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 by Reducing and Preventing Pollution 

6DRA.~~-l .... 6WQ. .. ,, ........... . 

6MD ............. 6SF ................ .. 

60EJ ............ 6RC ................. . September 8, 2011 

6P D.U ij,-:-!'.1. ± ... 6XA. q.m~.<J ••.•••••• 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, the Texas Commission on Environmental Quality (Commission) adopted 

a revision to the state implementation plan (SIP) for Lead Transport for the 2008 Lead 

National Ambient Air Quality Standard (NAAQS). 

The Commission adopted a SIP revision demonstrating that Texas is not contributing 

significantly to nonattainment of the lead NAAQS for areas in other states; not interfering 

with the maintenance of the 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 plan for any other state related to regional haze and visibility. 

Enclosed are the proposed revision to the SIP, a public hearing certification, a complete 

record of the public hearing, and the accompanying order. I look forward to your expeditious 

approval of these SIP revisions. 

Sincerely, 

~~~ 1rm 

BWS/ab 

Enclosures 

cc: The Honorable Rick Perry, Governor of Texas 

Mr. Toby Baker, Office of Budget, Planning and Policy, Office of the 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 

CO UNIT OF TRAVIS 

Docket No. 2011-0065-SIP 

Project No. 2011-005-SIP-NR 

This is to certify that the attached are true and correct copies of documents for 

revisions to the Texas State Implementation Plan, adopted on August 17, 2011, pursuant to 40 

Code of Federal Regulations § 51.104. I am the records administrator for the Air Quality 

Division of the Texas Commission on Environmental Quality (Commission). 

< O.,~u ~mer-;"Di ctor 

\)--Air Quality Division 

Texas Commission on Environmental Quality 
Texas 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-NR 
INTRODUCTION 

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 of the 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 

PROPOSAL 
PUBLIC 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 of the 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 of the 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 Services 
North Central Texas Council of Governments 

Houston-Galveston Area Council 

South East Texas Regional Planning Commission 

Texas Department of Transportation, Environmental Affairs Division 

Texas Department of Transportation, 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 Agency 
Example of Newspaper Classified Ad 

Austin American-Statesman, April15, 2011 

NO'IICEDPPUIUCHMRINGBY1 .. TEXAS'toMMISSION ON ENVIRONMIIII'AI. 

QUAUrY ON 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~~ I Regulations §51,102 of the United 

States Envffonml!ntai Protet:tlan Agency 

regtilatlons concerning SIPs. 

The p10posed revision would Incorporate a plln to. address lnd·transport: fur the 2001 

lead-National Ambient Air Quality Standarel 

(NAAQSJ. Tht proposal. would meet therequirements. ofthli'Federai Clean Air Act, 

§ 11 O{a){2)(D)(I}, relating to the lnterstm 

transport of lead under the 20081ead NAAQS. 

These revtslons re~ 0dstin9 control 

Jll'iltegles to rei::luce tlieconcenmstlan of 

lud, as Well as ~ion modeling of major 

lead sources ln Tela. AdditiOnally, the revision verifies that the Prev.ntion of Significant 

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 hHring on this pmposal wiJI Ill! held In Austin on May 17',2(11l,lt 10:00 a.m., at the 

TtEQ headquarun; 12100 Part 35 Clrde. . Building F, Room 2210. The hearing wiD be 

ttructured·for the receipt of cral cr writml 

ccmments by lnteruted. perlons.lndlvlduab 

may prese_nt oral satemcnts VYhen ailed 

upon In order. of reglstrltl_cn. There wiD be no 

open dlscwslon durlr!gthe.huring; Ito~, 

~ staff. will be BVIillble ttl dlsc;USS the 

propcui'3D,\'111Jjute;s.Jll1or tD the-hearing. . 

Pei'SOIV whcohaVi spectal·communlcatlon or 

other ac:Cotnmodationneeds who are pllnnlng to ;~ttend the hurlng shaukl CCII)tact 

Shel~ Nalk with the Air Quality Division ;Jt · 

(512) 23g..1 536; Requests should ·be made as 

far in advance as possible.· · Comments miy be submttted to Shelley Natk. 

MC 206. Air Qua~ Division, Chief Engineer's Office, Tun Commlulon on EnvlronrnenDI QuiUty, P.O."Boi' 13087,-Austln, Texas 7871 1· 

¥.'67, or faxed tc Cl12) 239-51587. Elettnric comments may be subm!tted It wwwS.tc2q. tms.gOV/nlleste:om'memsl. FMe size restrlc· .. tlons may apply to comments being submit-· 

. tad vla.the ecammentsl)'Stem. ~.1 com- ' ments pertaining-to-the Led TraRsport pt., 

. fer the l008 Lead NAAOS SIP rwlilon should Rm.nce PrDjed"Numbei'"2D1.1~P-Nfl;. 

The comment period doses. on May 2312011. 

Copies of the prcpastd SIP !"!!vision an be ·o~ed from the TCEQ's Web stce It Http'i/ 

www.tceq.texas.gayllmplemaotatluio/rk/tip/ 

texas-slplcriterilt-pollutantslsip-lead. For further itdc:ii 1 nalkJti, ,.._contact SbtlleyNID:,. 

AttQuaflty Planning Section, (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 of the 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 of Error 

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 of the 

TCEQ submitted the wrong defe definition of ''Volatile organic 

04 reflects an earlier version of the 

10. In consequence, that incorrect 

Texas Administrative Code. 

As defined in 40 Code of Federal 

I OO(s)(2)- (4), as emended on JanThe correct definition will be restor dtothe Texas Administrative Code 

on-line. 

TRD-201101405 

• • 

Notice of a 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 of Federal Regulations §51.102 of the 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 of the Federal 

Clean Air Ac~ §II O(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 of major 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 of registration. 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 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 apply to comments being submitted via the eComments system. All comments pertaining to the Lead Transport Plan for the 2008 Lead NAA QS 

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 at 

http://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 of Opportunity to Com ent on Agreed Orders of 

Administrative Enforcement A 

The Texas Commission on Enviro ental Qua1ity (TCEQ or commission) staff is 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 of the op rtunity to comment must be published in the Texas Register no late than the 30th day before the date 

on which the public comment perio c]oses, which in this 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 

IN ADDITION April 22, 2011 36 TexReg 2623 
Bryan 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 and Preventing Pollution 

NOTICE OF PUBLIC HEARING BY THE 

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 to the state implementation plan (SIP), under the 

requirements of Texas Health and Safety Code, §382.012 and §382.013; and 40 Code of Federal 

Regulations §51.102 of the 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 of 

the Federal Clean Air Act, §11o(a)(2)(D)(i), relating to the interstate transport oflead under the 

2008 lead NAAQS. These revisions reference 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 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 10:00 a.m., at the 

TCEQ headquarters, 12100 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 of registration. 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 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 be submitted at 

www5. tceq.texas.gov /rules/ ecomments/. File size restrictions may apply to comments being 

submitted via 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 of the 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. For further 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 paper 
REVISIONS 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 FOR mE 2008 LEAD NATIONAL 

AMBIENT AIR QUALTIY STANDARD 

PROJECT NUMBER 2011-005-SIP-NR 

Proposal 

April6, 2011 
This page intentionally left blank 
EXECUTIVE 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 of new or revised National Ambient Air Quality Standards (NAAQS) to meet the 

requirements of FCAA, §uo(a)(2), including FCAA, §uo(a)(2)(D)(i), relating to interstate 

transport. On October 15, 2008, the United States Environmental Protection Agency (EPA) 

substantially strengthened the NAAQS for lead. The new standard, set at 0.15 micrograms per 

cubic meter (j.1g/m3) 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 of this 

SIP revision is to document that any emissions from sources in Texas do not interfere with 

attainment or maintenance of the 20o8lead NAAQS in another state. 

Section uo(a)(2)(D)(i) also contains a requirement for all states to submit SIP revisions that 

contain adequate provisions prohibiting emissions that will 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 protect visibility. 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 Ambient Air Quality Standards" indicates that these requirements are satisfied 

if a state's SIP includes New Source Review (NSR) and Prevention of Significant 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 Teclmology (BART) determinations, lead 

is not included as a visibility-impairing pollutant and therefore is not expected to interfere with 

measures to protect visibility. 

The October 15, 2008, final rule for the 20o8lead NAAQS (73 FR 66964) included a 

requirement for monitors to be placed in areas with sources, sucll as industrial facilities, that 

emit 1.0 ton per year (tpy) or more oflead and in urban areas with more than soo,ooo people. 

The EPA may waive the source-oriented monitoring requirements if the monitoring agency 

demonstrates that emissions from the source would not contribute to maximum air lead 

concentrations greater than so% of the revised standard or 0.075 11g/m3. On December 14, 

2010, the EPA revised the ambient monitoring requirements for measuring lead in the air. The 

EPA cllanged the emission threshold for industrial facilities to 0.5 tpy, reduced from the 

previous threshold of 1.0 tpy. The TCEQ has completed modeling for the facilities that emit 1.0 

tpy or more and is in the process of completing modeling for the facilities that emit 0.5 tpy or 

more. 

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 near Texarkana (Red River), the American Smelting and Refining 

Company facility near Amarillo (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 eacll result in ambient concentrations ofless than 15% of 

the level of the 2008 lead NAAQS. Additionally, the September 8, 2005, Defense Base Closure 

and Realignment Commission report pursuant to Sections 2903 and 2914 of the Defense Base 

Closure and Realignment Act of 1990 requires the munitions demilitarization activities at Red 

ES-1 
River to be relocated to another facility.' 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 contribute to an ambient air concentration of lead greater than so% of the NAAQS. 

Source-oriented lead monitors have been installed for ASARCO, Exide, and ECS. Modeling of 

the five• operational facilities indicates that lead emissions do not transport over long distances 

and will therefore not impact surrounding nonattainment areas, maintenance areas, or states. 

Modeling for facilities that emit between 0.5 and 1.0 tpy is being conducted to determine the 

need for monitoring. This modeling is expected to give similar results to the previous modeling 

and indicate that there will be no impact on surrounding areas or states. Fort Hood and Oxbow 

model results predict levels of less than 15% of the NAAQS. For Exide, ECS, and ASARCO the 

predicted concentrations dropped to below half the level of the NAAQS within 2 kilometers of 

the property line. To further validate this modeling, there are currently no lead nonattainment 

or maintenance areas in any of the four states that border Texas: Louisiana, Oklahoma, 

Arkansas, and New Mexico. 

Texas has only one nonattainment area under the 2008 lead NAAQS. On November 16, 2010, 

the EPA designated a portion of Collin County, located in Frisco, Texas, as a lead nonattainment 

area, effective December 31, 2010 (75 FR. 71033). This nonattainment area surrounds the Exide 

lead battery recycling facility. An area surrounding Exide was originally designated 

nonattainment for the 1978lead NAAQS on November 6, 1991. On November 29, 1994, the EPA 

approved the Collin County lead attainment demonstration SIP revision. On August 31, 1999, 

the governor of Texas submitted to the EPA a requestto redesignate the nonattaimnent portion 

of Collin County to attainment and to 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 FR. 55421). In 2009, the governor of Texas submitted to the EPA the 

final ten-year maintenance plan for the 1978lead NAAQS. This SIP revision included 

contingency measures set in place to promptly correct any violations of the 1978lead NAAQS. 

The attainment demonstration for the 2008lead NAAQS will be due to the EPA by June 30, 

2012. 

Based on the 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 of nonattainment or maintenance areas in the four 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-2 
SECTION V: LEGAL AUTHORI'IY 

A General 

The Texas Commission on Environmental Quality (TCEQ) has the legal authority to implement, 

maintain, and enforce the National Ambient Air Quality Standards (NAAQS) and to control the 

quality of the state's air, including maintaining adequate visibility. 

