1 

MEMORANDUM 

To: Chuck French, U.S. Environmental Protection Agency, OAQPS 

From: Donna Lazzari and Mike Burr, ERG 

Date: April 2011 

Subject: Draft Cost Impacts for the Secondary Lead Smelting Source Category 

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

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

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

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

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

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

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

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

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

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

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

Chosen for Proposal 

2.0 Regulatory Options Considered for Proposal 

3.0 Methodology for Estimating Control Costs 

4.0 Methodology for Estimating Emissions Reductions 

5.0 Testing and Monitoring Cost Impacts 

6.0 Summary of Cost by Facility 

1.0 SUMMARY OF COST ESTIMATES AND EMISSIONS REDUCTIONS FOR THE 

REGULATORY OPTIONS CHOSEN FOR PROPOSAL 

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

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

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

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

 

1 ERG. Development of the RTR Emissions Dataset for the Secondary Lead Smelting Source Category, Mar. 2011. 

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

description of the options selected for the proposed revisions to the NESHAP and the associated 

costs and emissions reductions are summarized in Table 1-1. The most stringent options 

considered in this analysis are summarized in Table 1-2. A more detailed description of all the 

regulatory options considered for proposal and their associated cost and emissions reductions 

estimates are presented in section 2.0 of this memorandum. 

Table 1-1: Summary of the Estimated Costs and Emissions Reductions of Regulatory 

Options Selected for Proposal

Option Description

COST IN $ MILLIONS (2009 DOLLARS)

Total HAP 

Emissions 

Reductions 

(tons per 

year)

Cost per 

ton HAP 

reduction 

($MM)

Capital 

Cost 

Annualized 

Capital 

Cost 

Annual 

Operation 

and 

Maintenance 

Cost 

Total 

Annualized 

Cost 

3S Stack lead 

concentration 

limit of 1.0 

mg/dscm any 

stack, and 0.2 

mg/dscm 

facility 

average 

$7.7 $0.7 $0.9 $1.7 5.9 $0.29 

1D D/F 

Concentration 

based limit 

$0 $0 $0.26 $0.26 30* 

 

$0.009 

3F Fugitive 

enclosure + 

work practice 

$40 $3.8 $5.8 $9.6 9.5 $1.0 

Test, 

Monitor, 

Report 

Additional 

Testing, 

Monitoring 

$0.33 $0.03 $1.0 $1.0 

Total $48.0 $4.5 $8.0 $12.6 45.4 $0.28 

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

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

Option Description

COST IN $ MILLIONS (2009 DOLLARS)

Total HAP 

Emissions 

Reductions 

(tons per 

year)

Cost per 

ton HAP 

reduction 

($MM)

Capital 

Cost 

Annualized 

Capital 

Cost 

Annual 

Operation 

and 

Maintenance 

Cost 

Total 

Annualized 

Cost 

2S 

0.009 lb/ton 

Pb 

emissions 

limit 

$23.9 $2.3 $2.7 $5.0 9.6 $0.52 

2D 

Beyond the 

floor D/F 

limits for 

$5.9 $0.56 $2.4 $2.9 200* $0.015 
3 

Option Description

COST IN $ MILLIONS (2009 DOLLARS)

Total HAP 

Emissions 

Reductions 

(tons per 

year)

Cost per 

ton HAP 

reduction 

($MM)

Capital 

Cost 

Annualized 

Capital 

Cost 

Annual 

Operation 

and 

Maintenance 

Cost 

Total 

Annualized 

Cost 

blast 

furnaces 

1F and 2F 

Enclosures, 

work 

practices, 

monitoring 

$40 $3.8 $6.1 $9.9 9.5 $ 1.04 

Test, 

monitor, 

report 

Additional 

testing and 

monitoring 

$0.33 $0.03 $1.0 $1.0 

Total $70.1 $6.7 $14.4 $18.8 219 0.086

*We estimate a total of 200 tons of reductions in organic HAP emissions, including 31 grams of dioxins and furans, 

under this beyond-the-floor option. 

2.0 REGULATORY OPTIONS CONSIDERED FOR PROPOSAL 

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

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

and secondary impacts. 

