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Implementation of the 2008 Lead National Ambient
Air Quality Standards
Guide to Developing Reasonably Available Control Measures
(RACM) for Controlling Lead Emissions
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EPA-457/R-12-001
March 2012
Implementation of the 2008 Lead National Ambient Air Quality Standards
Guide to Developing Reasonably Available Control Measures (RACM) for Controlling Lead
Emissions
By:
Doug Mclntyre
EC/R Incorporated
Chapel Hill, North Carolina
Prepared for:
Ms. Mia South, Work Assignment Manager
Air Quality Policy Division
EPA Contract No. EP-D-07-001
Work Assignment #4-10
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Air Quality Policy Division
Research Triangle Park, NC 27711
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List of Acronyms
BDT
BOPF
BOPH
CAA
CFR
EAF
EIF
EPA
FR
GACT
HAP
HEPA
MACT
NAAQS
NAICS
NEI
NESHAP
NSPS
PM
RACM
RACT
SCAQMD
SIP
TPY
WESPs
Best Demonstrated Technology
Basic Oxygen Process Furnace
Basic Oxygen Process Heater
Clean Air Act
Code of Federal Regulations
Electric Arc Furnace
Electric Induction Furnace
Environmental Protection Agency
Federal Register
Generally Available Control Technology
Hazardous Air Pollutant
High Efficiency Particulate Air
Maximum Available Control Technology
National Ambient Air Quality Standard
North American Industry Classification System
National Emissions Inventory
National Emission Standards for Hazardous Air Pollutants
New Source Performance Standard
Particulate Matter
Reasonably Available Control Measure
Reasonably Available Control Technology
South Coast Air Quality Management District
State Implementation Plan
Tons Per Year
Wet Electrostatic Precipitators
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-TABLE OF CONTENTS-
1.0. INTRODUCTION 1
1.1. Purpose - Supporting the Implementation of the 2008 Lead NAAQS by Analyzing Relevant Control Measures
for RACM Development 1
1.2. The 2008 Lead NAAQS and RACM Requirements 1
2.0. EPA CRITERIA AND PROCEDURES FOR RACM DEVELOPMENT 3
2.1. EPA Criteria for Determining whether a Control Measure is a RACM 3
2.2. Using Particulate Matter Cost-Effectiveness Information as a Surrogate for Lead Cost- Effectiveness
Information 5
3.0. OVERVIEW OF RACM DEVELOPMENT FOR THE IMPLEMENTATION OF THE 2008 LEAD NAAQS 6
3.1. Overview of RACM Development 6
3.2. Selecting the Source Categories for which RACM Development is Focused on in this Document 6
3.3. Strategy for Developing RACM for Source Categories not Focused on in this Document 14
4.0. RACM DEVELOPMENT FOR THE SECONDARY LEAD SMELTING SOURCE CATEGORY 16
4.1. Overview of Source Category 16
4.2. Facility Operations and Lead Emission Points 16
4.3. Identification and Summary of Possible RACM Candidates 17
4.4. Application of RACM Criteria to Possible RACM Candidates 19
5.0. RACM DEVELOPMENT FOR THE LEAD ACID BATTERY MANUFACTURING SOURCE CATEGORY. 27
5.1. Overview of Source Category 27
5.2. Facility Operations and Lead Emission Points 27
5.3. Identification and Summary of Possible RACM Candidates 28
5.4. Application of RACM Criteria to Possible RACM Candidates 29
6.0. RACM DEVELOPMENT FOR THE IRON AND STEEL FOUNDRIES SOURCE CATEGORY 34
6.1. Overview of Source Category 34
6.2. Facility Operations and Lead Emission Points 35
6.3. Identification and Summary of Possible RACM Candidates 36
6.4. Application of RACM Criteria to Possible RACM Candidates 38
7.0. RACM DEVELOPMENT FOR THE INTEGRATED IRON AND STEEL MILLS SOURCE CATEGORY 51
7.1. Overview of Source Category 51
7.2. Facility Operations and Lead Emission Points 51
7.3. Identification and Summary of Possible RACM Candidates 53
7.4. Application of RACM Criteria to Possible RACM Candidates 54
8.0. RACM DEVELOPMENT FOR FUGITIVE DUST CONTROL MEASURES 60
8.1. The Economic Feasibility of Fugitive Dust Control Measures 60
8.2. The Capital Costs, Annualized Costs, and Cost Effectiveness of Fugitive Dust Control Measures 61
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8.3. Fugitive Dust Control Measures Adopted in Federal and State Regulations 62
8.4. Implications for RACM Development for Fugitive Dust Control Measures 65
ill
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1.0. INTRODUCTION.
1.1. Purpose - Supporting the Implementation of the 2008 Lead NAAQS by Analyzing Relevant
Control Measures for RACM Development.
In order to support the implementation of the 2008 Lead National Ambient Air Quality Standards
(NAAQS), this document contains an analysis of air control measures for the purpose of determining
what controls may constitute reasonably available control measures (RACM), including reasonably
available control technologies (RACT), for controlling lead emissions pursuant to Section 172(c)(l) of
the Clean Air Act (CAA). This document was prepared pursuant to EPA Contract EP-D-07-001, Work
Assignment #4-10, by EC/R Incorporated.
This document identifies control measures used to control lead emissions from sources in the Secondary
Lead Smelting, Lead Acid Battery Manufacturing, Iron and Steel Mills, and Iron and Steel Foundries
source categories. For each identified control measure, this document contains a RACM criteria
assessment to determine how likely each control measure is to constitute RACM. In addition, for the
Primary Lead Smelting, Secondary Aluminum Production, Secondary Copper Smelting, Mining, and
Petroleum Refineries source categories, data relevant to a RACM determination was collected from
EPA's CoST database and is presented here for a RACM criteria assessment.
A prior EPA document identifies potential RACM for controlling lead emissions.1 This document,
"Implementation of the 2008 Lead National Ambient Air Quality Standards (NAAQS): Guide to
Developing Reasonably Available Control Measures (RACM) for Controlling Lead Emissions," is
intended to replace such prior document, and any other EPA-issued document, with respect to
identifying RACM for controlling lead emissions.
1.2. The 2008 Lead NAAQS and RACM Requirements.
On November 12, 2008, EPA published the final rule on the Lead NAAQS. Based on its review, EPA
made revisions to the primary and secondary Lead NAAQS to provide requisite protection of the public
health and welfare. EPA revised the primary standard to provide increased protection for children and
other at-risk populations against an array of adverse health effects. Such health effects most notably
include neurological effects in children, including neurocognitive and neurobehavioral effects. EPA
revised the level from 1.5 to 0.15 micrograms per cubic meter (|ig/m3). EPA revised the secondary
standard to be identical in all respects to the revised primary standard.2
The CAA requires that states submit for each nonattainment area a state implementation plan (SIP) that
contains RACM, including RACT. Specifically, section 172(c)(l) of the CAA requires that
nonattainment SIPs "provide for the implementation of all reasonably available control measures as
expeditiously as practicable (including such reductions in emissions from existing sources in the area as
may be obtained through the adoption, at a minimum, of reasonably available control technology) and
shall provide for the attainment of the NAAQS [emphasis added]."3
The first step in addressing RACM for the 2008 Lead NAAQS is to identify potential measures for
controlling lead emissions from lead sources in nonattainment areas. In addition, if states are aware of
'"Lead Guideline Document." EPA-452/R-93-009. April 1993.
2National Ambient Air Quality Standards for Lead: Final Rule. 73 FR 66964. 67036 (Published November 12. 2008).
3Id. at 67036.
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information or receive substantive public comments that demonstrate through appropriate
documentation that additional control measures may be reasonably available in a specific area, the
measures should be added to the list of available measures for consideration in that particular area.4
While EPA does not presume that control measures are reasonably available in all areas, a reasoned
justification for rejection of any available control measure should be prepared. If it can be shown that
such control measures, if applied to individual sources or to a source category, are unreasonable because
emissions from the affected sources are insignificant (i.e., would not have any effect on attainment),
then the control measures may be excluded from further consideration as they would not be
representative of RACM for the affected area. The resulting control measures should then be evaluated
for reasonableness, considering their technological feasibility and the cost of control in the area for
which the SIP applies.5
5ld.
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2.0. EPA CRITERIA AND PROCEDURES FOR RACM
DEVELOPMENT.
This section provides EPA criteria and procedures for the development of RACM, which will be used in
subsequent sections to assess how likely each control measure is a RACM.
2.1. EPA Criteria for Determining whether a Control Measure is a RACM.
EPA provides that in determining whether a control measure is a RACM, the following factors should
be considered:
1. The economic feasibility of the control measure,
2. The capital costs, annualized cost, and cost effectiveness of the control measure; and
3. The extent of adoption of the control measure by state regulations.6
2.1.1. The Economic Feasibility of the Control Measure.
The economic feasibility of a control measure refers to the cost of reducing emissions and the difference
between the cost of the control measure at the particular source in question and the costs of control
measures that have been implemented at similar sources. Economic feasibility is largely determined by
evidence that other sources in a particular source category have applied the control measure in question,
although EPA does encourage the development of innovative measures not previously employed that
may be technically and economically feasible. Absent other indications, EPA, as a general matter,
expects that it is reasonable for similar sources to bear the costs for similar control measures.7
2.1.2. The Capital Costs, Annualized Costs, and Cost Effectiveness of the Control Measure.
Substantial weight should be given to cost effectiveness in evaluating whether a control measure is a
RACM. The cost effectiveness of a technology is its annualized cost (e.g, $/year) divided by the
emissions reduced (e.g., tons/year) which yields a cost per amount of emission reduction (e.g., $/ton).8
In considering what level of control is reasonable, EPA has not adopted a specific dollar per ton cost
threshold. However, a control measure is likely to be a RACM if it has a cost per ton similar to other
measures previously employed for that pollutant, or similar to that of other measures needed to achieve
expeditious attainment in the area within the CAA's timeframes. A higher cost per ton value may be
reasonable in areas with more serious air quality problems than in areas with less serious problems
because it is expected that the residents in the areas with more serious air quality problems could realize
greater public health benefits from attaining the standard as expeditiously as practicable. A higher cost
per ton value also may be reasonable in areas where essential reductions are difficult to achieve (e.g.,
because many sources are already controlled).9
In addition, EPA believes that in determining appropriate emission control levels, the state should
consider the collective public health benefits that can be realized in the area due to projected
6Id. at 67035-67037.
7Id. at 67036.
9Id.
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improvements in air quality.10 One such collective public health benefit might be improved air quality in
areas with large demographic populations that are the subject of environmental justice concerns, as more
expensive control measures might be more reasonable for sources in a nonattainment area with large
demographic populations that are the subject of environmental justice concerns. Considering
environmental justice concerns in this way is consistent with EPA Plan EJ 2014, which represents a
strategy aimed at protecting health in communities that are over-burdened by pollution.11
2.1.3. The Adoption of Control Measures by States.
The fact that a control measure has been adopted or is in the process of being adopted by states is an
indicator that the measure may be a RACM.12 This document will specifically focus on the state
regulations and permit requirements that pertain to source categories with corresponding sources in such
states.
Similarly, the fact that EPA has identified a control measure as a generally available control technology
(GACT), best demonstrated technology (BDT), or a maximum available control technology (MACT)
might also suggest that the control measure is reasonably available. EPA identifies control measures as
GACT when promulgating National Emission Standards for Hazardous Air Pollutants (NESHAP) for
area sources in a source category. In determining what constitutes GACT for a particular area source
category, EPA evaluates the control technologies and management practices that are generally available
for the area sources in a source category that reduce hazardous air pollutants (HAP). EPA may consider
costs in determining what constitutes GACT for the area source category.13 The fact that EPA has
considered a control measure GACT after considering costs would generally suggest that such a control
measure is likely a RACM.
EPA identifies control measures as BDT when promulgating New Source Performance Standards
(NSPS). BDT refers to the best system of continuous emissions reduction that has been demonstrated to
work in a given industry, considering economic costs and other factors, such as energy use.14 The fact
that EPA has considered a control measure BDT after considering costs would generally suggest that
such a control measure is a RACM.
EPA identifies control measures as MACT when promulgating NESHAP standards for major sources in
a source category. For major sources, MACT standards must reflect the maximum degree of emissions
reductions of HAP achievable after considering cost, energy requirements, and non-air quality health
and environmental impacts. The MACT "floor" is the minimum control level allowed for MACT
standards promulgated under CAA section 112(d)(3) and may not be based on cost considerations. For
new sources, the MACT floor cannot be less stringent than the emissions control that is achieved in
practice by the best controlled similar source. The MACT floors for existing sources can be less
stringent than floors for new sources, but they cannot be less stringent than the average emissions
limitation achieved by the best performing 12 percent of existing sources in the category or subcategory
(or the best performing five sources for categories or subcategories with fewer than 30 sources).15 In
10ld
"EPA Plan EJ 2014. EPA Office of Environmental Justice (Published September 2011).
12National Ambient Air Quality Standards for Lead: Final Rule. 73 FR 66964. 67036 (Published November 12. 2008).
13See, for example, NESHAP for Area Source: Acrylic and Modacrylic Fibers Production. Carbon Black Production.
Chemical Manufacturing. Flexible Polyurethane Foam Production and Fabrication. Lead Acid battery Manufacturing, and
Wood Preserving: Final Rule. 72 FR 38864. 38880 (Published July 16. 20071.
14NSPS for Portland Cement Manufacturing. 75 CFR 54970. 54974-54975 (Published September 9. 2010).
15See, for example, Proposed NESHAP for Iron and Steel Foundries. 67 CFR 78274. 78276 (Published December 23. 2002).
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some circumstances, such as when a large amount of time has passed since a control measure was
identified as MACT, the fact that a control technology was identified as MACT might suggest that such
a control measure is a RACM.
2.2. Using Particulate Matter Cost-Effectiveness Information as a Surrogate for Lead Cost-
Effectiveness Information.
As indicated in Section 2.1, cost-effectiveness information is an important factor to consider when
determining whether a control measure is a RACM. However, cost-effectiveness information for
controlling lead is often limited. Consequently, EPA often uses the cost-effectiveness information for
controlling particulate matter (PM) for a control measure as a surrogate for the cost-effectiveness of
controlling lead for the measure. That is, EPA will use evidence that suggests that a control measure is
cost effective for controlling PM emissions to support the contention that the control measure is also
cost effective for controlling lead emissions.
For example, for the development of RACM/RACT for the 2008 Lead NAAQS, EPA guidance indicates
that states should rely on the RACM guidance issued for PM. Regulations and guidance that address the
implementation of pre-existing NAAQS for lead are mainly provided in the following documents: (1)
"state Implementation Plans; General Preamble for the Implementation of Title I of the Clean Air Act
Amendments of 1990,"57 FR 13549, April 16, 1992, (2) "state Implementation Plans for Lead
Nonattainment Areas; Addendum to the General Preamble for the Implementation of Title I of the Clean
Air Act Amendments of 1990,"58 FR 67748, December 22, 1993, and (3) regulations listed at 40 CFR
51.117.16
In accordance with such EPA guidance, when lead cost-effectiveness information is limited for a control
measure, this document contains cost-effectiveness data for controlling PM for control measures to
glean whether the control measure might also be cost effective for controlling lead. However, it is
important to note that the cost-effectiveness for a control measure at a specific facility depends on many
factors such as the type, size and amount of emissions; the layout of the facility; control technology
specifications and several other factors. Consequently, it will not always be the case that a control
measure that is cost effective to control PM at one facility will be cost effective to control lead at the
same facility, at another facility within the same source category, or at another facility from a different
source category.
^National Ambient Air Quality Standards for Lead: Final Rule. 73 FR 66964. 67030 (Published November 12. 2008).
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3.0. OVERVIEW OF RACM DEVELOPMENT FOR THE
IMPLEMENTATION OF THE 2008 LEAD NAAQS.
This section provides an overview of RACM development for the 2008 Lead NAAQS. Section 3.1
explains why this document assesses control measures for RACM development within the context of
source categories. Section 3.2 explains why this document focuses on certain source categories -
Secondary Lead Smelting, Lead Acid Battery Manufacturing, Iron and Steel Foundries, and Iron and
Steel Mills - for RACM development. Section 3.3 provides a strategy for RACM development for
sources in source categories not focused on in this document.
3.1. Overview of RACM Development.
This document presents control measures within specific source categories because applying the RACM
criteria discussed in Section 2.117 is most conveniently analyzed and clearly presented within the context
of source categories. For example, economic feasibility of a control measure is largely determined by
the extent of adoption by sources is the same source category. Moreover, the cost-effectiveness of a
control measure is often more similar (although variable) across a certain source category. In addition,
state and federal regulations are generally written for specific source categories and, therefore, the extent
to which a control measure is adopted by state/federal regulations is most easily analyzed within the
context of source categories.