The first air pollution control act, known as the Clean Air Act ofTexas,.was passed by the Texas 

Legislature in 1965. In 1967, the Clean Air Act of Texas 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, and 2009. In 1989, the TCAA was 

codified as Chapter 382 of the 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, and its 

powers, duties, responsibilities, and functions were transferred to the Texas Natural Resource 

Conservation Commission (TNRCC). With the creation of the TNRCC, the authority over air 

quality is found in both the Texas Water Code and the TCAA Specifically, the authority of the 

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 of the TNRCC, and the 

responsibilities and authority of the executive director. This chapter also authorizes the TNRCC 

to implement action when emergency conditions arise and to conduct hearings. Chapter 7 gives 

the TNRCC enforcement authority. In 2001, the 77th Texas Legislature continued the existence 

of the TNRCC until September 1, 2013, and changed the name of the TNRCC to the Texas 

Commission on Emironmental Quality (TCEQ). In 2009, the 81st Texas Legislature, during a 

special session, amended section 5.014 of the Texas Water Code, changing the expiration date of 

the TCEQ to September 1, 2011, unless continued in existence by the Texas Sunset Act. 

The TCAA specifically authorizes the TCEQ to establish the level of quality to be maintained in 

the state's air and to control the quality of the state's air by preparing and developing a general, 

comprehensive plan. The TCAA, Subchapters A- D, also authorize the TCEQ to collect 

information to enable the commission to develop an inventory of emissions; to conduct research 

and investigations; to enter property and examine records; to prescribe monitoring 

requirements; to institute enforcement proceedings; to enter into 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 of the state as well as with industries and the 

federal government; and to establish and operate a system of permits for construction or 

modification of facilities. 

Local government authority is found in Subchapter E of the 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 of the TCEQ that affects their 

territorial jurisdiction, may bring enforcement actions, and may execute cooperative agreements 

with the TCEQ or other local governments. In addition, a city or town 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 of the commission. 
Subchapters G and H of the TCAA authorize the TCEQ to establish vehicle inspection and 

maintenance programs in certain areas of the state, consistent with the requirements of the 

Federal Clean Air Act; coordinate with federal, state, and local transportation planning agencies 

to develop and implement transportation programs and measures necessary to attain and 

maintain the NAAQS; establish gasoline volatility and low emission diesel standards; and fund 

and authorize participating counties to implement vehicle repair assistance, retrofit, and 

accelerated vehicle retirement programs. 

B. Anniicable Law 

The following statutes and rules provide necessary authority to adopt and implement the state 

implementation plan (SIP). The rules listed below have previously been submitted as part of the 

SIP. 

Statutes 

All sections of each subchapter are included, unless otherwise noted. 

TEXAS HEALTH & SAFElY CODE, Chapter 382 

TEXAS WATER CODE 

Chapter 5: Texas Natural Resource Conservation Commission 

Subchapter A:. General Provisions 

September 1, 2009 

September 1, 2009 

Subchapter B: Organization of the Texas Natural Resource Conservation Commission 

Subchapter C: Texas Natural Resource Conservation Commission 

Subchapter D: General Powers and Duties of the 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) 

Subchapter H: Delegation of Hearings 

Subchapter 1: Judicial Review 

Subchapter J: Consolidated Permit Processing 

Subchapter L: Emergency and Temporary Orders (§§5.514, 5.5145, and 5.515 only) 

Subchapter M: Environmental Permitting Procedures (§5.558 only) 

Chapter 7: Enforcement 

Subchapter A: General Provisions (§§7.001, 7.002, 7.0025, 7.004, and 7.005 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 of the following rules are found in 30 Texas Administrative Code, as of the following latest 

effective dates: 

Chapter 7: Memoranda of Understanding, §§7.110 and 7.119 

Chapter 19: Electronic Reporting 

Chapter 35: Subchapters A-C, K: Emergency and Temporary Orders and 

Permits; Temporary Suspension or Amendment of Permit Conditions 

ii 

May2, 2002 

March 15,2007 

July 20, 2006 
Chapter 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, Subchapter A Decentber 11, 2002 

Chapter 111: Control of Air Pollution from Visible Emissions and Particulate 

Matter July 19,2006 

Chapter 112: Control of Air Pollution from Sulfur Compounds July 16, 1997 

Chapter 113: Standards of Performance for Hazardous Air Pollutants and for 

Designated Facilities and Pollutants May 14, 2009 

Chapter 114: Control of Air Pollution from Motor Vehicles December 13, 2010 

Chapter 115: Control of Air Pollution from Volatile Organic Compounds February 17, 2011 

Chapter u6: Permits for New Construction or Modification March 3, 2011 

Chapter 117: Control of Air Pollution by Control of Air Pollution from 

Nitrogen Compounds February 4, 2010 

Chapter 118: Control of Air Pollution 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 of Economic Incentives, Marketable Permits, and 

Emissions Trading 

iii 

June3, 2001 
SECflON 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 of Nitrogen (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) 

iv 
TABLE OF CONTENTS 

Executive Summary 

Section V: Legal Authority 

Section VI: Control Strategy 

Table of Contents 

List of Acronyms 

List of Tables 

List of Appendices 

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 N onattainment and Interference with Maintenance 

Elements 

2.2.1.1 Dispersion Modeling 

2.2.1.2 Monitoring Sites 

2.2.2 Collin County SIP Revisions 

2.2.2.11993 Lead SIP 

2.2.2.2 1999 Redesignation Request and Maintenance Plan 

2.2.2.3 2009 Second Ten-Year Maintenance Plan 

2.2.2-4 Nonattainment Designation Under the 2008 Lead NAAQS 

2.2.3 Prevention of Significant Deterioration and Nonattainment New Source Review 

Elements 

v 
2.2-4 Protection of Visibility Element 

Chapter 3: Future Attainment Plans 

vi 
USTOFACRONYMS 

BART Best Available Retrofit Technology 

EPA United States Environmental Protection Agency 

FCAA Federal Clean Air Act 

FR Federal Register 

IQ Intelligence Quotient 

NAAQS National Ambient Air Quality Standard 

NSR New Source Review 

PSD Prevention of Significant 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 

J.ig/m3 micrograms per cubic meter 

vii 
UST OF TABLFS 

Table 1-1: Public Hearing Information 

viii 
APPendix 

Appendix A 

AppendixB 

LIST OF APPENDICES 

Appendix Name 

Lead Modeling Analyses 

TCEQ Lead Monitoring Network 

ix 
CHAPTER 1: GENERAL 

1.1 BACKGROUND 

"The History of the Texas State Implementation Plan (SIP)," a comprehensive overview of the 

SIP revisions submitted to the United States Environmental Protection Agency (EPA) by the 

State of Texas, 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 of lead descnbes how the Texas 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 of emissions activity within the state from emitting any air 

pollutants in amounts that will: 

• contribute significantly to nonattainment of the National Ambient Air Quality Standards 

(NAAQS) for areas in other states; 

• interfere with maintenance of the NAAQS by any other state; 

• interfere with measures required for any other state to meet an implementation plan related 

to Prevention of Significant Deterioration; or 

• interfere with measures required for any other state to meet the implementation plan related 

to regional haze and visibility. 

Based on the 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 of nonattainment or 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 strengthened theNAAQS for lead. The new 

standard, set at 0.15 micrograms per cubic meter (j.!g/m') measured as a rolling three-month 

average, is ten times more stringent than the previous standard of 1.5 j.!g/m' measured as a 

quarterly average. According to the EPA, scientific evidence about lead and health has expanded 

dramatically since the EPA issued the initial 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 

lower levels oflead in blood than previously thought. 

Lead that is emitted into the air can be inhaled directly or ingested 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 the body, lead 

distributes throughout the body in the blood and accumulates in the bones. Depending on the 

level of exposure, 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 of the blood. 

The lead effects most ·commonly encountered in current populations 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 of exposure to lead when compared to adults. The risk of 

1-1 
exposure is higher because children tend to put their hands and other objects which may contain 

lead into their mouths (e.g., lead-based paint chips from older homes). Children also have a 

higher risk of adverse effects because their brains are still developing. Infants and young 

children are especially sensitive to low levels of lead, which may contribute to behavioral 

problems, learning deficits, and lowered intelligence quotient (IQ). 

1.4 PUBLIC HEARING AND COMMENT INFORMATION 

The commission will hold a public hearing for this proposed SIP revision at the 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, or through the eComments system. All comments 

should reference the "Lead Transport Plan for the 2008 Lead National Ambient Air Quality 

Standard" and Project Number 2011-005-SIP-NR. Comments may be submitted to Shelley Naik, 

MC 206, State Implementation Plan Team, 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 be submitted at http://wwws.tceq.texas.gov/rules/ecomments. File 

size restrictions may apply to comments being submitted via the eComments system. Comments 

must be received by May 23, 2011. 

Copies of the proposed SIP revision and its appendices can be obtained from the TCEQ Web site 

at: http:/{www.tceq.texas.gov /implementation/air/sip/texas-sip or upon 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 SOCIAL AND ECONOMIC CONSIDERATIONS 

Because rulemaking is not a part of this SIP revision, there are no changes that would have an 

impact on society or the economy. 

1.6 FISCAL AND MANPOWER RESOURCFS 

The TCEQ has determined that its fiscal and manpower resources are adequate and will not be 

adversely affected through the implementation of this plan. 

1.7 COORDINATION WITH LOCAL AGENCIFS 

The TCEQ has determined that there will be no assignment to local agencies. However, preexisting assignments to local agencies regarding various enforcement activities remain in effect 

and could be utilized if enforcement activities are delegated to the TCEQ from the EPA. 

1·2 
1.8 ORGANIZATIONS RESPONSIBLE FOR DEVELOPMENT, IMPLEMENTATION, 

AND ENFORCEMENT 

The TCEQ is the agency delegated authority by the Texas Legislature regarding the protection of 

air quality in the State of Texas. Other local government entities have limited authority 

regarding air quality matters in the State of Texas. 

1.9 DATAAVAILABILITY 

The TCEQ affinns that it will retain all data used in the preparation of this SIP revision. All 

supporting documents 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 the TCEQ 

upon request. 

1·3 
CHAPTER 2: REQUIRED CONTROL STRATEGY ELEMENTS 

2.1 BACKGROUND 

There are currently six facilities in Texas that emit 1.0 ton per year (tpy) or more oflead. 

Dispersion modeling oflead emissions from the five operational facilities (the Red River Army 

Depot was not modeled because it will be 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 of these four states. 

Texas has only one nonattainment area under the 2oo8lead National Ambient Air Quality 

Standard (NAAQS). On November 16, 2010, the United States Environmental Protection Agency 

(EPA) designated a portion of Collin 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 under the 1978lead NAAQS. Control measures are in place under this 

maintenance plan. The attainment demonstration for the 2008 lead NAAQS is due to the EPA 

by June 30, 2012, and will include additional control measures, if necessary, to meet the 

attainment deadline of December 31, 2015. 

Texas has existing control strategies in place in Collin County and modeling that indicates that 

lead emissions from sources that emit 1.0 tpy or more will not transport to surrounding states. 

Therefore, interstate transport of lead emissions in Texas has been adequately addressed. 

2.2 CONTROL STRATEGY OVERVIEW 

Federal Oean Air Act (FCAA) §uo(a)(2)(D)(i) requires states to 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 amounts that will: 

• contribute significantly to nonattainment of the NAAQS for areas in other states; 

• interfere with maintenance of the 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 state to meet the implementation plan related 

to regional haze and visibility. 

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 or more tpy of lead and in 

urban areas with more than soo,ooo people. The EPA may waive the source-oriented 

monitoring requirements if the monitoring agency demonstrates that emissions from the source 

would not contnbute to maximum air lead concentrations greater than 50% of the revised 

standard, or 0.075 micrograms per cubic meter (~g/m'). On December 14, 2010, the EPA 

revised the ambient monitoring requirements for measuring lead in the air. The EPA changed 

the emission threshold for industrial facilities to 0.5 tpy, reduced from the previous threshold of 

1.0 tpy. The Texas Commission on Environmental Quality (TCEQ) has completed modeling for 

the facilities that emit 1.0 tpy or more and is in the process of completing modeling for the 

2·1 
facilities that emit between 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 of lead 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), the American Smelting and Refining Company facility 

near Amarillo (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 ofless than 15% of the 2008lead NAAQS. 

