

### The authority to propose and adopt the SIP is derived from Texas Health and Safety Code, Texas CleanAir Act (TCAA), §382.002, which provides thatthe policy andpurpose ofthe TCAA is to safeguard the state's air resources from pollution; TCAA, §382.011, which authorizes the commission to control the quality ofthe state's air; TCAA, §382.012, which ;mthorizes the commission to prepare and develop a general, comprehensive plan for the control ofthe state's air; andTexas Water Code, §5.02, General Powers, and §5.013, General Jurisdiction ofthe Commission. The FCAA, 42 USC §§7401, 

### etseq., requires states to submit SIP revisions that specify the manner in which the NAAQS will be achieved and maintained within each air quality control region ofthe state. Additionally, the specific requirements for the 2008 Lead NAAQS were published in the November 12, 2008, issue ofthe 

### Federal Register (73 FR 66963).

### Commissioners Page3 July 29, 2011 Re: Docket No. 2011-0065-SIP

Effect onthe: A.) Regulated community: 

### This SIP revision contains no new control measures and will not affect the regulated community. B.) Public: 

### None C.) Agency programs: 

### This SIP revision will ha\·e no new effect on agency programs. Stakeholder meetings: 

### Because there are no new rules associated with this SIP revision, no stakeholder meetings were held. Public comment: 

### The commission offered <1 

### public hearing for the proposed SIP revision on May 17, 2011, at 10:00 a.m. at the TCEQ llendquarters in Austin. A question and answer session was held 30 minutes prior to the meeting. The hearing was not officially openedbecause no party indicated a desire to give romment. The public comment period openedApril 22, 2011, and closed May 23, 2011. One comment was received, butit was outside the scope ofthe SIP revision. Significant changes from proposal: 

### After proposal, the TCEQ completed modeling for the two facilities that emitbetween o.s tons per year (tpy) and 1.0 tpy oflead: the International Power Coleta Creek Power Station near Fannin and San Miguel Electric Cooperative, Incorporated in Christine. Modeling for these two facilities was conducted after proposal to determine the need for monitoring. Modeled lead emissions from Coleta Creek and San Miguel each result in ambient concentrations ofless thnn 1% 

### ofthe level ofthe 2008 lead NAAQS and indicate that there will be no impact on surrounding areas or states. Potential controversial concerns and legislative interest: 

### Based on the TCEQ's analysis ofTexas' lead nonattainment area and the radius ofimpact ofthe major lead sources in the state, it has been concluded that Texas sources do not impact other states' attainment or maintenance ofthe lead NAAQS. However, the EPA has not yet issued guidance to address §11o(a)(1) and (2) requirements for the 2008lead NAAQS and may require additional analysis to approve this SIP revision. Does this SIP revision affect any current policies or require development of newpolicies? 

### No

### Commissioners Page4 July 29, 2011 Re: Docket No. zon-oo6s-SIP

"What are the consequences ifthis SIP revision does not go forward? Are there alternatives to this SIP revision? 

### The lead transport SIP is required by FCAA, §no(a). If

### a SIP revision is not submitted, the EPA will have an obligation topromulgate a Federal Implementation Plan (FIP) for Texas and possibly to begin a sanctions clock pursuant to FCAA, §179. · Agency contacts: 

### Shelley Naik, SIP Project Manager, 239-1536, Air Quality Division Amy Browning, StaffAttorney, 239-0891, Environmental Law 

### Division

cc: ChiefClerk, 2 copies Executive Director's Office Susana M. Hildebrand, P.E. Anne Idsal Curtis Seaton Ashley Morgan Office of General Counsel Shelley Naik Joyce Spencer

### RESPONSE TO COMMENTS RECEIVED REGARDING THE LEAD TRANSPORT PLAN FORTHE 2008 LEAD NATIONAL AMBIENTAIRQUALITY STANDARD The commission offered a public hearing for the proposed SIP revision on May 17, 2011, at 10:00 a.m. at the TCEQ Headquarters inAustin. A question and answer session was held 30 minutes priorto the meeting. The hearing was notofficially opened, because no partyindicated a desire to give comment. The public comment period opened on April22, 2011, and closed on May 23, 2011. The commission received written comments from one individual. GENERAL COMMENTS One individual expressed concern about public-propertylitter removal efforts in Texas. The purpose ofthis plan is to meet the interstate transport requirements of Federal Clean

### AirAct, §11o(a)(2)(D)(i) bydocumenting that anyleademissions into the air from sources in Texas do not interfere with attainment or maintenance ofthe 2008 Lead National AmbientAir Quality Standard in another state. Litter removal efforts are beyond the scope ofthis plan.

1

# STAFF RECOMMENDATIONSREVISIONS TO THE STATE OF TEXAS AIR QUALTIY IMPLEMENTATION PLAN CONCERNING TRANSPORT EMISSIONS

LEAD TRANSPORT

TEXAS COMMISSION ON ENVIRONMENTAL QUALTIY P.O. BOX 13087 AUSTIN, TEXAS 78711-3087

LEAD TRANSPORT PLAN FORTHE 2008 LEAD NATIONAL AMBIENTAIR QUALITYSTANDARD

PROJECT NUMBER 2011-oos-SIP-NR

Adoption August 17, 2011

### Thispage intentionally left blankEXECUTIVE SUMMARY 

### This revision to the State Implementation Plan (SIP) for lead transport sets forth how the Texas Commission on Environmental Quality (TCEQ) will meet the Federal Clean Air Act (FCAA), §no(a)(1) requirement for states to submit SIP revisions within three years after the promulgation ofnew orrevised National AmbientAir Quality Standards (NAAQS) to meet the requirements ofFCAA, §no(a)(2), including FCAA, §no(a)(2)(D)(i), relating to interstate transport. On October 15, 2008, the United States Environmental Protection Agency (EPA) substantially strengthenedthe NAAQS for lead. The new standard, set at 0.15 micrograms per cubic meter (J.ig/m') measured as a rolling three-month average, is ten times more stringent than the previous standard of 1.5 J.lg/m3 measured as a quarterly average. The purpose ofthis SIP revision is to document that any emissions from sources in Texas do notinterfere with attainmentor maintenance ofthe 2008 leadNAAQS in another state. Section no(a)(2)(D)(i) also contains a requirement for all states to submit SIP revisions that contain adequate provisions prohibiting emissions thatwill interfere with measures required to be includedin the applicable implementation plan in any other state to prevent significant deterioration ofair quality ortoprotectvisibility. The EPA's September 25, 2009, "Guidance on SIP Elements Required Under Sections no(a)(1) and (2) for the 2006 24-Hour Fine Particle (PM,. 5 ) 

### National Ambient Air Quality Standards" indicates thatthese requirements are satisfied ifa state's SIP includes New Source Review (NSR) and Prevention ofSignificant Deterioration (PSD) programs. This SIP revision includes verification that the PSD and NSR permitting programs are being implemented in Texas. According to the EPA's July 6, 2005, regional haze regulations and guidelines for Best Available Retrofit Technology (BART) determinations, lead is not included as a visibility-impairing pollutant and therefore is not expectedto interfere with measures to protectvisibility. The October 15, 2008, final rule for the 2oo8leadNAAQS (73 FR 66964) included a requirement for monitors to be placed in areas with sources, such as industrialfacilities, that emit 1.0 ton peryear (tpy) or more oflead and in urban areas with more than soo,ooo people. The EPA may waive the source-oriented monitoring requirements ifthe monitoring agency demonstrates that emissions from the source would not contribute to maximum air lead concentrations greater than so% ofthe revised standard or 0.075 J.lg/m3. On December 14, 2010, the EPA revised the ambient monitoring requirements for measuring lead in the air. The EPA changedthe emissions threshold for industrial facilities to 0.5 tpy, reduced from the previous threshold of 1.0 tpy. At the time ofproposal, the TCEQ had completed modeling for the five operational facilities that emit 1.0 tpy or more and after proposal completed modeling for the two facilities that emit 0.5 to 1.0 tpy. There are six facilities in Texas that emit 1.0 tpy or more oflead into the air: the United States Army Fort Hood installation near Killeen (Fort Hood), Oxbow Carbon in Port Arthur (Oxbow), the Red River Army Depot nearTexarkana (Red River), theAmerican Smelting and Refining Company facility near Amarillo (ASARCO), the ECS Refining plant inTerrell (ECS), andthe Exide Technologies, Incorporated lead batteryrecycling facility in Frisco (Exide). Two facilities in Texas emitbetween 0.5 and 1.0 tpy oflead into the air: the International Power Coleto Creek Power Station near Fannin (Coleto Creek) and San Miguel Electric Cooperative, Incorporatedin Christine (San Miguel). Modeled lead emissions from Fort Hood and Oxbow each resultin ambient concentrations of less than 15% ofthe level ofthe 2008 lead NAAQS. Additionally, the September 8, 2005, Defense Base Closure and Realignment Commission report pursuant to Sections 2903 and 2914 ofthe Defense Base Closure and Realignment Act of 1990 requires the munitions ES-1

### demilitarization activities at Red River to be relocated to another facility.' These demilitarization activities are scheduled to cease by September 30, 2011. The TCEQ has submittedwaiver requests for the source-oriented lead monitoringrequirements for these three facilities, since emissions from these sources are not expected to contribute to an ambient air concentration of lead greater than so% ofthe NAAQS. Source-orientedleadmonitors have been installed for ASARCO, Exide, and ECS. Modeling ofthe five 2 

### operational facilities indicates thatlead emissions do nottransport over long distances andwill therefore not impact surrounding nonattainment areas, maintenance areas, or states. Modeling for the two facilities that emit between 0.5 and 1.0 tpy was conducted after proposalto determine the needfor monitoring. Modeled lead emissions from Coleto Creek and San Miguel each result in ambient concentrations ofless than 1% ofthelevel ofthe 2008 lead NAAQS and indicate that there will beno impact on surrounding states. FortHood and Oxbow model results predictlevels ofless than 15% ofthe NAAQS. For Exide, ECS, andASARCO the predicted concentrations droppedto below halfthelevel ofthe NAAQS within 2 kilometers ofthe propertyline. To further validate this modeling, there are currently no lead nonattainment or maintenance areas in any ofthe four states thatborderTexas: Louisiana, Oklahoma, Arkansas, and New Mexico. Texas has onlyone nonattainment area under the 2008lead NAAQS. On November 16, 2010, the EPA designated a portion ofCollin County, located in Frisco, Texas, as a leadnonattainment area, effective December 31, 2010 (75 FR71033). This nonattainment area surroundsthe Exide leadbattery recycling facility. An 

### area surrounding Exide was originally designated nonattainmentfor the 1978 lead NAAQS on November 6, 1991. On November 29, 1994, the EPA approved the Collin Countylead attainment demonstration SIP revision. On August 31, 1999, the governor ofTexas submittedto the EPA a requestto redesignate the nonattainmentportion ofCollin County to attainment andto approve a ten-year maintenance plan for the area. The EPA redesignated the area to attainment and approved the ten-year maintenance plan effective December 13,1999 (64 FR55421). In 2009, the governor ofTexas submittedto the EPA the final ten-year maintenance plan for the 1978 leadNAAQS. This SIP revision included contingency measures set in place to promptly correct anyviolations ofthe 1978leadNAAQS. The attainment demonstration for the 2oo8lead NAAQS will 

### be due to the EPAbyJune 30, 2012. Based on the control strategies currently in place to reduce lead emissions inthe Collin County nonattainment area, modeling thatpredicts thatlead emissions from Texas will not impact surrounding states, and lack ofnonattainment or maintenance areas in the four surrounding states, Texas has adequately addressed interstate transport of!ead.