3.2. Selecting the Source Categories for which RACM Development is Focused on in this
Document.
This document focuses on four source categories for which RACM development for the 2008 Lead
NAAQS is likely to be most relevant. Some source categories do not emit lead in great enough
quantities to cause lead NAAQS exceedances. Other source categories do not have corresponding
sources in nonattainment areas with respect to lead and, therefore, no sources will be subject to the
RACM requirement. Section 3.2.1 identifies sources categories with corresponding sources in
nonattainment areas with respect to lead, and for such source categories, Section 3.2.2 provides an
assessment of how relevant RACM development would likely be for each source category. Sections 4
through 7 present control measures relevant to each of the four selected source categories and assess he
likelihood that each such control measure would constitute a RACM.
3.2.1. Identification of Lead-Emitting Sources in Nonattainment Areas with respect to the 2008 Lead
NAAOS.
The task of identifying the lead-emitting sources in nonattainment areas with respect to the 2008 Lead
NAAQS is a two-step process. First, the nonattainment areas with respect to the 2008 Lead NAAQS
must be identified. Then, the lead-emitting sources within such nonattainment areas can be identified.
In order to identify the areas of nonattainment with respect to the 2008 Lead NAAQS, EPA's Area
Designations for 2008 Lead Standards Website was reviewed.18 Specifically, the counties and specific
17(1) The economic feasibility of the control measure, as indicated by extent of adoption; (2) the capital costs, annualized
cost, and the cost effectiveness of the control measure; and (3) the extent of adoption of the control measure by state
regulations.
18EPA's Area Designations for 2008 Lead Standards Website (Accessed December. 2011).
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cities/townships that were in nonattainment were identified in the designation support documents for
19
each specific state as of December 1, 2011. Table 3-1 provides a summary of the nonattainment areas
with respect to the 2008 Lead NAAQS. Overall, there were 21 nonattainment areas within 22 counties.
Once the nonattainment areas were identified, the corresponding designation support documents were
reviewed and the lead-emitting sources (emitting > 0.10 TPY of lead) in each nonattainment area were
identified. In order to determine the corresponding source category for each source, the corresponding
North American Industry Classification System (NAICS) code and NAICS description for each source
were identified using EPA's National Emission Inventory Database.20 Table 3-2 provides a summary of
the most significant lead-emitting sources in areas of nonattainment with the 2008 Lead NAAQS, with
corresponding NAICS codes and descriptions. Table 3-2 also provides the values for emitted TPY of
lead for each facility as provided by each state in its respective designation support document, except
when indicated otherwise.
EPA's purpose in identifying the lead-emitting sources in nonattainment areas in Table 3-2 is to help
determine the source categories for which information related to RACM development will be most
useful and relevant. In preparing this draft document, EPA assumed that the source categories with the
most and largest lead-emitting sources in nonattainment areas would be the source categories for which
information on RACM development would be most useful and relevant. Therefore, this draft document
was prepared to provide more in-depth RACM development information in Sections 4 through 8 for
such source categories. However, EPA emphasizes that the list of sources identified in Table 3 -2 is not
an exhaustive list of all the lead-emitting sources in nonattainment areas. In addition, even though EPA
focused its search on sources emitting more than 0.10 TPY of lead, EPA recognizes that sources
emitting less than 0.10 TPY are might be required to install RACM pursuant to CAA §172(c)(l) and
might be significant contributors to NAAQS exceedances.
19Puerto Rico Support Document. Pennsylvania Support Document I. Pennsylvania Support Document II. Pennsylvania
Support Document III. Alabama Support Document. Tennessee Support Document. Florida Support Document. Illinois
Support Document I. Illinois Support Document II. Indiana Support Document. Michigan Support Document. Minnesota
Support Document, Ohio Support Document I. Ohio Support Document II. Ohio Support Document III, Texas Support
Document. Iowa Support Document. Kansas Support Document. Missouri Support Document I, Missouri Support
Document II, California Support Document I. (All documents represent the most recent state designation documents for the
2008 Lead NAAQS as of December, 2011).
20EPA's National Emission Inventory Database (Accessed December. 201IX
7
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Table 3-1. Nonattainment Areas with respect to the 2008 Lead NAAQS.
State
Alabama
California
Florida
Illinois
Indiana
Iowa
Kansas
Michigan
Minnesota
Missouri
Ohio
Pennsylvania
Puerto Rico
Tennessee
Texas
Total
Area Name
Troy
Los Angeles County within the South Coast Air Basin,
excluding San Clemente and Santa Catalina Islands
(Southern Los Angeles County)
Tampa
Granite City
Chicago
Muncie
Pottawattamie County
Saline County
Belding
Eagan
Iron County
Jefferson County
Bellefontaine
Cleveland
Delta
Lower Beaver Valley
Lyons
North Reading
Arecibo
Bristol
Frisco
2 1 Nonattainment Areas
County Name
Pike (partial)
Los Angeles (partial)
Hillsborough (partial)
Madison (partial)
Cook (partial)
Delaware (partial)
Pottawattamie (partial)
Saline (partial)
Ionia (partial)
Dakota (partial)
Iron (partial), Dent (partial),
Reynolds (partial)
Jefferson (partial)
Logan (partial)
Cuyahoga (partial)
Fulton (partial)
Beaver (partial)
Berks (partial)
Berks (partial)
Arecibo (partial)
Sullivan (partial)
Collin (partial)
22 partial counties (parts of Berks
County, PA in 2 areas)
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Table 3-2. Lead-emitting Sources (> 0.10 TPY) in Nonattainment Areas with the 2008 Lead NAAQS
Region
State
County
Source Name
Emissions
(TPY)
NAICS Code and Description
Secondary Lead Smelting
2
3
3
4
4
5
6
7
9
9
PR
PA
PA
AL
FL
IN
TX
MO
CA
CA
Arecibo
Berks
Berks
Pike
Hills-
borough
Delaware
Collin
Iron,
Dent,
Reynolds
LA
LA
The Battery
Recycling
Company
East Penn Manfg.
Co.
Exide Technologies
Sanders Lead
Comp.
EnviroFocus
Technologies
Exide Technologies
Exide Corp.
Buick Resources
Recycling
Exide Technologies
Quemetco Inc.
1.22
0.20
1.4421
4.44
1.30
0.81
2.0
12.1
2.00
0.32
331492
331492
331492
331492
331492
331492
331492
331492
335911
331492
Secondary Smelting, and
Alloying of Nonferrous
Metal
Lead Acid Battery Manufacturing
3
3
4
7
PA
PA
TN
KS
Berks
Berks
Sullivan
Salina
East Penn Manf.
Yuasa Battery Inc.
Exide Technologies
Exide Technologies
2.49
0.1 8""
0.78
2.17
335911
335911
335912
335912
Storage Battery Manf.
Primary Battery Manf.
Iron and Steel Foundries
5
7
7
IL
IA
KS
Madison
Potta-
wattamie
Saline
ASF-Keystone, Inc.
(Amsted Rail)
Griffin Pipe
Facility
Metlcast Products
0.1923
1.20
0.14
331513
331515
331515
Steel Foundries
Iron Foundries
Iron and Steel Mills
5
7
IL
OH
Madison
Fulton
US Steel Corp.
N. Blue-scope Steel
1.3324
0.19
33111
33111
Iron and Steel Mills
Other Source Categories25
7
MO
Jefferson
Doe Run
59.0026'27
331419
Primary Smelting and
21PA state 2008 inventory (As of December 2011).
22Id.
232008 NEI vl.5 (As of December 2011).
24Id.
25These are source categories with at least one corresponding source in a nonattainment area, which are not focused on in this
document. This document focuses on developing RACM for the following source categories: Secondary Lead Smelting, Lead
Acid Battery Manufacturing, Iron and Steel Foundries, Iron and Steel Mills
26The Regulatory Impact Analysis of the Proposed Revisions to the National Ambient Air Quality Standards for Lead
(Published October 2008). Page 7.
27EPA's purpose in identifying the lead-emitting sources in nonattainment areas in Table 3-2 is to help determine the source
categories for which information related to RACM development will be most useful and relevant. In preparing this draft
document, EPA assumed that the source categories with the most and largest lead-emitting sources in nonattainment areas
would be the source categories for which information on RACM development would be most useful and relevant. Therefore,
9
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Region
5
5
5
2
7
5
9
9
State
MN
IL
MI
PR
MO
IL
CA
CA
County
Dakota
Cook
Ionia
Arecibo
Iron,
Dent,
Reynolds
Cook
Los
Angeles
Los
Angeles
Source Name
Herculaneum
Gopher Resource
Corp.
H. Kramer &
Company
Mueller Industries
PREPA
Cambalache
Combustion
Turbine Plant
Doe Run
Company-Buick
Mill
Fisk Electric
Generating Station
BP West Coast
Products LLC
Tesoro LA
Refinery
Emissions
(TPY)
0.362S
0.122y
0.8030
0.17
0.10
0.0731
0.79
0.15
NAICS Code and Description
331314
331423
331421
221112
212231
221112
324110
324110
Refining of Nonferrous
Metal (except Copper and
Aluminum)
Secondary Smelting and
Alloying of Aluminum
Secondary Smelting,
Refining, and Alloying of
Copper
Copper Rolling, Drawing,
and Extruding
Fossil Fuel Electric Power
Generation
Lead Ore and Zinc Ore
Mining
Fossil Fuel Electric Power
Generation
Petroleum Refineries
Petroleum Refineries
3.2.2. Source Categories with Corresponding Sources in Nonattainment Areas for which RACM
Development is Likely to be Most Relevant.
RACM development is only relevant for a source category if corresponding sources from the source
category are located in nonattainment areas. For such source categories with a least one corresponding
source in a nonattainment area, we used four factors to determine which of these source categories to
include in this document for further assessment.
The first factor is the number of sources a corresponding source category has in nonattainment areas.
The more sources a corresponding source category has in nonattainment areas, the more likely that the
source category would be included in this document.
The second factor is the total annual emissions emitted from all the sources within a source category.
Specifically, higher emissions are likely to make control measures more cost effective and, therefore,
more appropriate to include in this document.
this draft document was prepared to provide more in-depth RACM development information in Sections 4 through 8 for such
source categories. However, EPA emphasizes that the list of sources identified in Table 3 -2 is not an exhaustive list of all the
lead-emitting sources in nonattainment areas. In addition, even though EPA focused its search on sources emitting more than
0.10 TPY of lead, EPA recognizes that sources emitting less than 0.10 TPY might be required to install RACM pursuant to
CAA §172(c)(l) and might be significant contributors to NAAQS exceedances.
282008 NEI vl.5 (As of December, 2011).
29Id.
30Id.
31Id.
10
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The third factor is the overall number of sources in a corresponding source category. The more sources
in a source category, the more likely that a source will be identified as being in an area classified as
nonattainment in the future and, therefore, more appropriate to include in this document.
The fourth factor is other reasons cited in designation support documents, such as if modeling indicates
that certain sources within a source category are significantly contributing to nonattainment with the
NAAQS. Specifically, control measures are more likely to be necessary for a source if emission
reductions are needed to attain the NAAQS.
Table 3.3 contains some of the information we used to decide which source categories to cover in this
document, including the overall lead emissions from each source category in TPY and the number of
sources in each source category.32
32The Regulatory Impact Analysis of the Proposed Revisions to the National Ambient Air Quality Standards for Lead
(Published October 2008). Page 7. (Unless indicated otherwise). Note that in the referenced RIA, the table lists many more
source categories and accounts for all lead emissions from stationary sources except for 7.08 % of the total national annual
lead emitted. The table was revised in this document to only list the source categories with corresponding lead-emitting
sources in nonattainment areas. In the referenced RIA, the smallest lead-emitting source category listed emitted 5 TPY of
lead. In the referenced RIA, the source categories of Petroleum Refineries and Fossil Fuel Electric Power Generation were
not listed, and therefore, the lead emissions are assumed to be less than 5 TPY.
11
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Table 3-3. Nationwide Lead Emissions from Stationary Source Categories with Corresponding
Sources in Current Nonattainment Areas.
Source Category
Iron and Steel Foundries
Primary Lead Smelting
Secondary Lead Smelting
Iron & Steel Mills
Lead Acid Battery
Manufacturing
Mining
Secondary Aluminum
Production
Secondary Copper Smelting
Petroleum Refineries
Fossil Fuel Electric Power
Generation
Annual
Emission
(Tons
Lead/Year)
83
59
44
17
17
15
9
6
<5
<5
Number of
Sources in Source
Category
600+ 33
I34
15"
18 Jb
60 3V
Undetermined
Undetermined
Undetermined
Undetermined
Undetermined
Remainder of Lead Emissions from Sources in Other Source
Categories
Relative % of Total
Emissions from Stationary
Source Categories
6.05
4.30
3.21
1.24
1.24
1.09
0.66
0.44
<0.40
<0.40
88%J"
Application of the four factors suggests that the following source categories are the most relevant for
including in this document: Secondary Lead Smelting, Lead Acid Battery Manufacturing, Iron and Steel
Mills, and Iron and Steel Foundries. The source category of Secondary Lead Smelting has the highest
number of corresponding sources in nonattainment areas, as shown in Table 3-2. Moreover, such
sources have some of the highest annual emissions of lead, with three sources each emitting four tons of
lead per year, also shown in Table 3-2. Overall, there are 15 secondary lead smelting sources in the
United States.39 However, this small number of facilities is responsible for the emission of 44 tons of
lead per year, which represents 3.21% of all lead emitted, as shown in Table 3-3. Consequently, control
measures for this source category are reviewed in this document.
33NESHAP for Iron and Steel Foundries - Background Information for Proposed Standards. Document # EPA-HQ-OAR-
2006-0359-0002 (Published December. 2002). Page 2-1 .
34Memorandum - Summary of Information Collection Request. Received from Source- Doe Run Resources Corporation.
From V. Hanzel. RTI International. To Docket. November 19. 2010.
35Memorandum -Draft Development of the RTR Emissions Dataset for the Secondary Lead Source Category. From Mike
Burr. ERG. To Chuck French of EPA/OAQPS. April 2011. Page 1.
36NESHAP for Iron and Steel Foundries - Background Information for Proposed Standards. Document # EPA-HQ-OAR-
2006-0359-0002 (Published December. 2002). Page 2-1.
37Memorandum - Lead Acid Battery Manufacturing Area Source Category Additional Information to Support Proposed Rule.
From Nancy Jones. EC/R. To U.S. EPA Docket Number EPA-HQ-OAR-2006-0897. February 28. 2007. Page 3.
38The largest-emitting source categories that make up this 88% are mobile sources (45.44%),
Industrial/Commercial/Institutional Boilers & Process Heaters (3.87%), and Hazardous Waste Incinerators (3.43%). All other
source categories have relative % of total lead emissions of less than 2%. Generally, many of the source categories that make
up this 88% were not focused on by this document because the emissions per source were too low to likely cause significant
contributions to NAAQS exceedances.
39Memorandum - Draft Development of the RTR Emissions Dataset for the Secondary Lead Smelting Source Category.
From Mike Burr. ERG. To Chuck French of EPA/OAOPS. April 2011. Page 1.
12
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The source category of Lead Acid Battery Manufacturing has the second highest number of
corresponding sources in nonattainment areas, as shown in Table 3-2. Moreover, such sources have
relatively high levels of annual lead emissions, with two sources each emitting over two tons of lead per
year, as shown in Table 3-2. Overall, there are roughly 60 lead acid battery manufacturing sources in the
United States.40 This high number of facilities is responsible for 17 tons of lead per year, which
represents 1.24% of all lead emitted, as shown in Table 3-3. Consequently, control measures for this
source category are reviewed in this document.
The source category of Iron and Steel Foundries has the third highest number of corresponding sources
in nonattainment areas, as shown in Table 3-2. Such sources have relatively moderate levels of annual
emissions of lead - only emitting less than two tons of lead per year. However, overall there are over 600
iron and steel foundries sources in the United States.41 This large number of facilities is responsible for
the emission of 83 tons of lead per year, which represents 6.05% of all lead emitted, as shown in Table
3-3. The percent of lead emissions emitted from the sources within the Iron and Steel Foundries source
category is higher than the lead emissions emitted from sources within any other one source category
with at least one corresponding source in a nonattainment area. Consequently, control measures for this
source category are reviewed in this document.