Additionally, the September 8, 2005, Defense Base Closure and Realignment Commission 

report pursuant to Sections 2903 and 2914 of the Defense Base Closure and Realignment Act of 

1990 requires the munitions 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 submitted waiver 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 oflead greater than so% of the NAAQS. Source-oriented lead 

monitors have been installed for ASARCO, Exide, and ECS. Modeling of the five3 operational 

facilities indicates that lead emissions do not transport over long distances and will therefore 

not impact surrounding areas or states. Fort Hood and Oxbow model results predict levels of 

less than 15% of the NAAQS. For Exide, ECS, and ASARCO the predicted concentrations 

dropped to below half the level of the NAAQS within 2 kilometers of the property line. 

The finding that lead does not transport over long distances is supported by the EPA in the 

December 14, 2010, "Revisions to Lead Ambient Air Monitoring Requirements." In that final 

rule, the EPA indicated when selecting airports for an airport monitoring study, "We selected a 

maximum distance to ambient air from the location of maximum emissions of 150 meters 

because the available information indicates that ambient lead concentrations drop off quickly 

with distance, and it is less likely that an exceedance of the lead NAAQS will occur at greater 

distances. "4 To further validate this finding, there are currently no lead nonattainment or 

maintenance areas in any of the four states surrounding Texas: Louisiana, Oklal10ma, Arkansas, 

and New Mexico. Details of the dispersion modeling conducted by the TCEQ can be found in 

Appendix A: Lead Modeling Analyses. 

2.2.1.2 Monitoring Sites 

The TCEQ currently operates ulead monitoring sites in Amarillo, Frisco, Terrell, Houston, 

Laredo, and Brownsville. These sites are listed in Appendix B: TCEQ Lead Monitoring 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 the TCEQ has submitted waiver 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 or more and operation of one lead 

monitor at each site that is part of the multi-pollutant site network known as the National Core 

monitoring network. Modeling for the sources meeting these criteria will be conducted by the 

TCEQ, and monitors will be installed or waiver requests will be submitted accordingly. The final 

rule also requires monitors to be installed at Stinson Municipal Airport in Bexar County and 

Northwest Regional Airport in Denton County for an airport monitoring study. 

3 Red River was not modeled, because it will be shut down in 2011. 

4 EPA, "Revisions to Lead Ambient Air Monitoring Requirements," December 14, 2010, 

http:/ jwww.epa.govjairjleadjpdfs/PbRevision-ForPublication.pdf 

2-2 
2.2.2 Collin County SIP Revisions 

2.2.2.1 1993 Lead SIP 

On November 6, 1991, the EPA published the notice of nonattainment designation for lead in the 

Federal Register (56 FR 56694) for the portion of Collin County that essentially encompassed 

the plant boundaries of the Gould National Battery, Incorporated facility, later known as GNB 

Technologies, Incorporated (GNB), and now known as Exide Technologies, Incorporated 

(Exide). The effective date of the nonattainment designation was January- 6, 1992. Under the 

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 nonattainment area was required to attain the 1978lead NAAQS by January- 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 New Source Review (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 

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 

of these reductions was to be maintained through pennit restrictions, emissions limits, and 

standard operating procedures for controlling emissions from process sources, process fugitive 

sources, and fugitive 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 had been 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 of the 

monitoring network that would be used to detennine when an exceedance of the lead NAAQS 

occurred for the purpose of triggering 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 the blast furnace; 

and (3) install an alternative measure that will provide, at a minimum, emissions reductions 

equivalent to those listed previously. 

The EPA approved the 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 of an additional SIP revision to provide for maintenance of the 

1978 NAAQS for lead for the second ten-year period following redesignation of the 

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 

contingency measures set in place to promptly correct any violations of the 1978lead NAAQS. 

2-3 
The contingency measures 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 those listed previously. The contingency measures were made legally enforceable under an 

agreed order adopted concurrently with the maintenance plan. 

2.2.2.4 Nonattainment Designation 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 in Collin County, Texas as a 

lead nonattainment area. The attainment demonstration for the 2008 lead NAAQS is due to the 

EPA by June 30, 2012, and will include control measures necessary to meet the attainment 

deadline of December 31, 2015. 

2.2.3 Prevention of Significant Deterioration and Nonattainment 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 or type of emissions activity within the state from 

emitting air pollutants in amounts that will interfere with another state's SIP measures for 

preventing significant deterioration of air 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) National Ambient Air Quality Standards" indicates that these requirements are satisfied 

if a state's SIP includes NSR and PSD programs. 

All major sources in Texas are subject to PSD and nonattainrnent NSR permitting programs, 

implemented in 30 Texas Administrative Code (TAC) Chapter 116. Major sources are defined in 

30 TAC §116.12(17) in relation to the federal classification of an area for nonattainment 

permitting and by reference to 40 Code of Federal Regulations §51.166 for PSD. 

2.2.4 Protection ofViSioility Element 

Section no(a)(2)(D)(i)(Il) also contains a requirement for all states to submit SIPs that contain 

adequate provisions prohibiting" ... any source or other type of emission activity within the state 

from emitting any air pollutant in amounts which will interfere with measures required to be 

included in the applicable implementation plan for any other state .... to protect visibility." On 

July 6, 2005, the EPA published regional haze regulations and guidelines for Best Available 

Retrofit Technology (BART) determinations in the Federal Register. The BART guidelines 

include the following list of visibility-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 not expected to interfere with measures to protect 

visibility in any other state. 

2-4 
CHAPTER 3: FUIURE ATI'AINMENT PLANS 

Federal Clean Air Act (FCAA), §uo(a)(l) requires states to submit state implementation plans 

within three years after the promulgation of new or revised National Ambient Air Quality 

Standards (NAAQS) to meet the requirements of FCAA, §uo(a)(2), including FCAA, 

§uo(a)(2)(D)(i), relating to interstate transport. Therefore, if the NAAQS are revised in the 

future, the Texas Commission on Environmental Quality will need to take the adequate steps 

relating to the interstate transport of air pollution. 

3-1 
APPENDIX A: LEAD MODEUNG ANALYSES 
Texas Commission on Environmental Quality 

INTEROFF1CE MEMORANDUM 

To: 

Thru: 

From: 

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 22,2009 

Subject: Modeling Analysis of Lead 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 for lead based on a rolling threemonth average (73 Federal Register 66964). In general, the rule requires sourceoriented ambient air lead monitoring by January 1, 2010, at sites with actual annual 

lead emissions of one or more tons per year. Asarco LLC 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 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 of one or 

more tons. 

The TCEQ conducted air dispersion modeling of all the lead 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 of any required source-<Jriented monitors. 

ArcReader Published Map: 

\\Msgjswrk\and\MODEL PROJECIS\Lead NAAOS 

Analvsis 2009\Lead NMOS Analvsis Results.pmf 

2.0 Report Summary. 

The predicted maximum ground level concentration (GLCrnax) is 0.21 J.lg/m3 for a 

rolling three-month average. The location of the GLCmax is along the southeastern 

property line. Ail predicted concentrations exceeding the NAAQS are located to the 

southeast of the Asarco LLC site and extended less than 150 meters from the site 

property line. Table 1lists the location of the predicted GLCrnax. The location 

coordinates are in the UTM Zone 14 North, North American Datum of 1927 (NAD27) 

coordinate system. · 
David Brymer 

Page 2 of 4 

June 22, 2009 

Modeling Analysis of Lead 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 using AERMAP 

(Version 09040). The input data used for 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 source parameters and emission rates were provided by Asarco 

LLC. The source locations were validated by ADMT using aerial photography. Only 

source 7A has a listed maximum allowable emission rate for lead. For the other three 

sources, emissions estimates were submitted by Asarco LLC and then validated by APD 

permit reviewing staff for use in this analysis. The emission rates represent worst case 

1-hour average emission rates and may be more conservative than 24-hour or monthly 

average emission rates. The emission source coordinates are in the UTM :l<me 14 

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) 

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 5.49 
David Brymer 

Page 3 of 4 

June 22, 2009 

Modeling Analysis of Lead 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. The building locations were validated by ADMT 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 AERSURF ACE analysis conducted of the area surrounding the Asarco LLC site 

resulted in a calculated roughness length of 0.155 meters. The vast majority of the area 

considered industrial and urbanized (and with a higher roughness length) is 

concentrated ncar the emission sources. The dispersion of emissions from the sources 

will be highly influenced by this higher roughness length- A representative roughness 

length for the area would be approximately 0.5 meters. For this reason, the 

meteorological data set used for this analysis was developed using a roughness length 

of 0.5 meters. 

7.0 Receptor Grid. 

The receptor grid used in the modeling analysis consisted of receptors with 100 meter 

spacing and extended approximately 2 kilometers (km) from the Asarco LLC site 

property line in all directions. The purpose of the receptor grid was to determine a 

representative maximum ground-level concentration and the extent of ground-level 

concentrations at or above half of the lead NAAQS standard. 
David Brymer 

Page4 of 4 

June 22, 2009 

Modeling Analysis of Lead 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 of the application site. Since the current version 

of AERMOD is not capable of calculating rolling three-month average concentrations, 

the EPA post processor LeadPost was used. The input values to LeadPost 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 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: Modeling Analysis of Lead 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 per cubic meter (J.Lg/m3) NMQS for lead based on a rolling threemonth average ( 73 Federal Register 66964). In general, the rule requires sourceoriented ambient air lead monitoring by January 1, 2010, at sites with actual annual 

lead emissions of one or more tons per year. ECS Refining Texas LLC 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 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 of one or more tons. 

The TCEQ conducted air dispersioR modeling of all the lead 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 of any required source-oriented monitors. 

ArcReader Published Map: 

\\Msgiswrk\apd\MODEL PROJECf8\Lead NMOS 

Analvsis 2009\Lead NMOS Ana!vsis Results.pmf 

2.0 Report Summary. 

The predicted maximum ground level concentration (GLCmax) is 4.06 J.Lg/m3 for a 

rolling three-month average. The location of the GLCmax is along the northern 

property line. 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, 

and 0.3 km to the east of the site property line. Table 1lists the location of the 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 

June 29, 2009 

Modeling Analysis of Lead 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 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 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 provided by ECS 

Refining Texas LLC. 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 permit 19430. The emission rates 

represent worst case 1-hour average emission rates and may be more conservative than 

24-hour or monthly average emission rates. The emission source coordinates are in the 

UTM Zone 14 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) 

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 0.66 
David Brymer 

Page 3 of 4 

June 29, 2009 

Modeling Analysis of Lead 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 

provided by ECS Refining Texas LLC. The building locations were validated by ADMT 

using aerial photography. 

6.o Meteorological Data. 

Surface Station and ID: Dallas/Fort Worth, 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 of the area surrounding the ECS Refining Texas 

LLC site resulted in a calculated roughness length of 0.109 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 set used 

for this analysis was developed using a roughness length of 0.5 meters. 
David Brymer 

Page4 of 4 

June 29, 2009 

Modeling Analysis of Lead for ECS Refining Texas LLC 

7.0 Receptor Grid. 

The receptor grid used in the modeling analysis consisted of receptors with 100 meter 

spacing and extended approximately 3 kilometers (km) from the ECS Refining Texas 

LLC site property line in all directions. The purpose of the receptor grid was to 

determine a representative maximum ground-level concentration and the extent of 

ground-level concentrations at or above half of the lead NAAQS standard 

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 of the application site. Since the current version 

of AERMOD is not capable of calculating rolling three-month average concentrations, 

the EPA post processor LeadPost was used. The input values to LeadPost are monthly 

average values at each receptor in the POSTFILE output format from AERMOD. 
Texas Commission on Environmental 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 of Lead 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.Lg/m3) NAAQS for lead based on a rolling threemonth average (73 Federal Register 66964). In general, the rule requires sourceoriented ambient air lead monitoring by January 1, 2010, at sites with actual annual 

lead emissions of one or more tons per year. 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 Toxics 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 of one or more tons. 