2.1 Stack Emissions – Metal HAP

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

are presented in the following sections. 

a. Option 1S 

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

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

mg/dscm. Based on emissions data received in an information collection request ( ICR) sent to 

the industry, 90 percent of the stacks in this source category reported concentrations below 0.5 

mg/dscm. Ten emissions points at six facilities reported concentrations above 0.5 mg/dscm; 

estimates of cost and emissions reductions were made for 8 of these stacks. One facility is 

currently undergoing an upgrade with plans to replace existing baghouses, and thus, we assumed 

this would reduce the lead concentration at this stack below 0.5 mg/dscm. For seven of the 

stacks reporting concentrations above 0.5 mg/dscm, we assumed that a replacement baghouse 

would be installed. For one stack at which a baghouse was recently installed, we assumed that 

lead concentrations below 0.5 mg/dscm could be achieved through replacement bags 

performance of additional maintenance on the unit. One additional stack reported concentrations 

that were very close to 0.5 mg/dscm; no costs for were estimated for this unit. The total 

estimated capital cost for the seven new baghouses that would likely be necessary to achieve 
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concentrations below 0.5 mg/dscm is $11.8 million, resulting in an annualized capital cost of 

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

changes for the baghouses, are estimated at $1.6 million above the costs of operating the current 

air pollution control devices. The total estimated annualized cost above current cost for the 8 

baghouses is $2.7 million (2009 dollars). The estimated emissions reductions of Option 1S are 

6.5 tons per year of lead and 8.3 tons per year of total metal HAP. 

b. Option 2S 

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

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

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

baghouses would likely be necessary at 19 emissions points at six facilities to meet the limit 

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

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

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

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

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

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

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

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

baghouses would be needed. 

The total estimated capital cost for this regulatory option is $23.9 million, resulting in an 

annualized capital cost of $2.3 million. Additional annual operational and maintenance costs, 

including more frequent bag changes for the baghouses, are estimated at $2.7 million above 

current costs. The total annualized cost above current air pollution control device operating costs 

for the 19 baghouses is $5.0 million (2009 dollars). Total anticipated emissions reductions of 

lead and other metal HAP in this option are estimated at 9.6 tons per year. 

c. Option 3S 

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

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

individual stack. We estimate that this option would require reductions in lead emissions at three 

emissions points located at two facilities. We assumed that replacement baghouses would be 

needed at each of these emissions points. The total estimated capital cost for the new baghouses 

is $7.7 million, resulting in an annualized capital cost of $0.7 million. Additional annual 

operational and maintenance costs, including more frequent bag changes for the baghouses, are 
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estimated at $0.9 million above the currently operated air pollution control device operating 

costs. The total annualized cost above current cost for the three baghouses is $1.7 million (2009 

dollars). Lead emissions reductions for this option are estimated at 4.7 tons per year with total 

metal HAP emissions reductions of 5.9 tons per year. 

d. Option 4S 

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

precipitator (WESP) at each facility to control stack emissions of metal HAP. One facility in this 

source category currently utilizes a WESP to control metal HAP emissions from stacks (i.e., 

Quemetco, Inc. in City of Industry, CA). Based on emissions data received in the ICR, this 

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

the other 13 facilities in the source category would be required to install a WESP. Based on the 

configuration of the existing WESP reported in the ICR, we assumed that facilities that would 

need to install a WESP under this option would use the WESP to control metal HAP emissions 

from process and process fugitive emissions sources only. More specifically, we assumed that 

existing hygiene baghouses would not be routed to the WESP. The total estimated capital cost 

for installation of a WESP at 13 facilities is $400 million, resulting in an annualized capital cost 

of $36 million. The total annualized cost above current cost is estimated at $55 million. Lead 

emissions reductions for this option are estimated at 10.9 tons per year with total estimated metal 

HAP emissions reductions of 13.8 tons per year. 

e. Summary 

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

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

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

Considered for Stack Emissions of Metal HAP. 