The source category of Iron and Steel Mills only has two sources in nonattainment areas, which have
relatively small annual lead emissions, as shown in Table 3-3. However, there are 18 iron and steel mill
sources in the United States.42 This number of facilities is responsible for 17 tons of lead per year, which
represents 1.24% of all lead emitted, as shown in Table 3-3. Consequently, control measures for this
source category are reviewed in this document.
Other source categories with at least some corresponding sources in nonattainment areas are not
included in this document for several reasons, including: (1) lack of a large number of corresponding
sources in nonattainment areas, or (2) a small likelihood that a source category's corresponding sources
in nonattainment areas will contribute significantly to NAAQS exceedances due to low emissions or
otherwise. Such source categories include the following: Primary Lead Smelting, Secondary Aluminum
Production, Secondary Copper Smelting, Mining, and Petroleum Refineries.
The source category of Primary Lead Smelting has only one corresponding source in a nonattainment
area, as shown in Table 3-2. Such a source currently has a very large level of annual emissions of lead,
with the one source emitting over 60 tons of lead per year, as shown in Table 3-2. However, there are no
other primary lead smelters currently operating in the United States, even though the emissions from this
one source account for 4.3% of the total lead annual emissions.43 More importantly, this one source is
being rebuilt from the ground up with state-of-the art control technology. Consequently, control
measures for this source are not reviewed in this document.
The source category of Secondary Aluminum Production has only two corresponding sources in
nonattainment areas, as shown in Table 3-2. Moreover, while one source is a fairly large emitter,
40Memorandum - Lead Acid Battery Manufacturing Area Source Category Additional Information to Support Proposed Rule.
From Nancy Jones. EC/R. To U.S. EPA Docket Number EPA-HQ-OAR-2006-0897. February 28. 2007. Page 3.
41NESHAP for Iron and Steel Foundries - Background Information for Proposed Standards. Document # EPA-HQ-OAR-
2006-0359-0002 (Published December 2002). Page 2-1.
42NESHAP for Integrated Iron and Steel Plants - Background Information for Proposed Standards. Document # EPA-453/R-
01-005. (Published January 2001). Page 2-1.
""Memorandum - Summary of Information Collection Request. Received from Source- Doe Run Resources Corporation.
From V. Hanzel. RTI International. To Docket. November 19. 2010.
13
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emitting over three tons of lead per year, the other source emits less than one ton of lead per year, as
shown in Table 3-2. Moreover, while there are a very large number (> 100) of secondary aluminum
production facilities,44 the overall annual emissions of lead from such facilities is very small - only 9
tons of lead per year. This is less than one percent of the total annual lead emitted from all source
categories, as shown in Table 3-3. Consequently, control measures for this source category are not
reviewed in this document.
The source category related to Secondary Copper Production has only two corresponding sources in
nonattainment areas, as shown in Table 3-2. Both facilities emit under one ton of lead per year each, as
shown in Table 3-2.45 Moreover, such facilities account for a less than one percent of the overall annual
lead emissions (6 tons, or less than 0.6%). Consequently, control measures for this source category are
not reviewed in this document.
The source category of Petroleum Refineries has only two corresponding sources in nonattainment
areas, as shown in Table 3-2. Moreover, both facilities emit well under one ton of lead per year each, as
shown in Table 3-2. While the total number of facilities in the source category was not determined, the
annual emissions from all facilities in the source category are very small, not even registering in Table
3-3. Furthermore, the designation support document for the corresponding nonattainment county
indicates that a secondary lead smelter in the county is responsible for the elevated lead concentrations,
and not the petroleum refineries listed.46 Consequently, control measures for this source category are not
reviewed in this document.
The source category of Fossil Fuel Electric Power Generation has only one corresponding source in a
nonattainment area, as shown in Table 3-2. Moreover, the emissions from this source are less than 0.5
TPY, as shown in Table 3-2. While the number of facilities in the source category was not determined,
the annual emissions from all facilities in the source category are very small, not even registering in
Table 3-3. Consequently, control measures for this source category are not reviewed in this document.
The source category of Mining has only one corresponding source in a nonattainment area, as shown in
Table 3-2. Moreover, the emissions from this source are less than 0.5 TPY. While the number of mining
facilities was not determined, the annual emissions from all mining facilities are only about 1 percent, as
shown in Table 3-3. Consequently, control measures for this source are not reviewed in this document.
3.3. Strategy for Developing RACM for Source Categories not Focused on in this Document.
Most sources that will be required to implement RACM will be in the source categories focused on by
this document - Secondary Lead Smelting, Lead Acid Battery Manufacturing, Iron and Steel Foundries,
and Iron and Steel Mills. However, there might be some sources in other source categories that will be
required to implement RACM for controlling lead emissions.
For source categories not focused on by this document states can begin to determine what constitutes
RACM accordingly. First, states can begin developing RACM by using EPA's CoST database. A review
of all stationary source categories was conducted to determine the control measures typically used to
44List of Sources Subject to the Secondary Aluminum Production MACT Standard. EPA.
45Current Status of Secondary Copper Production Facilities in the United States. Document # EPA-HQ-OAR-2006-0510-
0008 (Published March 31. 2006).
46California Designation Support Document I. (Most recent state designation document for 2008 Lead NAAQS as of
December, 2011).
14
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control lead emissions. Specifically, EPA's CoST database contains the most cost effective control
technologies typically used to control PM process emissions and, therefore, likely lead process
emissions, including fabric filters (e.g., reverse air, mechanical shaker, pulse jet), scrubbers (e.g.,
impingement and Venturi) and electrostatic precipitators (e.g., wet and dry). The database contains the
most cost effective control technologies typically used to control PM fugitive dust emissions, including
paving unpaved roads, chemically stabilizing unpaved roads, and vacuum sweeping paved roads.47
In addition, states can glean information from the control measure information for the source categories
focused on in this document. States might analyze the three RACM factors for its corresponding source
category to see how they compare to the control measures for source categories focused on in this
document. As an example, suppose a state is determining how likely a particular control measure is
RACM for a hypothetical source category. Suppose that the extent of adoption of the control measure in
the hypothetical source category is as widespread as the extent of the adoption of the control measure in
the Secondary Lead Smelting source category. Further, suppose that the cost effectiveness of the control
measure for sources in the hypothetical source category is similar to the cost effectiveness of the control
measure for sources in the Secondary Lead Smelting source category. Also suppose that the control
measure has been adopted by state regulations pertaining to the hypothetical source category to a similar
extent that the control measure has been adopted by state regulations pertaining to the Secondary Lead
Smelting source category. In this situation, the control measure is as likely to be a RACM for the
hypothetical source category as it is likely to be RACM for the Secondary Lead Smelting source
category.
States can also search other sources of information on how the RACM criteria apply to various possible
control measures for controlling lead emissions. With respect to the first two RACM factors - the
economic feasibility of the control measures (as indicated by extent of adoption by other sources in
source category) and the cost effectiveness of the control measures - information related to such factors
can be found in support documents located in the dockets of related MACT standard development.
Information related to the third RACM factor - extent of adoption by state regulations-can be obtained
through state environmental agencies.
In addition, it is important to note that, while not all sources will be covered by the four source
categories focused on by this document, many of the sources in source categories not focused on in this
document may have implemented corresponding RACM in order to comply with other federal or state
regulations. For instance, the controls required by MACT standards for sources in the Fossil Fuel
Electric Power Generation and Petroleum Refinery source categories may be RACM.
47EPA CoST database.
15
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4.0. RACM DEVELOPMENT FOR THE SECONDARY LEAD
SMELTING SOURCE CATEGORY.
This section presents control measures to consider for RACM development for the Secondary Lead
Smelting source category. Section 4.1 provides an overview of the Secondary Lead Smelting source
category. Section 4.2 provides a summary of the operations and lead emission points with respect to
secondary lead smelting facilities. Section 4.3 provides a summary of the control measures utilized at
secondary lead smelting facilities, and Section 4.4 provides a more detailed application of the RACM
criteria to each identified control measure.
4.1. Overview of Source Category.
The Secondary Lead Smelting source category includes any facility at which lead-bearing scrap
material, primarily, but not limited to, lead acid batteries, is recycled into elemental lead or lead alloys
by smelting.48 The corresponding NAICS Code for the Secondary Lead Smelting source category is
331492. The NAICS description for facilities with such NAICS code is "establishments primarily
engaged in alloying purchased nonferrous metals and/or recovering nonferrous metals from scrap." The
NAICS description specifically includes establishments engaged in "lead recovering from scrap and/or
alloying purchased metals."49
As of March, 2012, there are 15 secondary lead smelting facilities in the United States. No new
secondary lead smelters have been built in the last 20 years. However, one facility is currently in the
process of expanding its operations.50 Another facility is currently under construction in South
Carolina.51
4.2. Facility Operations and Lead Emission Points.
The secondary lead smelting process consists of pre-processing lead-bearing materials, melting lead
metal and reducing lead compounds of lead metal in the smelting furnace, and refining and alloying lead
to customer specifications. There are three types of emissions from secondary lead smelting facilities:
process emissions, process fugitive emissions, and fugitive dust emissions. Each type of emissions has
its own corresponding control measures.52
Process emissions include exhaust gases from feed dryers and from blast, reverberatory, rotary, and
electric-melting furnaces. While such emissions include some organic compounds, process emissions
are mostly metal, primarily lead compounds. Such emissions are released from a stack directly into the
atmosphere. The control measures used to control such process emissions are fabric filters, wet
electrostatic precipitators (WESPs), and cartridge controls.53
48Memorandum - Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category. From Mike
Burr. ERG, to Chuck French. EPA/OAQPS. April 2011. Page 2.
North American Industry Classification System Website (Accessed December. 2011).
49-
50Memorandum - Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category. From Mike
Burr. ERG, to Chuck French. EPA/OAOPS. April 2011. Page 2.
^Correspondence with Nathan Topham of EPA/RTP (December, 2011).
52Id at 2.
53Id
16
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Process fugitive emissions are released from various sources throughout the smelting process, including
smelting furnace charging and tapping points, refining kettles, agglomerating furnace product taps, and
kiln transition equipment. Process fugitive emissions are comprised primarily of metal emissions, such
as lead.54 The control measures used to control such emissions include partial and total enclosures,
which may or may not be maintained under negative pressure.
Fugitive dust emissions are another type of emissions from secondary lead smelting facilities. Such
emissions are not associated with a specific process or process fugitive vent or stack. Fugitive dust
emissions are comprised of metal emissions, such as lead, and result from the entrainment of emissions
in ambient air due to material handling activities, vehicle traffic, wind, and other activities.55 The control
measures used to control such emissions include paving unpaved roads, vacuuming paved roads, and
chemical stabilization of paved roads.
4.3. Identification and Summary of Possible RACM Candidates.
Table 4-2 provides a summary of control measures for which the RACM criteria are applied and the
relative likelihood that each control measure is a RACM. Specifically, each control measure is assigned
a rating of 1 through 3; where the higher the number, the more likely that the control measure is a
RACM. Table 4-1 provides an explanation of these assigned values.
Table 4-1. General Meanings of Assigned RACM Ratings.
RACM
Rating
1
2
3
U
(+ or -)
General Meaning of RACM Rating
There is limited support for identifying the control measure as a RACM.
There is some support for identifying the control measure as a RACM; more than for a control measure
with a RACM Rating of "1."
There is substantial support for identifying the control measure as a RACM.
A "U" indicates that the likelihood that the control measure constitutes a RACM is undetermined due to
incomplete information. A corresponding "+" indicates that despite incomplete information, an
application of RACM criteria would likely suggest that the control measure is a RACM, while a "-"
indicates that despite incomplete information, an application of the RACM criteria would likely suggest
that the control measure is not a RACM.
54Id
55Id.
17
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Table 4-2. Secondary Lead Smelting Source Category - Summary of Known Control Measures
and Relative Likelihood that each Control Measure is a RACM.
RACM
Rating
Control Measure
Brief Reasoning for RACM Rating
Fabric filters controlling uncontrolled
lead process emissions from stacks.
1. Adoption by almost all sources.
2. Cost data suggest cost effective.
OO
3. Identified as MACT for almost 14 years.
4. California's South Coast Air Quality
Management District (SCAQMD) adopted a rule
practically requiring such a control measure; it
requires that filter media other than filter bags
are to be rated by the manufacturer of achieving
99.97% capture efficiency for 0.3 micron
particles.
1.5
Fabric filters with downstream add-on
control devices controlling uncontrolled
lead process emissions from stacks.
1. Adoption by 1 of 14 sources and plans to
adopt by two other sources.
2. Cost data suggest not cost effective.
3. Not required by any known federal regulation.
Replacing old fabric filters controlling
uncontrolled lead process emissions
from stacks with new fabric filters.
1. No known adoption.
2. Cost data suggest not cost effective.
3. Not required by any known federal regulation.
4. California's SCAQMD adopted a rule that
might practically require such a control measure;
it requires that filter media other than filter bags
are to be rated by the manufacturer of achieving
99.97% capture efficiency for 0.3 micron
particles.
U +
Other control measures for process
emissions from fabric filters: (1)
switching bag types, (2) properly
installing bags, (3) sealing ducts and
dust conveyance devices, (4) replacing
and not repairing torn bags.
1. Not enough information to apply RACM
criteria.
2. California's SCAQMD adopted a rule that
might practically require such a control measure;
it requires that filter media other than filter bags
are to be rated by the manufacturer of achieving
99.97% capture efficiency for 0.3 micron
particles.
Enclosure hoods and partial enclosures
with wet suppression for process units
and storage areas to capture process
fugitive emissions.
1. Adoption by all sources, and exceeded by a
supermajority of sources.
2. No known cost data.
3. Identified as MACT for almost 14 years.
4. California's SCAQMD adopted a rule that
requires total enclosures for many areas and
operations.
In addition to enclosure hoods, a
combination of negative pressure total
enclosures and partial enclosures with
wet suppressions for process units and
storage areas to capture fugitive
emissions.
1. Adoption by 11 of 14 sources.
2. No known cost data.
3. Required by 2012 NESHAP for secondary
lead smelters.
4. California's SCAQMD adopted a rule that
requires total enclosures under negative pressure
for many areas/operations.
18
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RACM
Rating
Control Measure
Brief Reasoning for RACM Rating
In addition to enclosure hoods, negative
pressure total enclosures for all process
units and storage areas to capture
process fugitive emissions.
1. Adoption by 7 of 14 sources.
2. No known cost data.
3. Not required by any known federal
regulations.
4. California's SCAQMD adopted a rule that
requires total enclosures under negative pressure
for many areas/operations, and the 2012
NESHAP for secondary lead smelting requires
such controls.
Paving unpaved roads and cleaning
paved roads for controlling fugitive dust
sources.
1. Adoption by all sources.
2. Cost data suggest cost effective.
3. Identified as MACT for almost 14 years.
4. Required by California's SCAQMD rule as
this rule requires cleaning surfaces subject to
vehicular traffic and paving facility ground
subject to traffic.
Partial enclosure, wet suppression, and
pavement cleaning of operating areas
and storage piles; totally enclosing
operating areas and storage piles; and
vehicle washing at each facility exit to
control fugitive dust lead emissions.
1. Adoption by all sources.
2. No known cost data available.
3. Identified as MACT for almost 14 years.
4. Required by rule adopted by California's
SCAQMD. Rule requires several such measures
including requiring dust-forming material to be
stored in enclosure, washing/vacuuming
surfaces accumulating lead-containing dust, etc.
U
Other control measures for controlling
fugitive dust emissions: more complete
vehicle washing inside buildings,
improved roadway cleaning techniques,
pavement of entire facility, cleaning of
building and roofs, etc.
1. Seven of 14 facilities adopted a combination
of such control measures, and, generally,
emissions from such facilities were lower.
2. California's SCAQMD rule requires several
such control measures.
3. The 2012 NESHAP for secondary lead
smelting requires many such control measures.
4.4. Application of RACM Criteria to Possible RACM Candidates.
4.4.1. Fabric Filters (or other Primary Controls) Controlling Uncontrolled Lead Emissions from Stacks.
The common use of fabric filters by secondary lead smelters suggests that fabric filters are the most
economically feasible control technologies for regulating process lead emissions from stacks. A 2011
review of information collection request responses from secondary lead smelters revealed that almost all
(if not all) secondary lead smelters use fabric filters to control uncontrolled PM (including lead)
emissions from stacks. Several types of fabric filters are used by the industry, including shaker, pulse jet,
and reverse pulse jet fabric filters.56
In addition, the available data suggest that fabric filters are cost effective for regulating process lead
emissions. Specifically, cost-effectiveness information for PM was available for selected control
technologies in the source category of Lead Processing, as shown in Table 4-3, where cost-effectiveness
6Id at 4.