In 2009, the TCEQ conducted air dispersion modeling of all the lead emission sources 

at the site using the most current modeling parameters and associated permitted 

allowable emissions rates. In October 2010, Exide Technologies submitted information 

to the TCEQ documenting a reduction in permitted allowable emission rates for some 

sources. Some of these 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 of any required sourceoriented monitors. 

Since monitoring already exists at and near the 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 of a lead nonattainment area. 

ArcReader Published Map: 

\\Msgiswrk\aod\MODEL PRQJECTS\Lead NMOS 

Analysis 2010 reyjsed\Lead NMOS Analvsis Results 2010 reviseQ..pmf 
David Brymer 

Page 2 of? 

October 8, 2010 

Modeling Analysis of Lead 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 ofthe GLCmax is the same as the location of 

monitor 480850009 on the north property line of the Exide Technologies site. 

Predicted concentrations exceeding the NAAQS extended approximately 0.8 kilometers 

(km) to the north, o.s krn to the south, 0.5 krn to the west, and 0.2 krn to the east of the 

site property line. All predicted concentrations greater than the NAAQS are located 

within Collin County. Table 1 lists the predicted concentrations at the current monitor 

locations and proposed monitor location near the intersection of 1st Street and Ash 

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 and Terrain. 

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 using AERMAP 

(Version 09040). The input data 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 source parameters and emission rates were provided by 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 in the 

liTM Zone 14 North, North American Datum of 1927 (NAD27) coordinate system. 
David Brymer 

Page 3 of7 

October 8, 2010 

Modeling Analysis of Lead for Exide Technologies, Frisco Battery Recycling Plant 

Table 2. On-Property Point Source Parameter Information 

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 

0.1707 
David Brymer 

Page4 of? 

October 8, 2010 

Modeling Analysis of Lead 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 0.02 
David Brymer 

Page 5 of7 

October 8, 2010 

Modeling Analysis of Lead for Exide Technologies, 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 0.13 
David Brymer 

Page 6 of7 

October 8, 2010 

Modeling Analysis of Lead 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 

provided by Exide Technologies. The building locations were validated by ADMT using 

aerial photography. 

6.0 Meteorological Data. 

Surface Station and ID: Dallas/Fort Worth, 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 AERSURFACE analysis conducted of the area surrounding the Exide Technologies 

site resulted in a calculated roughness length of 0.129 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 

2008 aerial photography, a representative roughness length for the area would be 

approximately o.s meters. For this reason, the meteorological data set used for this 

analysis was developed using a roughness length of o.s meters. 

7.0 Receptor Grid. 

The receptor grid used in the modeling analysis consisted of receptors with so meter 

spacing and extended approximately 1.5 kilometers (km) from the Exide Technologies 

site property line in all directions. An additional grid consisted of receptors with 100 m 

spacing and extended 3·5 km beyond the first receptor grid in all directions. Discrete 

receptors were used for the locations of the three existing monitoring stations and the 

location of a proposed monitoring station near the intersection of 1st Street and Ash 

Street. The purpose of the receptor grid was to determine a representative maximum 

ground-level concentration and the extent of ground-level concentrations at or above 

half of the 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 the latest approved EPA model version. For refined screening, 

National Weather Service (NWS) meteorological raw input data are used with 

generalized surface cllaracteristics of the application site. Since the current version of 

AERMOD is not capable of calculating rolling three-month average concentrations, the 

EPA post processor LeadPost was used. The input values to LeadPost are monthly 

average values at each receptor in the POSTFILE output format from AERMOD. 
David Brymer 

Page 7 of7 

October 8, 2010 

Modeling Analysis of Lead for Exide Technologies, Frisco Battery Recycling Plant 

For this analysis, only emission sources at the Exide Technologies site were considered. 

The nearest source of lead emissions outside the modeling domain is approximately 20 

Ian from the Exide Technologies site with reported 2007lead annual emissions 

approximately one percent of the annual lead emissions reported by Exide 

Technologies. The largest nearby source of lead emissions is approximately so Ian from 

the Exide Technologies site with annual reported emissions approximately ten percent 

of the annual emissions reported by Exide Technologies. Due to the great distance to 

the Exide Technologies site and the small reported emission, no other sources of lead 

emissions would have a significant contribution near the Exide Technologies site or the 

modeling domain used for this analysis. 
Texas Commission on Environmental 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 Modeling Team 

Air Permits Division 

September 25, 2009 

Subject: Modeling Analysis of Lead 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 per cubic meter (l!g/mJ) NAAQS for lead based on a rolling threemonth average (73 Federal Register 66964). In general, the rule requires sourceoriented ambient air lead monitoring by January 1, 2010, at sites with actual annual 

lead emissions of one or more tons per year. Oxbow Calcining LLC 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 predicted by modeling, that results from sources with annual lead 

emissions of one or more tons. 

The TCEQ conducted air dispersion modeling of all the lead 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 of any required source-oriented monitors. 

ArcReader Published Map: 

\ \Msgiswrk\apd\ MODEL PROJEcrg\Lead NMQS 

Analvsis 20og\Lead NAAOS Analvsis Results.pmf 

2.0 Report Summary. 

The predicted maximum ground level concentration (GLCmax) is 0.016 11gfmJ for a 

rolling three-month average. The location of the GLCmax is approximately 70 meters 

from the northwest property line. Table 11ists the location of the predicted GLCmax. 

The location coordinates are in the UTM Zone 15 North, North American Datum of 

1927 (NAD27) coordinate system. 
Jim Price 

Page 2 of 4 

September 25, 2009 

Modeling Analysis of Lead 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 and Terrain. 

GlC Standard 

(1-l&'m') (ll8fm') 

0.016 0.1S 

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 using AERMAP 

(Version 09040). The input data used for this analysis was the United States Geological 

Survey (USGS) National Elevation Dataset (NED) for the Port Arthur 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 aerial photography. The emission rates represent worst case 1-hour average 

emission rates and may be more conservative than 24-hour or monthly average 

emission rates. The emission source coordinates are in the 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 2.37 
Jim Price 

Page3 of 4 

September 25, 2009 

Modeling Analysis of Lead 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 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 by ADMT 

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 

The AERSURF ACE analysis conducted of the area surrounding the Oxbow Calcining 

LLC site resulted in a calculated roughness length of 0.028 meters. Since the 

AERSURFACE 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 0.05 meters. For this reason, the meteorological data set used 

for this analysis was developed using a roughness length of 0.05 meters. 

7.0 Receptor Grid. 

The receptor grid used in the modeling analysis consisted of receptors with 1 oo meter 

spacing and extended approximately 1.5 kilometers (km) from the Oxbow Calcining 

LLC site property line in all directions. The purpose of the receptor grid was to 

determine a representative maximum ground-level concentration and the extent of 

ground-level concentrations at or above half of the lead NAAQS standard. 
Jim Price 

Page4 of 4 

September 25, 2009 

Modeling Analysis of Lead for Oxbow Calcining LLC 

8.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 of the application site. Since the current version 

of AERMOD is not capable of calculating rolling three-month average concentrations, 

the EPA post processor LeadPost was used. The input values to LeadPost 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 Modeling Team 

Air Permits Division 

Date: July 24, 2009 

Subject: Modeling Analysis of Lead 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 (~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 by January 1, 2010, at sites with actual annual 

lead emissions of one 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 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 of one or more tons. 

The TCEQ conducted air dispersion modeling of all 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 of any required source-oriented 

monitors. 

ArcReader Published Map: 

\\Msgjswrk\aod\MODEL PROJECTS\Lead NAAOS 

Analysis 2009\Lead NMOS Analysis Results.pmf 

2.0 Report Summary. 

The predicted maximum ground level concentration (GLCmax) is 0.02 ~g/m3 for a 

rolling three-month average. The location of the GLCmax is along the southern 

property line. Table 1lists the location of the predicted GLCmax. The location 

coordinates are in the UTM Zone 14 North, North American Datum of 1927 (NAD27) 

coordinate system. 
David Brymer 

Page 2 of 4 

July 24, 2009 

Modeling Analysis of Lead 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 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 using AERMAP 

(Version 09040). The input data used for this analysis was the United States Geological 

Survey (USGS) National Elevation Dataset (NED) for Gatesville West, Gatesville East, 

Shell Mountains, North Fort Hood, Fort Hood, and Post Oak Mountains quadrangles. 

4.0 Modeling Emissions Inventory. 

The modeled emission source parameters and emission rates were provided by Fort 

Hood. The source locations were validated by ADMT. The source emission rates 

modeled were based on air emissions estimates reported in the Fort Hood 2007 Toxic 

Release Inventory (TRI). Though the emissions were reported for many firing ranges at 

various locations around Fort Hood, for this demonstration all of the emissions were 

conservatively represented to be emitted only from the firing ranges nearest the areas 

of public activity. From the 2007 TRI data and activity data for 2008, the firing ranges 

with the highest emissions were the furthest away from public locations and largest in 

extent. Public activities are limited to the southern and the northern ends of Fort Hood. 

The central areas and areas on the east and west of Fort Hood are restricted from 

public access. The emission rates represent worst case 1-hour average emission rates 

and may be more conservative than 24-hour or monthly average emission rates. 

Table 2. On-Property Source Modeled Emission Rates 

Source Averaging Emission Rates 

Pollutant 

10 Time (lb/hr) 

NFHS Lead 1-hr 0.0056 

NFHR Lead 1-hr 0.0079 
David Brymer 

Page 3 of 4 

July 24, 2009 

Modeling Analysis of Lead 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 

0.0367 
David Brymer 

Page4 of 4 

July 24, 2009 

Modeling Analysis of Lead for U.S. Army (Fort Hood) 

Upper Air Station and ID: Stephenville, TX (Station #: 13091) 

Meteorological Dataset: 1985, 1987, 1988, 1989, 1990 

Profile Base Elevation: 499 feet 

The AERSURF ACE analysis conducted of the area surrounding the U.S. Army (Fort 

Hood) site resulted in a calculated roughness length of 0.369 meters. Since the 

AERSURFACE 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 set used 

for this analysis was developed using a roughness length of 0.5 meters. 

7.0 Receptor Grid. 

The two receptor grids used in the modeling analysis consisted of receptors with 100 

meter spacing. The larger receptor grid was located in close proximity to the southern 

firing ranges and extended approximately 2 kilometers (km) from these firing ranges to 

the south. The smaller receptor grid was located in close proximity to the northern 

firing ranges and extended approximately 2 km from these firing ranges to the 

northeast. The purpose of the receptor grid was to determine a representative 

maximum ground-level concentration and the extent of ground-level concentrations at 

or above half of the lead NAAQS standard. 

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 

of AERMOD is not capable of calculating rolling three-month average concentrations, 

the EPA post processor LeadPost was used. The input values to LeadPost are monthly 

average values at each receptor in the POSTFILE output format fromAERMOD. 
APPENDIX B: TCEQ LEAD MONITORING NE1WORK 
Table 1: TCEQ Lead Monitoring Network 

AQS1 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 

SLAMS 

SLAMSSpecial 

Purpose 

SLAMS/ 

Border 

SLAMS/ 

Border 

s Inductively Coupled Plasma Mass Spectrometry (ICP-MS) 

• Quality Assurance (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 TESTIMONY 
Reference Number 

W-1 

INDEX OF WRITTEN TESTIMONY 

Submitted by 

Steve Spacek 
From: 

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 of the 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 of Texas 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 of man-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 of American state governance. 
INDEX OF ORAL TESTIMONY 

NO ORAL TESTIMONYW AS RECEIVED PERTAINING TO 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 Chief Clerk 

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 strengthened the 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) of the Federal Clean Air Act (FCAA) requires states to submit a SIP 

revision to provide for the implementation, maintenance, and enforcement of the NAAQS. 