1 

### "zoos Defense Base Closure and Realignment Commission Report," September 8, 2005, http:/ jwww.brac.govfdocsjfinai/BRACReportcomplete.pdf. 2 

### Red ruver was not modeled, because itwill

### be shut down in 2011.

ES-2

### SECI'ION V: LEGAL AUTIIORilY A. 

### General The Texas Commission on Environmental Quality (TCEQ) has thelegal authority to implement, maintain, and enforce the National Ambient Air Quality Standards (NAAQS) and to control the quality ofthe state's air, including maintaining adequate visibility. The first air pollution control act, known as the Clean Air Act ofTexas, was passed bythe Texas Legislature in 1965. In 1967, the Clean Air Act ofTexas was superseded by a more comprehensive statute, the Texas Clean Air Act (TCAA), found in Article 4477-5, Vernon's Texas Civil Statutes. The legislature amended the TCAA in 1969, 1971, 1973, 1979, 1985, 1987, 1989, 1991, 1993, 1995, 1997, 1999, 2001, 2003, 2005, 2007, 2009, and 2011. In 1989, the TCAA was codified as Chapter 382 ofthe Texas Health and Safety Code. Originally, the TCAA stated that the Texas Air Control Board (TACB) was the state air pollution control agency and was the principal authority in the state on matters relating to the quality of air resources. In 1991, the legislature abolished the TACB effective September 1, 1993, andits powers, duties, responsibilities, andfunctions were transferred to the Texas Natural Resource Conservation Commission (TNRCC). With the creation ofthe TNRCC, the authority over air quality is found in both the Texas Water Code and the TCAA. Specifically, the authority ofthe TNRCC is found in Chapters 5 and 7. Chapter 5, Subchapters A- F, 

### H- J, 

### and L, include the general provisions, organization, and general powers and duties ofthe TNRCC, and the responsibilities and authority ofthe executive director. This chapter also authorizes the TNRCC to implement action when emergency conditions arise and to conducthearings. Chapter 7 gives the TNRCC enforcement authority. In 2001, the 77th Texas Legislature continued the existence oftheTNRCC until September 1, 

### 2013, and changed the name ofthe TNRCC to the Texas Commission on Environmental Quality (TCEQ). In 2009, the 81st Texas Legislature, during a special session, amended section 5.014 ofthe Texas Water Code, changing the expiration date of theTCEQ to September 1, 2011, unless continued in existence bythe Texas Sunset Act. In 2011, the 82nd Texas Legislature continued the existence ofthe TCEQ until 2023. TheTCAA specifically authorizes the TCEQ to establish thelevel ofqualityto be maintained in the state's air and to control the quality ofthe state's air by preparing and developing a general, comprehensive plan. The TCAA, Subcliapters A-D, also authorize the TCEQ to collect information to enable the commission to develop an inventory ofemissions; to conduct research andinvestigations; to enter property and examine records; to prescribe monitoring requirements; to institute enforcement proceedings; to enter into contracts and execute instruments; toformulate rules; to issue orders takinginto consideration factors bearing upon health, welfare, social and economic factors, and practicability and reasonableness; to conduct hearings; to establish air quality control regions; to encourage cooperation with citizens' groups and other agencies and political subdivisions ofthe state as well as with industries and the federal government; and to establish and operate a system ofpermits for construction or modification offacilities. Local government authority is found in Subchapter E ofthe TCAA. Local governments have the same power as the TCEQ to enter property and make inspections. They also may make recommendations to the commission concerning any action ofthe TCEQ that affects their territorialjurisdiction, may bring enforcement actions, and may execute cooperative agreements with the TCEQ or other local governments. In addition, a city ortown may enact and enforce

### ordinances for the control and abatement ofair pollution notinconsistentwith theprovisions of the TCAA and the rules or orders ofthe commission. Subchapters G and H ofthe TCAA authorize theTCEQ to establish vehicle inspection and maintenance programs in 

### certain areas ofthe state, consistentwith the requirements ofthe Federal CleanAir Act; coordinate with federal, state, andlocal transportation planning agencies to develop and implement transportation programs and measures necessary to attain and maintain the NAAQS; establish gasoline volatility andlow emission diesel standards; andfund and authorize participating counties to implementvehicle repair assistance, retrofit, and accelerated vehicle retirement programs. B. Ap_plicable Law The following statutes and rules provide necessary authority to adopt andimplementthe state implementation plan (SIP). The ruleslistedbelowhave previouslybeen submitted as partofthe SIP. Statutes All sections ofeach subchapter areincluded, unless otherwise noted. TEXAS HEALTH & 

### SAFETY C.ODE, Chapter 382 TEXASWATERCODE·

. • .· Chapter 5: Texas Natural Resource Conservation Commission Subchapter A; 

### General Provisions September 1, 2009 September 1, 2009

Subchapter B: Organization oftheTexas Natural Resource Conservation Commission Subchapter C: Texas Natural Resource Conservation Commission Subchapter D: General Powers and Duties ofthe Commission Subchapter E: Administrative Provisions for Commission Subchapter F: Executive Director (except §§5.225, 5.226, 5.227, 5.2275,5.231, 5.232, and 5-236) SubchapterH: Delegation ofHearings Subchapter I: Judicial Review Subchapter J: Consolidated Permit Processing Subchapter L: Emergency andTemporary Orders (§§5.514, 5.5145, and5.515 only) Subchapter M: Environmental PermittingProcedures (§5.558 only) Chapter 7: Enforcement SubchapterA: General Provisions (§§7.001, 7.002, 7.0025, 7.004, and7.005 only) Subchapter B: Corrective Action and Injunctive Relief (§7.032 only) Subchapter C: Administrative Penalties Subchapter D: Civil Penalties (except §7.109) Subchapter E: Criminal Offenses and Penalties (§§7.177, 7.179-7.183) Rules All ofthe following rules are found in 30TexasAdministrative Code, as ofthefollowing latest effective dates: ,. 

### Chapter 7: Memoranda ofUnderstanding, §§7.110 and 7.119 December 13, 1996 andMay 2, 2002 Chapter 19: Electronic Reporting March 15, 2007 ii

### Chapter 35: SubchaptersA-C, K: Emergency andTemporary Orders and Permits; Temporary Suspension orAmendment ofPermit Conditions Chapter 39: Public Notice, §§39.201; 39-401; 39-403(a) and (b)(8)-(10); 39-405(f)(1) and (g); 39-409; 39-411 (a), (b)(1)-(6), and (8)-(10) and (c)(1)-(6) and (d); 39-413(9), (11), (12), and (14); 39-418(a) and (b)(3) and (4); 39-419(a), (b), (d), and (e); 39-420(a), (b) and (c)(3) and (4); 39-423 (a) and (b); 39.601-39.605 Chapter 55: Requests for Reconsideration and Contested Case Hearings; Public Comment, §§55.1; 55.21(a)- (d), (e)(2), (3), and (12), (f) and (g); 55.101(a), (b), and (c)(6)- (8); 55.103; 55.150; 55.152(a)(1), (2), and (6) and (b); 55.154; 55.156; 55.200; 55.201(a)- (h); 55.203; 55.205; 55.209, and July 20, 2006

June 24, 2010

55.211 June 24, 2010 Chapter 101: General Air Quality Rules May 12, 2011 Chapter 106: Permits by Rule, SubchapterA May 12, 2011 Chapter 111: Control ofAir Pollution from Visible Emissions and Particulate Matter July 19, 2006 Chapter 112: Control ofAir Pollution from Sulfur Compounds July 16, 1997 Chapter 113: Standards ofPerformance for Hazardous Air Pollutants and for Designated Facilities and Pollutants May 14, 2009 Chapter 114: Control ofAir Pollution from MotorVehicles December 13,2010 Chapter 115: Control ofAir Pollution from Volatile Organic Compounds February 17, 2011 Chapter 116: Permits for New Construction or Modification March 3, 2011 Chapter 117: Control ofAir Pollution from Nitrogen Compounds May 12, 2011 Chapter 118: Control ofAir Pollution Episodes March 5, 2000 Chapter 122: §122.122: Potential to Emit December 11, 2002 Chapter 122: §122.215: Minor Permit Revisions June 3, 2001 Chapter 122: §122.216: Applications for Minor Permit Revisions June 3, 2001 Chapter 122: §122.217: Procedures for Minor Permit Revisions December 11, 2002 Chapter 122: §122.218: Minor Permit Revision Procedures for Permit Revisions Involving the Use ofEconomic Incentives, Marketable Permits, and Emissions Trading

iii 

### June 3, 2001

### SECTION VI: CONfROL STRATEGY A Introduction (No change) B. Ozone (No change) C. Particulate Matter (No change) D. Carbon Monoxide (No change) 

### E. Lead (No change) F. Oxides ofNitrogen (No change) G. Sulfur Dioxide (No change) H. Conformitywith the National AmbientAir Quality Standards (No change) 

### I. Site Specific (No change) 

### J. Mobile Sources Strategies (No change) K. 

### Clean Air 

### Interstate Rule (No change) L. 

### Transport (Revised) M. Regional Haze (No change)

ivTABLE OF CONTENTS 

### Executive Summary Section V: Legal Authority Section VI: Control Strategy Table ofContents List ofAcronyms List ofAppendices Chapter 1: 

### General 1.1 

### Background 1.2 

### Introduction 1.3 

### Health Effects 1.4 

### Public Hearing and Comment Information 1.5 Social and Economic Considerations 1.6 

### Fiscal and Manpower Resources 1.

### 7 Coordination with Local Agencies 1.8 

### Organizations Responsible for Development, Implementation, and Enforcement 1.9 

### Data Availability Chapter 2: 

### Required Control Strategy Elements 2.1 

### Background 2.2 

### Control Strategy Overview 2.2.1 

### Significant Contribution to Nonattainment and Interference with Maintenance Elements 2.2.1.1 

### Dispersion Modeling 2.2.1.2 

### Monitoring Sites 2.2.2 

### Collin County SIP Revisions 2.2.2.1 1993 

### Lead SIP 2.2.2.2 1999 

### Redesignation Request and Maintenance Plan 2.2.2.3 2009 

### SecondTen-Year Maintenance Plan 2.2.2.4 

### Nonattainment Designation Under the 2008 

### Lead NAAQS 2.2.3 

### Prevention ofSignificant Deterioration and Nonattainment New Source Review Elements 2.2.4 

### Protection ofVisibility Element

v

### Chapter 3: Future Revisions to the NationalAmbientAir Quality Standards (NAAQS) Response to Comments Received Regarding the Lead Transport Plan for the 2008 

### Lead NationalAmbientAir Quality Standard Appendices

vi

### LIST OF ACRONYMS 

### BART Best Available Retrofit Technology EPA United States Environmental ProtectionAgency FCAA Federal Clean Air Act FR Federal Register IQ Intelligence Quotient NAAQS National Ambient Air Quality Standard NSR New Source Review PSD Prevention ofSignificant Deterioration PM,_5 

### Fine Particulate Matter SIP State Implementation Plan TAC Texas Administrative Code TACB Texas Air Control Board TCAA Texas Clean Air Act TCEQ Texas Commission on Environmental Quality (commission) TNRCC Texas Natural Resource Conservation Commission tpy tons per year 1-lg/m' micrograms per cubic meter

vii

### Appendix AppendixA AppendixB LIST OF APPENDICES 

### Appendix Name Lead ModelingAnalyses TCEQ LeadMonitoring Network

viii

# - CHAPTER1: GENERAL

1.1 

### BACKGROUND 

### "The History ofthe Texas State Implementation Plan (SIP)," a comprehensive overview ofthe SIP revisions submitted to the United States Environmental Protection Agency (EPA) by the State ofTexas, is available atthe following Web site at: http://www.tceq.texas.gov/airquality/sip/sipintro.html

1.2 

### INTRODUCTION 

### This SIP revision for the transport oflead under the 2008 Lead National Ambient Air Quality Standard (NAAQS) describes how the Texas Commission on Environmental Quality (TCEQ) will meet the requirements of §no(a)(2)(D)(i) Federal Clean Air Act (FCAA), which requires states to submit a SIP that contains adequate provisions thatprohibit any source or other type of emissions activity within the statefrom emitting any air pollutants in amounts that will:

• contribute significantly to nonattainment ofthe NAAQS for areas in other states; • interfere with maintenance ofthe NAAQS byany other state; • interfere with measures required for any other state to meet an implementation plan related to Prevention ofSignificant Deterioration; or • interfere with measures required for any other stateto meet the implementation plan related to regional haze and visibility. Based onthe control strategies already in place to reduce lead emissions in the Collin County nonattainment area, modeling that predicts that lead emissions from Texas will not impact surrounding states, and lack ofnonattainmentor maintenance areas in the four surrounding states, this SIP revision demonstrates that Texas has adequately addressed the FCAA §uo(a)(2)(D)(i) requirements. 1.3 HEALTH EFFECTS 