19
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values for fabric filters are on average roughly $400/ton.57 This information suggests that fabric filters
are cost effective for regulating lead as well.
Table 4-3. Cost-Effectiveness Information for Selected Control Technologies for Controlling
Particulate Matter for the Lead Processing Source Category.
Control Technology
Dry Electrostatic Precipitator - Wire Plate Type
Fabric Filter - Reverse- Air Cleaned Type
Fabric Filter (Mech. Shaker Type)
WESP - Wire Plate Type
Cost Effectiveness*
($/ton PM)
400
500
450
800
Low/High Control
Efficiency
95/98
99/99.5
99/99.5
99/99.5
* Rounded to the nearest $50 and escalated from 1999 to 2011 U.S. dollars.^
The 1997 NESHAP for Secondary Lead Smelting suggests that such fabric filters are reasonably
available. Specifically, the 1997 NESHAP applies to process emissions from the following furnace
configurations: collated blast and reverberatory furnace; blast furnace; and reverberatory, rotary and
electric furnaces. The 1997 NESHAP provides an emissions limit for lead compounds of 2.0 milligrams
per dry standard cubic meter (mg/dscm) from each such furnace configuration. Such a standard does not
explicitly require a control, such as a fabric filter, but such a control is practically required in order to
comply with the emission limit. The fact that such controls were MACT 14 years ago, and have been
required by all currently operating sources for at least 11 years, suggests that such controls may be
RACM today.59
A review of state rules from California and Missouri further suggests that such control measures are
reasonably available. These states were chosen for review because they both have secondary lead
sources (2 in each state) within their states. Missouri incorporates the federal 1997 NESHAP into state
law.60 California's SCAQMD adopted a rule practically requiring such a control measure adopted a rule
that might practically require such a control measure; it requires that filter media other than filter bags
are to be rated by the manufacturer of achieving 99.97% capture efficiency for 0.3 micron particles.61
4.4.2. Fabric Filters (or other Primary Controls) Controlling Uncontrolled Lead Emissions with Add-on
Downstream Control Technologies.
The current use of add-on control technologies, such as WESP and high efficiency particulate air
(HEPA) filters, downstream of fabric filters (or other primary controls) to further reduce lead emissions
from stacks suggests that such add-on control technologies are less economically feasible but are
becoming more economically feasible. Specifically, while only one secondary lead smelting facility uses
a WESP as an add-on control to a fabric filter, two other facilities currently have plans to install WESP
57EPA CoST database.
58In order to escalate from 1999 dollars to 2011 dollars, used the formula and approach presented in EPA's Control Strategy
Tool (CoST) Control Measures Database (CMDB) Documentation. Page 9.
59NESHAP for Secondary Lead Smelting. 40 CFR 63. Subpart X (Published June 13. 1997).
6010 CSR 10-6.075 Maximum Achievable Control Technology Regulations: Air Quality Standards. Definitions. Sampling.
and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri. (Published August 16. 1977).
Page 91.
61 California (South Coast Air Quality Management District). Rule 1420.1 - Emission Standards for Lead from Large Lead
Acid Battery Recycling Facilities (Adopted November 5. 2010).
20
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units to be used as add-on controls to fabric filters. Several facilities also reported using HEPA filters as
add-on controls downstream of their fabric filters.62
However, the available data suggest that using add-on control technologies downstream of fabric filters
is much less cost effective for controlling lead than the cost effectiveness of the primary control.
Specifically, installing an add-on control technology, such as a WESP, downstream of the primary
control would double the control technology costs. Moreover, because fabric filters can achieve
efficiencies of greater than 99%, the amount of further lead emissions captured is relatively low
compared to the amount captured with a fabric filter controlling uncontrolled emissions. In fact, one
recent estimate of the cost effectiveness of an add-on WESP at a secondary lead smelting facility in
Quemetco, California, revealed that the cost effectiveness of the add-on WESP would be $295,900/ton
PM (and $2,279,500/ton of lead)63. Thus using a WESP as an add-on control can be over 250 times less
cost effective than using a WESP as a primary control. There is no known federal standard currently
requiring such a control measure.
There is no known federal standard currently requiring such a control measure. However, California's
SCAQMD, which has two sources, adopted a rule that practically requires such a control measure by
requiring 99.97% capture efficiency for 0.3 micron particles.64
4.4.3. Replacing Old Fabric Filters Controlling Uncontrolled Lead Emissions from Stacks with New
Fabric Filters.
A recent comparison of fabric filter outlet lead emissions revealed that the controlling factor determining
the effectiveness of the fabric filter was the age of the fabric filter. Generally, older fabric filters have
higher outlet lead emissions, while newer fabric filters have lower outlet emissions. The average outlet
lead concentration for lead emissions for fabric filters installed in the 1960s is roughly 0.40 mg/dscm, in
the 1970s roughly 0.30 mg/dscm, in the 1980s roughly 0.20 mg/dscm, and in the 2000s less than 0.10
mg/dscm. Consequently, one possible control measure would be to replace old fabric filters with new
fabric filters, as on average, this could reduce lead emissions by a factor of four or more.65
Similarly, a recent comparison of fabric filter outlet lead emissions also revealed that another factor that
determines the effectiveness of the fabric filter is the type of fabric filter (e.g., shaker, pulse jet, reverse
bag pulse jet). Specifically, shaker fabric filters appear to have higher outlet lead concentrations than
those of the pulse jet or reverse bag pulse jet type. However, this finding may be misleading because the
majority of the older units appear to be shaker types.66
There is no known federal standard currently requiring old fabric filters to be replaced by higher
efficiency types. A review of state rules from California and Missouri weakly suggests that such control
measures might be within economic reach. Such states were chosen for review because they both have
secondary lead sources (2 in each state) within their states. Missouri incorporates the federal 1997
NESHAP into state law, which does not require such a measure.67 However, California's SCAQMD,
62Memorandum - Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category. From Mike
Burr. ERG, to Chuck French. EPA/OAQPS. April 2011. Page 4.
63Cost estimate provided by Nathan Topham/EPA/OAQPS/SPPD/MIG.
64California (South Coast Air Quality Management District). Rule 1420.1 - Emission Standards for Lead from Large Lead
Acid Battery Recycling Facilities (Adopted November 5. 2010).
65Id at 7.
66Id
67AirlO CSR 10-6.075 Maximum Achievable Control Technology Regulations: Air Quality Standards. Definitions.
21
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which has two sources, adopted a rule that might practically require such a control measure; it requires
that filter media other than filter bags are to be rated by the manufacturer of achieving 99.97% capture
efficiency for 0.3 micron particles.68
4.4.4. Other Control Measures for Controlling Process Lead Emissions.
One company in the industry has suggested that Teflon (polytetrafluoroethylene) bags specifically
supplied by Gore-Tex© performed better than other bag types, such as polyester. The company also
suggested that the most critical factors influencing fabric filter performance are proper installation and
maintenance practices. The company mentioned specific practices such as ensuring proper installation of
the bags and properly sealing all ducts and dust conveyance devices help increase control efficiency.
Additionally, the company claimed that replacing torn bags, rather than repairing them, can significantly
improve fabric filter performance. However, while such control measures might be utilized, information
is not available for a RACM criteria analysis.69
4.4.5. Partial and Total Enclosures to Control Fugitive Process Lead Emissions.
The complete adoption of partial and total enclosures by secondary lead smelters to control fugitive
process emissions suggests that partial and total enclosures are economically feasible control measures.
Specifically, all secondary lead smelting facilities currently use partial and total enclosures to control
process fugitive emissions from the following emission sources: smelting furnace and dryer charging
hoppers, chutes, and skip hoists; smelting furnace lead taps, and molds during tapping; smelting furnace
slag taps, and molds during tapping; refining kettles; dryer transition pieces; and agglomerating furnace
product taps. All secondary lead smelters equip such fugitive emission sources with an enclosure hood
or locate such sources in a total enclosure subject to general ventilation that maintains the building at a
lower than ambient pressure to ensure in-draft through any doorway opening accordingly. All process
fugitive hoods (except for refining kettles and dryer transition pieces) are ventilated to ensure a face
velocity of at least 90 meters per minute at all hood openings. Process fugitive hoods for refining kettles
are ventilated to maintain a face velocity of at least 75 meters per minute. Process fugitive hoods for
dryer transition pieces are ventilated to maintain a face velocity of at least 110 meters per minute. Such
ventilation air is conveyed to a controlled device. 70 No cost-effectiveness information was available for
such control measures.
The 1997 NESHAP for Secondary Lead Smelting requires such partial and total enclosure control
measures for fugitive process lead emissions. The fact that such controls were MACT 14 years ago, and
have been required by all currently operating sources for 11 years, suggests such controls are RACM
today.71
A review of state rules from California and Missouri further suggests that such control measures are
reasonable. Such states were chosen for review because they both have secondary lead sources (2 in
Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August
16. 1977). Page 91.
68California (South Coast Air Quality Management District). Rule 1420.1 - Emission Standards for Lead from Large Lead
Acid Battery Recycling Facilities (Adopted November 5. 2010).
69Memorandum - Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category. From Mike
Burr. ERG, to Chuck French. EPA/OAOPS. April 2011. Page 7.
70Idatll.
71NESHAP for Secondary Lead Smelting. 40 CFR 63. Subpart X (Published June 13. 1997).
22
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each state) located within the state. Missouri incorporates the federal 1997 NESHAP into state law.72
California's SCAQMD adopted a rule that requires total enclosure of several areas (e.g., battery
breaking areas; materials storage and handling areas; dryer and dryer areas; smelting furnaces;
agglomerating furnaces; and refining and casting areas).
4.4.6. In Addition to Enclosure Hoods, a Combination of Negative Pressure Total Enclosures and Partial
Enclosures with Wet Suppression for Process Units and Storage Areas.
The common use of, in addition to enclosure hoods, a combination of negative pressure total enclosures
and partial enclosures with wet suppression for process units and storage areas, suggests these additional
control measures are economically feasible. Specifically, 12 of the 14 secondary lead smelting facilities
use a combination of negative pressure total enclosures and partial enclosures with wet suppression for
process units and storage areas in addition to enclosures hoods. Additionally, half of the secondary lead
smelting facilities, in addition to enclosure hoods for process fugitive sources, use negative pressure
total enclosures for all process units and storage areas.73 No cost-effectiveness information was available
for such control measures.74
There is no identified federal standard currently requiring such a control measure. However, California
requires negative pressure total enclosures for several areas (e.g., battery breaking areas; materials
storage and handling areas; dryer and dryer areas; smelting furnaces; agglomerating furnaces; and
refining and casting areas).75 Also, the 2012 NESHAP for Secondary Lead Smelting requires facilities to
locate and control sources of fugitive lead emissions within total enclosures that are maintained under
negative pressure and vented to a control device.76 These emissions sources include the smelting
furnaces; smelting furnace charging areas; lead taps; slag taps; molds during tapping; battery breakers,
refining kettles; casting areas; dryerts; material handling areas; and areas where dust from fabric filters,
sweepings, or used fabric filters are processed.
4.4.7. Paving Unpaved Roads and Cleaning Paved Roads for Controlling Fugitive Dust Lead Emissions.
The common practice of paving plant roadways, including all areas subject to vehicle traffic - and
cleaning such pavement twice per day, except when natural precipitation makes cleaning unnecessary or
when sand or similar material has been spread on plant roadways to provide traction on ice and snow,
suggest that such practice is economically feasible. Specifically, all secondary smelting facilities have
adopted such practices.77
In addition, available data suggest that such control measures are cost effective for controlling lead
emissions. Specifically, cost-effectiveness information was available for the control measures in the
source category of Lead Processing for PM in 2010 dollars, as shown in Table 4-3, where cost-
72AirlO CSR 10-6.075 Maximum Achievable Control Technology Regulations: Air Quality Standards. Definitions.
Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August
16. 1977). Page 91.
73Memorandum - Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category. From Mike
Burr. ERG, to Chuck French. EPA/OAQPS. April 2011. Page 11.
74Id.atll.
75California (South Coast Air Quality Management District). Rule 1420.1 - Emission Standards for Lead from Large Lead
Acid Battery Recycling Facilities (Adopted November 5. 2010).
76NESHAP for Secondary Lead Smelting (Published January. 2012).
77Memorandum - Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category. From Mike
Burr. ERG, to Chuck French. EPA/OAOPS. April 2011. Page 11.
23
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effectiveness values for such measures were on average roughly $500/ton.78 Since lead is commonly
associated with PM, this information suggests that such control measures are cost effective for
controlling lead as well.
Table 4-4. Cost-Effectiveness Information for Selected Control Measures for Controlling
Particulate Matter with respect to All Source Categories.
Control Measure
Vacuum Sweeping Paved Roads
Hot Asphalt Paving of Unpaved Roads
Cost Effectiveness*
($/ton PM)
500
800
Control Efficiency
(%)
50.0
66.6
* Rounded to the nearest $100 and escalated from 1999 to 201 1 U.S. dollars. /y
A review of state rules from California and Missouri suggests such control measures reasonable. Such
states were chosen for review because they both have secondary lead sources (2 in each state) within the
state. Missouri incorporates the federal 2007 NESHAP into state law, which only requires such control
measures for major sources.80 A California's SCAQMD rule requires paving facility grounds and daily
cleaning/sweeping of such paved surfaces.81
4.4.8. Partially Enclosing , Wet Suppressing, and Pavement Cleaning of Operating Areas and Storage
Piles: Totally Enclosing of Operating Areas and Storage Piles: and Vehicle Washing at each
Facility Exit to Control Fugitive Dust Lead Emissions.
The common practices of (1) partially enclosing, wet suppressing, and pavement cleaning of operating
areas and storage piles, (2) totally enclosing operating areas and storage piles, and (3) vehicle washing at
each facility exit to control fugitive dust lead emissions suggests that such practices are economically
feasible. All secondary lead smelting facilities have adopted such practices. Specifically, for battery
breaking areas, all secondary lead smelting facilities partially enclose storage piles, wet suppress storage
piles with sufficient frequency and quantity to prevent the formation of dust, and clean the pavement of
such areas twice per day; or alternatively, totally enclose the battery breaking area. For furnace areas, all
secondary lead smelting facilities partially enclose such areas and clean the pavement of such areas
twice per day, or alternatively, totally enclose and ventilate the enclosed areas to a control device. For
refining and casting areas, all secondary lead smelting facilities partially enclose and clean the pavement
of such areas twice per day; or alternatively, totally enclose and ventilate such areas to a control device.
For material and storage handling areas, all secondary lead smelting facilities partially enclose such
areas, wet suppress the storage piles with sufficient frequency and quantity to prevent the formation of
dust, wash vehicles at each exit from the such areas, and pave such areas; or alternatively, totally enclose
such areas and ventilate to a control device. Moreover all facilities wash vehicles at the exits of facility
property.82
78EPA CoST database.
79In order to escalate from 1999 dollars to 2011 dollars, used the formula and approach presented in EPA's Control Strategy
Tool (CoST) Control Measures Database (CMDB) Documentation. Page 9.
80AirlO CSR 10-6.075 Maximum Achievable Control Technology Regulations: Air Quality Standards. Definitions.
Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August
16. 19771. Page 91.
81 California (South Coast Air Quality Management District). Rule 1420.1 - Emission Standards for Lead from Large Lead
Acid Battery Recycling Facilities (Adopted November 5. 2010).
82Memorandum - Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category. From Mike
Burr. ERG, to Chuck French. EPA/OAOPS. April 2011. Page 11.
24
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No cost-effectiveness information is available for such practices. The 1997 NESHAP for Secondary
Lead Smelting requires such control measures for controlling fugitive dust process lead emissions. The
old NESHAP was published June 1997. The fact that such controls were MACT 14 years ago, and have
been required by all currently operating sources for 15 years, suggests such controls are RACM today.83
The 2012 NESHAP requires the total enclosure under negative pressure with ventilation to a control
device of process areas that are sources of fugitive lead emissions. The 2012 NESHAP also requires
facilities to adopt a list of specified work practice standards to minimize fugitive emissions, including
wet suppression, pavement cleaning, and vehicle washing at facility exits.84
A review of state rules from California and Missouri suggests such control measures are reasonable.