States must adopt and submit new SIP revisions within three years after the promulgation 

of a 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 of the NAAQS in any other 

state, interfere with maintenance in any other state, interfere with any other state's 

required measures to prevent significant deterioration of its air quality, or interfere 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 Ambient Air Quality Standards" for states to use to 

address the §11o(a)(2)(D)(i) interstate transport requirements. The EPA Region 6 

communicated to the Texas Commission on Environmental Quality (TCEQ) on May 17, 

2007, that the §11o(a)(2)(D )(i) submittal for 1997 eight-hour ozone and 1997 fine 

particulate matter (PM2.5) should be submitted as a SIP revision, and required notice, 

comment, and public hearing by the state. Based on this 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 of the SIP revision: 

A.) Summary of what the SIP revision will do: 

The adopted SIP revision would meet the requirements of the FCAA, §no(a)(2)(D)(i), 

relating to the interstate transport of lead under the 2008 lead NAAQS. The SIP revision 

will reference existing control strategies to reduce the concentration of lead in Collin 

County, as well as dispersion modeling of major 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. 

B.) Scope required by federal 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 significantly to nonattainment of the lead NAAQS for areas in other 

states; 

• not interfering with the maintenance of the 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; and 

• not interfering with measures required to meet the implementation plan for any 

other state related to regional haze and visibility . 

. C.) Additional staff recommendations that are not required by federal rule or 

state statute: 

None 

Statutory authority: 

The authority to propose and adopt the SIP is derived from Texas Health and Safety Code, 

Texas Clean Air Act (TCAA), §382.002, which provides that the policy and purpose of the 

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 of the state's air; and Texas Water Code, §5.02, General Powers, and §5.013, 

General Jurisdiction of the Commission. 

The FCAA, 42 USC §§7401, et seq., 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 of the state. Additionally, the specific requirements for the 2008 Lead 

NAAQS were published in the November 12, 2008, issue of the Federal Register (73 FR 

66963). 
Commissioners 

Page3 

July 29, 2011 

Re: Docket No. 2011-0065-SIP 

Effect on the: 

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 opened because no party 

indicated a desire to give rom ment. 

The public comment period opened April 22, 2011, and closed May 23, 2011. One comment 

was received, but it was outside the scope of the SIP revision. 

Significant changes from proposal: 

After proposal, the TCEQ completed modeling for the two facilities that emit between o.s 

tons per year (tpy) and 1.0 tpy of lead: 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 of less thnn 1% of the level of the 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 of Texas' lead nonattainment area and the radius of impact 

of the major lead sources in the state, it has been concluded that Texas sources do not 

impact other states' attainment or maintenance of the lead NAAQS. However, the EPA has 

not yet issued guidance to address §11o(a)(1) and (2) requirements for the 2008 lead 

NAAQS and may require additional analysis to approve this SIP revision. 

Does this SIP revision affect any current policies or require development of 

new policies? 

No 
Commissioners 

Page4 

July 29, 2011 

Re: Docket No. zon-oo6s-SIP 

"What are the consequences if this 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 to promulgate 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, Staff Attorney, 239-0891, Environmental Law Division 

cc: Chief Clerk, 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 FOR THE 2008 LEAD NATIONAL AMBIENT AIR QUALITY 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 in Austin. A question 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 April22, 2011, and closed on May 23, 2011. The 

commission received written comments from one individual. 

GENERAL COMMENTS 

One individual expressed concern about public-property litter removal efforts in Texas. 

The purpose of this plan is to meet the interstate transport requirements of 

Federal Clean Air Act, §11o(a)(2)(D)(i) by documenting that any lead emissions 

into the air from sources in Texas do not interfere with attainment or maintenance 

of the 2008 Lead National Ambient Air Quality Standard in another state. Litter 

removal efforts are beyond the scope of this plan. 

1 
STAFF 

RECOMMENDATIONS
REVISIONS 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 FOR THE 2008 LEAD NATIONAL 

AMBIENT AIR QUALITY STANDARD 

PROJECT NUMBER 2011-oos-SIP-NR 

Adoption 

August 17, 2011 
This page intentionally left blank 
EXECUTIVE 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 of new or revised National Ambient Air Quality Standards (NAAQS) to meet the 

requirements of FCAA, §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 strengthened the 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 of this 

SIP revision is to document that any emissions from sources in Texas do not interfere with 

attainment or maintenance of the 2008 lead NAAQS 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 that will 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 protect visibility. 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 that these requirements are satisfied 

if a state's SIP includes New Source Review (NSR) and Prevention of Significant 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 expected to interfere with 

measures to protect visibility. 

The October 15, 2008, final rule for the 2oo8lead NAAQS (73 FR 66964) included a 

requirement for monitors to be placed in areas with sources, such as industrial facilities, that 

emit 1.0 ton per year (tpy) or more of lead and in urban areas with more than soo,ooo people. 

The EPA may waive the source-oriented monitoring requirements if the monitoring agency 

demonstrates that emissions from the source would not contribute to maximum air lead 

concentrations greater than so% of the 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 changed the emissions threshold for industrial facilities to 0.5 tpy, reduced from the 

previous threshold of 1.0 tpy. At the time of proposal, 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 of lead 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), the American Smelting and Refining 

Company facility near Amarillo (ASARCO), the ECS Refining plant in Terrell (ECS), and the 

Exide Technologies, Incorporated lead battery recycling facility in Frisco (Exide ). Two facilities 

in Texas emit between 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, Incorporated in 

Christine (San Miguel). 

Modeled lead emissions from Fort Hood and Oxbow each result in ambient concentrations of 

less than 15% of the level of the 2008 lead NAAQS. Additionally, the September 8, 2005, 

Defense Base Closure and Realignment Commission report pursuant to Sections 2903 and 2914 

of the 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 submitted waiver 

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 of 

lead greater than so% of the NAAQS. Source-oriented lead monitors have been installed for 

ASARCO, Exide, and ECS. Modeling of the five 2 operational facilities indicates that lead 

emissions do not transport over long distances and will 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 proposal to determine the need for monitoring. 

Modeled lead emissions from Coleto Creek and San Miguel each result in ambient 

concentrations of less than 1% of the level of the 2008 lead NAAQS and indicate that there will 

be no impact on surrounding states. Fort Hood and Oxbow model results predict levels of less 

than 15% of the NAAQS. For Exide, ECS, and ASARCO the predicted concentrations dropped to 

below half the level of the NAAQS within 2 kilometers of the property line. To further validate 

this modeling, there are currently no lead nonattainment or maintenance areas in any of the 

four states that border Texas: Louisiana, Oklahoma, Arkansas, and New Mexico. 

Texas has only one nonattainment area under the 2008lead NAAQS. On November 16, 2010, 

the EPA designated a portion of Collin County, located in Frisco, Texas, as a lead nonattainment 

area, effective December 31, 2010 (75 FR 71033). This nonattainment area surrounds the Exide 

lead battery recycling facility. An area surrounding Exide was originally designated 

nonattainment for the 1978 lead NAAQS on November 6, 1991. On November 29, 1994, the EPA 

approved the Collin County lead attainment demonstration SIP revision. On August 31, 1999, 

the governor of Texas submitted to the EPA a request to redesignate the nonattainment portion 

of Collin County to attainment and to 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 of Texas submitted to the EPA the 

final ten-year maintenance plan for the 1978 lead NAAQS. This SIP revision included 

contingency measures set in place to promptly correct any violations of the 1978lead NAAQS. 

The attainment demonstration for the 2oo8lead NAAQS will be due to the EPA by June 30, 

2012. 

Based on the control strategies currently 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 of nonattainment 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 it will be shut down in 2011. 

ES-2 
SECI'ION V: LEGAL AUTIIORilY 

A. General 

The Texas Commission on Environmental Quality (TCEQ) has the legal authority to implement, 

maintain, and enforce the National Ambient Air Quality Standards (NAAQS) and to control the 

quality of the state's air, including maintaining adequate visibility. 

The first air pollution control act, known as the Clean Air Act of Texas, was passed by the Texas 

Legislature in 1965. In 1967, the Clean Air Act of Texas 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 of the 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, and its 

powers, duties, responsibilities, and functions were transferred to the Texas Natural Resource 

Conservation Commission (TNRCC). With the creation of the TNRCC, the authority over air 

quality is found in both the Texas Water Code and the TCAA. Specifically, the authority of the 

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 of the TNRCC, and the 

responsibilities and authority of the executive director. This chapter also authorizes the TNRCC 

to implement action when emergency conditions arise and to conduct hearings. Chapter 7 gives 

the TNRCC enforcement authority. In 2001, the 77th Texas Legislature continued the existence 

of the TNRCC until September 1, 2013, and changed the name of the TNRCC to the Texas 

Commission on Environmental Quality (TCEQ). In 2009, the 81st Texas Legislature, during a 

special session, amended section 5.014 of the Texas Water Code, changing the expiration date of 

the TCEQ to September 1, 2011, unless continued in existence by the Texas Sunset Act. In 2011, 

the 82nd Texas Legislature continued the existence of the TCEQ until 2023. 

The TCAA specifically authorizes the TCEQ to establish the level of quality to be maintained in 

the state's air and to control the quality of the 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 of emissions; to conduct research 

and investigations; to enter property and examine records; to prescribe monitoring 

requirements; to institute enforcement proceedings; to enter into 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 regions; to encourage cooperation with citizens' groups 

and other agencies and political subdivisions of the state as well as with industries and the 

federal government; and to establish and operate a system of permits for construction or 

modification of facilities. 

Local government authority is found in Subchapter E of the 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 of the TCEQ that affects their 

territorial jurisdiction, may bring enforcement actions, and may execute cooperative agreements 

with the TCEQ or other local governments. In addition, a city or town 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 of the commission. 

Subchapters G and H of the TCAA authorize the TCEQ to establish vehicle inspection and 

maintenance programs in certain areas of the state, consistent with the requirements of the 

Federal Clean Air Act; coordinate with federal, state, and local transportation planning agencies 

to develop and implement transportation programs and measures necessary to attain and 

maintain the NAAQS; establish gasoline volatility and low emission diesel standards; and fund 

and authorize participating counties to implement vehicle repair assistance, retrofit, and 

accelerated vehicle retirement programs. 

B. Ap_plicable Law 

The following statutes and rules provide necessary authority to adopt and implement the state 

implementation plan (SIP). The rules listed below have previously been submitted as part of the 

SIP. 

Statutes 

All sections of each subchapter are included, 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 of the Texas Natural Resource Conservation Commission 

Subchapter C: Texas Natural Resource Conservation Commission 

Subchapter D: General Powers and Duties of the 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) 

Subchapter H: Delegation of Hearings 

Subchapter I: Judicial Review 

Subchapter J: Consolidated Permit Processing 

Subchapter L: Emergency and Temporary Orders (§§5.514, 5.5145, and 5.515 only) 

Subchapter M: Environmental Permitting Procedures (§5.558 only) 

Chapter 7: Enforcement 

Subchapter A: General Provisions (§§7.001, 7.002, 7.0025, 7.004, and 7.005 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 of the following rules are found in 30 Texas Administrative Code, as of the following latest 

effective dates: ,. 