### On October 15, 2008, the EPA substantially strengthenedthe NAAQS for lead. The new standard, set at 0.15 micrograms per cubic meter (J.ig/m') measured as a rolling three-month average, is ten times more stringent than the previous standard of 1.5 J.ig/m' measured as a quarterly average. According to the EPA, scientific evidence about lead and its potential health effects has expanded dramatically since the EPA issued the initial standard of 1.5 J.lg/m' in 1978, and more than 6,ooo new studies on lead health effects, environmental effects, andlead in the air have been published since 1990. Evidence from health studies shows that adverse effects occur at much lower levels oflead in blood than previously thought. · Lead that is emitted into the air canbe inhaled directly or ingested after it settles onto surfaces or soils. However, for the general population, exposure to lead occurs primarilyvia ingestion through contact with contaminated soils or other surfaces. Once taken into the body, lead distributes throughout the body in the blood and accumulates in thebones. Depending onthe level ofexposure, lead can adversely affect the nervous system, kidney function, immune system, reproductive and developmental systems, and the cardiovascular system. Lead exposure also affects the oxygen-carrying capacity oftheblood. The lead effects most commonly encountered in currentpopulations are neurological effects in children and cardiovascular effects (e.g., high blood pressure and heart disease) in adults. Children are at a relatively higher risk ofexposure to lead when compared to adults. The risk of exposure is higher because children tend to put their hands and other objects which may contain

1·1

### lead into their mouths (e.g., lead-basedpaintchips from older homes). Children also have a higher risk ofadverse effects because theirbrains are still developing. Infants andyoung children are especially sensitive to lowlevels oflead, which may contribute to behavioral problems, learning deficits, andlowered intelligence quotient (IQ). 14 PUBLIC HEARINGAND COMMENT INFORMATION The commission offered a public hearing for the proposed SIP revision on May 17, 2011, at 10:00 a.m. at the TCEQ Headquarters inAustin. Aquestion and answer session was held 30 minutes prior to the meeting. The hearing was not officially opened, because no party indicated a desire to give comment. The public comment period opened on Apri!22, 2011, and closed on May 23, 2011. Written comments were acceptedvia mail, fax, orthroughthe eComments system. A summaryofthe comment andthe TCEQ response is provided as part ofthis SIP revision inthe

### Response to Comments. Copies ofthe proposed SIP revision andits appendices canbe obtained from the TCEQ Web site at: http://www.tceq.texas.gov/airquality/sip/criteria-pollutants/sip-lead. 1.5 SOCIALAND ECONOMIC CONSIDERATIONS Because rulemaking is not a partofthis SIP revision, there are no changes that would have an impact on society orthe economy. 1.6 FISCALAND MANPOWERRESOURCES The TCEQ has determinedthat its fiscal and manpower resources are adequate and will 

### notbe adversely affected through the implementation ofthis 

### plan. 1.7 

### COORDINATION WITH LOCAL AGENCIES The TCEQ has determinedthatthere will 

### be no assignment tolocal agencies. However, preexisting assignments to local agencies regarding various enforcement activities remain in effect and couldbe utilized if

### enforcement activities are delegatedtothe TCEQ from the EPA. 1.8 ORGANIZATIONS RESPONSIBLE FORDEVEWPMENT, IMPLEMENTATION, AND ENFORCEMENT The TCEQ is the agency delegated authoritybythe Texas Legislature regarding the protection of air quality in the State ofTexas. Otherlocal government entities have limited authority regarding air quality matters in

### the State ofTexas. 1.9 DATAAVAIIABILTIY The TCEQ affiffilS thatit will 

### retain all dataused in the preparation ofthis 

### SIP revision. All supporting documents anddata are publicly available via the TCEQ Web site at: htt:p:(/www.tceg.texas.gov/airquality/sip or are available from the TCEQ upon request.

1-2

### CHAPTER 2: 

### REQUIRED CONTROL STRATEGY ELEMENTS

2.1 

### BACKGROUND 

### There are currently six facilities in Texas that emit 1.0 ton peryear (tpy) or more oflead. They are the United StatesArmy Fort Hood installation near Killeen (Fort Hood), Oxbow Carbon in PortArthur (Oxbow), the Red River Army Depot near Texarkana (Red River), the American Smelting and Refining Company facility nearAmarillo (ASARCO), the ECS Refining plantin Terrell (ECS), and the Exide Technologies, Incorporatedleadbattery recycling facility in Frisco (Exide). Dispersion modeling oflead emissions from the five operationalfacilities (the Red River Army Depot was notmodeledbecause itwill be shut down in 2011) indicates thatlead does not transport over long distances andwill therefore not impact the four surrounding states: Louisiana, Arkansas, New Mexico, and Oklahoma. There are currently no lead nonattainment or maintenance areas in any ofthese four states. Texas has only one nonattainment area under the 2008 Lead National Ambient Air Quality Standard (NAAQS). On November 16, 2010, the United States Environmental Protection Agency (EPA) designated a portion ofCollin County, located in Frisco, Texas, as a lead nonattainment area, effective December 31, 2010 (75 FR71033). This nonattainment area surrounds the Exide leadbattery recycling facility. An 

### area surrounding Exide is currently a maintenance area under the 1978 Lead NAAQS. Control measures are in place under this maintenance plan. The attainmentdemonstration for the 2008 Lead NAAQS is due tothe EPA by

### June 30, 2012, and will include additional control measures, ifnecessary, to meet the attainment deadline of December 31, 2015. Texas has existing control strategies in place in Collin County andmodeling that indicates that lead emissions from the six statewide sources that emit 1.0 tpy or more will not transport to surrounding states. Therefore, interstate transport oflead emissions in Texas has been adequately addressed.
2.2 

### CONTROL STRATEGY OVERVIEW 

### Federal Clean Air Act (FCAA) §11o(a)(2)(D)(i) requires statesto submit a state implementation plan (SIP) revision that contains adequate provisions to prohibit any source or other type of emissions activity within the state from emitting any air pollutants in amountsthatwill:

• contribute significantly to nonattainment ofthe NAAQS for areas in other states; • interfere with maintenance ofthe NAAQS in any other state; • interfere with measures for any other state required to meet an implementation plan related to Prevention of Significant Deterioration (PSD); or • interfere with measures required for any other stateto meet the implementation plan related to regional haze andvisibility.

2.2.1 

### Significant Contribution to Nonattainment and Interference with 

### Maintenance Elements 2.2.1.1 Dispersion Modeling The October 15, 2008, final rule for thelead NAAQS included a requirement for monitors to be placed in areas with sources such as industrial facilities that emit 1.0 tpy or more oflead and in urban areas with more than soo,ooo people. The EPA may waive the source-oriented monitoringrequirements ifthe monitoring agency demonstrates that emissions from the source would not contribute to maximum air lead concentrations greaterthan so% ofthe revised standard, or 0.075 micrograms per cubic meter (J.lg/m'). On December 14, 2010, the EPA

2-1revised the ambient monitoring requirements for measuring lead in the air. The EPA changed the emissionsthresholdfor industrial facilities to o.s tpy, reduced from the previous threshold of 1.0 tpy. At thetime ofproposal, the Texas Commission on Environmental Quality (TCEQ) had completed modeling for thefive operational facilities that emit1.0 tpy ormore and after proposal completed modeling for the two facilities that emitbetween o.s tpyand 1.0 tpyto determine the need for monitoring nearthose facilities. Six facilities inTexas emit 1.0 tpy or more ofleadinto the air: Fort Hood, Oxbow, Red River, ASARCO, ECS, and Exide. Two facilities in Texas emitbetween 0.5 tpy and 1.0 tpy oflead into the air: the International Power Coleto Creek Power Station near Fannin (Coleto Creek) and San Miguel Electric Cooperative, Incorporated in Christine (San Miguel). Modeledlead emissions from Fort Hood and Oxbow result in predicted concentrations oflessthan 15% ofthe 2008lead NAAQS. Additionally, the September 8, 2005, Defense Base Closure and Realignment Commission report pursuant to Sections 2903 and 2914 ofthe Defense Base Closure and RealignmentAct of 1990 requires the munitions demilitarization activities at Red River tobe relocated to another facility. These demilitarization activities are scheduledto cease by September 30, 2011. TheTCEQ has submittedwaiver requests for the source-orientedlead monitoring requirements for these three facilities since emissions from these sources are not expected to contribute to an ambient air concentration oflead greaterthan 50% ofthe NAAQS. Source-orientedlead monitors have been installedforASARCO, Exide, and ECS. Modeling of thefive' operational facilities indicates that lead emissionsfrom sources atthose facilities do not transport overlong distances and will therefore notimpact surrounding states. Fort Hood and Oxbow model results predict levels oflessthan 15% ofthe NAAQS. For Exide, ECS, and ASARCO the predicted concentrations dropped to below halfthe level ofthe NAAQS within 2 kilometers ofthepropertyline. Modeling for thetwo facilities that emitbetween 0.5 and 1.0 tpy was conducted afterproposal to determinethe needfor monitoring. Modeled lead emissions from Coleto Creek and San Miguel each result in ambient concentrations of!essthan 1% ofthe level ofthe 2oo8lead NAAQS, and indicatethatthere willbe no impact on surrounding states. Thefinding thatlead does nottransport overlong distances is supportedbythe EPA in the December 14, 2010, "Revisions to LeadAmbientAir Monitoring Requirements." Inthatfinal rule, the EPA indicated when selecting airports for an airport monitoring study, "We selected a maximum distance to ambient 

### airfrom the location ofmaximum emissions of 150 meters becausethe available information indicatesthat ambientlead concentrations drop offquickly with distance, and it islesslikely that an exceedance ofthelead NAAQS 

### will occur at greater distances."• To further validatethisfinding, there are currently no lead nonattainment or maintenance areas in any ofthefour states surroundingTexas: Louisiana, Oklahoma, Arkansas, andNew Mexico. Details ofthe dispersion modeling conductedbythe TCEQ canbe found in Appendix A: 

### LeadModelingAnalyses. 2.2.1.2 Monitoring Sites The TCEQ leadmonitoringnetworkcurrentlyincludes 15 lead monitors inAmarillo, El Paso, Frisco, Terrell, Houston, Laredo, and Brownsville. These sites are listed inAppendix B: TCEQ 

### LeadMonitoringNetwork. This list includes the EPA-required source-orientedmonitors for lead sources that emit 1.0 tpy or more, except for those for which theTCEQ has submitted waiver requests. Changes tothelead monitoring requirements publishedbythe EPA in the

3 Red River was not modeled, because it will be shut down in 2011. • EPA, "Revisions to LeadAmbientAirMonitoring Requirements," December 14, 2010, http:/ jwww.epa.govjair/lead/pdfs/PbRevision-ForPublication.pdf 2-2

### Federal Register on December 27, 2010, require source-oriented lead monitors for industrial sources that emit 0.5 tpy or more and operation ofonelead monitor at each site that is part of the multi-pollutant site network known as the National Core Monitoring Network. After proposal ofthis SIP revision, modeling for the two sources that emit between 0.5 and 1.0 tpy was conductedby the TCEQ, and modeled emissions results for both facilities showed ambient concentrations ofless than 1% ofthe level ofthe 2oo8lead NAAQS. Waiver requests for both sources will be submitted in .July 2011 asAppendix A to the 

### TCEQ 2011

### AnnualAmbientAir Monitoring Network Rcl'icw. The final rule also requires lead monitors to be installed at Stinson Municipal Airport in Bexar County and Northwest Regional Airport in Denton County for a one-year airport monitoring study. The new monitors are required to be operational no later than December 27, 2011.