Such states were chosen for review because they both have secondary lead sources (2 in each state)
within the state. Missouri incorporates the federal 1997 NESHAP into state law, which only requires
such a control measure for major sources.85 California's SCAQMD rule requires such control measures
and is even more stringent.86
4.4.9. Other Control Measures for Controlling Fugitive Dust Emissions.
A recent review revealed that, generally, facilities that adopted the following additional fugitive dust
emissions controls had lower fugitive dust emissions:
1. More complete vehicle washing inside buildings.
2. Improved roadway cleaning techniques and frequency.
3. Pavement of entire facility grounds.
4. Cleaning of building roofs and exteriors.
5. Use of daily ambient monitoring to diagnose plant activities that lead to exceedances of the
NAAQS for lead.
6. Timely cleaning of accidental releases.
7. Inspection of outside battery storage areas for broken batteries.87
Moreover, California's SCAQMD adopted a rule that requires several such control measures for
controlling fugitive dust emissions, which include the following:
1. Clean rooftop structures and other areas where lead-containing waste generated from
housekeeping activities are stored, disposed of, recovered, or recycled by wet wash or vacuum
equipped with a filter rated by the manufacturer to achieve 99.97% capture efficiency for 0.3
micron particles in a manner that does not generate fugitive lead dust (monthly or quarterly,
depending on the height of the roof).
2. Monthly inspection of total enclosures and facility structures that contain fugitive dust emissions
for gaps, breaks, separations, leak points, etc.
3. Pave, concrete, asphalt or encapsulate certain facility grounds.
83NESHAP for Secondary Lead Smelting. 40 CFR 63. Subpart X (Published June. 1997).
84NESHAP for Secondary Lead Smelting (Published January. 2012).
85AirlO CSR 10-6.075 Maximum Achievable Control Technology Regulations: Air Quality Standards. Definitions.
Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August
16. 19771. Page 91.
86California (South Coast Air Quality Management District). Rule 1420.1 - Emission Standards for Lead from Large Lead
Acid Battery Recycling Facilities (Adopted November 5. 2010).
87Memorandum - Draft Summary of the Technology Review for the Secondary Lead Smelting Source Category. From Mike
Burr. ERG, to Chuck French. EPA/OAOPS. April 2011. Page 11.
25
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4. Storing all materials capable of generating any amount of fugitive lead-dust in a sealed, leak-
proof container.88
In addition, the 2012 NESHAP for Secondary Lead Smelting requires many such control measures for
controlling fugitive emissions to be installed by January 2014. Sources that will be subject to the
NESHAP must prepare an operating procedures manual that describes in detail the work practice
standards that will be put in place and implemented to control fugitive dust emissions from plant
roadways, plant buildings, plant building exteriors, accidental releases, battery storage areas, equipment
maintenance areas, material storage areas and material handling areas. Specifically, the proposed
NESHAP would require the following fugitive dust control measures to be included in the operating
procedures manual:
1. Cleaning certain areas by wet wash or a vacuum equipped with a filter rated by the manufacturer
to achieve 99.97 percent capture efficiency for 0.3 micron particles.
2. Paving all areas subject to vehicle traffic and cleaning such pavement twice per day.
3. Monthly or quarterly cleaning of building roofs and exteriors, depending on the height of such
roofs and exteriors.
4. Initiating cleaning of affected areas within one hour after any accidental release of lead dust.
5. Inspection of unenclosed battery storage areas twice each day.
6. Washing of vehicles at each exit of the material storage and handling areas.
7. Paving grounds on the facility sufficient to prevent wind-blown dust.89
California (South Coast Air Quality Management District). Rule 1420.1 - Emission Standards for Lead from Large Lead
Acid Battery Recycling Facilities (Adopted November 5. 2010).
89NESHAP for Secondary Lead Smelting (Published January. 2012).
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5.0. RACM DEVELOPMENT FOR THE LEAD ACID BATTERY
MANUFACTURING SOURCE CATEGORY.
This section presents control measures to consider for RACM development for the Lead Acid Battery
Manufacturing source category. Section 5.1 provides an overview of the Lead Acid Battery source
category. Section 5.2 provides a summary of operations and lead emission points for lead acid battery
facilities. Section 5.3 provides a summary of the control measures utilized at lead acid battery
manufacturing facilities, and Section 5.4 provides a more detailed application of the RACM criteria to
each identified control measure.
5.1. Overview of Source Category.
The Lead Acid Battery Manufacturing source category includes any facility that manufactures either
starting lighting/ignition batteries that are primarily used in automobiles or industrial/traction batteries
that are used for uninterruptible power supply or to power electric vehicles such as forklifts.90 The
corresponding NAICS code for the Lead Acid Battery Manufacturing source category is 335911. The
NAICS Description for facilities with such NAICS Code is "establishments primarily engaged in
manufacturing primary batteries." The NAICS description specifically includes "lead acid storage
batteries manufacturing."91
Today, there are approximately 60 lead acid battery manufacturing facilities in the United States, all of
which are area sources. Such facilities are located throughout 23 states and Puerto Rico.92
5.2. Facility Operations and Lead Emission Points.
Lead acid batteries are produced from lead alloy ingots, sheet lead, and lead oxide. Lead acid battery
manufacturing consists of several processes, including the following: (1) grid casting, (2) grid stamping,
lead paste mixing, (3) the three-process operation of plate stacking, plate burning and plate assembly, (4)
charge formation, and (5) lead reclamation.93
Specifically, the manufacturing process includes preparing battery grids through stamping or casting
lead. Lead oxide paste is added to the grids in the grid pasting operation creating plates that are cured
and assembled into a battery. Batteries are then charged using sulfuric acid in the forming operations.
Lead oxide may be prepared by the battery manufacturer, as is the case for many larger battery
manufacturing facilities, or may be purchased from a supplier. The control measures that are used to
control such process emissions are fabric filters for the paste mixing, three-process plate operation, lead
oxide manufacturing, and other lead emitting processes; and impingement scrubbers for the grid casting
and lead reclamation operations.94
90Memorandum - Lead Acid Battery Manufacturing Area Source Category Additional Information to Support Proposed Rule.
From Nancy Jones. EC/R. To U.S. EPA Docket Number EPA-HQ-OAR-2006-0897. February 28. 2007. Page 1.
91 North American Industry Classification System Website (Accessed December. 2011).
92Memorandum - Lead Acid Battery Manufacturing Area Source Category Additional Information to Support Proposed Rule.
From Nancy Jones. EC/R. To U.S. EPA Docket Number EPA-HQ-OAR-2006-0897. February 28. 2007. Page 1.
93Idatl.
94Idat2.
27
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5.3. Identification and Summary of Possible RACM Candidates.
Table 5-2 provides a summary of control measures used in the Lead Acid Battery source category for
which the RACM criteria are applied in section 5.4 and the relative likelihood that each control measure
is a RACM. Specifically, each control measure is assigned a rating of 1 through 3; where the higher the
number, the more likely that the control measure is a RACM. Such assigned values are explained in
Table 5-1.
Table 5-1. General Meanings of Assigned RACM Ratings.
RACM
Rating
1
2
3
U
(+ or -)
General Meaning of RACM Rating
There is limited support for identifying the control measure as a RACM.
There is some support for identifying the control measure as a RACM; more than for a control measure
with a RACM Rating of "1."
There is substantial support for identifying the control measure as a RACM.
A "U" indicates that the likelihood that the control measure constitutes a RACM is undetermined due
to incomplete information. A corresponding "+" indicates that despite incomplete information, an
application of RACM criteria would likely suggest that the control measure is a RACM, while a "-"
indicates that despite incomplete information, an application of the RACM criteria would likely
suggest that the control measure is not a RACM.
Table 5-2. Lead Acid Battery Source Category - Summary of Known Control Measures and
Relative Likelihood that each Control Measure is a RACM.
RACM
Rating
Control Measure
Brief Reasoning for RACM Rating
Fabric Filters to Control Process
Lead Emissions from Paste Mixing,
Three-Process Plate Operation,
Lead Oxide Manufacturing, and
Other Lead Emitting Processes.
1. Adoption by almost all (or all) sources.
2. Cost data suggest cost effective.
3. EPA determined such control measures constitute
BDT over thirty years ago and as GACT four years
ago.
4. California's SCAQMD adopted a rule practically
requiring such a control measure, as it requires 98%
efficiency for lead for facilities exceeding specific
process and emission thresholds (i.e., processing
more than 2 tons of lead per year with daily
emissions of lead greater than or equal to
0.51bs/day).
Impingement Scrubbers to Control
Process Lead Emissions from Lead
Reclamation and Grid Casting
Operations.
1. Adoption by almost all (or all) sources.
2. Cost data suggest cost effective.
3. EPA determined such control measures constitute
BDT over thirty years ago and as GACT four years
ago.
4. California's SCAQMD adopted a rule practically
requiring such a control measure, as it requires 98%
efficiency for lead for facilities exceeding specific
process and emission thresholds (i.e., processing
more than 2 tons of lead per year with daily
emissions of lead greater than or equal to
0.51bs/day).
Other control measures to control
process lead emissions from stacks.
1. Only limited adoption by facilities revealed
through a review of publicly available information
28
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RACM
Rating
Control Measure
Brief Reasoning for RACM Rating
and correspondence with EPA employees.
2. EPA determined that cost data suggested such
additional control measures not cost effective.
3. EPA refused to develop any such controls as
GACT technology as recent as four years ago.
4. California's SCAQMD adopted a rule practically
requiring such control measures as it requires 98%
efficiency for lead for facilities exceeding specific
process and emission thresholds (i.e., processing
more than 2 tons of lead per year with daily
emissions of lead greater than or equal to
0.51bs/day)..
1.5
Paving unpaved roads and cleaning
unpaved roads for controlling
fugitive dust sources.
1. Only limited adoption by facilities revealed
through a review of public available information and
correspondence with EPA employees.
2. Cost data suggest cost effective.
3. Not required by any known federal regulation.
4. Required in part by California's SCAQMD. The
SCAQMD rule requires cleaning surfaces subject to
vehicular traffic weekly.
U-
Other Control measures to control
fugitive emissions.
1. Lack of known adoption by any facilities for
controlling lead emissions.
2. No known cost data. However, lead acid battery
facilities are all area sources, which results in
fugitive dust control measures being less likely to be
cost effective.
3. Not required by any known federal regulation.
4. California's SCAQMD requires several such
measures, such as requiring dust-forming material to
be stored in enclosures, washing/vacuuming surfaces
accumulating lead-containing dust, etc.
5.4. Application of RACM Criteria to Possible RACM Candidates.
5.4.1. Fabric Filters to Control Process Lead Emissions from Paste Mixing, the Three-Process Plate
Operation. Lead Oxide Manufacturing, and Other Lead Emitting Processes: and Impingement
Scrubbers to Control Process Lead Emissions from Lead Reclamation and Grid Casting
Operations.
The almost complete adoption of fabric filters by lead acid battery manufacturing facilities in the United
States to control process lead emissions from paste mixing, the three-process plate operation, lead oxide
manufacturing, and other lead-emitting processes; and almost complete adoption of impingement
scrubbers to control process emissions from lead reclamation and grid casting operations, suggests that
such control measures are the most economically feasible control technologies for regulating lead
emissions from such operations in the Lead Acid Battery source category. Specifically, almost all
(53/58) of the lead acid battery manufacturing facilities comply with the current NSPS and NESHAP
standards for the Lead Acid Battery source category, which are identical standards. The NSPS and
29
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NESHAP emission limitations, control efficiencies, and control bases for relevant operations are listed
in Table 5-3.
95
Table 5-3. NSPS and NESHAP for Lead Acid Battery Manufacturing (40 CFR 60, Subpart KK;
40 CFR 63, Subpart PPPPPP).
Operation
Paste mixing
Three-process operation
Lead oxide
manufacturing
Other lead emitting
processes
Grid casting
Lead Reclamation
Emission Limitation
1 mg/dscm
(0.00044 gr/dscf)
1 mg/dscm
(0.00044 gr/dscf)
5 mg/kg of lead
processed
1 mg/dscm
(0.00044 gr/dscf)
0.4 mg/dscm
(0.00024 gr/dscf)
4.5 mg/dscm
(0.0022 gr/dscf)
Control Efficiency
99%
99%
> 99%
90%
90%
90%
Control Basis
Fabric filter
(6: 1 air to cloth ratio)
Fabric filter
(6:1 air to cloth ratio)
Fabric Filter
(2: 1 air to cloth ratio)
Fabric filter
(6:1 air to cloth ratio)
Impingement scrubber
Impingement scrubber
The available cost information might further suggest that such control measures are cost effective. For
example, a recent cost analysis was conducted to determine the cost effectiveness of fabric filters for the
paste mixing, three plate process, and other lead process operations for a typical lead acid battery
manufacturing plant. Such cost analysis assumed the characteristics for the fabric filters and plants listed
in Table 5-4. Such cost analysis revealed that the cost effectiveness of the fabric filters ranged from
roughly $381,000 to $4.3 million per ton of lead.96
Table 5-4. Cost Effectiveness of Fabric Filters Controlling Previously Uncontrolled Lead
Emissions for Paste Mixing, Three Plate Process, and Other Lead Processes in a Typical Lead
Acid Battery Manufacturing Plant.
Operation
Paste
Mixing
Three
Plate
Process
Other
Lead
Processes
Capital Costs
Low/High
($)
70,000/
70,000
130,000/
520,000
234,000/
773,000
Annual Costs
Low/High
($)
224,000 /
224,000
253,000 /
321,000
290,000 /
385,000
Equipment
Life
(Years)
20
20
20
Annual
Emissions
(Tons Lead
per year)
0.052
0.420
0.790
Cost Effectiveness,
Low/High
($/Ton Lead)
4,375,000/4,375,000
617,857/826,190
381,898/536,265
Current and past federal regulations suggest that such control measures are reasonably available.
Specifically, the NSPS for Lead Acid Battery Manufacturing Plants (40 CFR 60, Subpart KK),
Id. at Attachment 2.
96Memorandum - Lead Acid Battery Manufacturing Area Source Category Costing Information in Response to Comments on
Proposed Rule. From Nancy Jones. EC/R. To Sharon Nizich. EPA/OAQPS/SPPD/MICG. June 12. 2007. Page 4.
30
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published in 1982, imposes the control technologies with corresponding emissions limitations and
control efficiencies shown in Table 5-3.97 Such standards require control technologies that are BDT. The
fact that such control measures were BDT almost thirty years ago suggests that each such control
measure constitutes a RACM.
Moreover, the current NESHAP for the Lead Acid Battery Manufacturing Area Sources (40 CFR 63,
Subpart PPPPPP), published in 2007, incorporates the exact same control measures and corresponding
emission limits and control efficiencies as the older NSPS.98 The current NESHAP requires control
technologies that are generally available control technologies (GACT). The fact that EPA determined
that such control measures were GACT technologies in the source category four years ago further
suggests that such control measures are RACM.
A review of rules from California and Missouri further suggests that such control measures are
reasonable. Such states were chosen for review because they both have lead acid battery manufacturing
sources within the state. Missouri incorporates the federal NESHAP into state law. " California's
SCAQMD adopted a rule practically requiring such a control measure, as it requires 98% efficiency for
lead for facilities exceeding specific process and emission thresholds (i.e., processing more than 2 tons
of lead per year with daily emissions of lead greater than or equal to 0.51bs/day).100
5.4.2. Other Control Measures to Control Process Lead Emissions from Stacks.
A review of publicly available literature and correspondence with several EPA employees revealed
limited adoption of other control measures to control process lead emissions from the stacks from lead
acid battery facilities. Specifically, one lead acid battery manufacturing facility has fabric filter
baghouses with HEPA filter add-ons to control process lead emissions from two of its mills.101 Such
limited known adoption suggests that other control measures to control lead process emissions from
stacks in lead acid battery manufacturing plants are not reasonably economically feasible.
The available cost data further suggest that other control measures to control process emissions from
stacks is not cost effective. For example, a recent analysis was performed to determine the cost for a
typical battery manufacturing plant to upgrade from the current 90/99.0 percent controls (i.e., controls
required by current NESHAP and NSPS) to 99.9 percent controls. Such estimate revealed that the total
capital investment to upgrade to 99.9 percent controls could range from more than $600,000 to almost
$1.7 million, depending on the technologies selected. Moreover, the annual costs of such additional
control for a typical plant would be around $1.2 million per year due to increased operator labor costs,
maintenance labor/material costs, electricity/other utility costs, taxes, insurance and capital recovery
costs. Such cost represents about 5 percent of the total shipments for an average lead acid battery
establishment. EPA has indicated that it does not believe that such costs are appropriate for the area
sources in the category. Such costs incurred per ton of lead emissions reduced would be around
97NSPS for Lead acid Battery Manufacturing Plants. 40 CFR 60. Subpart KK (Published April 16. 1982).