Chapter 7: Memoranda of Understanding, §§7.110 and 7.119 

December 13, 1996 and May 2, 2002 

Chapter 19: Electronic Reporting March 15, 2007 

ii 
Chapter 35: Subchapters A-C, K: Emergency and Temporary Orders and 

Permits; Temporary Suspension or Amendment of Permit 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, Subchapter A May 12, 2011 

Chapter 111: Control of Air Pollution from Visible Emissions and Particulate 

Matter July 19, 2006 

Chapter 112: Control of Air Pollution from Sulfur Compounds July 16, 1997 

Chapter 113: Standards of Performance for Hazardous Air Pollutants and for 

Designated Facilities and Pollutants May 14, 2009 

Chapter 114: Control of Air Pollution from Motor Vehicles December 13,2010 

Chapter 115: Control of Air Pollution from Volatile Organic Compounds February 17, 2011 

Chapter 116: Permits for New Construction or Modification March 3, 2011 

Chapter 117: Control of Air Pollution from Nitrogen Compounds May 12, 2011 

Chapter 118: Control of Air 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 of Economic 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 of Nitrogen (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) 

iv 
TABLE OF CONTENTS 

Executive Summary 

Section V: Legal Authority 

Section VI: Control Strategy 

Table of Contents 

List of Acronyms 

List of Appendices 

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 Second Ten-Year Maintenance Plan 

2.2.2.4 Nonattainment Designation Under the 2008 Lead NAAQS 

2.2.3 Prevention of Significant Deterioration and Nonattainment New Source Review 

Elements 

2.2.4 Protection of Visibility Element 

v 
Chapter 3: Future Revisions to the National Ambient Air Quality Standards (NAAQS) 

Response to Comments Received Regarding the Lead Transport Plan for the 2008 Lead 

National Ambient Air Quality Standard 

Appendices 

vi 
LIST OF ACRONYMS 

BART Best Available Retrofit Technology 

EPA United States Environmental Protection Agency 

FCAA Federal Clean Air Act 

FR Federal Register 

IQ Intelligence Quotient 

NAAQS National Ambient Air Quality Standard 

NSR New Source Review 

PSD Prevention of Significant 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 

Appendix A 

AppendixB 

LIST OF APPENDICES 

Appendix Name 

Lead Modeling Analyses 

TCEQ Lead Monitoring Network 

viii 
- CHAPTER1: GENERAL 

1.1 BACKGROUND 

"The History of the Texas State Implementation Plan (SIP)," a comprehensive overview of the 

SIP revisions submitted to the United States Environmental Protection Agency (EPA) by the 

State of Texas, is available at the following Web site at: 

http://www. tceq. texas.gov /airquality/sip/sipintro.html 

1.2 INTRODUCTION 

This SIP revision for the transport of lead 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 that prohibit any source or other type of 

emissions activity within the state from emitting any air pollutants in amounts that will: 

• contribute significantly to nonattainment of the NAAQS for areas in other states; 

• interfere with maintenance of the NAAQS by any other state; 

• interfere with measures required for any other state to meet an implementation plan related 

to Prevention of Significant Deterioration; or 

• interfere with measures required for any other state to meet the implementation plan related 

to regional haze and visibility. 

Based on the 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 of nonattainment or 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 strengthened the 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, and lead in the 

air have been published since 1990. Evidence from health studies shows that adverse effects 

occur at much lower levels of lead in blood than previously thought. · 

Lead that is emitted into the air can be inhaled directly or ingested 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 the body, lead 

distributes throughout the body in the blood and accumulates in the bones. Depending on the 

level of exposure, 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 of the blood. 

The lead effects most commonly encountered in current populations 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 of exposure 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-based paint chips from older homes). Children also have a 

higher risk of adverse effects because their brains are still developing. Infants and young 

children are especially sensitive to low levels of lead, which may contribute to behavioral 

problems, learning deficits, and lowered intelligence quotient (IQ). 

14 PUBLIC HEARING AND 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 in Austin. A question 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 accepted via mail, fax, or through the eComments system. A summary of the 

comment and the TCEQ response is provided as part of this SIP revision in the Response to 

Comments. 

Copies of the proposed SIP revision and its appendices can be obtained from the TCEQ Web site 

at: http://www. tceq. texas. gov /airquality/sip/ criteria-pollutants/sip-lead. 

1.5 SOCIAL AND ECONOMIC CONSIDERATIONS 

Because rulemaking is not a part of this SIP revision, there are no changes that would have an 

impact on society or the economy. 

1.6 FISCAL AND MANPOWER RESOURCES 

The TCEQ has determined that its fiscal and manpower resources are adequate and will not be 

adversely affected through the implementation of this plan. 

1.7 COORDINATION WITH LOCAL AGENCIES 

The TCEQ has determined that there will be no assignment to local agencies. However, preexisting assignments to local agencies regarding various enforcement activities remain in effect 

and could be utilized if enforcement activities are delegated to the TCEQ from the EPA. 

1.8 ORGANIZATIONS RESPONSIBLE FOR DEVEWPMENT, IMPLEMENTATION, 

AND ENFORCEMENT 

The TCEQ is the agency delegated authority by the Texas Legislature regarding the protection of 

air quality in the State of Texas. Other local government entities have limited authority 

regarding air quality matters in the State of Texas. 

1.9 DATAAVAIIABILTIY 

The TCEQ affiffilS that it will retain all data used in the preparation of this SIP revision. All 

supporting documents and data 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 per year (tpy) or more oflead. They 

are 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), the American 

Smelting and Refining Company facility near Amarillo (ASARCO), the ECS Refining plant in 

Terrell (ECS), and the Exide Technologies, Incorporated lead battery recycling facility in Frisco 

(Exide). Dispersion modeling of lead emissions from the five operational facilities (the Red 

River Army Depot was not modeled because it will be 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 of these 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 of Collin County, located in Frisco, Texas, as a lead nonattainment 

area, effective December 31, 2010 (75 FR 71033). This nonattainment area surrounds the Exide 

lead battery 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 

attainment demonstration for the 2008 Lead NAAQS is due to the EPA by June 30, 2012, and 

will include additional control measures, if necessary, to meet the attainment deadline of 

December 31, 2015. 

Texas has existing control strategies in place in Collin County and modeling 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 of lead emissions in Texas has been 

adequately addressed. 

2.2 CONTROL STRATEGY OVERVIEW 

Federal Clean Air Act (FCAA) §11o(a)(2)(D)(i) requires states to 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 amounts that will: 

• contribute significantly to nonattainment of the NAAQS for areas in other states; 

• interfere with maintenance of the 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 state to meet the implementation plan related 

to regional haze and visibility. 

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 the lead NAAQS included a requirement for monitors to be 

placed in areas with sources such as industrial facilities that emit 1.0 tpy or more of lead and in 

urban areas with more than soo,ooo people. The EPA may waive the source-oriented 

monitoring requirements if the monitoring agency demonstrates that emissions from the source 

would not contribute to maximum air lead concentrations greater than so% of the revised 

standard, or 0.075 micrograms per cubic meter (J.lg/m'). On December 14, 2010, the EPA 

2-1 
revised the ambient monitoring requirements for measuring lead in the air. The EPA changed 

the emissions threshold for industrial facilities to o.s tpy, reduced from the previous threshold 

of 1.0 tpy. At the time of proposal, the Texas Commission on Environmental Quality (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 between 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: Fort Hood, Oxbow, Red River, 

ASARCO, ECS, and Exide. Two facilities in Texas emit between 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). Modeled lead emissions 

from Fort Hood and Oxbow result in predicted concentrations ofless than 15% of the 2008lead 

NAAQS. Additionally, the September 8, 2005, Defense Base Closure and Realignment 

Commission report pursuant to Sections 2903 and 2914 of the Defense Base Closure and 

Realignment Act of 1990 requires the munitions 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 submitted waiver 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 of lead greater than 50% of the NAAQS. 

Source-oriented lead monitors have been installed for ASARCO, Exide, and ECS. Modeling of 

the five' operational facilities indicates that lead emissions from sources at those facilities do not 

transport over long distances and will therefore not impact surrounding states. Fort Hood and 

Oxbow model results predict levels ofless than 15% of the NAAQS. For Exide, ECS, and 

ASARCO the predicted concentrations dropped to below half the level of the NAAQS within 2 

kilometers of the property line. Modeling for the two facilities that emit between 0.5 and 1.0 tpy 

was conducted after proposal to determine the need for monitoring. Modeled lead emissions 

from Coleto Creek and San Miguel each result in ambient concentrations of!ess than 1% of the 

level of the 2oo8lead NAAQS, and indicate that there will be no impact on surrounding states. 

The finding that lead does not transport over long distances is supported by the EPA in the 

December 14, 2010, "Revisions to Lead Ambient Air Monitoring Requirements." In that final 

rule, the EPA indicated when selecting airports for an airport monitoring study, "We selected a 

maximum distance to ambient air from the location of maximum emissions of 150 meters 

because the available information indicates that ambient lead concentrations drop off quickly 

with distance, and it is less likely that an exceedance of the lead NAAQS will occur at greater 

distances."• To further validate this finding, there are currently no lead nonattainment or 

maintenance areas in any of the four states surrounding Texas: Louisiana, Oklahoma, Arkansas, 

and New Mexico. Details of the dispersion modeling conducted by the TCEQ can be found in 

Appendix A: Lead Modeling Analyses. 

2.2.1.2 Monitoring Sites 

The TCEQ lead monitoring network currently includes 15 lead monitors in Amarillo, El Paso, 

Frisco, Terrell, Houston, Laredo, and Brownsville. These sites are listed in Appendix B: TCEQ 

Lead Monitoring Network. This list includes the EPA-required source-oriented monitors for 

lead sources that emit 1.0 tpy or more, except for those for which the TCEQ has submitted 

waiver requests. Changes to the lead monitoring requirements published by the EPA in the 

3 Red River was not modeled, because it will be shut down in 2011. 

• EPA, "Revisions to Lead Ambient Air Monitoring 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 of one lead monitor at each site that is part of 

the multi-pollutant site network known as the National Core Monitoring Network. After 

proposal of this SIP revision, modeling for the two sources that emit between 0.5 and 1.0 tpy 

was conducted by the TCEQ, and modeled emissions results for both facilities showed ambient 

concentrations ofless than 1% of the level of the 2oo8lead NAAQS. Waiver requests for both 

sources will be submitted in .July 2011 as Appendix A to the TCEQ 2011 Annual Ambient Air 

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 published the notice of nonattainment designation for lead in the 

Federal Register (56 FR 5661)4) for the portion of Collin County that essentially encompassed 

the plant boundaries of thl' Gould National Battery, Incorporated facility, 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. Under the 

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 1978lead NAAQS by January 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 

of these reductions was to be maintained through permit restrictions, emissions limits, and 

standard operating procedures for controlling emissions from process sources, process fugitive 

sources, and fugitive 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 had been 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 of the 

monitoring network that would be used to determine when an exceedance of the lead NAAQS 

occurred for the purpose of triggering 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 the blast furnace; 

2-3 
and (3) install an alternative measure that will provide, at a minimum, emissions reductions 

equivalent to those listed previously. 

The EPA approved the 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 of an additional SIP revision to provide for maintenance of the 

1978 NAAQS for lead for the second ten-year period following redesignation of the 

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 

contingency measures set in place to promptly correct any violations of the 1978lead NAAQS. 

The contingency measures 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 those listed previously. The contingency measures were made legally enforceable under an 

agreed order adopted concurrently with the maintenance plan. 

2.2.2.4 Nonattainment Designation 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 in Collin County, Texas as a 

lead nonattainment area. The attainment demonstration for the 2008 lead NAAQS is due to the 

EPA by June 30, 2012, and will include control measures necessary to meet the attainment 

deadline of December 31, 2015. · 

2.2.3 Prevention of Significant Deterioration and N onattainment 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 or type of emissions activity within the state from 

emitting air pollutants in amounts that will interfere with another state's SIP measures for 

preventing significant deterioration of air 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 

if a state's SIP includes NSR and PSD programs. 

All major sources in Texas are subject to PSD and nonattainment NSR permitting programs, 

implemented in 30 Texas Administrative Code (TAC) Chapter n6. Major sources are defined in 

30 TAC §116.12(17) in relation to the federal classification of an area for nonattainment 

permitting and by reference to 40 Code of Federal Regulations §51.166 for PSD. 

2.2-4 Protection ofVisibility Element 

Section no(a)(2)(D)(i)(ll) also contains a requirement for all states to submit SIPs that contain 

adequate provisions prohibiting " ... any source or other type of emission activity within the state 

from emitting any air pollutant in amounts which will interfere with measures required to be 

included in the applicable implementation plan for any other state .... to protect visibility." On 

July 6, 2005, the EPA published regional haze regulations and guidelines for Best Available 

Retrofit Teclmology (BARn determinations in the Federal Register. The BART guidelines 

include the following list of visibility-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 not expected to interfere with measures to protect 

visibility in any other state. 

2-4 
CHAPTER 3: FUTURE REVISIONS TO THE NATIONAL AMBIENT 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 of new or revised NAAQS to meet the requirements of 

FCAA, §uo(a)(2), including FCAA, §uo(a)(2)(D)(i), relating to interstate transport. Therefore, 

if the NAAQS are revised in the future, the Texas Commission on Environmental Quality will 

need to take the adequate steps relating to the interstate transport of air pollution. 