2.2.2 Collin County Sll' Re\isions 

### 2.2.2.1 1993 Lead SIP On November 6, 1991, thl' EPA publishedthe notice ofnonattainment designation for leadinthe 

### Federal Register (56 FR 5661)4) for the portion ofCollin Countythat essentially encompassed the plant boundaries of thl' Gould National Battery, Incorporatedfacility, later known as GNB Technologies, Incorporatl'u (G:\'B), and now known as Exide Technologies, Incorporated (Exide). The effective dall' of the nonattainment designation was January 6, 1992. Underthe federal guidelines, the Texas Air Control Board, a predecessor agency to the TCEQ, responded by submitting a site-specific SIP revision to the EPA on June 18,1993. Under the FCAA, the Collin County nonattainml'nt area was required to attain the 1978leadNAAQS byJanuary 6, 1997· The 1993 SIP revision includes an air quality analysis through the fourth quarter of 1992, a 1992 emissions inventory, dispersion modeling that demonstrated NAAQS attainment for the area, control measures in Board Order Number 92-09(k), contingency measures in Board Order Number 93-12, and state Kew Source Review (NSR) provisions for lead sources. The EPA approved the SIP revision on**~ovember** 

### 29, 1994 (59 FR 60930). The approval became effective January 30, 1995. 2.2.2.2 1999 Redesignation Request and Maintenance Plan On August 31, 1999, Texas submitted to the EPA a request that Collin County be redesignated from a nonattainment to an attainment area and a maintenance plan that meets FCAA §175A requirements. The maintenance plan contained an agreed order with GNB (now Exide), making emissions reductions that had occurred since 1993 permanent and enforceable. The permanence ofthese reductions was to be maintained through permit restrictions, emissions limits, and standard operating procedures for controlling emissions from process sources, process fugitive sources, andfugitive dust sources from National Emissions Standards for Hazardous Air Pollutants mandated maximum achievable control technology for secondary lead smelters. The plan also included contingency measures that hadbeen included in the 1993 attainment demonstration and that GNB had already implemented. For example, the company added a supplemental ventilation baghouse to its metallurgical furnace operation, enclosed areas that had previously not been enclosed and improved maintenance and operating procedures. The plan also included new contingency measures, their associated triggers, and a description ofthe monitoring network that would be used to determine when an exceedance ofthe lead NAAQS occurred for the purpose oftriggering contingency measure notification during the ten-year maintenance period. The contingency measures would require GNB to (1) install a new wheel washing facility; (2) install a scale and automatic tuyere punching device at theblastfurnace;

2-3

### and (3) install an alternative measurethatwill provide, at a minimum, emissions reductions equivalent tothoselisted previously. The EPA approvedthe redesignation request and maintenance plan on October 13, 1999, effective December 13, 1999 (64 FR 55421). 2.2.2.3 2009 Second Ten-Year Maintenance Plan FCAA §175A requires submission ofan additional SIP revision to provide for maintenance ofthe 1978 NAAQS for leadfor the secondten-year period following redesignation ofthe nonattainment area to attainment. On August 26, 2009, the commission approved this maintenance plan for the Collin County area. The 2009 maintenance plan included new contingencymeasures setinplace topromptly correct any violations ofthe 1978lead NAAQS. The contingency measures wouldrequire Exide to (1) automate the scale and feed for the reverberatory furnace; (2) expand the existing water misting dust suppression system; and (3) utilize an alternative measure thatwill provide, at a minimum, emissions reductions equivalent to thoselistedpreviously. The contingency measures were madelegally enforceable under an agreed order adopted concurrentlywith the maintenance plan. 2.2.2.4 Nonattainment Designation Under the 2008 Lead NAAOS Texas has one nonattainment area underthe 2008lead NAAQS. On November 16, 2010, the EPA designated an area surroundingthe Exide lead recycling facility in Collin County, Texas as a lead nonattainment area. The attainment demonstration for the 2008 lead NAAQS is due tothe EPA byJune 30, 2012, andwill include control measures necessary to meetthe attainment deadline ofDecember 31, 2015. · 2.2.3 

### Prevention ofSignificant Deterioration and NonattainmentNew Source ReviewElements FCAA §no(a)(2)(D)(i)(II) contains a requirementfor states to submit SIP revisions that contain adequate provisionsto prohibit any source or type ofemissions activity within the state from emitting air pollutants in amounts thatwill 

### interfere with another state's SIP measuresfor preventing significant deterioration ofair quality. The EPA's September 25, 2009, "Guidance on SIP Elements Required Under Sections no(a)(1) and (2) for the 2006 24-Hour Fine Particle (PM2.5) 

### National Ambient Air Quality Standards" indicates that these requirements are satisfied ifa state's SIP includes NSR and PSD programs. All major sources inTexas are subjectto PSD and nonattainment NSRpermittingprograms, implemented in 30 Texas Administrative Code (TAC) Chapter n6. Major sources are defined in 30 TAC §116.12(17) in relation to thefederal classification ofan areafor nonattainment permitting andby reference to 40 Code ofFederal Regulations §51.166 for PSD.

2.2-4 

### Protection ofVisibilityElement Section no(a)(2)(D)(i)(ll) also contains a requirementfor all statesto submit SIPs that contain adequate provisions prohibiting "

... any source or othertype ofemission activity within the state from emitting any airpollutant in amounts which will 

### interfere with measures required to be included in the applicable implementation plan for any other state

.... to protectvisibility." On July 6, 2005, the EPA published regional haze regulations and guidelines for BestAvailable Retrofit Teclmology (BARn determinations in the

### Federal Register. The BART guidelines include the following list ofvisibility-impairingpollutants: sulfur dioxide, nitrogen oxides, particulate matter, volatile organic compounds, and ammonia. Leadis notincluded as a visibility-impairing pollutant andtherefore is not expected to interfere with measures toprotect visibility in anyother state. 2-4

### CHAPTER 3: FUTURE REVISIONS TO THE NATIONALAMBIENT AIR QUALI1Y STANDARDS (NAAQS) Federal Clean Air Act (FCAA), §uo(a)(l) requires states to submit state implementation plans within three years after the promulgation ofnew or revised NAAQS to meet the requirements of FCAA, §uo(a)(2), including FCAA, §uo(a)(2)(D)(i), relating to interstate transport. Therefore, ifthe NAAQS are revised in the future, the Texas Commission on Environmental Quality will need to take the adequate steps relating to the interstate transport ofair pollution.

3-1APPENDIX A: LEAD MODELINGANALYSES

# Texas Commission on Environmental Quality

To: Thru:

From: INTEROFFICE MEMORANDUM

David Brymer Air Quality Planning Division Robert Opiela, P.E., Technical Specialist Technical Program Support Section Air Permits Division Matthew Kovar, Megan Cox Air Dispersion Modeling Team Air Permits Division Date: June 22, 2009

Subject: Modeling Analysis ofLead for Asarco LLC (RN101701654) 1.0 Project Identification Information. On November 12, 2008, the U.S. Environmental Protection Agency (EPA) finalized the new 0.15 microgram per cubic meter (f!g/m3) NAAQS for leadbased on a rolling threemonth average (73 

### Federal Register 66964). In general, the rule requires sourceoriented ambient air lead monitoring byJanuary 1, 2010, at sites with actual annual lead emissions ofone or more tons per year. Asarco LLC was identified as having emissions at or above this level based on the reported 2007TCEQ Emissions Inventory and/or 2006 Toxics Release Inventory. The rule further requires that this monitoring be conducted at or near the maximum off-site ambient air lead concentration, as predictedby modeling, that results from sources with annual lead emissions ofone or more tons. The TCEQ conducted air dispersion modeling ofall the leademission sources at the site using the most current modeling parameters and associated permitted allowable emissions rates. The TCEQ will use the dispersion modeling results to determine the optimal location ofany required source-oriented monitors. ArcReader Published Map: \\Msgiswrk\apd\MODEL PROJECTS\Lead NAAOS Analysis 2000\Lead NAAOS Analysis Results.pmf 2.0 Report Summary. The predicted maximum ground level concentration (GLCmax) is 0.21 f!g/m3 for a rolling three-month average. The location ofthe GLCmax is along the southeastern propertyline. All predicted concentrations exceeding the NAAQS are located to the southeast ofthe Asarco LLC site and extended less than 150 meters from the site propertyline. Table 1liststhe location ofthe predicted GLCmax. The location coordinates are in the UTM Zone 14 North, North American Datum of 1927 (NAD27) coordinate system.

### David Brymer Page2of4 June22,2009 ModelingAnalysis ofLead for Asarco LLC Table 1. 

### Modeling Results for Lead

252500 3906900 rolling three-month 

### 3.0 Land Use and Terrain. 0.21 0.15



### A land usefland cover analysis was performed using AERSURF ACE consistent with guidance given in theAERMOD Implementation Guide (March 19, 2009). The recommended input data, the National Land Cover Data 1992 archives (NLCD92), were used for this analysis. Terrain elevations within the modeling domainwere determined using AERMAP (Version 09040). The inputdataused for this analysis were United States Geological Survey (USGS) digital elevation models (DEMs) for Pullman, Amarillo East, Mayer, and PleasantValley data sets. 4.0 Modeling Emissions Inventory. The modeled emission source parameters and emission rates were providedbyAsarco LLC. The sourcelocations were validatedby ADMT using aerial photography. Only source 7A has a listed maximum allowable emission ratefor lead. For the otherthree sources, emissions estimates were submitted byAsarco LLC and then validated byAPD permit reviewing stafffor use inthis analysis. The emission rates represent worst case 1-hour average emission rates and maybe more conservative than 24-hour or monthly average emission rates. The emission source coordinates are in

### the UTM Zone 14 North, NorthAmerican Datum of 1927 (NAD27) coordinate system. Table 2. On-Property Point Source Parameter Information

7A 251881.8 3907527.8 24.99 456.48 1.19 5.49 48 251554.8 3907622.8 38.71 310.37 12.31 1.22 6A 251623.8 3907942.8 30.48 388.71 0.65 5.49 60 251732.8 3907896.8 30.48 408.15 0.87 5:49

### David Brymer Page 3 of4 June 22, 2009 Modeling Analysis of Lead for Asarco LLC Table 3. On-Property Source Modeled Emission Rates

. Source Pollutant Averaging Emission Rates lD Time (lb/hr) 7A Lead 1-hr 4.27 46 Lead 1-hr 0.48 6A Lead 1-hr 0.02 6D Lead 1-hr 0.04 

### 5.0 Building Wake Effects (Downwash). Input data to Building Profile Input Program Prime (BPIP-PRM Version 04274) were providedby Asarco LLC. The building locations were validated by ADMT using aerial photography. 6.0 

### Meteorological Data. Surface Station and ID: Amarillo, TX (Station#: 23047) Upper Air Station and ID: Amarillo, TX (Station#: 23047) Meteorological Dataset: 1987, 1988, 1989, 1990, 1991 Profile Base Elevation: 3591 feet The AERSURFACE analysis conducted ofthe area surrounding the Asarco LLC site resulted in a calculated roughness length of 0.155 meters. The vast majority ofthe area considered industrial and urbanized (and with a higher roughness length) is concentrated near the emission sources. The dispersion ofemissions from the sources will be 

### lrighly influencedby tlris lrigher roughness length. A representative roughness length for the area would be approximately 0.5 meters. For this reason, the meteorological data set used for tlris analysis was developed using a roughness length of0.5 meters. 7.0 

### Receptor Grid. The receptor grid used in the modeling analysis consisted ofreceptors with 100 meter spacing and extended approximately 2 

### kilometers (krn) 

### from the Asarco LLC site propertyline in all directions. The purpose ofthe receptor grid was to determine a representative maximum ground-level concentration and the extent ofground-level concentrations at or above halfofthe lead NAAQS standard.

### David Brymer Page 4 of4 June 22, 2009 

### Modeling Analysis ofLead for Asarco LLC S.o Model Used andModeling Techniques. AERMOD (Version 07026) 

### was usedin a refined screening mode. Forrefined screening, NationalWeather Service (NWS) meteorological raw inputdata are used with generalized surface characteristics ofthe application site. Since the current version ofAERMOD 

### is not capable ofcalculating rolling three-month average concentrations, the EPA post processor LeadPost was used. The inputvalues to LeadPost are monthly average values at eacb receptor inthe POSTFILE outputformat from AERMOD.

# Texas Commission on Environmental Quality INTEROFFICE MEMORANDUM

To: Thru:

From: Da,;d Brymer Date: Air Quality Planning Division Robert Opiela, P.E., Technical Specialist Technical Program Support Section Air Permits Di\ision Matthew Kovar, Megan Cox Air Dispersion Modeling Team Air Permits Di,ision June 29, 2009

Subject: Modelin!' Analysis ofLead for ECS Refining Texas LLC (RN10o804467) 1.0 Project Identification Information. On November 12, :!Oo8, the U.S. Emironmental Protection Agency (EPA) finalized the new 0.15 microgram per cubic meter (J.Lg/m') NAAQS for lead based on a rolling threemonth average (73 

### l·hlcra/Register 66964). In general, the rule requires sourceoriented ambient air lead monitoringbyJanuary 1, 2010, at sites with actual annual lead emissions ofonL' or more tons peryear. ECS Refining Texas LLC was identified as ha\ing emissions at or above this level based on the reported 2007TCEQ Emissions Inventory and/or 2006 Toxics Release Inventory. The rule further requires thatthis monitoring be conducted at or near the maximum off-site ambient air lead concentration, as predicted by modeling, that results from sources with annual lead emissions ofone or more tons. The TCEQ conductcd air dispersion modeling ofall the leademission sources at the site using the most current modeling parameters and associated permitted allowable emissions rates. The TCEQ will use the dispersion modeling results to determine the optimal location of any requiredsource-oriented monitors. ArcReader Published Map: \\Msgiswrk\apd\:\IODEL PROJECTS\Lead NAAOS Analysis 2oog\l..ead NAAOS Analysis Results.pmf 2.0 Report Summa!}·. The predicted maximum groundlevel concentration (GLCmax) is 4.06 J.Lg/m' for a rolling three-month average. The location ofthe GLCmax is along the northern propertyline. All predicted concentrations exceeding the NAAQS are located within approximately 1.1 kilometers (km) 

### to the north, 0.7 km

### to the west, 0.6 km

### to the south, and 0.3 km 

### to the east ofthe site propertyline. Table I 

### lists the location ofthe predicted GLCmax. Thelocation coordinates are in the UTM Zone 14 North, NorthAmerican· Datum of 1927 (NAD27) coordinate system.