98NESHAP for Lead Acid Battery Manufacturing Plants. 40 CFR 63 Subpart PPPPPP (Published July 16. 2007).
"AirlO CSR 10-6.075 Maximum Achievable Control Technology Regulations: Air Quality Standards. Definitions.
Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August
16. 19771. Page 91.
'""California (South Coast Air Quality Management District). Rule 1420 - Emission Standards for Lead (Published
September. 1992).
101 Correspondence with Stephanie Doolan /EPA Region 7 in December, 2011 revealed that the Exide Facility in Salina,
Kansas has adopted such additional control measures that control process lead emissions from stacks.
31
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$450,000 to $500,000 based on replacing existing control devices or installing additional devices to
increase control efficiency up to 99.9 percent.
102
In addition, the EPA decision to not incorporate other control measures to control process emissions
from stacks in recent standard development further suggests that there are no other control measures that
are economically feasible. Specifically, citing the excessive costs, EPA decided that other control
measures to control process emissions from stacks did not constitute GACT in the recent NESHAP for
the Lead Acid Battery Manufacturing Source Category.103
A review of state rules from California and Missouri suggests that such control measures might be
within economic reach. Such states were chosen for review because they both have lead acid battery
manufacturing sources within the state. Missouri only incorporates the federal NESHAP into state
law.104 However, California's SCAQMD adopted a rule that might practically require such a control
measure as it requires 98% efficiency for lead for facilities exceeding specific process and emission
thresholds (i.e., processing more than 2 tons of lead per year with daily emissions of lead greater than or
equal to 0.51bs/day).105
5.4.3. Hot Asphalt Paving of Unpaved Roads, Chemical Stabilization of Unpaved Roads, and Vacuum
Cleaning of Paved Roads to Control Fugitive Dust Lead Emissions.
A review of publicly available literature and correspondence with several EPA employees revealed
limited adoption of control measures, like paving unpaved roads, chemically stabilizing unpaved roads,
and vacuum cleaning of paved roads, to control fugitive dust emissions from lead acid battery facilities.
Specifically, one lead acid battery manufacturing facility is paved on two sides, needs repair on one side,
and the state in which the facility is located wants the facility to pave the unpaved side and repair the
other side to control emissions.106 Such limited adoption of such control measures suggests that such
control measures do not constitute RACM.
Cost-effectiveness data for PM suggest that such control measures might be cost effective for controlling
lead emissions as well. Specifically, such control measures have been shown to be cost effective, on
average, for all facilities in all source categories for controlling PM, as shown in Table 5.5.107 However,
all of the facilities in the Lead Acid Battery Manufacturing source category are area sources, which
suggests that the amount of emissions are much smaller than on average for all facilities.108
Consequently, with lower emissions, the cost effectiveness for such control measures would decrease.
"^Memorandum - Lead Acid Battery Manufacturing Area Source Category Costing Information in Response to Comments
on Proposed Rule. From Nancy Jones. EC/R. To Sharon Nizich. EPA/OAQPS/SPPD/MICG. June 12. 2007. Page 4.
"^Introductory text to Lead Acid Battery Manufacturing Area Source NESHAP. 40 CFR 63. Subpart PPPPPP (Published
July 16. 2007).
104AirlO CSR 10-6.075 Maximum Achievable Control Technology Regulations: Air Quality Standards. Definitions.
Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August
16. 1977). Page 91.
""California (South Coast Air Quality Management District). Rule 1420 - Emission Standards for Lead (Published
September. 1992).
106Correspondence with Stephanie Doolan /EPA Region 7 in December, 2011, regarding the Exide Facility in Salina, Kansas.
107EPA CoST database.
108Memorandum - Lead Acid Battery Manufacturing Area Source Category Additional Information to Support Proposed
Rule. From Nancy Jones. EC/R. To U.S. EPA Docket Number EPA-HQ-OAR-2006-0897. February 28. 2007.
32
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Table 5-5. Cost-Effectiveness Information for Selected Control Measures for Controlling
Particulate Matter with respect to the All Source Categories.
Control Measure
Vacuum Sweeping Paved Roads
Hot Asphalt Paving of Unpaved Roads
Chemical Stabilization of Unpaved Road
Cost Effectiveness*
($/TonofPM)
400
700
2600
Control Efficiency
(%)
50.0
66.6
37.5
* Rounded to the nearest $100 and escalated from 1999 to 201 1 U.S. dollars.109
No federal standards adopt such control measures. A review of state rules from California and Missouri
suggests such control measures are reasonable. Such states were chosen for review because they both
have secondary lead sources within the state. Missouri incorporates the federal NESHAP into state law,
which does not require such control measures.uo A California SCAQMD rule partially provides for such
control measures by requiring sources to clean surfaces weekly that are subject to vehicular traffic.m
5.4.4. Other Control Measures for Controlling Fugitive Lead Emissions.
A review of state rules from California and Missouri suggests such control measures might be within
economic reach, but there is a lack of support that such control measures are reasonably available. Such
states were chosen for review because they both have secondary lead sources within the state (2 in each
state). Missouri only incorporates the federal NESHAP into state law, which does not require such
control measures.112 However, a California SCAQMD rule requires several such control measures
including requiring dust-forming material to be stored in an enclosure, washing/vacuuming surfaces
accumulating lead-containing dust, etc.113
109In order to escalate from 1999 dollars to 2011 dollars, used the formula and approach presented in EPA's Control Strategy
Tool (CoST) Control Measures Database (CMDB) Documentation. Page 9.
110AirlO CSR 10-6.075 Maximum Achievable Control Technology Regulations: Air Quality Standards. Definitions.
Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August
16. 1977). Page 91.
'"California (South Coast Air Quality Management District). Rule 1420 - Emission Standards for Lead (Published
September. 1992).
112AirlO CSR 10-6.075 Maximum Achievable Control Technology Regulations: Air Quality Standards. Definitions.
Sampling, and Reference Methods and Air Pollution Control Regulations for the Entire State of Missouri (Published August
16. 19771. Page 91.
113California (South Coast Air Quality Management District). Rule 1420 - Emission Standards for Lead (Published
September. 1992).
33
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6.0. RACM DEVELOPMENT FOR THE IRON AND STEEL
FOUNDRIES SOURCE CATEGORY.
This section presents control measures to consider for RACM development for the Iron and Steel
Foundries source category. Section 6.1 provides an overview of the Iron and Steel Foundries source
category. Section 6.2 provides a summary of operations and lead emission points for iron and steel
foundry facilities. Section 6.3 provides a summary of the control measures utilized at iron and steel
foundries facilities, and Section 6.4 provides a more detailed application of the RACM criteria to each
identified control measure.
6.1. Overview of Source Category.
The Iron and Steel Foundries source category is actually two source categories that are normally
considered collectively due to the similarity in processes, emissions and controls. The Iron Foundries
source category consists of plants engaged in producing final shape castings from grades of iron. The
production steps related to the source category include raw materials handling, metal melting, mold/core
production, and casting/finishing.114 The corresponding NAICS Code for the Iron Foundries source
category is 331511. The NAICS Description for facilities with such NAICS Code is "establishments
primarily engaged in manufacturing iron castings and further manufacturing them into finished products
that are further classified based on the specific finished product."115
The Steel Foundries category includes any facility engaged in producing final shape steel castings by the
melting, alloying, and molding of pig iron and steel scrap. This source category also includes raw
materials handling, metal melting, mold/core production, and casting/finishing.116 The corresponding
NAICS codes for the Steel Foundries source category are 331512 and 331513. The NAICS Descriptions
for facilities with NAICS Codes of 331512 and 331513 are "establishments primarily engaged in
manufacturing steel casings (except steel investment castings) and manufacturing steel investment
castings and further manufacturing them into finished products" and "establishments primarily engaged
in manufacturing steel investment castings and manufacturing steel castings and further manufacturing
them into finished products," respectively.117
A 1992 census revealed that there were roughly 2800 iron and steel foundries in the United States at that
time. Exactly 595 iron and steel foundries returned survey data from an EPA Information Collection
Request in 2002, and roughly 100 of such sources are major sources, while the remaining are area
118
sources.
114National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page
1-2.
115North American Industry Classification System Website.
"^National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page
1-2.
117North American Industry Classification System Website.
118National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page
5-12.
34
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6.2. Facility Operations and Lead Emission Points.
The operations and processes for iron and steel foundries include the following: (1) pattern making, (2)
mold/core making, (3) scrap preparation, (4), metal melting, (5) pouring, cooling, and shakeout, (6) sand
handling, (7) mechanical finishing, and (8) cleaning and coating.119
The first step in production of castings is making a pattern, which is a metal, wood, or plaster replica of
a finishing casting, which can be used to create molds into which molten metal is poured. The next step
in production of castings is preparing and melting metal, where typically recycled scrap metals are used
as the source of metal. Such scrap metals typically undergo some type of preparation prior to melting
such as sizing, cleaning, and drying. Then such scrap is "charged" to a furnace for melting, and the
molten metal is poured from the furnace (i.e., tapped) into either a holding furnace or a transfer ladle,
and then the molten metal is transported to the pouring location. Upon reaching the pouring area, the
molten metal is poured into a mold. After it has solidified and cooled, it is separated from the mold, and
the casting is transferred to a finishing and cleaning area. Specific finishing and cleaning operations will
vary depending on the type of mold used to produce the casting and casting specifications. Finishing
typically involves mechanical operations such as abrasive cleaning, torch cutoff, air-carbon arc cleaning,
chipping, core knockout, and grinding. Cleaning usually involves the use of organic solvents to remove
rust, oil, grease, and dirt from the surface of the casting. The casting may also be given a coating.120
Emissions points for lead are associated with the following operations: (1) scrap preparation, (2) metal
melting, and (3) pouring, cooling, and shakeout. With respect to scrap preparation, the primary lead
emissions come from preheaters, which are used to preheat the scrap for melting in the furnace. The
control devices used to control lead emissions from preheaters are generally fabric filters.121
With respect to the metal melting process, the predominant types of furnaces used to melt metal include
cupolas, which are used only at iron foundries; electric arc furnaces (EAF), which are used mainly at
steel foundries; and electric induction furnaces (EIF), which are commonly used at both iron and steel
foundries. For lead emissions from cupolas, such emissions arise primarily from the melting operations.
The control devices used to control lead emissions from cupolas are generally fabric filters and also wet
scrubbers (usually Venturi scrubbers).122
For lead emissions from electric furnaces, such furnaces do not have well-defined stacks like cupolas.
Consequently, control systems for these furnaces must include hoods or other types of capture
mechanisms ducted to the control device. Moreover, the charging, melting, and tapping phases of the
melting cycle occur in sequence, not simultaneously as with cupolas. Consequently, it is more likely that
the charging and melting emissions may be captured by different systems because the furnace is
different for the two operations. The two exhaust streams may be ducted to separate control devices or to
the same device. Depending on the capture systems used, tapping emissions may also be captured,
usually incidentally because these emissions are relatively insignificant and no system dedicated to these
emissions is normally used. The control devices used to control lead emissions from electric furnaces
include fabric filters and wet scrubbers. Similar control devices are used for EAFs. Capture systems
119Id.at3-3.
120Id.
121Id
122Id.
35
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used for EAFs and EIFs include side draft hoods, direct evacuation control system, fume rings, close-
fitting hoods, canopy hoods, total furnace enclosures, and building and bay evacuation.
123
With respect to the pouring, cooling, and shakeout operations, lead emissions are primarily a problem in
the shakeout process. Such emissions are usually controlled by fabric filters and cartridge filters, but wet
scrubbers and other devices are also used.
124
6.3. Identification and Summary of Possible RACM Candidates.
Table 6-2 provides a summary of control measures used in the Iron and Steel Foundries source category
for which the RACM criteria are applied in section 6.4 and the relative likelihood that each control
measure is a RACM. Specifically, each control measure is assigned a rating of 1 through 3; where the
higher the number, the more likely that the control measure is a RACM. Such assigned values are
explained in Table 6-1.
Table 6-1. General Meanings of Assigned RACM Ratings.
RACM
Rating
1
2
3
U
(+ or -)
General Meaning of RACM Rating
There is limited support for identifying the control measure as a RACM.
There is some support for identifying the control measure as a RACM; more than for a control measure
with a RACM Rating of "1."
There is substantial support for identifying the control measure as a RACM.
A "U" indicates that the likelihood that the control measure constitutes a RACM is undetermined due
to incomplete information. A corresponding "+" indicates that despite incomplete information, an
application of RACM criteria would likely suggest that the control measure is a RACM, while a "-"
indicates that despite incomplete information, an application of the RACM criteria would likely
suggest that the control measure is not a RACM.
123
124
id.
36
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Table 6-2. Iron and Steel Foundries Source Category - Summary of Known Control Measures and
Relative Likelihood that each Control Measure is a RACM.
RACM
Rating
Control Measure
Brief Reasoning for RACM Rating
1
Control devices (e.g., filters, cyclones,
scrubbers) to control process lead
emissions from preheaters during scrap
preparation operations (e.g., loading,
heating, and discharging).
1. Minority, albeit significant, adoption by sources.
2. Cost data suggest not cost effective.
3. Not identified as GACT for recent NESHAP.
4. Lack of adoption of such controls by state regulations.
5. California's SCAQMD adopted a rule practically
requiring such a control measure, as it requires 98%
efficiency for lead for facilities exceeding specific process
and emission thresholds (i.e., processing more than 2 tons
of lead per year with daily emissions of lead greater than or
equal to 0.51bs/day).
Control devices (e.g., filters, wet
scrubbers, electrostatic precipitators) to
control process lead emissions from
cupolas during the melting operations at
iron foundries.
1. Almost complete adoption by sources.
2. Cost data suggest cost effective for large and medium
sources, but less cost effective for small sources.
3. Identified as GACT for larger area sources and MACT
for major sources.
4. Many state regulations practically require such controls
for cupolas.
5. California's SCAQMD adopted a rule practically
requiring such a control measure, as it requires 98%
efficiency for lead for facilities exceeding specific process
and emission thresholds (i.e., processing more than 2 tons
of lead per year with daily emissions of lead greater than or
equal to 0.51bs/day).
Control devices (e.g., filters and wet
scrubbers) to control process lead
emissions from electric arc furnaces
(EAFs) during the melting operations.
1. Almost complete adoption by sources.
2. Cost data suggest cost effective for large and medium
sources, but less cost effective for small sources.
3. Identified as GACT for larger area sources and MACT
for major sources.
4. Many state regulations practically require such controls
for EAFs.
5. California's SCAQMD adopted a rule practically
requiring such a control measure, as it requires 98%
efficiency for lead for facilities exceeding specific process
and emission thresholds (i.e., processing more than 2 tons
of lead per year with daily emissions of lead greater than or
equal to 0.51bs/day).
2.5
Control devices (e.g., filters and wet
scrubbers) to control process lead
emissions from electric induction
furnaces (EIFs).
1. Minority, and less widespread, adoption by sources.
2. Cost effective for large foundries, but less cost effective
for medium and small foundries.
3. Identified as GACT for larger area sources and MACT
for major sources.
4. Some state regulations might practically require such
controls for EIFs.
5. California's SCAQMD adopted a rule practically
requiring such a control measure, as it requires 98%
efficiency for lead for facilities exceeding specific process
and emission thresholds (i.e., processing more than 2 tons
of lead per year with daily emissions of lead greater than or
37
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RACM
Rating
Control Measure
Brief Reasoning for RACM Rating
equal to 0.51bs/day).
Control devices (e.g., filters) to control
process lead emissions from the
shakeout process.
1. Minority, albeit significant, adoption by sources.
2. Cost data suggest not cost effective.
3. Not identified as GACT for recent NESHAP.
4. Lack of adoption of such controls by state regulations.
U
Improving currently installed control
devices (e.g., filters and wet scrubbers)
to more efficiently control process lead
emissions (e.g., decreasing air to cloth
ratio, increasing pressure differential,
using horizontally hanging bags instead
of vertically hanging bags).
1. Evidence suggests that such measures are more efficient,
but there are limited cost data available.
Capture systems (e.g., side draft hoods,
direct evacuation control systems, fume
rings, close-fitting hoods, canopy
hoods, total furnace enclosures, and
building and bay evacuation) to control
process fugitive lead emissions from
EAFs during melting operations.
1. Majority use for at least some operations.
2. No cost data identified.
3. Identified as GACT for large area source foundries, but
not for small foundries.