3-1 
APPENDIX A: LEAD MODELING ANALYSES 
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 of Lead 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 lead based on a rolling threemonth average (73 Federal Register 66964). In general, the rule requires sourceoriented ambient air lead monitoring by January 1, 2010, at sites with actual annual 

lead emissions of one or more tons per year. Asarco LLC 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 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 of one or 

more tons. 

The TCEQ conducted air dispersion modeling of all the lead 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 of any 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 of the G LCmax is along the southeastern 

property line. All predicted concentrations exceeding the NAAQS are located to the 

southeast of the Asarco LLC site and extended less than 150 meters from the site 

property line. Table 1lists the location of the 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 

Modeling Analysis of Lead 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 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 used for 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 source parameters and emission rates were provided by Asarco 

LLC. The source locations were validated by ADMT using aerial photography. Only 

source 7A has a listed maximum allowable emission rate for lead. For the other three 

sources, emissions estimates were submitted by Asarco LLC and then validated by APD 

permit reviewing staff for use in this analysis. The emission rates represent worst case 

1-hour average emission rates and may be more conservative than 24-hour or monthly 

average emission rates. The emission source coordinates are in the UTM Zone 14 

North, North American 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 of 4 

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 

provided by 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 of the area surrounding the Asarco LLC site 

resulted in a calculated roughness length of 0.155 meters. The vast majority of the area 

considered industrial and urbanized (and with a higher roughness length) is 

concentrated near the emission sources. The dispersion of emissions from the sources 

will be lrighly influenced by 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 

of 0.5 meters. 

7.0 Receptor Grid. 

The receptor grid used in the modeling analysis consisted of receptors with 100 meter 

spacing and extended approximately 2 kilometers (krn) from the Asarco LLC site 

property line in all directions. The purpose of the receptor grid was to determine a 

representative maximum ground-level concentration and the extent of ground-level 

concentrations at or above half of the lead NAAQS standard. 
David Brymer 

Page 4 of4 

June 22, 2009 

Modeling Analysis of Lead for Asarco 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 of the application site. Since the current version 

of AERMOD is not capable of calculating rolling three-month average concentrations, 

the EPA post processor LeadPost was used. The input values to LeadPost are monthly 

average values at eacb receptor in the POSTFILE output format 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 of Lead 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 monitoring by January 1, 2010, at sites with actual annual 

lead emissions of onL' or more tons per year. ECS Refining Texas LLC was identified as 

ha\ing emissions at or above this level based on the reported 2007 TCEQ 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 predicted by modeling, that results from sources with annual lead 

emissions of one or more tons. 

The TCEQ cond uctcd air dispersion modeling of all the lead 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 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 ground level concentration (GLCmax) is 4.06 J.Lg/m' for a 

rolling three-month average. The location of the GLCmax is along the northern 

property line. 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 of the site property line. Table I lists the location of the 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 

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 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 using AERMAP 

(Version 09040). The input data 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 provided by ECS 

Refining Texas LLC. The source locations were validated by ADMT using aerial 

photography. The source emission 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 and may be more conservative than 

24-hour or monthly ·average emission rates. The emission source coordinates are in the 

UTM Zone 14 North, North American Datum of 1927 (NAD27) coordinate system. 

Table 2. On-Property Point 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 of 4 

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 

provided by ECS Refining Texas LLC. The building locations were validated by ADMT 

using aerial photography. 

6.0 Meteorological Data. 

Surface Station and ID: Dallas/Fort Worth, 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 of the area surrounding the ECS Refining Texas 

LLC site resulted in a calculated roughness length of 0.109 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 set used 

for this analysis was developed using a roughness length of 0.5 meters. 

7.0 Receptor Grid. 

The receptor grid used in the modeling analysis consisted of receptors with 100 meter 

spacing and extended approximately 3 kilometers (km) from the ECS Refining Texas 

LLC site property line in all directions. The purpose of the receptor grid was to 

determine a representative maximum ground-level concentration and the extent of 

ground-level concentrations at or above half of the lead NAAQS standard. 
David Brymer 

Page4of4 

June 29, 2009 

Modeling Analysis of Lead 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 of the application site. Since the current version 

of AERMOD is not capable of calculating rolling three-month average concentrations, 

the EPA post processor LeadPost was used. The input values to LeadPost 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 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 of Lead 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 lead based on a rolling threemonth average (73 Federal Register 66964). In general, the rule requires sourceoriented ambient air lead monitoring by January 1, 2010, at sites with actual annual 

lead emissions of one or more tons per year. 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 predicted by modeling, that results from sources 

with annual lead emissions of one or more tons. 

In 2009, the TCEQ conducted air dispersion modeling of all the lead emission sources 

at the site using the most current modeling parameters and associated permitted 

allowable emissions rates. In October 2010, Exide Technologies submitted information 

to the TCEQ documenting a reduction in permitted allowable emission rates for some 

sources. Some of these 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 of any required sourceoriented monitors. 

Since monitoring already exists at and near the 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 of a 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 of Lead for Exide Technologies, Frisco Battery Recycling Plant 

2.0 Report Summary. 

The predicted maximum ground level concentration (GLCmax) is 0.837 f.lg/m3 for a 

rolling three-month average. The location of the GLCmax is the same as the location of 

monitor 480850009 on the north property line of the Exide Technologies site. 

Predicted concentrations exceeding the NAAQS extended approximately 0.8 kilometers 

(km) to the north, 0.5 km to the south, 0.5 km to the west, and 0.2 km to the east of the 

site property line. All predicted concentrations greater than the NAAQS are located 

within Collin County. Table 1lists the predicted concentrations at the current monitor 

locations and proposed monitor location near the intersection of 1st Street and Ash 

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 Land Use and Terrain. 

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 using AERMAP 

(Version 09040 ). The input data 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 source parameters and emission rates were provided by 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 in the 

UTM Zone 14 North, North American Datum of 1927 (NAD27) coordinate system. 
David Brymer 

Page 3 of7 

October 8, 2010 

Modeling Analysis of Lead 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 of Lead for Exide Technologies, Frisco Battery Recycling Plant 

Table 3. Area Source Parameter Information 

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 of Lead 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 

.. 41.· .. . Lead 1-hr om$8 . ·. 

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 of Lead 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 

provided by Exide Technologies. The building locations were validated by ADMT using 

aerial photography. 

6.o Meteorological Data. 

Surface Station and ID: Dallas/Fort Worth, 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 of the area surrounding the Exide Technologies 

site resulted in a calculated roughness length of 0.129 meters. Since the AERSURFACE 

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 

2008 aerial photography, a representative roughness length for the area would be 

approximately o.s meters. For this reason, the meteorological data set used for this 

analysis was developed using a roughness length of 0.5 meters. 

7.0 Receptor Grid. 

The receptor grid used in the modeling analysis consisted of receptors with so meter 

spacing and extended approximately 1.5 kilometers (km) from the Exide Technologies 

site property line in all directions. An additional grid consisted of receptors with 100 m 

spacing and extended 3.5 km beyond the first receptor grid in all directions. Discrete 

receptors were used for the locations of the three existing monitoring stations and the 

location of a proposed monitoring station near the intersection of 1st Street and Ash 

Street. The purpose of the receptor grid was to determine a representative maximum 

ground-level concentration and the extent of ground-level concentrations at or above 

half of the 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 the latest approved EPA model version. For refined screening, 

National Weather Service (NWS) meteorological raw input data are used with 

generalized surface characteristics of the application site. Since the current version of 

AERMOD is not capable of calculating rolling three-month average concentrations, the 

EPA post processor LeadPost was used. The input values to LeadPost are monthly 

average values at each receptor in the POSTFILE output format from AERMOD. 
David Brymer 

Page7of7 

October 8, 2010 

Modeling Analysis of Lead for Exide Technologies, Frisco Battery Recycling Plant 

For this analysis, only emission sources at the Exide Technologies site were considered. 

The nearest source of lead emissions outside the modeling domain is approximately 20 

km from the Exide Technologies site with reported 2007lead annual emissions 

approximately one percent of the annual lead 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 

of the 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 of Lead for Oxbow Calcining LLC (RN 100209287) 

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 Federal Register 66964). In general, the rule requires sourceoriented ambient air lead monitoring by January 1, 2010, at sites with actual annual 

lead emissions of one or more tons per year. Oxbow Calcining LLC 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 predicted by modeling, that results from sources with annual lead 

emissions of one or more tons. 

The TCEQ conducted air dispersion modeling of all the lead 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 of any 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 of the GLCmax is approximately 70 meters 

from the northwest property line. Table I lists the location of the predicted GLCmax. 

The location coordinates are in the lJfM Zone 15 North, North American Datum of 

1927 (NAD27) coordinate system. 
Jim Price 

Page 2 of 4 

September 25, 2009 

Modeling Analysis of Lead 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 land usc/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 using AERMAP 

(Version 09040). The input data used for this analysis was the United States Geological 

Survey (USGS) National Elevation Dataset (NED) for the Port Arthur 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 aerial photography. The emission rates represent worst case 1-hour average 

emission rates and may be more conservative than 24-hour or monthly average 

emission rates. The emission source coordinates are in the UTM Zone 15 North, North 

American Datum of 1927 (NAD27) coordinate system. 

Table 2. On-Property Point Source Parameter Information 

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 2.37 
Jim Price 

Page 3 of 4 

September 25, 2009 

Modeling Analysis of Lead 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 by ADMT 

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 

The AERSURF ACE analysis conducted of the area surrounding the Oxbow Calcining 

LLC site resulted in a calculated roughness length of 0.028 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 1992 based on comparing the land 

cover data to 2004 aerial photography, a representative roughness length for the area 

would be approximately 0.05 meters. For this 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 of receptors with 100 meter 

spacing and extended approximately 1.5 kilometers (km) from the Oxbow Calcining 

LLC site property line in all directions. The purpose of the receptor grid was to 

determine a representative maximum ground-level concentration and the extent of 

ground-level concentrations at or above half of the lead NAAQS standard. 
Jim Price 

Page 4 of 4 

September 25, 2009 

Modeling Analysis of Lead for Oxbow Calcining LLC 

B.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 of the application site. Since the current version 

of AERMOD is not capable of calculating rolling three-month average concentrations, 

the EPA post processor LeadPost was used. The input values to LeadPost are monthly 

average values at each receptor in the POSTFILE output format 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 of Lead 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 monitoring by January 1, 2010, at sites with actual annual 

lead emissions of one 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 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 of one or more tons. 

The TCEQ conducted air dispersion modeling of all 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 of any 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. The location of the GLCmax is along the southern 

property line. Table 1 lists the location of the predicted GLCmax. The location 

coordinates are in the UTM Zone 14 North, North American Datum of 1927 (NAD27) 

coordinate system. 
David Brymer 

Page 2 of 4 

July 24, 2009 

Modeling Analysis of Lead 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 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 using AERMAP 

(Version 09040). The input data used for this analysis was the United States Geological 

Survey (USGS) National Elevation Dataset (NED) for Gatesville West., Gatesville East, 

Shell Mountains, North Fort Hood, Fort Hood, and Post. Oak Mountains quadrangles. 

4.0 Modeling Emissions Inventory. 

The modeled emission source parameters and emission rates were provided by Fort 

Hood. The source locations were validated by ADMT. The source emission rates 

modeled were based on air emissions estimates reported in the Fort Hood 2007 Toxic 

Release Inventory (TRI). Though the emissions were reported for many firing ranges at 

various locations around Fort Hood, for this demonstration all of the emissions were 

conservatively represented to be emitted only from the firing ranges nearest. the areas 

of public activity. From the 2007 TRI data and activity data for 2008, the firing ranges 

with the highest emissions were the furthest. away from public locations and largest. in 

extent. Public activities are limited to the southern and the northern ends of Fort Hood. 