### David Brymer Page 2 of4 June 29, 2009 Modeling Analysis of Lead for ECS Refining Texas LLC Table 1. Modeling Results for Lead

751500 362440 rolling three-month 

### 3.0 Land Use and Terrain. ""

## )~LC. "•""•"" 

# •<ll&lm'>

4.06**St~ndard"** (ll&/m') '"

0.15



### A land use/land cover analysis was performed usingAERSURF ACE consistent with guidance given in the AERMOD Implementation Guide (March 19, 2009). The recommended input data, the National Land Cover Data 1992 archives (NLCD92), were used for this analysis. Terrain elevations within the modeling domain were determined using AERMAP (Version 09040). The input data usedfor this analysis was the United States Geological Survey (USGS) National Elevation Dataset (NED) for Terrell North, Terrell South, Forney North, andForney South quadrangles. 4.0 Modeling Emissions Inventory. The modeled emission source parameters and emission rates were providedby ECS Refining Texas LLC. The source locations were validatedbyADMT using aerial photography. The sourceemission rates modeled were consistent with the maximum allowable emission rates authorized througll permit 19430.The emission rates represent worst case 1-hour average emission rates andmaybe more conservative than 24-hour or monthly·average emission rates. The emission source coordinates are inthe UTM Zone 14 North, NorthAmerican Datum of 1927 (NAD27) coordinate system. Table 2. 

### On-PropertyPoint Source Parameter Information

P6 751508.5 3624260.2 16.04 310.04 8.84 0.78 P12 751514.5 3624253.2 12.85 303.87 16.74 1.07 P14 751488.5 3624262.2 17.63 305.15 12.93 1.12 P15 751494.5 3624268.2 17.28 308.15 13.47 0.66 P17 751464.5 3624251.2 11.4 312.32 6.1 0.48

### David Brymer Page3 of4 June 29, 2009 Modeling Analysis of Lead for ECS Refining Texas LLC Table 3. On-Property Source Modeled Emission Rates

Source**Av~aging** Emission Rates Pollutant ID Time (lb/hr) P6 Lead 1-hr 0.32 P12 Lead 1-hr 0.04 P14 Lead 1-hr 1.01 P15 Lead 1-hr 0.1 P17 Lead 1-hr 0.11 

### 5.0 Building Wake Effects (Downwash). Input data to Building Profile Input Program Prime (BPIP-PRM Version 04274) were providedby ECS Refining Texas LLC. The building locations were validated by ADMT using aerial photography. 6.0 Meteorological Data. Surface Station and ID: Dallas/FortWorth, TX (Station#: 03927) Upper Air Station and ID: Stephenville, TX (Station#: 13091) Meteorological Dataset: 1985, 1987, 1988, 1989, 1990 Profile Base Elevation: 551 feet The AERSURF ACE analysis conducted ofthe area surrounding the ECS Refining Texas LLC site resulted in a calculated roughness length of0.109 meters. Since the AERSURF ACE analysis used land cover data from 1992 and since the area near the site has become more developed and urbanized since 1992 based on comparing the land cover data to 2004 aerial photography, a representative roughness length for the area would be approximately 0.5 meters. For this reason, the meteorological data setused for this analysis was developed using a roughness length of0.5 meters. 7.0 Receptor Grid. The receptor grid used in the modeling analysis consisted ofreceptors with 100 meter spacing and extended approximately 3 kilometers (km) 

### from the ECS Refining Texas LLC site property line in all directions. The purpose ofthe receptor grid was to determine a representative maximum ground-level concentration and the extent of ground-level concentrations at or above halfofthe lead NAAQS standard.

### David Brymer Page4of4 June 29, 2009 

### ModelingAnalysis ofLead for ECS Refining Texas LLC S.o Model Used and Modeling Techniques. AERMOD (Version 07026) 

### was used in a refined screening mode. For refined screening, National Weather Service (NWS) meteorological raw input data are used with generalized surface characteristics ofthe application site. Since the currentversion ofAERMOD is not capable ofcalculating rolling three-month average concentrations, the EPA post processor LeadPostwas used. The inputvalues to LeadPost are monthly average values at each receptor in the POSTFILE outputformat from AERMOD.

# Texas Commission on Environmental Quality

To:
Thru:

From: INTEROFFICE MEMORANDUM

David Brymer Date: Air Quality Planning Division Robert Opiela, P.E., Technical Specialist Technical Program Support Section Air Permits Division Matthew Kovar, Megan Cox Air Dispersion Modeling Team Air Permits Division October 8, 2010



### Subject: Modeling Analysis ofLead for Exide Technologies, Frisco Battery Recycling Plant (RN100218643)
1.0 

### Project Identification Information. On November 12, 2008, 

### the U.S. Environmental Protection Agency (EPA) finalized the new 0.15 

### microgram per cubic meter (J.!g/m3) NAAQS for leadbased on a rolling threemonth average (73 

### Federal Register 66964). 

### In general, the rule requires sourceoriented ambient air lead monitoringbyJanuary 1, 2010, 

### at sites with actual annual lead emissions ofone or more tons peryear. Exide Technologies, Frisco Battery Recycling Plant was identified as having emissions at or above this level based on the reported 2007

### TCEQ Emissions Inventory and/or 2006 

### Taxies Release Inventory. The rule further requires that this monitoring be conducted at or near the maximum off-site ambient air lead concentration, as predictedby modeling, that results from sources with annual lead emissions ofone or more tons. In 2009, 

### the TCEQ conducted air dispersion modeling ofall thelead emission sources atthe site using the most current modeling parameters and associated permitted allowable emissions rates. In October 2010, 

### Exide Technologies submittedinformation to theTCEQ documenting a reduction in permitted allowable emission rates for some sources. Some ofthese reductions will be validated through stack testing at a future date. This modeling analysis addresses those emission reductions and supersedes the previous modeling analysis report (NSRG document #9136). 

### The TCEQ will use the dispersion modeling results to determine the optimal location ofany required sourceoriented monitors. Since monitoring already exists at and nearthe Exide Technologies site, and monitored values exceeding the new lead standard have been recorded, the dispersion modeling results will 

### also be used to determine the proposed boundaries ofa lead nonattainment area. ArcReader Published Map: \\Msgiswrk\apd\MODEL PROJECTS\Lead NAAOS Analysis 2010 

### revised\Lead NAAOS Analysis Results 2010 

### revised.pmf

### David Brymer Page2of7 October 8, 2010 Modeling Analysis ofLead for Exide Technologies, Frisco Battery Recycling Plant 2.0 Report Summary. Thepredictedmaximum groundlevel concentration (GLCmax) is 0.837 f.lg/m3 for a rolling three-month average. Thelocation ofthe GLCmax is the same as thelocation of monitor 480850009 on the north propertyline ofthe Exide Technologies site. Predictedconcentrations exceeding the NAAQS extended approximately 0.8 kilometers (km) 

### to the north, 0.5km to the south, 0.5 kmto the west, and 0.2 kmtothe east ofthe site propertyline. All predicted concentrations greater than the NAAQS are located within Collin County. Table 1liststhepredicted concentrations at the current monitor locations andproposed monitorlocation nearthe intersection of 1st Street andAsh Street. Table 1. Modeling Results for Lead

ilime 480850009 rolling three-month 0.837 0.15 480850003 rolling three-month 0.477 0.15 480850007 rolling three-month 0.292 0.15

Proposed rolling three-month ·0.311 0.15 

### 3.0 LandUse andTerrain. A landuse/land cover analysis was performedusingAERSURF ACE consistent with guidance given in theAERMOD Implementation Guide (March 19, 2009). The recommended input data, the National Land Cover Data 1992 archives (NLCD92), were usedfor this analysis. Terrain elevationswithin the modeling domain were determined using AERMAP (Version 09040). The input data usedfor this analysis were United States Geological Survey (USGS) digital elevation models (DEMs) for little Elm, Frisco, Lewisville East, and Hebron data sets. 4.0 Modeling Emissions Inventory. Themodeled emission source parameters and emission rates were providedby Exide Technologies. The sourcelocations were validated by

### ADMT using aerial photography. The source emission rates modeled were consistent with the maximum allowable emission rates authorized throughpermits 3048A and 1147A Several source emissions rateswere revised through a permitalteration submitted October 2010. The revised emission rates are highlighted in Table 4. The emission source coordinates are inthe UTM Zone 14 North, NorthAmerican Datum of1927 (NAD27) coordinate system.

### David Brymer Page 3 of7 October 8, 2010 

### Modeling Analysis ofLead for Exide Technologies, Frisco Battery Recycling Plant Table 2. 

### On-Property Point Source Parameter Information**~a**sting Northing Stack •,· Stack 

### Stack 

### Exit · ID I (meters) , . (meters) Height,·.·. Temp Velocity (meters) (K)

.. {meters/sec) 11 702713.06 3668796.5 16.764 369.26 12.0396 12 702713.25 3668793.75 16.764 369.26 8.5039

. 13 702713.25 3668791.5 15.8496 391.48 13.1674 14 702721 3668792.75 16.764 327.59 27.9624 15 702725.31 3668807.5 16.764 349.82 14.1732 16 702717.88 3668803 17.3736 369.26 13.4722 17 702728.88 3668779.5 16.764 355.37 14.0208 18 702628.13 3668767.75 30.6324 303.71 5.1206 21 702626.88 3668739.25 31.242 304.82 16.5811 22 702685.69 3668804.25 22.86 0 15.1486 23 702637.38 3668764.5 6.096 0 1.8288 24 702721.88 3668782.5 16.4592 369.26 11.491 25 702721.75 3668777.75 16.4592 358.15 9.4488 26 702736.31 3668782.75 9.144 355.37 11.5824 37 702682.56 3668810 22.86 298.15 19.6901 38 702620.19 3668771.75 33.8328 315.37 16.7945 39 702544.5 3668727.75 10.668 0 0.0009 45 702623.06 3668713.75 32.1564 0 14.0238 48 702585 3668771 11.2776 0 1.6764 Stack Diameter (meters) 0.3048 0.3048 0.3048 0.5334 0.381 0.253 0.381 1.6154 1.521 0.8108 0.3048 0.381 0.381 0.1524 1.6764 1.3716 1.524 1.8044 0.1707

### David Brymer Page 4 of7 October 8, 2010 

### Modeling Analysis ofLead for Exide Technologies, Frisco Battery Recycling Plant

Table 3. Area Source ParameterInformation 

# l'i>!i;!;,l 

# .......**·1~11-'"** ,, A,', "; 

## I, ,. ' : .

# J;~;,:},' ., ,

# ~j'**c~..** '

. ': '"(

# ~~l'**;~** ; 

### ' 

# : ln4**'~•':tn'**jf;>**1:,~'** <:;;' ·.. >>:,;"' 

### ·"·" 

## '!,1,,,,_ ·; ,

### ..'._.**\<;1_0i~** • ' 10 702642.65 3668770.8 4.572 28.956 24.384 -2 27 702733.81 3668767.5 4.572 0.9144 0.9144 0 28 702756.31 3668782 4.572 0.9144 0.9144 0 35 702654.26 3668740.35 4.572 22.86 30.48 -2 36 702645.75 3668754.8 4.572 32.004 15.24 -2 41 702518.28 3668768.73 0.3048 94.488 21.336 40 42 702625.1 3668693.38 0.3048 80.772 44.196 -2 43 702702.77 3668745.25 0.3048 62.484 39.624 -2 44 702590.79 3668760.22 3.9929 24.384 41.148 -2 52 702631.81 3668765.63 4.572 21.336 16.764 -2 53 702615.56 3668762.28 1.8288 16.764 19.812 -2 

### Table 4· On-Property Source Allowable Emission Rates

10 Lead 1-hr 0.08 11 Lead 1-hr 0.05 12 Lead 1-hr 0.03 13 Lead 1-hr 0.05 14 Lead 1-hr 0.03 15 Lead 1-hr 0.05 16 Lead 1-hr 0.02 17 Lead 1-hr 0.05

### David Brymer Page 5 of7 October 8, 2010 

### Modeling Analysis ofLead for Exide Technologies, Frisco Battery Recycling Plant

Scenario Averaging . E .• m1ss1on Rates Pollutant ID Time (lb/hr) 18 Lead 1-hr O.Q? 21 Lead 1-hr 0.25 22 Lead 1-hr 0.02 23 Lead 1-hr 0.03 24 Lead 1-hr 0.006 25 Lead 1-hr 0.004 26 Lead 1-hr 0.001 27 Lead 1-hr 0.001 28 Lead 1-hr 0.001 35 Lead 1-hr

. 0.08 36 Lead 1-hr 0.01 37 Lead 1-hr 0.09



### . 38 Lead 1-hr 0.2 39 Lead 1-hr 0.12

.. 

