From: Billy_Nichols@URSCorp.com

To: Chuck French/RTP/USEPA/US@EPA 

Cc: rb@sanderslead.com

Date: 02/11/2011 05:14 PM 

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

Mr. French, 

On behalf of Sanders Lead Company, please find attached their comments related to the fugitive 

emission releases from their facility in Troy, Alabama. 

Please let us know if you have any questions. 

Billy R. Nichols, P.E. 

URS Corporation 

1000 Corporate Centre Drive, Suite 250 

Franklin, TN 37067 

office 615-771-2480 

direct line 615-224-2135 

fax 615-771-2459 

cellular 615-202-6556 

Email: billy_nichols@urscorp.com

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Sanders Lead Company – Response to Fugitive Lead Emission Estimates

Sanders Lead Company has received and reviewed the recently prepared “Draft Estimates of 

Fugitive Lead Emissions for the Secondary Lead Smelting” especially as it relates to the 

emission estimates provided for Sanders Lead Company’s facility in Troy, AL as well as email 

from Mr. Chuck French to Roy Baggett dated February 1, 2011 (with Attachment 1 received 

February 7, 2011).

The emissions estimates for fugitive lead (3.24 tons/yr) provided in the ICR request were based 

on a recent precursory study performed by a consultant that has been hired to assist in 

developing long term control strategies. The values were reported as “maximum expected 

emissions” and therefore realistically should not be considered as annual averages. This data has 

not been validated through any means such as air modeling and comparison with actual air 

monitoring data. The emission estimates provided in the TRI database (1.6 tons/yr) were 

estimates prepared several years ago by another consultant as part of a PSD application. 

Although, as with the estimates discussed above, these have likewise not been validated, they 

appeared reasonable and had historically been acceptable to the state air regulatory agency.

In completing the ICR Sanders Lead chose to include the more conservative values; however, 

we, like EPA, feel these estimates are too high to represent and annual average emission rate. 

We feel the 1.6 tons per year is a much more reasonable estimate, although it is unknown to 

Sanders Lead at this time if the fugitive emission factor that has been include is too high or too 

low. From review this week of previous modeling of stack emissions and comparing the stack 

impacts with ambient monitoring data, our best guess is that the current actual fugitive lead 

emissions are less than 1.6 tons per year. As part of the SIP update process, we will be 

performing in the near future air dispersion modeling that will help substantiate our believe that 

the current fugitive emissions are 1.6 tons per year or less.

The fugitive emissions estimates provided by EPA (dated February 7, 2011) appear to a very 

minimal effort without much sound logic. It is unclear how a partially enclosed facility would 

have 3⁄4 the emission of a fully enclosed facility. Maybe this is a typo. Also, we don’t understand 

the reference to unenclosed facility? Such a facility does not exist under the current MACT 

rules.