From: <French.Chuck@epamail.epa.gov>

To: <Mark.Cummings@exide.com>

CC: Donna Lazzari <Donna.Lazzari@erg.com>, <Topham.Nathan@epamail.epa.gov>, 

<michael.burr@erg.com>

Date: 1/31/2011 5:32 PM

Subject: Secondary Lead Smelters - Fugitive lead emissions and ICR responses

Dear Mr. Cummings,

 Thank you for the information and data that you submitted to us in

response to the information collection request letters that we sent you

in June and July of 2010. The data and information are very helpful for

our Risk and Technology Review of the Secondary Lead Smelting source

category. We have been using much of the data and information in our

analyses as you reported.

 However, with regard to the estimates of fugitive emissions,

because of complexities of estimating these emissions, the data gaps and

incomplete information, and various uncertainties, we determined that it

was appropriate to gather additional information and conduct

supplemental analyses to calculate revised estimates of fugitive

emissions for some of the facilities.

 As you know, in the section 114 survey, we requested information

for stack and fugitive emissions from your facilities. We are now in

the process of conducting dispersion modeling of the emission estimates.

In some instances, we have found a discrepancy between the preliminary

results of the dispersion model and the values recorded at local ambient

monitors which cannot be accounted for by the stack and fugitive

emissions reported. EPA assumes the stack emissions are generally

reliable as they are based on actual test data, and the primary cause of

the discrepancy is due to releases of fugitive emissions. Moreover, for

some of the facilities either no estimate was provided or estimates were

provided for only one of the sources of fugitive dust emissions (i.e.,

roadways), or the calculation method used was not sufficiently explained

or documented.

 Therefore, we have derived new or revised draft estimates of

fugitive emissions for several of the facilities based upon a review of

the ICR responses and industry practices and calculation methodologies.

We have taken into account the size of the facility, the degree to which

facilities are contained within enclosures, and the reported work

practices described in your survey. Moreover, we analyzed available

ambient monitoring data near these facilities in relation to initial

preliminary modeling estimates.

 The draft estimates for fugitive emissions we have calculated for

your facility and the original estimate you provided in the survey are

provided in the table below.

 

Facility | Stated basis for | Estimate | EPA draft 

 | estimate provided in | provided in | estimate 
 | survey | survey | (tons/yr Pb) 

 | | (tons/yr Pb) | 

------------------------+-----------------------+-----------------+------------------ 

Exide, Baton Rouge LA | Roadway fugitives | 0.002 | 0.84 

------------------------+-----------------------+-----------------+------------------ 

Exide, Forest City MO | None provided | None provided | 0.57 

------------------------+-----------------------+-----------------+------------------ 

Exide, Frisco TX | Roadway fugitives, | 1.03 | 1.03 

 | raw material | | 

 | storage, slag | | 

 | handling, material | | 

 | handling, blast and | | 

 | reverb fugitives, | | 

 | refining and casting | | 

 | fugitives | | 

------------------------+-----------------------+-----------------+------------------ 

Exide, Muncie IN | Ambient monitoring | 0.22 | 0.26 

------------------------+-----------------------+-----------------+------------------ 

Exide, Reading PA | Roadway fugitives | 0.35 | 0.75 

------------------------+-----------------------+-----------------+------------------ 

Exide, Vernon CA | Dust analysis (‘91 | 0.10 | 0.23 

 | and source test ’98) | | 

 

 With this email we are providing you an opportunity to comment on

our revised draft estimates, or provide calculations and documentation

to support your original estimates, and/or provide alternative estimates

that you believe are more accurate. If you suggest alternative

estimates, please provide complete documentation and explanation of the

basis of such alternatives. If you would like to provide comments,

additional information, or alternative estimates and documentation,

please send a response to this email by February 7th, 2011.

 Sincerely,

 Chuck French, Environmental Scientist,

 U.S. EPA, Office of Air Quality Planning and Standards,

Sector Policies and Program Division

 Phone: 919-541-7912