## om$8 41.·

.. . Lead 1-hr



### . 

## ·. 42 'lead · ·1-hr 

# . 0.0388 43 •• Lead 1-hr •;' .. 0.0388 44 Lead 1-hr 0.03 45 Lead 1-hr 0.25 48 Lead 1-hr 0.06 52 Lead 1-hr 0.01 53 Lead 1-hr

. 0.13

### David Brymer Page 6 of? October 8, 2010 Modeling Analysis ofLead for Exide Technologies, Frisco Battery Recycling Plant

s.o Building Wake Effects (Downwash). Input data to Building Profile Input Program Prime (BPIP-PRM Version 04274) were providedby Exide Technologies. The building locations were validatedbyADMT using aerial photography. 6.o Meteorological Data. Surface Station andID: Dallas/FortWorth, TX (Station#: 03927) UpperAir Station and ID: Stephenville, TX (Station #: 13091) Meteorological Dataset: 1985, 1987, 1988, 1989, 1990 Profile Base Elevation: 551 feet TheAERSURF ACE analysis conducted ofthe area surroundingthe Exide Technologies siteresulted in a calculated roughness length of0.129 meters. Since theAERSURFACE analysis used land cover data from 1992 and since the area near the site has become more developed and urbanized since 1992based on comparing theland cover data to 2008 aerial photography, a representative roughness length for the area wouldbe approximately o.s meters. For this reason, the meteorological data setused for this analysis was developed using a roughness length of0.5 meters. 7.0 Receptor Grid. The receptor grid used inthe modeling analysis consisted ofreceptors with so meter spacing and extended approximately 1.5 kilometers (km) 

### from the Exide Technologies sitepropertyline in 

### all directions. An 

### additional grid consisted ofreceptors with 100 m spacing and extended 3.5 km

### beyond the first receptor gridin all 

### directions. Discrete receptors were used for thelocations ofthethree existing monitoring stations and the location ofa proposed monitoring station near the intersection of 1st Street andAsh Street. The purpose ofthe receptor grid was to determine a representative maximum ground-level concentration andthe extent ofground-level concentrations at or above halfofthelead NAAQS standard. 8.0 Model Used and Modeling Techniques. AERMOD (Version 09292) was used in a refined screening mode. A newversion of AERMOD was released onOctober 23, 2009. This version was used in the modeling analysisbecause it 

### is thelatest approved EPA model version. For refined screening, National Weather Service (NWS) meteorological raw input data are used with generalized surface characteristics ofthe application site. Since the currentversion of AERMOD is notcapable ofcalculating rolling three-month average concentrations, the EPApost processor LeadPost was used. The inputvalues to LeadPost are monthly averagevalues at each receptor inthe POSTFILE outputformat from AERMOD.

### David Brymer Page7of7 October 8, 2010 ModelingAnalysis of Lead for Exide Technologies, Frisco Battery Recycling Plant For this analysis, only emission sources atthe Exide Technologies site were considered. The nearest source oflead emissions outside the modeling domain is approximately 20 km 

### from the Exide Technologies site with reported 2007lead annual emissions approximately one percent ofthe annuallead emissions reported by Exide Technologies. The largest nearby source oflead emissions is 

### approximately so km 

### from the Exide Technologies site with annual reported emissions approximately ten percent ofthe annual emissions reported by Exide Technologies. Due to the great distance to the Exide Technologies site and the small reported emission, no other sources oflead emissions woultl haYe a significant contribution near the Exide Technologies site or the modeling domain usetl for this analysis.

# Texas Commission on Environmental Quality

To:
Thru:

From: INTEROFFICE MEMORANDUM

Jim Price Air Quality Division Robert Opiela, P.E.,Technical Specialist Technical Program Support Section Air Permits Division Matthew Kovar, Megan Cox Air Dispersion Modeling Team Air Permits Division Date: September 25, 2009

Subject: Modeling Analysis ofLead for Oxbow Calcining LLC (RN100209287) 1.0 Project Identification Information. On November 12,2008, the U.S. Environmental ProtectionAgency(EPA)finalized the new 0.15 microgram per cubic meter (!lg/m') NAAQS for lead based on a rolling threemonth average (73 FederalRegister 66964). In general, therule requires sourceoriented ambient air leadmonitoring by January 1, 2010, at sites with actual annual lead emissions ofone or more tonsperyear. Oxbow Calcining LLC was identified as having emissions at or above this level based on the reported 2007TCEQEmissions Inventory and/or 2006 Taxies Release Inventory. The rule further requires that this monitoring be conductedat or nearthe maximum off-site ambient air lead concentration, as predictedby modeling, that results from sources with annual lead emissions ofone or moretons. The TCEQ conducted air dispersionmodeling of all the lead emission sources atthe site using the most currentmodelingparameters andassociated permitted allowable emissions rates. TheTCEQ will usethe dispersion modeling results to determinethe optimal location ofany required source-oriented monitors. ArcReader Published Map: \\Msgiswrk\apd\MODEL PROJECTS\Lead NAAOS Analvsis 2009\Lead NAAOS Analvsis Results.nmf 2.0 Report Summary. The predicted maximum ground level concentration (GLCmax) is 0.016 llg/m' for a rolling three-month average. The location ofthe GLCmax is approximately 70 meters from the northwest property line. Table I liststhe location ofthe predicted GLCmax. The location coordinates are in the lJfM Zone 15 North, North American Datum of 1927 (NAD27) coordinatesystem.JimPrice Page 2 of4 September 25, 2009 Modeling Analysis ofLead for Oxbow Calcining LLC

Location Easting (meters) 407000 3.0 Land Use and Terrain.Table 1. Modeling Results for Lead

location ,-, .,/ : Northing' (meters} 3301300 rolling three-month 0.016 0.15

A landusc/land cover analysis was performed usingAERSURF ACE consistent with guidance given in the AERMOD Implementation Guide (March 19, 2009). The recommended input data, the National Land Cover Data 1992 archives (NLCD92), were used for this analysis. Terrain elevations within the modeling domainwere determined usingAERMAP (Version 09040).The input dataused for this analysis was the United States Geological Survey (USGS) National Elevation Dataset (NED) for the PortArthur South quadrangle. 4.0 Modeling Emissions Inventory. The modeled emission source parameters and maximum allowable emission rates were obtained from permits 45622 and 5421. The source locations were validated byADMT using aerial photography. The emission rates represent worst case 1-hour average emission rates and maybe more conservative than 24-hour ormonthly average emission rates. The emission source coordinates are inthe UTM Zone 15 North, North American Datum of 1927 (NAD27) coordinate system. Table 2. On-Property Point Source ParameterInformation

ID Easting (meters}

KS2 406942 3300668 38.1 1366.48 14.78 3.17 WHBS3 406991 3300709 45.72 477.59 23.13 2.07 WHBS4 406935 3300796 45.72 477.59 23.13 2.07 WHBS5 406976 3300631 56.39 477.59 23.96 2.37Jim Price Page 3 of4 September 25, 2009 Modeling Analysis ofLead for Oxbow Calcining LLC Table 3. On-Property Source Modeled Emission Rates

Source Averaging Emission Rates Pollutant ID Time (lb/hr) KS2 Lead 1-hr 0.13 WHBS3 Lead 1·hr 0.22 WHBS4 Lead 1-hr 0.22 WHBSS Lead 1-hr 0.31



### s.o Building Wake Effects (Downwash). Input data to Building Profile Input Program Prime (BPIP-PRM Version 04274) were provided by Oxbow Calcining LLC. The building locations were validated byADMT using aerial photography. 6.0 Meteorological Data. Surface Station and ID: PortArthur, TX (Station#: 12917) UpperAir Station and ID: Lake Charles, LA (Station#: 3937) Meteorological Dataset: 1987-1991 Profile Base Elevation: 16 feet The AERSURF ACE analysis conducted ofthe area surrounding the Oxbow Calcining LLC site resulted in a calculated roughness length of0.028 meters. Since the AERSURF ACE analysis used land cover data from 1992 and since the area near the site has become more developed and urbanized since 1992based on comparing the land cover data to 2004 aerial photography, a representative roughness length for the area would be approximately 0.05 meters. Forthis reason, the meteorological data set used for this analysis was developed using a roughness length of

### o.os meters. 7.0 Receptor Grid. The receptor grid used in the modeling analysis consisted ofreceptors with 100 meter spacing and extended approximately 1.5 kilometers (km) from the Oxbow Calcining LLC site property line in all directions. The purpose ofthe receptor grid was to determine a representative maximum ground-level concentration andthe extent of ground-level concentrations at or above halfofthe lead NAAQS standard.Jim Price Page 4 of4 September 25, 2009 ModelingAnalysis ofLead for Oxbow Calcining LLC B.o Model Used and ModelingTechniques. AERMOD (Version 07026) was used in a refined screeningmode. Forrefined screening, National Weather Service (NWS) meteorologicalraw input data are used with generalized surface characteristics ofthe application site. Since the currentversion ofAERMOD is not capable ofcalculating rolling three-month average concentrations, the EPApost processor LeadPostwas used. The inputvalues to LeadPost are monthly average values at eachreceptorinthe POSTFILE outputformat fromAERMOD.

## '_! 

# Texas Commission on Environmental Quality

To:

Thru:

From: INTEROFFICE MEMORANDUM

David Brymer Air Quality Planning Division Robert Opiela, P.E., Technical Specialist Technical Program Support Section Air Permits Division Matthew Kovar, Megan Cox Air Dispersion Modeling Team Air Permits Division Date: July 24, 2009

Subject: Modeling Analysis ofLead for U.S. Army (Fort Hood) (RN101612083) 1.0 Project Identification Information. On November 12, 2008, the U.S. Environmental Protection Agency (EPA) finalized the new 0.15 microgram per cubic meter (1Jg/m3) NAAQS for lead based on a rolling threemonth average (73 Federal Register 66964). In general, the rule requires sourceoriented ambient air lead monitoringby January 1, 2010, at sites with actual annual lead emissions of one ormore tons per year. The U.S. Army (Fort Hood) was identified as having emissions at or above this level based on the reported 2007TCEQ Emissions Inventory and/or 2006Toxics Release Inventory. The rule further requires that this monitoring be conducted at or near the maximum off-site ambient air lead concentration, as predicted by modeling that results from sources with annual lead emissions ofone or more tons. The TCEQ conducted air dispersion modeling ofall the lead emission sources at the site usingthe most current modeling parameters. The TCEQ will use the dispersion modeling results to determine the optimal location ofany required source-oriented monitors. ArcReader Published Map: \\Msgiswrk\apd\MODEL PROJECTS\Lead NAAOS Analvsis 20oo\Lead NAAOS Analysis Results.pmf 2.0 Report Summary. The predicted maximum ground level concentration (GLCmax) is 0.02 1Jg/m3 for a rolling three-month average. Thelocation ofthe GLCmax is along the southern property line. Table 1lists the location ofthe predicted GLCmax. The location coordinates are in the UTM Zone 14 North, NorthAmerican Datum of 1927 (NAD27) coordinate system.David Brymer Page 2 of4 July 24, 2009 Modeling Analysis ofLead for U.S. Army (Fort Hood)

. Location

.Easting
• (meterS:)

