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

To: <rb@sanderslead.com>

CC: Russell Kemp <rkemp@environcorp.com>, Donna Lazzari <Donna.Lazzari@erg.com>, 

<Topham.Nathan@epamail.epa.gov>, <michael.burr@erg.com>

Date: 2/1/2011 4:34 PM

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

Dear Mr. Roy Baggett,

 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 lead 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 results of

the preliminary 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. In your

survey, you provided an estimate for fugitive lead emissions from the

battery breaker, decasing of batteries, the RMS building, traffic, and

furnace and refining building. However, the calculation method used was

not sufficiently explained or documented.

 Therefore, we have derived new or revised estimates of fugitive

emissions for your facility 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 preliminary modeling estimates.

 The draft estimates we have derived for your facility and the

original estimate you provided in the survey are as follows:

A. Sanders, AL:
1. The estimate of fugitive lead emissions provided in your survey

response = 3.24 tons per year, and the survey response indicated that

this estimate was for battery Breaker, decasting of batteries, RMS

Building Traffic, Furnace and Refining building.

2. The EPA draft estimate of total fugitive emissions of lead for this

facility = 1.4 tons per year.

 With this email, we are providing you with an opportunity to

comment on our revised estimates, provide calculations and documentation

to support your original estimates, 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 comment or provide

additional information or alternative estimates, please send a response

to this email by February 8, 2011.

 Thank You.

 Chuck French