Option Description

COST IN $ MILLIONS (2009 DOLLARS)

Total HAP 

Emissions 

Reductions 

(tons per 

year)

Cost per 

ton HAP 

reduction 

($MM)

Capital 

Cost 

Annualized 

Capital 

Cost 

Annual 

Operation 

and 

Maintenance 

Cost 

Total 

Annualized 

Cost 

1S 

Concentration 

limit of 0.5 

mg/dscm 

$11.8 $1.1 $1.6 $2.7 8.3 $0.33 

2S 

0.009 lb Pb / 

Ton Pb 

produced $23.9 $2.3 $2.7 $5.0 9.6 $0.52 

3S 

Concentration 

limit of 1.0 

mg/dscm any 

stack, and 0.2 

$7.7 $0.7 $0.9 $1.7 5.9 $0.29 
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Option Description

COST IN $ MILLIONS (2009 DOLLARS)

Total HAP 

Emissions 

Reductions 

(tons per 

year)

Cost per 

ton HAP 

reduction 

($MM)

Capital 

Cost 

Annualized 

Capital 

Cost 

Annual 

Operation 

and 

Maintenance 

Cost 

Total 

Annualized 

Cost 

mg/dscm 

facility 

average 

4S WESP $400 $36 $19 $55 13.8 $4.0

2.2 Stack Emissions – Organic HAP and D/F

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

D/F are presented in the following sections. 

a. Option 1D

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

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

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

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

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

reverberatory furnaces not collocated with blast furnaces, electric arc furnaces, and rotary 

furnaces. The THC MACT limits for blast furnaces and collocated blast and reverberatory 

furnaces in the existing NESHAP would remain unchanged under the proposed revisions. We do 

not anticipate that this regulatory option will require installation of additional controls at any 

facilities. We do anticipate, however, that four facilities operating blast furnaces will likely 

increase the temperature of their afterburners to ensure continuous compliance with the new 

MACT floors for D/F and THC. The cost of the natural gas required to raise the temperature 100 

degrees Fahrenheit (°F) at afterburners was estimated at $260,000 per year (2009 dollars). Under 

this regulatory option, we estimate D/F emissions reductions of about 2.9 grams per year and 

organic HAP emissions reductions of about 30 tons per year. 

b. Option 2D 

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

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

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

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

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

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

considered. This concentration represents an approximate 90 percent reduction in total D/F 

emissions from blast furnaces in this source category. 

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

of the six blast furnaces needing D/F emissions reductions. One of the blast furnaces has an 

afterburner currently installed that meets the requirements of this considered regulatory option. 

The total estimated capital cost for installation of the additional afterburners is $5.9 million, 

which results in an estimated annualized capital cost of $0.56 million. Annual operational and 

maintenance costs increases, including additional natural gas fuel, are estimated at $2.4 million 

above current control device operating costs. The total annualized cost above current cost for the 

afterburners is estimated to be $2.9 million (2009 dollars). Under this scenario, we anticipate 

D/F emissions reductions of 31 grams per year, with a co-reduction of 200 tons per year of all 

other organic HAP. We also estimate that this option would result in a significant increase in 

fuel use along with increased emissions of carbon dioxide (CO2) and oxides of nitrogen (NOx) 

associated with operation of the additional afterburners. 

c. Summary 

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

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

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

for Stack Emissions of D/F and Organic HAP. 

Option Description

COST IN $ MILLIONS (2009 DOLLARS)

Total HAP 

Emissions 

Reductions 

(tons per 

year)

Cost per 

ton HAP 

reduction 

($MM)

Capital 

Cost 

Annualized 

Capital 

Cost 

Annual 

Operation 

and 

Maintenance 

Cost 

Total 

Annualized 

Cost 

1D Concentration 

based MACT 

limit 

$0 $0 $0.26 $0.26 30*

 

$0.009

2D Beyond the 

floor for Blast 

furnaces 

$5.9 $0.56 $2.4 $2.9 200* $0.015 

* based on total organic HAP 

2.3 Fugitive Emissions – Metal HAP

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

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

calculated. Instead, regulatory options were considered that prescribed specific controls or lead 
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compliance monitoring at the property boundary as a means of demonstrating compliance. The 

three options considered are as follows: 

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

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

Standard (NAAQS) for lead. 