618000 3.0 Land Use and Terrain.Table 1. Modeling Results for Lead Location

### Norttitii~;

# ;r ·.**(met~<s):i•·••·.··** 3446900 ·Averaging Time·

rolling three-month 0.02 0.15

A landuse(land cover analysis was performed using AERSURF ACE consistentwith guidance given in the AERMOD Implementation Guide (March 19, 2009). The recommended input data, the National Land Cover Data 1992 archives (NLCD92), were usedfor this analysis. Terrain elevations within the modeling domainwere determined usingAERMAP (Version 09040). The input data used for this analysis wasthe United States Geological Survey (USGS) National Elevation Dataset (NED) for Gatesville West., Gatesville East, Shell Mountains, North Fort Hood, Fort Hood, and Post. OakMountains quadrangles. 4.0 Modeling Emissions Inventory. The modeled emission source parameters and emission rates were providedbyFort Hood. The source locations were validatedbyADMT. The source emission rates modeled were based on airemissions estimates reported in the Fort Hood 2007Toxic Release Inventory (TRI). Though the emissions were reported for manyfiring ranges at various locations aroundFortHood, for this demonstration all ofthe emissions were conservatively representedto be emitted onlyfrom the firing ranges nearest.the areas ofpublic activity. Fromthe 2007TRI data and activity datafor 2008, thefiring ranges withthehighest emissions were the furthest. away from public locations andlargest. in extent. Public activities are limitedto the southern andthe northern ends ofFort Hood. The central areas and areas onthe east. andwest. ofFortHood arerestricted from public access. The emission rates represent worst. case 1-hour average emission rates and maybe more conservative than 24-hour or monthly average emission rates. Table 2. On-Property Source Modeled Emission Rates

NFHS Lead 1-hr 0.0056 NFHR Lead 1-hr 0.0079

# - David Brymer Page 3 of4 July 24, 2009 Modeling Analysis ofLead for U.S. Army (Fort Hood)

Source Pollutant Averaging ID Time OBJID_8 Lead 1-hr OBJID_9 Lead 1-hr

IHSR Lead 1-hr HGQ Lead 1-hr PKGL Lead 1-hr BGRB Lead 1-hr BGPQ Lead 1-hr BGRC Lead 1-hr PKAT4 Lead 1-hr BWPA Lead 1-hr BWPB Lead 1-hr HGC Lead 1-hr NFHRB Lead 1-hr HGDA Lead 1-hr BWGL Lead 1-hr PKRZ Lead 1-hr PKRA Lead 1-hr BWMS Lead 1-hr

P5R Lead 1-hr

s.o Building Wake Effects (Downwash). Building downwash is not applicable for area source modeling. 6.0 Meteorological Data. Surface Station and ID: Waco, TX (Station#: 13959) Emission Rates (lb/hr) O.G105 0.0062 0.0306 0.0026 0.0053 0.0113 0.0017 0.0255 0.0054 0.0018 0.0017 0.0025 0.0128 0.0023 0.0149 0.0068 0.0066 0.0411 0.0367David Brymer Page4 of4 July 24, 2009 Modeling Analysis ofLead for U.S. Army (Fort Hood) UpperAir Station and ID: Stephenville, TX (Station#: 13091) Meteorological Dataset: 1985, 1987, 1988, 1989, 1990 Profile Base Elevation: 499feet TheAERSURFACE analysis conducted ofthe area surrounding the U.S. Army (Fort Hood) site resulted in a calculated roughness length of0.369 meters. Since the AERSURFACE analysisusedland cover datafrom 1992 and since the area nearthe site has become more developed andurbanized since 1992 based on comparing theland cover datato 2004 aerial photography, a representative roughness lengthfor the area wouldbe approximately 0.5 meters. Forthis reason, the meteorological data setused for this analysis was developed using a roughness length of0.5 meters. 7.0 Receptor Grid. The two receptor grids used inthe modeling analysis consisted ofreceptors with 100 meter spacing. The larger receptor grid was located in close proximitytothe southern firing ranges and extended approximately 2 kilometers (km)from these firing ranges to the south. The smallerreceptorgrid was located in close proximitytothe northern firing ranges and extended approximately 2 Ian fromthesefiring ranges to the northeast. The purpose ofthe receptor grid wasto detennine a representative maximum ground-level concentration and the extent ofground-level concentrations at or above halfofthe lead NAAQS standard. 8.0 Model Used andModelingTechniques. AERMOD (Version 07026) was used in a refined screening mode. Forrefined screening, NationalWeather Service (NWS) meteorological raw inputdata are used with generalized surface characteristics ofthe application site. Since the currentversion ofAERMOD is not capable ofcalculating rolling three-month average concentrations, the EPA post processorLeadPostwas used. The inputvalues to LeadPost are monthly average values at each receptorin the POSTFILE outputformat fromAERMOD.

# Texas Commission on Environmental Quality

To: Thru:

From: INTEROFFICE MEMORANDUM

David Brymer Air Quality Planning Division Robert Opiela, P.E., Technical Specialist Technical Program Support Section Air Permits Division Jessica Carter, Justin Cherry Air Dispersion Modeling Team Air Permits Division Date: March 30, 2011

Subject: ModelingAnalysis ofLead for Coleta Creek Power Station (RN100226919) 1.0 Project Identification Information. On November 12, 2008, the U.S. Environmental Protection Agency (EPA) finalized the new 0.15 microgram per cubic meter (j.igfm') NAAQS for leadbased on a rolling threemonth average. On December 14, 2010, the EPA loweredthe emission threshold from annual lead emissions ofone ton or moreto a halfa ton ormore in actual emissions that state agencies mustuse to determine ifan air qualitymonitor shouldbe placed near an industrial facility that emits lead (75 Federal Register 81134). The rule further requires that this monitoring be conducted at or nearthe maximum off-site ambient air lead concentration, as predictedby modeling. In general, the rule requires sourceoriented ambient air lead monitoring by December 27, 2011 at sites with actual annual lead emissions ofhalfa ton or more peryear. Coleta Creek Power Stationwas identified as having emissions at orabove this level based on the reported 2009TCEQ Emissions Inventory and/or 2009 Taxies Release Inventory. The TCEQ conducted air dispersion modeling ofall the lead emission sources at thesite using the most current modeling parameters and associated permitted allowable emissions rates. TheTCEQ will use the dispersion modeling results to determinethe optimal location ofany required source-oriented monitors. ArcReader Published Map: \\Msgiswrk\apd\MODEL PRO.JECTS\3425\3425 Coleta Creek.pmf 2.0 Report Summary. The predicted maximum ground level concentration (GLCmax) is 0.000117 !lg/m' for a rolling three-month average. The location ofthe GLCmax is along the northern property line. Table 11ists the location ofthe predicted GLCmax. The location coordinates are in the UTM Zone 14 North, North American Datum of 1983 (NAD83) coordinate system.David Brymer Page 2 of4 March 30, 2011 ModelingAnalysis ofLead for Coleto Creek Power Station

location Easting (meters) 674100 3.0 Land Use and Terrain.Table 1. Modeling Results for Lead**L~>datidri**

## N~~~~~g ;_,-, '''';:;';":,,,' t 

### ltl1eter:;)

3179300 rolling three-month 

### iGlc ·· 

### {pgttl1')

0.000117 Standard (IJgfm')

0.15

A landuse(land cover analysis wa:s performed usingAERSURFACE consistent with guidance given in theAERMOD Implementation Guide (March 19, 2009). The recommended inputdata, the National Land Cover Data 1992 archives (NLCD92), were used for this analysis. Terrain elevations withinthe modeling domainwere determined using AERMAP (Version 09040). The inputdataused for this analysis were United States Geological Survey (USGS) seamless datathat covers digital elevation models (DEMs) for Fannin, Hensley Lake, Schroeder, andAnder data sets. 4.0 Modeling Emissions Inventory. Themodeled emission source parameters and emission rates were providedby Coleto Creek Power Station. The source locations were validated byADMT using aerial photography. No sources have a listed maximum allowable emission rate for lead. For all three sources, emissions estimates were submittedby Coleto CreekPower Station andthen validatedbyAPD permitreviewing stafffor use inthis analysis. The emission rates representworst case 1-hour average emission rates and maybemore conservative than 24-hour or monthly average emission rates. The emission source coordinates are inthe UTM Zone 14 North, NorthAmerican Datum of 1983 (NAD83) coordinate :;ystem. Table 2. On-Property Point Source Parameter Information

UNIT 1 674412 3177468 124.66 448.2 35.51 6.096 EMG 1 674495.35 3177551.44 5.33 735.9 35.72 0.253 FWP 1 674499.647 3177628.32 3.89 722 42 0.204David Brymer Page 3 of4 March 30, 2011 Modeling Analysis ofLead for Coleta Creek Power Station

Table 3. On-Property Source Modeled Emission Rates

Source Averaging Emission Rates Pollutant ID Time (lb/hr} UNIT 1 Lead 1-hr 0.0683 EMG1 Lead 1-hr 0.0000468 FWP 1 Lead 1-hr 0.0000359

s.o Building Wake Effects (Downwash). Input data to Building Profile Input Program Prime (BPIP-PRM Version 04274) were providedby Coleta Creek Power Station. The building locations were validatedby ADMT using aerial photography. 6.o Meteorological Data. Surface Station and ID: Victoria, TX (Station#: 12912) UpperAir Station and ID: Victoria, TX (Station#: 12912) Meteorological Dataset: 1983, 1984, 1986, 1987, 1988 Profile Base Elevation: 107 feet The AERSURF ACE analysis conducted ofthe area surrounding the Coleto Creek Power Station site resulted in a calculated roughness length of0.081 meters. The vast majority ofthe area considered waterbodies such as the Coleta Creek Resevoir and cooling waterlakes at the Coleta Creek Power Station (and with a lower roughness length) is concentrated nearthe emission sources. The dispersion ofemissions from the sources will be highly influenced bythis lower roughness length. Arepresentative roughness length for the area would be approximately 0.05 meters. Forthis reason, the meteorological data set used for this analysis was developed using a roughness length ofo.os meters. 7.0 Receptor Grid. The receptor grid used in the modeling analysis consisted ofreceptors with 100meter spacing and extended approximately 1.5 kilometers (km) from the Coleta Creek Power Station site property line to the north and east, 1.9 km to the west, and 2.6 kmto the south. Thepurpose ofthe receptor grid wasto determine a representative maximum ground-level concentration andthe extent ofground-level concentrations at or above half ofthelead NAAQS standard.David Brymer Page4 of4 March 30, 2011 Modeling Analysis ofLead for Coleto Creek Power Station 8.0 Model Used and Modeling Techniques. AERMOD (Version 09292) was used in a refined screening mode. Forrefined screening, National Weather Service (NWS) meteorological raw input data are used with generalized surface characteristics ofthe application site. Sincethe current version ofAERMOD is not capable ofcalculating rolling three-month average concentrations, the EPA post processor LeadPostwas used. Theinput values to LeadPost are monthly average values at each receptor inthe POSTFILE outputformat from AERMOD. The results from the LeadPost reports are limited tothree decimal places; therefore, the monthly average predicted concentrations were examined from theAERMOD output files using the MA.,"I(!FILE option sincetheAERMOD output files display results outto five decimal places. The rolling 3-month averages to five decimal places were calculated from the monthly averages from the MAXIFILE output.