4. Many state regulations practically require such controls.
Capture systems (e.g., side draft hoods,
direct evacuation control systems, fume
rings, close-fitting hoods, canopy
hoods, total furnace enclosures, and
building and bay evacuation) to control
process fugitive lead emissions from
EIFs during melting operations.
1. Less widespread use compared to EAFs.
2. No cost data identified.
3. Identified as GACT for large area source foundries, but
not for small foundries.
4. Many state regulations practically require such controls.
2.5
Pollution prevention measure of using
scrap management practices and
materials specifications to reduce lead
content of scrap.
1. Extent of use not identified.
2. Cost data suggest cost effective.
OO
3. Identified as GACT for both large and small area source
foundries.
U +
Fugitive dust control measures.
1. Extent of use not identified.
2. No cost data identified.
3. A GACT emission limit exists, which prohibits foundries
from discharging certain levels of fugitive emissions.
6.4. Application of RACM Criteria to Possible RACM Candidates.
6.4.1. Control devices (e.g.. Filters, cyclones, and scrubbers) to control process lead emissions from
preheaters during scrap preparation operations (i.e.. loading, heating, and discharging).
The common, but less than majority, use of control devices (e.g., filters, cyclones and scrubbers) for
controlling process lead emissions from preheaters during scrap preparation operations suggests that
such controls are somewhat economically feasible for larger foundries but less economically feasible for
smaller foundries. For example, a majority of the total number of preheaters at iron and steel foundries
are uncontrolled. Specifically, about 61 % of the total number of preheaters at iron foundries (68 of the
113 preheaters) and about 48% of iron foundries (76 of 157 iron foundries) use no controls to control
process emissions from preheaters during all scrap preparation operations (i.e., loading, heating and
38
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discharging); 125 and about 78% of the total number of preheaters at steel foundries (7 of the 9
preheaters) and 90 % of the steel foundries (18 of the 20 steel foundries) use no controls to control
process emissions from preheaters during scrap preparation operations (i.e., loading, heating and
discharging).126
However there is a significant, albeit minority, use of such controls to control process emissions from
preheaters at iron and steel foundries. Specifically, about 15% of the total number of preheaters at iron
foundries (17 of the 113 preheaters) and about 15% of iron foundries (24/157 iron foundries) use filters
to control process emissions from preheaters during all scrap preparation operations (i.e., loading,
heating and discharging).127 About 25% of the total number of preheaters at iron foundries (28 of 113
preheaters) and about 44% of iron foundries (50 of 113 iron foundries) use a control device (i.e., filter,
scrubber, cyclone) to control process emissions from preheaters during some scrap preparation
operations (i.e., loading, heating, discharging), but not all scrap preparation operations.128 No steel
foundries use filters to control process emissions from preheaters during all scrap preparation operations
(i.e., loading, heating, and discharging).129 One steel foundry uses a filter on one preheater to control
process emissions from preheaters during scrap preparation for heating and discharging operations, but
not for loading. One steel foundry uses a scrubber on one preheater to control process emissions during
scrap preparation during discharging operations, but not for heating or loading.130
Available cost-effectiveness data suggest that such controls to control lead process emissions from
preheaters is not cost effective. Specifically, EPA determined from an assessment of the impacts of
meeting different candidate control options using three different model plants (small model plant with
capacity of 500 TPY, medium model plant with capacity of 5,000 TPY, and large model plant with
capacity of 50,000 TPY) that such controls were not reasonably cost effective for reducing emissions of
PM and HAP metal compounds from sources for scrap preparation options (e.g., preheaters).131 This
suggests that using such controls to control lead emissions from preheaters is also not cost effective.
The recent NESHAP for Iron and Steel Foundries Area Sources (40 CFR 63, Subpart ZZZZZ) provides
support that controls to control the process lead emissions from preheaters at foundries are not
reasonably available.132 Specifically, such standard does not require controls on preheaters. EPA's
recent refusal to identify such controls as GACT suggests that such controls may not be RACM.
The current NESHAP for Iron and Steel Foundries Majors Sources (40 CFR 63, Subpart EEEEE)
provides some support that controls to control the process lead emissions from preheaters at foundries
are reasonably available. Specifically, such NESHAP requires that each scrap preheater at a new iron
and steel foundry must not discharge emissions through a conveyance to the atmosphere that exceed
either the of following limits for PM and total metal HAP: (1) 0.001 gr/dscf of PM, or (2) 0.0008 gr/dscf
of total metal HAP; and requires that an existing iron and steel foundry must not discharge emissions
125Id. at 4-8.
126Id
127Id
128Id
129Id
130Id
131Memorandum - Impact Estimates for Area Source Iron and Steel Foundries. From Conrad Chin. EPA/SPPD. To EPA
Docket Number EPA-HQ-OAR-2006-0359-0005-1. September 4. 2007. Page 4.
132NESHAP for Iron and Steel Foundries Area Sources. 40 CFR 63. Subpart ZZZZZ (Published April 22. 2004).
39
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through a conveyance to the atmosphere that exceed either of the following limits for PM and total metal
HAP: (1) 0.005 gr/dscf of PM, or (2) 0.0004 gr/dscf of total metal HAP.""
133
The lack of adoption of such controls in state regulations suggests that such controls are not highly
reasonable for preheaters. Specifically, Table 6-3 lists state regulations from the six states with the
highest foundry metal melting rates.134 While one has a PM emission limit that applies to all foundry
operations that might practically require implementation of such control measures on preheaters, no
other of such states have such PM limits.
California's SCAQMD Rule 1420 requires a control efficiency of 98% for all operations.135
Consequently, this requirement would apply to control devices to control process lead emissions from
preheaters during scrap preparation operations (i.e., loading, heating, and discharging). Notwithstanding,
this requirement only applies to facilities processing more than 2 tons of lead per year with daily
emissions of lead greater than or equal to 0.51bs/day.
133ld
134National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page
4-49.
135California (South Coast Air Quality Management District). Rule 1420 - Emission Standards for Lead (Published
September. 1992).
40
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Table 6-3. State Regulations from the Six States with the Highest Foundry Metal Melting Rates
that Practically Require Implementation of Lead Control Measures.
Michigan
Wisconsin
Indiana
Ohio
Illinois
Alabama
Melting Furnace -
Cupolas
(gr PM/dscf)
Existing cupolas:
0.2 (where melting
capacity <10
tons/hour) to
0.08 (where melting
capacity > 20
tons/hour).
New cupolas:
emission factor
limits.
0.24
0.15
Based on process
rate capacity of a
generic PM
emission source -
vary widely.
Based on process
weight rates - vary
widely.
Based on process
weight rates - vary
widely
Melting Furnace
-EAFs
(gr Lead/dscf)
0.05
0.05
None
Based on process
rate capacity of a
generic PM
emission source -
vary widely.
Based on process
weight rates -
vary widely.
Based on process
weight rates -
vary widely
Melting
Furnace - EIFs
(gr Lead/dscf)
None
0.05
None
Based on
process rate
capacity of a
generic PM
emission source
- vary widely.
Based on
process weight
rates - vary
widely.
Based on
process weight
rates - vary
• j i
widely
All Foundry
Operations
(gr PM/dscf)
None
Cannot discharge
any gases > 0.07
None
None
None
Opacity Limit
for Buildings
that House
Process
Equipment136
Opacity
emission limits
were found for
five states,
which
generally apply
to general roof
vents that may
contain
fugitive
emissions from
various sources
throughout the
foundry. Four
of the five
states
(Alabama,
Wisconsin,
Michigan, and
Ohio) have 20
% opacity
limits, while
one state
(Indiana) has a
30% to 40%
• , -i • • .
opacity limit,
depending on
the location of
the source.
6.4.2. Control devices (e.g.. Filters, wet scrubbers, electrostatic precipitators) to control process lead
emissions from cupolas during the melting operations at iron foundries.
The almost complete adoption of control devices (e.g., filters, scrubbers, and electrostatic precipitators)
for controlling process lead emissions from cupola furnaces during melting operations (i.e., charging,
melting, tapping) at iron foundries suggests that such controls are economically feasible. Specifically,
about 44% of foundries (48/110) and about 43% (62/143) of the total number of cupolas at iron
foundries use a filter to control process emissions from cupolas during melting operations (charging,
melting, and tapping). About 48% of foundries (53/110) and 50% of cupolas (71/143) at such foundries
EPA examined such limits and determined that almost all States apply an opacity limit for buildings that house the process
equipment. EPA determined that fugitive emissions from such equipment are effectively regulated by such opacity limits.
NESHAP for Iron and Steel Foundries -Background Information for Promulgated Standards. EPA Document # EPA-HQ-
OAR-2002-0034-0144 (Published August 20031. Page 109.
41
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use wet scrubbers to control process emissions from cupolas during melting operations. Exactly 1/110
foundries and 1/143 cupolas at such foundries use electrostatic precipitator to control process emission
from cupolas during melting (i.e., charging, melting, and tapping). Only about 7% (8/110) of foundries
and about 6% (9/143) of the cupolas at such foundries did not use any control.137
Available cost-effectiveness data suggest that such controls to control lead process emissions from
cupolas is generally cost effective. EPA determined from an assessment of the impacts of meeting
different candidate control options using three different model plants (small model plant with capacity of
500 TPY, medium model plant with capacity of 5,000 TPY, and large model plant with capacity of
50,000 TPY) that add-on controls, such as filters (and cyclones or scrubbers) are reasonably cost
effective for reducing emissions of PM and HAP metal compounds from medium and large sources for
melting operations on furnaces, but less cost effective for smaller foundries.138 Specifically, the model
plant analysis also indicated that add-on controls for metal melting furnaces are much less cost effective
for the small model plant than for the large model plant (costs exceeded $60,000/ton of PM removed for
the 500 TPY model plant versus $3,000/ton of PM removed or less for the 50,000 TPY model plant).
EPA further noted that the cost effectiveness for add-on controls for the medium model plants appeared
to be reasonable for cupolas.139 This suggests that using such controls to control lead from cupolas is
cost effective, especially for medium and large plants.
The current NESHAP for Iron and Steel Foundries Area Sources (40 CFR 63, Subpart ZZZZZ) suggests
that such controls are reasonably available. Specifically, such NESHAP requires that large foundries
(existing source with annual metal melt production > 20,000 tons or new source with an annual metal
melt capacity > 10,000 tons), but not small foundries (existing source with annual melt production of <
20,000 tons or less or new source with an annual metal melt capacity of < 10,000 tons or less) must not
discharge to the atmosphere emissions from any metal melting furnace or group of all metal melting
furnaces that exceed the applicable limits: (1) for an existing iron and steel foundry, 0.8 pounds of PM
per ton of metal charged or 0.06 pounds of total metal HAP per ton of metal charged and (2) for a new
iron and steel foundry, 0.1 pounds of PM per ton of metal charged or 0.008 pounds of total metal HAP
per ton of metal charged.140 The fact that EPA recently decided that such controls are GACT for some
area sources suggests that such controls are RACM.
Moreover, such controls are required by the NESHAP for Iron and Steel Foundries Major Sources (40
CFR 63, Subpart EEEEE) for both new and existing sources. This provides support that such controls
are RACM, since such controls represent MACT standards that are 7 years old.141
The fact that many state regulations practically require such controls for cupolas suggests that such
controls are reasonable. Specifically, Table 6-3 lists state regulations from the six states with the highest
foundry metal melting rates.142 All states require PM emission limits that might practically require
implementation of such control measures on cupolas.
137National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page
4-11.
138Memorandum - Impact Estimates for Area Source Iron and Steel Foundries. From Conrad Chin. EPA/SPPD. To EPA
Docket Number EPA-HQ-OAR-2006-0359-0005-1. September 4. 2007. Page 4.
139Id.at4.
140NESHAP for Iron and Steel Foundries Area Sources. 40 CFR 63. Subpart ZZZZZ (Published April 22. 2004).
141Id
142National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
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California's SCAQMD Rule 1420 requires a control efficiency of 98% for all operations.143
Consequently, this requirement would apply to control devices to control process lead emissions from
cupolas during the melting operations at iron foundries. Notwithstanding, this requirement only applies
to facilities processing more than 2 tons of lead per year with daily emissions of lead greater than or
equal to 0.51bs/day.
6.4.3. Control devices to control process emissions from EAFs during the melting operations at iron
and steel foundries.
The almost complete adoption of control devices (mostly filters) for controlling emissions from EAFs
during melting operations (i.e., charging, melting, tapping) at iron and steel foundries suggests that such
controls are economically feasible. Specifically, there were no uncontrolled EAFs at iron foundries. One
hundred percent of the total number of EAFs at iron foundries (28 of the 28) and one hundred percent of
iron foundries (11 of 11) use controls (mostly filters) to control process emissions from EAFs during at
least some melting operations (i.e., charging, melting or tapping).144
Moreover, only about 2% (3/136) of the total number of EAFs at steel foundries and about 2% (3/71) of
the total number of steel foundries are uncontrolled.145 About 73% (99/135) of the total number of EAFs
at steel foundries and about 70% (50/71) of steel foundries used filters to control emissions from EAFs
during some melting operations (i.e., charging, melting, tapping) at steel foundries.146 About 24%
(33/135) of the total number of EAFs at steel foundries and about 30% (21/71) foundries used filters to
control emissions from EAFs during the melting operations (i.e., charging, melting, and tapping) at steel
foundries.147
Available cost-effectiveness data suggest that such controls to control EAFs are cost effective. EPA
determined from an assessment of the impacts of meeting different candidate control options using three
different model plants (small model plant with capacity of 500 TPY, medium model plant with capacity
of 5,000 TPY, and large model plant with capacity of 50,000 TPY) that add-on controls, such as filters
(and cyclones or scrubbers) are reasonably cost effective for reducing emissions of PM and HAP metal
compounds from medium and large sources for melting operations on furnaces, but less cost effective
for smaller foundries.148 Specifically, the model plant analysis also indicated that add-on controls for
metal melting furnaces are much less cost effective for the small model plant than for the large model
plant (costs exceeded $60,000/ton of PM removed for the 500 TPY model plant versus $3,000/ton of
PM removed or less for the 50,000 TPY model plant). EPA further noted that the cost effectiveness for
add-on controls for the medium model plants appeared to be reasonable for EAFs.
The current NESHAP for Iron and Steel Foundries Area Sources (40 CFR 63, Subpart ZZZZZ) suggests
that such controls are reasonably available. Specifically, such NESHAP requires that large foundries
4-49.
143California (South Coast Air Quality Management District). Rule 1420 - Emission Standards for Lead (Published
September. 1992).
144National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page
4-27.
145Id. at 4-27.
146Id
147Id
148Memorandum - Impact Estimates for Area Source Iron and Steel Foundries. From Conrad Chin. EPA/SPPD. To EPA
Docket Number EPA-HQ-OAR-2006-0359-0005-1. September 4. 2007. Page 4.
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(existing source with annual metal melt production > 20,000 tons or new source with an annual metal
melt capacity > 10,000 tons), but not small foundries (existing source with annual melt production of <
20,000 tons or less or new source with an annual metal melt capacity of < 10,000 tons or less) must not
discharge to the atmosphere emissions from any metal melting furnace or group of all metal melting
furnaces that exceed the applicable limits: (1) for an existing iron and steel foundry, 0.8 pounds of PM
per ton of metal charged or 0.06 pounds of total metal HAP per ton of metal charged and (2) for a new
iron and steel foundry, 0.1 pounds of PM per ton of metal charged or 0.008 pounds of total metal HAP
per ton of metal charged.149 The fact that EPA recently decided that such controls are GACT for some
area sources suggests that such controls are RACM.
Moreover, such controls are required by the NESHAP for Iron and Steel Foundries Major Sources (40
CFR 63, Subpart EEEEE) for both new and existing sources. This further provides support that such
controls are RACM, since such controls represent MACT standards that are 7 years old. 15°
The fact that many state regulations practically require such controls for EAFs suggests that such
controls are reasonable. Specifically, Table 6-3 lists state regulations from the six states with the highest
foundry metal melting rates.151 Five of the six states require PM emission limits that might practically
require implementation of such control measures on EAFs.
California's SCAQMD Rule 1420 requires a control efficiency of 98% for all operations.152
Consequently, this requirement would apply to control devices to control process emissions from EAFs
during the melting operations at iron and steel foundries. Notwithstanding, this requirement only applies
to facilities processing more than 2 tons of lead per year with daily emissions of lead greater than or
equal to 0.51bs/day.
6.4.4. Control devices (e.g., filters, wet scrubbers, and cyclones) used to control the process emissions
from EIFs during the melting operations at iron and steel foundries.