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

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

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

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

lead monitoring at or near the property boundary. 

3. Option 3F: This is the primary regulatory option selected by EPA for proposal in the 

revised NESHAP for the Secondary Lead Smelting source category. This option is 

identical to option 2F with the exception that ambient lead monitoring at or near the 

boundaries of the facilities would not be required. Instead, compliance would be 

demonstrated through construction of total enclosures and operation according to a 

standard operating procedures (SOP) manual detailing how the required fugitive control 

work practices will be implemented. 

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

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

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

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

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

This estimate is considered to be a high end conservative estimate of costs, particularly for 

facilities where operations are not close to the property boundary. Based on information 

submitted in the ICR, the facilities that are currently achieving ambient lead concentrations at or 

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

processes totally enclosed. Therefore, we assumed facilities that do not have all of their lead 

manufacturing processes in total enclosures will construct the appropriate enclosures and 

reconfigure their facilities to reduce their overall footprint as described in section 3.3 of this 

memorandum. 

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

associated control devices is $40 million, which results in an annualized capital cost of $3.8 

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

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

enclosures for six facilities is $6.6 million. Costs associated with the additional work practices 

are estimated at $300,000 per facility for 10 facilities at a total cost of $3 million. The total 

estimated annualized cost of reducing fugitive emissions for the primary regulatory option 

selected by EPA for proposal (Option 3F) is $9.6 million (2009 dollars). For option 1F and 2F, 

the cost of operating two compliance monitors at or near the property boundary of each facility is 
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estimated at $23,000 per facility for a total additional annualized cost of $322,000. We estimate 

reductions in fugitive emissions of 8.7 tons per year of lead and 9.5 tons per year of metal HAP. 

The estimated costs and emissions reductions associated with the regulatory options 

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

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

Option Description

COST IN $ MILLIONS (2009 DOLLARS)

Total HAP 

Emissions 

Reductions 

(tons per 

year)

Cost per 

ton HAP 

reduction 

($MM)

Capital 

Cost 

Annualized 

Capital 

Cost 

Annual 

Operation 

and 

Maintenance 

Cost 

Total 

Annualized 

Cost 

1F and 2F Enclosure, 

work 

practice, 

monitoring 

$40 $3.8 $6.1 $9.9 9.5 $1.04 

3 F Enclosure, 

work 

practice 

$40 $3.8 $5.8 $9.6 9.5 $1.0 

3.0 METHODOLOGY FOR ESTIMATING CONTROL COSTS 

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

with the regulatory options considered for proposal in the revised NESHAP for the Secondary 

Lead Smelting source category. 

3.1 Stack Emissions – Metal HAP

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

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

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

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

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

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

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

(which included a WESP). 

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

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

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

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

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

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

limit or the unit in question was relatively new (installed after the year 2000), we assumed that 
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replacement bags or additional baghouse maintenance could sufficiently reduce the 

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

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

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

below the considered limit. 

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

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

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

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

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

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

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

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

submitted directly by the industry is likely more representative of actual costs incurred by this 

source category. 

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

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

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

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

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

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

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

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

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

baghouse was assumed to be 20 percent higher than the flow-rate measured during a compliance 

test. 

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

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

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

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

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

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

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

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

developed using information submitted in the ICR. 
11 

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

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

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

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

ventilation sources. We used the rapid estimation exponential method described in Perry’s 

Chemical Engineers’ Handbook3to derive an equation representing the expected flow-rate into 

the WESP at each facility. Our estimate of annualized costs primarily includes electricity to 

operate the WESP and capital recovery. 

3.2 Stack Emissions – Organic HAP and D/F

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

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

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

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

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

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

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

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

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

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

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

operated afterburners with a sufficient residence time can achieve high destruction efficiency

4

. 

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

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

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

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

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

90 percent reduction in D/F emissions. 