# Texas Commission on Environmental Quality

To:
Thru:

From: INTEROFFICE MEMORANDUM

David Brymer Air Quality Planning Division Robert Opiela, P.E., Technical Specialist Technical Program Support Section Air Permits Division Jessica Carter, Justin Cherry Air Dispersion Modeling Team Air Permits Division Date: March 30, 2011

Subject: Modeling Analysis ofLead for San Miguel Electric Cooperative Inc (RN100226539) 1.0 Project Identification Information. On November 12, 2008, the U.S. Environmental Protection Agency (EPA) finalized the new 0.15 microgram per cubic meter**(~g/m')** NAAQS for lead based on a rolling threemonth average. On December 14, 2010, the EPA lowered the emission threshold from annual lead emissions ofone ton or more to a halfa ton ormore in actual emissions that state agencies mustuse to determine ifan air quality monitor should be placed near an industrial facility that emits lead (75 Federa/Register81134). The rule further requires that this monitoring be conducted at or near the maximum off-site ambient air lead concentration, as predicted by modeling. In general, the rule requires sourceoriented ambient air lead monitoring by December 27, 2011 at sites with actual annual lead emissions ofhalfa ton ormore peryear. San Miguel Electric Cooperative Inc was identified as having emissions at or above this level based onthe reported 2009 TCEQ Emissions Inventoryand(or 2009Toxics Release Inventory. TheTCEQ conducted air dispersion modeling of all the lead emission sources atthe site using the most current modeling parameters and associated permitted allowable emissions rates. The TCEQ will use the dispersion modeling results to determine the optimal location ofanyrequired source-oriented monitors. ArcReader Published Map: \\Msgiswrk\apd\MODEL PROJECTS\3425\3425 San Miguel.pmf 2.0 Report Summary. The predicted maximum ground level concentration (GLCmax) is 0.00091**~g(m'** for a rolling three-month average. The location ofthe GLCmax is approximately goo meters from property line to the north. Table I lists the location ofthe predicted GLCmax. The location coordinates are in the UTM Zone 14 North, North American Datum of 1983 (NAD83) coordinate system.David Brymer Page 2 of4 March 30, 2011 Modeling Analysis ofLead for San Miguel Electric Cooperative Inc Table 1. Modeling Results for Lead

551000 3176600 rolling three-month 3.0 Land Use andTerrain. 0.00091 · Standard 

### ' (li!Vm'J

0.15

A landusefland cover analysis was performed using AERSURF ACE consistent witb guidance given in tbe AERMOD Implementation Guide (March 19, 2009).The recommended input data, tbe National Land Cover Data 1992 archives CNLCD92), were used for tbis analysis. Terrain elevations within tbe modeling domain were determined usingAERMAP (Version 09040). The input dataused fortbis analysis were United States Geological Slirvey (USGS) digital elevation models (DEMs) for Christine East, Christine West, Cross NE, and Caballos Creekdata sets. 4.0 Modeling Emissions Inventory. The modeled emission source parameters and emission rates were provided bySan Miguel Electric Cooperative Inc.The source locations were validatedbyADMT using aerial photography. Source 6 has a listed maximum allowable emission rate for lead in tons peryear only. The maximum hourly emission rate was derived from tbetons per year andbased on 8,064 operating hoursperyear. The emission rates represent worst case 1-hour average emission rates andmay be more conservative tban 24-hour or monthly average emission rates. The emission source coordinates are intbe UTM Zone 14 North, North American Datum of1983 (NAD83) coordinate system. Table 2. On-Property Point Source ParameterInformationDavid Brymer Page 3 of4 March 30, 2011 Modeling Analysis ofLead for San Miguel Electric Cooperative Inc

Table 3. On-Property Source Modeled Emission Rates

Source Averaging Emission Rates Pollutant ID Time (lb/hr) 6 Lead 1-hr 0.22 5.0 Building Wake Effects (Downwash). Input data to Building Profile InputProgram Prime (BPJP-PRM Version 04274) were derived from aerial photographybythe ADMT. 6.o Meteorological Data. Surface Station and ID: San Antonio, TX (Station #: 12921) UpperAir Station and ID: Del Rio, TX (Station#: 22010) Meteorological Dataset: 1986, 1987, 1988, 1989, 1991 Profile Base Elevation: 242.3 meters The AERSURF ACE analysis conducted ofthe area surrounding the San Miguel Electric Cooperative Inc site resulted in a calculated roughness length of0.200 meters. The meteorological data set used for this analysis was developed using a roughness length of0.5 meters. Ahigher roughness length value would tendto enhance dispersion more than a lower value. However, since the only source oflead is a very tall stack, over 100 meters high, enhanced dispersion would mix air contaminantsfrom the source to ground level to a greater extent. Therefore, use ofa roughness length of0.5 meters is conservative. According to EPA's Meteorological Monitoring Guidance for RegulatoryModeling Applications, the meteorological dataset for 1988 does not meet regulatory completeness (only 86-4% complete). There was a total of 1195 hours ofmissing data for the entire year (8760 hours). The number ofhours missing per month ranged from zero hours to 226 hours. April was the month with the highest number ofmissing hours (226 hours out of720 hours). There were zero hours missing for the months of August, September, October, and November. Since the predicted concentrations are extremely small, itis unlikelythat the results would significantly change due to these missing hours. 7.0 Receptor Grid. The receptor grid used in the modeling analysis consisted ofreceptors with 100 meter spacing and extended approximately 2.5 kilometers (km) from the San Miguel ElectricDavid Brymer Page4 of4 March 30, 2011 Modeling Analysis ofLead for SanMiguel Electric Cooperative Inc Cooperative Inc site propertyto the north, and approximately 1.5 Ianfrom the site propertyin all other directions. The purpose ofthe receptor grid was to detemrine a representative maximum ground-level concentration and theextent ofground-level concentrations at or above halfofthe lead NAAQS standard. 8.0 Model Used and Modeling Techniques. AERMOD (Version 09292) was usedin a refined screening mode. Forrefined screening, National Weather Service (NWS) meteorological raw inputdata areused with generalized surface characteristics ofthe application site. Since the currentversion ofAERMOD is not capable ofcalculating rolling three-monthaverage concentrations, the EPA postprocessor LeadPostwas used. The inputvalues to LeadPost are monthly average values at each receptor inthePOSTFILE outputformat fromAERMOD. The results from the LeadPost reports arelimited to three decimal places; therefore, the monthly average predicted concentrations were examined from theAERMOD output files usingthe MAXIFILE option since the AERMOD outputfiles display results outto five decimal places. Therolling 3-month averages to five decimal places were calculated from the monthly averages.APPENDIX B: TCEQ LEAD MONITORING NETWORK

## (

Table 1: 

### TCEQ Lead Monitoring Network AQS; CAMS11 Region Site name Monitor Monitoring Sampling Analysis Collection Sample Parameter Activated Type Objective Frequency Duration code 48-375-0024 24 1 Amarillo SH SLAMS;;; Highest TSP;' for ICP-MS' Every 6th 24 hours 14129 4/25/2010 136 Concentration Lead Day 48-085-0009 16 4 Frisco SLAMS Source TSP for ICP-MS Every 6th 24 hours 14129 1/15/1995 Eubanks Oriented Lead Day 48-085-0007 NA 4 Frisco 7 SLAMS Population TSP for ICP-MS Every 6th 24 hours 14129 7/17/1999 Exposure Lead Day 48-085-0007 NA 4 Frisco 7 SLAMS Population TSP for ICP-MS Every 6th 24 hours 14129 7/17/1999 (collocated) Exposure Lead- Day Collocated 48-085-0003 NA 4 Frisco 5th St SLAMS Source TSP for ICP-MS Every 6th 24 hours 14129 1/1/1984 Oriented Lead Day 48-085-0029 29 4 Frisco SLAMS- NA TSP for ICP-MS Every 6th 24 hours 14129 1/1/2011 Stonebrook Special Lead Day Purpose 48-257-0020 20 4 Terrell SLAMS Highest TSP for ICP-MS Every 6th 24 hours 14129 12/1/2010 Temtex Concentration Lead Day 48-201-1034 1 12 Houston SLAMS- General/ TSP for ICP-MS Every 6th 24 hours 14129 5/11/1999 East Special Background Lead Day Purpose 48-479-0016 44/144 16 Laredo SLAMS Population Speciated ICP-MS Every 6th 24 hours 14129 9/12/1996 Border Exposure Day 48-061-0006 80/180 16 Brownsville SLAMS Population Speciated ICP-MS Every 6th 24 hours 14129 11/11/1995 Exposure Day 48-141-0033 NA 6 El Paso Kern SLAMS Population TSP for ICP-MS Every 6th 24 hours 14129 1/1/1979 Fire Station Exposure Lead Day 48-141-0058 72 6 El Paso SLAMS Population TSP for ICP-MS Every 6th 24 hours 14129 7/11/2000 Skyline Park Exposure Lead Day 48-141-0002 413 6 El Paso SLAMS Population TSP for ICP-MS Every 6th 24 hours 14129 1/1/1969 Tillman Exposure Lead Day 48-141-0002 413 6 El Paso SLAMS Population TSP for ICP-MS Every 6th 24 hours 14129 1/1/1969 Tillman Exposure Lead- Day (Collocated) Collocated 48-141-0055 37/159 6 Ascarate SLAMS Population TSP ICP-MS Every 6th 24 hours 14129 1/27/2011 /172 NCORE Exposure Dayi Air Quality System (AQS) ii ContinuousAir Monitoring Station (CAMS) iii State and Local AirMonitoring Station (SLAMS) ''Total Suspended Particles (TSP) 'Inductively Coupled Plasma Mass Spectrometry (ICP-MS)THE STATEPfTEXAS 

### TEXAS COMMISSION ON

### ENVIRON!Q2mwl91\l~TY I hereby certify that this is a true and correct copy of a

### .'~· Texas Commission on Environmental Quality document, 

## l."'r-J),.,\""·1 wh;ch ;s filed mthe permanent records of the Commission. l.iO

### ~~~J Given

### und~r my hand and the seal of office on

## ·~~·**~~rk**

# AUG 2 9 2011 ORDERADOPTINtias Commission on Environmental Quality 

### REVISION TO THE STATE IMPLEMENTATION PLAN

Docket No. 

### 2011-oo6s-SIP On August 17, 2011, 

### the Texas Commission on Environmental Quality (Commission), during a public meeting, considered adoption ofa revision to the state implementation plan (SIP). The Commission adopts a revision to the SIP for Lead Transport for the 2008 

### Lead National Ambient Air Quality Standard (NAAQS). The Commission adopts this SIP revision demonstrating thatTexas is not contributing significantly to nonattainment ofthe lead NAAQS for areas inother states; not interfering**\~ith** 

### the maintenance ofthe lead NAAQS in any other state; notinterfering with measures required to meetan implementation plan for any other state related to prevention ofsignificant deterioration (PSD); and not interfering with measures required to meet the implementation plan for any other state relatedto regional haze and visibility. Under Tex. Health & 

### Safety Code Ann. §§ 382.011, 382.012, 

### and 382.023 

### (Vernon 2008), 

### the Commission has the authority to control the quality ofthe state's air and to issue orders consistent**~ith** 

### the policies and purposes oftheTexas CleanAir Act, Chapter 382 

### ofthe Tex. Health & 

### Safety Code. Notice ofthe proposed SIP revision was publishedfor comment inthe April 22, 2011, 

### issue ofthe 

### Texas Register (36 

### TexReg 2623). 

### Pursuant to 40 Code ofFederal Regulations § 51.102 

### and after proper notice, the Commission conducted a public hearing to consider a revision to the SIP. Proper notice included prominent advertisement inthe areas affected at least 30 

### days prior to the date of the hearing. Apublic hearing was held in Austin on May 17, 2011. 

### The Commission circulated hearing notices ofitsintended action to the public, including interestedpersons, the Regional Administrator ofthe EPA, and all applicable local air pollution control agencies. The public was invited to submit data, views, and recommendations on the proposed SIP revision, either orally orin >•Titing, at the hearing or during the comment period. Prior to the scheduledhearing, copies ofthe proposed SIP re\ision were available for public inspection atthe Commission's central office and on the Commission's Web site. Data, views, andrecommendations ofinterestedpersons regarding the proposed SIP re>ision were submitted to the Commission during the comment period and were considered bythe Commission as reflected inthe analysis oftestimony incorporated by reference to this Order. The Commission finds thatthe analysis oftestimony includes the names ofall interested groups or associations offering comment on the proposed SIP revision andtheir position concerning the same., 

### ' IT 

### ISTHEREFORE ORDERED BY THE COMMISSION that the revision to the SIP

### incorp~rated

# byreference to this Order are hereby adopted. The adoptedrevision to the SIP are irtcorp9ratedbyreference in this Order as ifset forth atlength verbatim in this Order. ', , ffiS 

### FURTHER ORDERED BY THE COMMISSION that onbehalfofthe Commission, the**Chairman,~hciuld** 

### transmit a copy ofthis Order, togetherwith the adopted revision tothe SIP, to 

### the'Regiimal Administrator ofEPA as a proposedrevision to theTexas SIP pursuantto the Federal Clean Air Act, codified at 42 U.S. Code Ann. §§ 

### 7401- 7671q, as amended. 

### Ifany portion ofthis Order is for any reason heldtobeinvalidbya court ofcompetent jurisdiction, the invalidity ofany portion shall not affect thevalidity ofthe remaining portions.

Date issued: 

# AUG 2 5 2011

TEXAS COMMISSION ON ENVIRONMENTAL QUALITY 

# 4hu. Shaw, Ph.D., Chairman