The central areas and areas on the east. and west. of Fort Hood are restricted from 

public access. The emission rates represent worst. case 1-hour average emission rates 

and may be 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 of 4 

July 24, 2009 

Modeling Analysis of Lead 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 down wash 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 

0.0367 
David Brymer 

Page4 of 4 

July 24, 2009 

Modeling Analysis of Lead for U.S. Army (Fort Hood) 

Upper Air Station and ID: Stephenville, TX (Station#: 13091) 

Meteorological Dataset: 1985, 1987, 1988, 1989, 1990 

Profile Base Elevation: 499 feet 

The AERSURFACE analysis conducted of the area surrounding the U.S. Army (Fort 

Hood) site resulted in a calculated roughness length of 0.369 meters. Since the 

AERSURFACE 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 set used 

for this analysis was developed using a roughness length of 0.5 meters. 

7.0 Receptor Grid. 

The two receptor grids used in the modeling analysis consisted of receptors with 100 

meter spacing. The larger receptor grid was located in close proximity to the southern 

firing ranges and extended approximately 2 kilometers (km) from these firing ranges to 

the south. The smaller receptor grid was located in close proximity to the northern 

firing ranges and extended approximately 2 Ian from these firing ranges to the 

northeast. The purpose of the receptor grid was to detennine a representative 

maximum ground-level concentration and the extent of ground-level concentrations at 

or above half of the lead NAAQS standard. 

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 of the application site. Since the current version 

of AERMOD is not capable of calculating rolling three-month average concentrations, 

the EPA post processor LeadPost was used. The input values to LeadPost 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 

Jessica Carter, Justin Cherry 

Air Dispersion Modeling Team 

Air Permits Division 

Date: March 30, 2011 

Subject: Modeling Analysis of Lead 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 lead based on a rolling threemonth average. On December 14, 2010, the EPA lowered the emission threshold from 

annual lead emissions of one ton or more to a half a ton or more in actual emissions 

that state agencies must use to determine if an air quality monitor should be placed 

near an industrial facility that emits lead (75 Federal Register 81134). 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 of half a ton or more per year. Coleta Creek Power Station was identified 

as having emissions at or above this level based on the reported 2009 TCEQ Emissions 

Inventory and/or 2009 Taxies Release Inventory. 

The TCEQ conducted air dispersion modeling of all the lead 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 of any 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 of the GLCmax is along the northern 

property line. Table 11ists the location of the 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 of Lead 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 land use (land cover analysis wa:s performed using AERSURFACE 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 used for this analysis were United States Geological 

Survey (USGS) seamless data that covers digital elevation models (DEMs) for Fannin, 

Hensley Lake, Schroeder, and Ander data sets. 

4.0 Modeling Emissions Inventory. 

The modeled emission source parameters and emission rates were provided by Coleto 

Creek Power Station. The source locations were validated by ADMT using aerial 

photography. No sources have a listed maximum allowable emission rate for lead. For 

all three sources, emissions estimates were submitted by Coleto Creek Power Station 

and then validated by APD permit reviewing staff for use in this analysis. The emission 

rates represent worst case 1-hour average emission rates and may be more conservative 

than 24-hour or monthly average emission rates. The emission source coordinates are 

in the UTM Zone 14 North, North American 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 0.204 
David Brymer 

Page 3 of 4 

March 30, 2011 

Modeling Analysis of Lead 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 

provided by Coleta Creek Power Station. The building locations were validated by 

ADMT using aerial photography. 

6.o Meteorological Data. 

Surface Station and ID: Victoria, TX (Station#: 12912) 

Upper Air Station and ID: Victoria, TX (Station#: 12912) 

Meteorological Dataset: 1983, 1984, 1986, 1987, 1988 

Profile Base Elevation: 107 feet 

The AERSURF ACE analysis conducted of the area surrounding the Coleto Creek Power 

Station site resulted in a calculated roughness length of 0.081 meters. The vast 

majority of the area considered water bodies such as the Coleta Creek Resevoir and 

cooling water lakes at the Coleta Creek Power Station (and with a lower roughness 

length) is concentrated near the emission sources. The dispersion of emissions from the 

sources will be highly influenced by this lower roughness length. A representative 

roughness length for the area would be approximately 0.05 meters. For this 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 of receptors with 100 meter 

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 km to the 

south. The purpose of the receptor grid was to determine a representative maximum 

ground-level concentration and the extent of ground-level concentrations at or above 

half of the lead NAAQS standard. 
David Brymer 

Page4 of 4 

March 30, 2011 

Modeling Analysis of Lead for Coleto Creek Power Station 

8.0 Model Used and Modeling Techniques. 

AERMOD (Version 09292) was used in a refined screening mode. For refined 

screening, National Weather Service (NWS) meteorological raw input data are used 

with generalized surface characteristics of the application site. Since the current version 

of AERMOD is not capable of calculating rolling three-month average concentrations, 

the EPA post processor LeadPost was used. The input values to LeadPost are monthly 

average values at each receptor in the POSTFILE output format from AERMOD. The 

results from the Lead Post reports are limited to three decimal places; therefore, the 

monthly average predicted concentrations were examined from the AERMOD 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 of Lead 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 of one ton or more to a half a ton or more in actual emissions 

that state agencies must use to determine if an air quality monitor should be placed 

near an industrial facility that emits lead (75 Fed era/Register 81134). 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 of half a ton or more per year. San Miguel Electric Cooperative Inc was 

identified as having emissions at or above this level based on the reported 2009 TCEQ 

Emissions Inventory and( or 2009 Toxics Release Inventory. 

The TCEQ conducted air dispersion modeling of all the lead 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 of any required 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 of the GLCmax is approximately goo meters 

from property line to the north. Table I lists the location of the predicted GLCmax. The 

location coordinates are in the UTM Zone 14 North, North American Datum of 1983 

(NAD83) coordinate system. 
David Brymer 

Page 2 of 4 

March 30, 2011 

Modeling Analysis of Lead for San Miguel Electric Cooperative Inc 

Table 1. Modeling Results for Lead 

551000 3176600 rolling three-month 

3.0 Land Use and Terrain. 

0.00091 

· Standard 

' (li!Vm'J 

0.15 

A land usefland 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 using AERMAP 

(Version 09040). The input data used fortbis analysis were United States Geological 

Slirvey (USGS) digital elevation models (DEMs) for Christine East, Christine West, 

Cross NE, and Caballos Creek data sets. 

4.0 Modeling Emissions Inventory. 

The modeled emission source parameters and emission rates were provided by San 

Miguel Electric Cooperative Inc. The source locations were validated by ADMT using 

aerial photography. Source 6 has a listed maximum allowable emission rate for lead in 

tons per year only. The maximum hourly emission rate was derived from tbe tons per 

year and based on 8,064 operating hours per year. The emission rates represent worst 

case 1-hour average emission rates and may be more conservative tban 24-hour or 

monthly average emission rates. The emission source coordinates are in tbe UTM Zone 

14 North, North American Datum of1983 (NAD83) coordinate system. 

Table 2. On-Property Point Source Parameter Information 
David Brymer 

Page 3 of 4 

March 30, 2011 

Modeling Analysis of Lead 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 Input Program Prime (BPJP-PRM Version 04274) were 

derived from aerial photography by the ADMT. 

6.o Meteorological Data. 

Surface Station and ID: San Antonio, TX (Station #: 12921) 

Upper Air 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 of the area surrounding the San Miguel Electric 

Cooperative Inc site resulted in a calculated roughness length of 0.200 meters. The 

meteorological data set used for this analysis was developed using a roughness length 

of 0.5 meters. A higher roughness length value would tend to enhance dispersion more 

than a lower value. However, since the only source of lead is a very tall stack, over 100 

meters high, enhanced dispersion would mix air contaminants from the source to 

ground level to a greater extent. Therefore, use of a roughness length of 0.5 meters is 

conservative. 

According to EPA's Meteorological Monitoring Guidance for Regulatory Modeling 

Applications, the meteorological dataset for 1988 does not meet regulatory 

completeness (only 86-4% complete). There was a total of 1195 hours of missing data 

for the entire year (8760 hours). The number of hours missing per month ranged from 

zero hours to 226 hours. April was the month with the highest number of missing 

hours (226 hours out of 720 hours). There were zero hours missing for the months of 

August, September, October, and November. Since the predicted concentrations are 

extremely small, it is unlikely that the results would significantly change due to these 

missing hours. 

7.0 Receptor Grid. 

The receptor grid used in the modeling analysis consisted of receptors with 100 meter 

spacing and extended approximately 2.5 kilometers (km) from the San Miguel Electric 
David Brymer 

Page4 of4 

March 30, 2011 

Modeling Analysis of Lead for San Miguel Electric Cooperative Inc 

Cooperative Inc site property to the north, and approximately 1.5 Ian from the site 

property in all other directions. The purpose of the receptor grid was to detemrine a 

representative maximum ground-level concentration and the extent of ground-level 

concentrations at or above half of the lead NAAQS standard. 

8.0 Model Used and Modeling Techniques. 

AERMOD (Version 09292) was used in a refined screening mode. For refined 

screening, National Weather Service (NWS) meteorological raw input data are used 

with generalized surface characteristics of the application site. Since the current version 

of AERMOD is not capable of calculating rolling three-month average concentrations, 

the EPA post processor LeadPost was used. The input values to LeadPost are monthly 

average values at each receptor in the POSTFILE output format from AERMOD. The 

results from the LeadPost reports are limited to three decimal places; therefore, the 

monthly average predicted concentrations were examined from the AERMOD output 

files using the MAXIFILE option since the AERMOD output files display results out to 

five decimal places. The rolling 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 

Stone brook 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 Day 
i Air Quality System (AQS) 

ii Continuous Air Monitoring Station (CAMS) 

iii State and Local Air Monitoring Station (SLAMS) 

''Total Suspended Particles (TSP) 

'Inductively Coupled Plasma Mass Spectrometry (ICP-MS) 
THE STATE Pf TEXAS 

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 m the 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 of a 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 that Texas is not contributing significantly to nonattainment of the lead 

NAAQS for areas in other states; not interfering \~ith the maintenance of the 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 plan for any other state related to 

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 of the state's 

air and to issue orders consistent ~ith the policies and purposes of the Texas Clean Air Act, 

Chapter 382 of the Tex. Health & Safety Code. Notice of the proposed SIP revision was 

published for comment in the April 22, 2011, issue of the Texas Register (36 TexReg 2623). 

Pursuant to 40 Code of Federal 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 in the areas affected at least 30 days prior to the date of 

the hearing. A public hearing was held in Austin on May 17, 2011. 

The Commission circulated hearing notices of its intended action to the public, 

including interested persons, the Regional Administrator of the 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 or in >•Titing, at the hearing or 

during the comment period. Prior to the scheduled hearing, copies of the proposed SIP 

re\ision were available for public inspection at the Commission's central office and on the 

Commission's Web site. 

Data, views, and recommendations of interested persons regarding the proposed SIP 

re>ision were submitted to the Commission during the comment period and were considered 

by the Commission as reflected in the analysis of testimony incorporated by reference to this 

Order. The Commission finds that the analysis of testimony includes the names of all 

interested groups or associations offering comment on the proposed SIP revision and their 

position concerning the same. 
, ' IT IS THEREFORE ORDERED BY THE COMMISSION that the revision to the SIP 

incorp~rated by reference to this Order are hereby adopted. The adopted revision to the SIP 

are irtcorp9rated by reference in this Order as if set forth at length verbatim in this Order. 

', , ffiS FURTHER ORDERED BY THE COMMISSION that on behalf of the Commission, 

the Chairman,~hciuld transmit a copy of this Order, together with the adopted revision to the 

SIP, to the 'Regiimal Administrator of EPA as a proposed revision to the Texas SIP pursuant to 

the Federal Clean Air Act, codified at 42 U.S. Code Ann. §§ 7401- 7671q, as amended. 

If any portion of this Order is for any reason held to be invalid by a court of competent 

jurisdiction, the invalidity of any portion shall not affect the validity of the remaining 

portions. 

Date issued: AUG 2 5 2011 

TEXAS COMMISSION ON 

ENVIRONMENTAL QUALITY 

4hu. 

Shaw, Ph.D., Chairman