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

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

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

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

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

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

 

3

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

4

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

incineration plants and experimental investigation, Waste Management 20 (2000) 27-49.
12 

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

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

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

estimates was chosen as the basis for our cost estimate. For the capital cost estimate, we 

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

increasing the temperature of the stream leaving the existing afterburner to a temperature of 

1600°F would be installed. We used an equation modeled after equation 2.32 in the EPA Air 

Pollution Control Cost Manual to scale the size and cost of a thermal incinerator based on the 

reported flow-rates for each of the blast furnaces. The typical cost for an installed afterburner 

with a design flow-rate of 17,000 acfm was estimated at $1.2 million. 

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

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

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

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

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

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

3.3 Fugitive Emissions – Metal HAP

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

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

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

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

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

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

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

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

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

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

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

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

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

other forces can then re-entrain the deposited dust as fine airborne particles. Stack emissions 

containing lead and other metal HAP can also settle onto surfaces near the facility and can be 

subsequently re-entrained as fine airborne particles. 

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

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

pressure enclosure hoods and vented to a control device. There is a minimum face velocity 
13 

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

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

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

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

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

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

handled. 

EPA requested information in the ICR regarding the fugitive control techniques 

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

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

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

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

concentrations at nearby monitors were assumed to achieve more efficient control of fugitive 

emissions. We assumed that facilities with ambient monitoring data showing lead concentrations 

above the lead NAAQS would need to install permanent total enclosures with ventilation to a 

control device and implement additional work practices to prevent the formation of fugitive dust 

in other areas of their facilities. This approach may overstate the costs for facilities that choose 

to demonstrate compliance through monitoring at the property boundary, and where operations 

are a significant distance from the property boundary. 

For each facility, we estimated the area that is currently under a total enclosure ventilated 

to a control device. We then estimated the additional enclosure area necessary fully enclose the 

entire process. We assumed facilities that required a substantial area of new enclosures would 

re-configure their facility in a manner that reduces the overall footprint of the facility. 

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

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

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

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

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

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

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

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

required for all other facilities. 

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

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

pressure. Based on information submitted in the ICR, we estimated a flow-rate that would result 
14 

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

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

of this memorandum. 

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

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

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

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

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

the EPA Air Pollution Control Cost Manual. 

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

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

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

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

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

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

acceptable level. We estimated that an additional four employees per facility (one per shift for 

four shifts) at an annualized cost of $300,000 will be needed to implement the following 

additional fugitive control work practices: maintenance of negative pressure monitors in 

enclosures, monthly cleaning of rooftops, weekly cleaning of all areas where waste generated by 

housekeeping activities are stored or disposed of, immediate cleaning after accidental releases, 

inspections of enclosures once per month, daily inspection of battery storage area and immediate 

processing of cracked batteries, and thorough cleaning and inspection of any vehicles leaving the 

process area. 

4.0 METHODOLOGY FOR ESTIMATING EMISSIONS REDUCTIONS 

This section discusses the methodology used to estimate emissions reductions associated 

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

4.1 Stack Emissions – Metal HAP

a. Option 1S

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

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

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

baghouse at that emissions point. We assumed that the outlet lead concentration from the newly 

installed baghouse would be equivalent to the average of all outlet lead concentrations reported 
15 

in the ICR; we calculated this average to be 0.159 mg/dscm. We estimated the expected 

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

would occur assuming an outlet lead concentration of 0.159 mg/dscm (see Equation 1). 

 = [( × ) − (0.159 × )] × × (Eq. 1) 

Where: 

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

F = flow rate (dscm/hr), 

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

H = annual hours of operation, and 

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

We concluded that 8 stacks throughout the industry would need new baghouse 

installations. One additional source reported an outlet lead concentration above 0.5 mg/dscm. 

However, they reported an ongoing project that includes upgrading the baghouse in question, and 

therefore, this source was not included in the emissions reduction calculation. 

b. Option 2S 

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

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

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

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

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

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

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

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

concentration of 0.159 mg/dscm. We estimated that a total of 20 emissions points at six facilities 

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

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

proportionally to lead emissions. 

c. Option 3S 

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

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

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

concentration limit of 1.0 mg/dscm using a modified form of Equation 1. Based on this analysis, 

we estimated that three stacks would need replacement baghouses. Additionally, each facility’s 

flow-weighted average lead concentration was calculated based on emissions data submitted in 
16 

the ICR. We then compared that value to facility-wide flow-weighted average limit of 0.2 

mg/dscm considered in this option. We estimate that five facilities currently have a flowweighted average lead concentration above the considered limit. We also considered the impacts 

of the proposed fugitive control standards presented in section 2.3 of this memorandum on the 

flow-weighted average concentration of each facility. Because we assumed that each facility 

will be required to have all processes under total enclosures with negative pressure and 

ventilation to a control device, we assumed that facilities needing additional enclosures would 

install one additional corresponding hygiene baghouse. Based on the average outlet lead 

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

concentration from these hygiene baghouses would be 0.05 mg/dscm. We estimated that three of 

the five facilities initially identified as having emissions above the limit considered in this option 

would meet the considered limit after installation of the additional enclosures required in the 

fugitive control options. Furthermore, we estimate that replacing all baghouses reporting 

concentrations above 1.0 mg/dscm in combination with the installation of additional enclosures 

will result in all facilities being in compliance with the limits considered in this option. The total 

emissions reductions for this option were calculated using Equation 1. 

d. Option 4S 

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

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

Based on this information, we assumed that emissions of lead and other metal HAP from any 

source expected to be controlled by the WESP would be reduced by 99.98 percent.

4.2 Stack Emissions – Organic HAP and D/F

a. Option 1D 

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

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

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

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

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

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

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

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

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

b. Option 2D 
17 

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

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

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

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

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

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

source category. 

4.3 Fugitive Emissions – Metal HAP

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

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

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

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

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

fugitive emissions of 75 percent from baseline levels were estimated if new total enclosures were 

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

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

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

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

Lead Smelting Source Category. 

5.0 TESTING AND MONITORING COST IMPACTS 

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

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

regulatory options chosen for proposal in the revised NESHAP require annual stack testing for 

lead and THC and stack testing once every five years for D/F. The additional costs associated 

with the stack testing requirements above current costs are anticipated to be $750,000 per year 

(an average of $53,000 per facility). 

Bag leak detection systems (BLDS) are required by the existing NESHAP for all 

baghouses unless a secondary HEPA filter is installed. The proposed revisions to the NESHAP 

eliminate the BLDS exemption for emissions points where secondary HEPA filters are installed. 

The capital cost associated with installation of seven new BLDS is $230,000 and was estimated 

using the EPA’s bag leak detection guidance5and CEMS cost model 

(http://www.epa.gov/ttn/emc/cem.html). The capital cost associated with additional differential 

pressure monitors for total enclosures is $97,000. 

 

5

EPA Office of Air Quality Planning and Standards Fabric Filter Bag Leak Detection Guidance – (EPA 454/R-98-

015).
18 

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

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

$1,020,000. A detailed burden estimate is available in the docket for this rulemaking 

(Supporting Statement, National Emission Standards for Secondary Lead Smelting). 

6.0 SUMMARY OF COST BY FACILITY 

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

smelting source category. 

Table 6-1 Summary Cost Estimates by Facility* 

Facility Total Capital Cost Total Annual Cost

Doe Run 18,200,000 3,550,000

East penn 0 380,000

EnviroFocus 0 390,000

Exide Baton Rouge 7,250,000 1,890,000

Exide Forest City 2,560,000 750,000

Exide Frisco 4,390,000 1,160,000

Exide Muncie 0 360,000

Exide Reading 5,630,000 1,320,000

Exide Vernon 0 87,000

Gopher Eagan 0 350,000

Quemetco (CA) 0 87,000

Quemetco (IN) 0 94,000

RSR 0 87,000

Sanders 9,520,000 2,048,000

Total 47,550,000 12,553,000

*Some of these cost estimates are likely overstated since some facilities may be able to comply with the rule 

under the alternative compliance option (i.e., monitoring at facility boundary and implementing work practices) 

and may not need to construct full enclosures. If so, actual costs would be significantly lower than shown here 

for those facilities.