The less widespread adoption of control devices used to control the process emissions from EIFs during
the melting operations at iron and steel foundries suggests that such controls are less economically
feasible for EIFs than for EAFs or cupolas. For example, most iron foundries do not control EIFs with a
control device. Specifically, about 58% (438 of the 754) of the total number of EIFs at iron foundries
and about 64% (181 of 286) of iron foundries (64%) use no controls to control process emissions from
EIFs during melting (i.e., charging, melting, tapping). Only about 28% (210 of the 754) of the total
number of EIFs at iron foundries and about 24% (69 of 286) of iron foundries use filters to control
process emissions from EIF during melting (i.e., charging, melting, tapping). About 12 % (88 of the
754) of the total number of EIFs at iron foundries and about 10% (30 of 286) of iron foundries (10%)
use filters to control process emissions from EIF during some melting operations (charging, melting,
tapping) but not all.153 About 2% (17 of 754) of the total number of EIFs at iron foundries and about 2%
(6 of 286) of iron foundries use wet scrubbers to control process emissions from EIF during some
melting (i.e., charging, melting, tapping) but not all. Less than 1% (2 of 754) of the total number of EIFs
149NESHAP for Iron and Steel Foundries Area Sources. 40 CFR 63. Subpart ZZZZZ (Published April 22. 2004).
150NESHAP for Iron and Steel Foundries Major Sources. 40 CFR 63. Subpart EEEEE (Published April 22. 2004).
151National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page
4-49.
152California (South Coast Air Quality Management District). Rule 1420 - Emission Standards for Lead (Published
September. 1992).
153Id. at 4-21 through 4-22.
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at iron foundries and less than 1% (2 of 286) of the iron foundries use cyclones to control process
emissions from EIFs during some melting operations (i.e., charging, melting, and tapping) but not all.
154
Most steel foundries also do not control EIFs with a control device. Specifically, about 79% (509 of the
643) of the total number of EIFs at steel foundries and about 77% (144 of 186) of steel foundries use no
controls to control process emissions from EIFs during melting (i.e., charging, melting, tapping).155
About 13% (81 of the 643) of the total number of EIFs at steel foundries, and about 12% (23 of 186) of
steel foundries use filters to control process emissions from EIFs during melting (i.e., charging, melting,
tapping).156 About 5% (34 of the 643) of the total number of EIFs at steel foundries, and about 7% of (13
of 186) steel foundries use filters to control process emissions from EIFs during some melting (i.e.,
charging, melting or tapping).157 Less than 1% (6 of the 643) of the total number of EIFs at steel
foundries, and about 1% (2 of 186) of steel foundries use wet scrubbers to control process emissions
from EIFs during some melting (charging, melting or tapping).158 Less than 1 % (6 of the 643) of the
total number of EIFs at steel foundries, and about 1% (2 of 186) of steel foundries, use cyclones to
control process emissions from EIFs during some melting (i.e., charging, melting or tapping).159
Available cost-effectiveness data suggest that such controls to control for lead process emissions from
EIFs are less cost effective than for cupolas and EAFs. EPA determined from an assessment of the
impacts of meeting different candidate control options using three different model plants (small model
plant with capacity of 500 TPY, medium model plant with capacity of 5,000 TPY, and large model plant
with capacity of 50,000 TPY) that add-on controls, such as filters (and cyclones or scrubbers) are
reasonably cost effective for reducing emissions of PM and HAP metal compounds from sources for
melting operations on furnace, but less cost effective for smaller foundries. Specifically, the model plant
analysis also indicated that add-on controls for metal melting furnaces are much less cost effective for
the small model plant than for the large model plant (costs exceeded $60,000/ton of PM removed for the
500 TPY model plant versus $3,000/ton of PM removed or less for the 50,000 TPY model plant). EPA
further noted that the cost effectiveness for add-on controls for the medium model plants appeared to be
reasonable for cupolas and EAFs, but were less reasonable for EIFs due to the lower emissions from
uncontrolled EIFs as compared to cupolas and EAFs. 16°
The current NESHAP for Iron and Steel Foundries Area Sources (40 CFR 63, Subpart ZZZZZ) suggests
that such controls are reasonably available. Specifically, such NESHAP requires that large foundries
(existing source with annual metal melt production > 20,000 tons or new source with an annual metal
melt capacity > 10,000 tons), but not small foundries (existing source with annual melt production of <
20,000 tons or less or new source with an annual metal melt capacity of < 10,000 tons or less) must not
discharge to the atmosphere emissions from any metal melting furnace or group of all metal melting
furnaces that exceed the applicable limits: (1) for an existing iron and steel foundry, 0.8 pounds of PM
per ton of metal charged or 0.06 pounds of total metal HAP per ton of metal charged and (2) for a new
iron and steel foundry, 0.1 pounds of PM per ton of metal charged or 0.008 pounds of total metal HAP
154National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page
4-22.
155Id. at 4-23.
156Id. at 4-23.
157Id
158Id
159Id
160Memorandum - Impact Estimates for Area Source Iron and Steel Foundries. From Conrad Chin. EPA/SPPD. To EPA
Docket Number EPA-HQ-OAR-2006-0359-0005-1. September 4. 2007. Page 4.
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per ton of metal charged.161 The fact that EPA has recently decided that such controls are GACT for
some area sources provides some support that such controls are reasonably available.
Moreover, such controls are required by the NESHAP for Iron and Steel Foundries Major Sources (40
CFR 63, Subpart EEEEE) for both new and existing sources. This further provides support that such
controls are RACM, since such controls represent MACT standards that are 7 years old.162
The fact that some state regulations practically require such controls for EIFs might suggest that such
controls are reasonable. Specifically, Table 6-3 lists state regulations from the six states with the highest
foundry metal melting rates.163 Four of the six states require PM emission limits that might practically
require implementation of such control measures for EIFs.
California's SCAQMD Rule 1420 requires a control efficiency of 98% for all operations.164
Consequently, this requirement would apply to control devices used to control the process emissions
from EIFs during the melting operations at iron and steel foundries. Notwithstanding, this requirement
only applies to facilities processing more than 2 tons of lead per year with daily emissions of lead
greater than or equal to 0.51bs/day.
6.4.5. Control devices (e.g., filters, wet scrubbers) to control the process emissions from the shakeout
process.
The less widespread adoption of control devices used to control the process emissions from shakeout
processes at iron and steel foundries suggests that such controls are less economically feasible for
shakeout stations than for melting operations. For example, about 33% (384 of the 1156) of shakeout
stations and about 40% (225 of 569) of foundries use no controls to control process emissions from
shakeout stations.165 Meanwhile, about 53% (602 of the 1156) of shakeout stations and about 63% (360
of the 569) foundries use filters to control process emissions from shakeout stations.166 About 14% (161
of the 1156) of shakeout stations and 14% (79 of the 569) of foundries use wet scrubbers to control
process emissions from shakeout stations. Less than 1% (9 of the 1156) of shakeout stations and less
than 2% (7 of the 569) of foundries use other control devices (cyclones) to control process emissions
from shakeout stations.
Available cost-effectiveness data suggest that such controls to control preheaters are not cost effective.
Specifically, EPA determined from an assessment of the impacts of meeting different candidate control
options using three different model plants (small model plant with capacity of 500 TPY, medium model
plant with capacity of 5,000 TPY, and large model plant with capacity of 50,000 TPY) that add-on
controls, such as filters (and cyclones or scrubbers) were not cost effective for reducing emissions of PM
and HAP metal compounds from sources for shakeout processes.167 This suggests that using such
controls for controlling lead is also not cost effective.
161NESHAP for Iron and Steel Foundries Area Sources. 40 CFR 63. Subpart ZZZZZ (Published April 22. 2004).
162NESHAP for Iron and Steel Foundries Major Sources. 40 CFR 63. Subpart EEEEE (Published April 22. 2004).
163National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page
4-49.
164California (South Coast Air Quality Management District). Rule 1420 - Emission Standards for Lead (Published
September. 1992).
165Id. at 4-41
166Id
""Memorandum - Impact Estimates for Area Source Iron and Steel Foundries. From Conrad Chin. EPA/SPPD. To EPA
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Moreover, such controls are required by the NESHAP for Iron and Steel Foundries Major Sources (40
CFR 63, Subpart EEEEE) for both new and existing sources. This further provides support that such
controls are RACM, since such controls represent MACT standards that are 7 years old.168
The lack of adoption of such controls in state regulations suggests that such controls are not highly
reasonable for the shakeout process. Specifically, Table 6-3 lists state regulations from the six states
with the highest foundry metal melting rates.169 While one has a PM emission limit that applies to all
foundry operations that might practically require implementation of such control measures for the
shakeout process, no other of such states have such PM limits.
6.4.6. Improving current control devices used to control the process emissions from iron and steel
foundries.
Several measures could possibly improve the efficiency of controls that control process lead emissions
from iron and steel foundries. Such measures include increasing the pressure differential of Venturi
scrubbers, increasing the air-to-cloth ratio of fabric filters, and using horizontally hanging instead of
vertically hanging bags for fabric filters.
For example, pressure differential is a key factor affecting the efficiency of a scrubber in removing PM,
and similarly, lead. As a rule of thumb, a high-efficiency scrubber is one with a pressure differential
greater than 50 inches of water column.170 The pressure differential at Venturi scrubbers used on cupolas
is in Table 6-4.171 Many of the pressure differentials are less than 50 inches of water column. Such
pressure differentials might be increased to increase the efficiency of such controls.
Table 6-4. Pressure Differentials of Venturi Scrubbers used on Cupola Furnaces at Iron Foundries
Pressure differential, inches of water column
<8
20 to 29
30 to 39
40 to 49
50 to 59
60 to 70
Number of Scrubbers
9
5
14
11
9
7
Similarly, the air-to-cloth ratio, which is the major design factor that affects the efficiency of fabric
filters, might be decreased to increase the efficiency of fabric filters.
A more uncertain method of increasing the efficiency of fabric filters is to use horizontally hanging
instead of vertically hanging bags. Specifically, two sources have implemented horizontally hanging
bags rather than the traditional vertically hanging bags, and allege that such horizontally hanging bags
are cheaper and more efficient. According to an operator of one of these novel fabric filters, a lighter
Docket Number EPA-HQ-OAR-2006-0359-0005-1. September 4. 2007. Page 4.
168NESHAP for Iron and Steel Foundries Major Sources. 40 CFR 63. Subpart EEEEE (Published April 22. 2004).
169National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page
4-49.
170Id. at 4-12.
171National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page
4-16.
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weight fabric can be used when the bags are horizontally supported. When bags hang vertically, the tops
of the bags must be strong enough to hold up the weight of the entire bag, and the entire filter cake on
that bag. A light-weight bag would not be able to support the weight, and would tear. By having the bags
supported horizontally, they are able to reduce the weight that the bag material supports to only the
small amount under the horizontal support. The light-weight bag is easier to clean and is more
permeable, which allows for a more even distribution of the air flow. Heavier-weight bags tend to get
more material caught in the bag material, and as a result need to be cleaned more frequently and more
vigorously. One source indicated that, "since 80% of emissions are associated with cleaning," by
lowering the cleaning frequency, the fabric filter emissions are lowered. The light-weight bag is also
more permeable, so that pressure drop is reduced, and air flow is more evenly distributed. This, along
with the low air-to-cloth ratio for these fabric filters, allows more of the PM material, and associated
lead, to be collected on the bag surface, rather than becoming impregnated into the fabric, making it
easier to clean the bags.172
6.4.7. Capture systems used for EAFs and EIFs including side draft hoods, direct evacuation control
systems, fume rings, close-fitting hoods, canopy hoods, total furnace enclosures, and building and
bay evacuation.
Capture systems consist of two general types: close capture and general capture. Close-capture systems,
which are more effective, use techniques such as side draft hoods, direct evacuation systems, fume rings,
and close-fitting hoods that capture emissions before they escape from the immediate vicinity of the
furnace. These systems require only a small volume of air flow, which is drawn through attached
ductwork to a control device that can be dedicated to specific operations. General-capture systems
employ canopy hoods or total enclosures, both of which can be used with dedicated control devices but
require a higher volume of air flow than close-capture systems, or building or bay evacuation systems,
which also require large volumes of air and must serve the entire building or a large segment of it.173
Tables 6-5 and 6-6 show the extent of adoption of capture systems to control fugitive process emissions
from control devices attached to EIFs and EAFs at foundries, respectfully.174 Such tables demonstrate
that capture devices are much more widely adopted for use on EAFs than EIFs. Moreover, for both EIFs
and EAFs, close-captures are more generally adopted than other types of capture devices.175
172Id. at 4-15 through 4.16.
173Id. at 4-30.
174In the following tables, close capture includes side draft hood, fume ring, close-fitting hood, and direct evacuation. Others
include canopy hood, draft system or ventilation to a fabric filter, area ducting, section tube, and building evacuation to a
fabric filter. No capture includes not reported, roof vent, exhaust fan, lid or cover, or general ventilation.
175Id. at 4-31.
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Table 6-5. Use of Capture Systems on EIFs at Iron and Steel Foundries.
Capture system type
Close Capture
Number of furnaces
Number of foundries
Other Type
Number of furnaces
Number of foundries
No Capture
Number of furnaces
Number of foundries
Melting furnace operation serviced
Charging
211
66
185
69
1001
334
Total number furnaces: 1397
Melting
261
78
200
84
936
315
Tapping
160
53
169
63
1068
353
Total number foundries: 445
Table 6-6. Use of Capture Systems on EAFs at Iron and Steel Foundries.
Capture system type
Close Capture
Number of furnaces
Number of foundries
Other Type
Number of furnaces
Number of foundries
No Capture
Number of furnaces
Number of foundries
Melting furnace operation serviced
Charging
32
20
41
18
92
46
Total number furnaces: 168
Melting
120
62
26
9
17
10
Tapping
33
19
17
11
113
52
Total number foundries: 81
The NESHAP for Iron and Steel Foundries Area Sources (40 CFR 63, Subpart ZZZZZ) suggests that
such controls are reasonably available. Specifically, such NESHAP requires that large foundries
(existing source with annual metal melt production > 20,000 tons or new source with an annual metal
melt capacity > 10,000 tons), but not small foundries (existing source with annual melt production of <
20,000 tons or less or new source with an annual metal melt capacity of < 10000 tons or less) must
operate a capture and collection system for each metal melting furnace at a new or existing iron and steel
foundry where each capture and collection system must meet accepted engineering standards.176 The fact
that EPA has recently decided that such controls are generally available for some area sources provides
support that such controls are reasonably available.
The fact that many state regulations practically require such controls for EIFs suggests that such controls
might be reasonable. Specifically, Table 6-3 lists state regulations from the six states with the highest
foundry metal melting rates.177 Five of the six states require opacity limits resulting from fugitive
process emissions, and therefore might practically require implementation of such control measures to
control fugitive process lead emissions.
176NESHAP for Iron and Steel Foundries Area Sources. 40 CFR 63. Subpart ZZZZZ (Published April 22. 2004).
177National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page
4-49.
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6.4.8. Pollution prevention measure of using scrap management practices and materials specifications to
reduce HAP content of scrap.
EPA conducted an assessment of the impacts of meeting different candidate control options using three
different model plants (small model plant with capacity of 500 TPY, medium model plant with capacity
of 5,000 TPY, and large model plant with capacity of 50,000 TPY). One such control option was use of
scrap management practices to reduce HAP content of scrap.178 EPA decided such measure was cost
effective enough to include as GACT for small and large area sources. Moreover, the source must
prepare and operate at all times according to written material that (1) provides for the purchase and use
of only iron and steel scrap that has been depleted (to the extent practicable) of HAP metals in the
charge materials used by the iron and steel foundry; (2) provides for metallic scrap materials charged to
a scrap preheater or metal melting furnace to be depleted (to the extent practicable) of the presence of
accessible lead-containing components (such as batteries and wheel weights), except that for scrap
charged to a cupola metal melting furnace that is equipped with an afterburner, specifications for
metallic scrap materials to be depleted (to the extent practicable) of the presence of chlorinated plastics
and accessible lead-containing components (such as batteries and wheel weights), and (3) must provide
specifications of a program to ensure the scrap materials are drained of free liquids.179
6.4.9. Other control measures for controlling fugitive process and dust emissions.
The NESHAP for Iron and Steel Foundries Area Sources (40 CFR 63, Subpart ZZZZZ) prohibits
discharging to the atmosphere fugitive emissions from foundry operations that exhibit a certain opacity
limit. This suggests that there might be other fugitive control measures that might be reasonably
available since EPA decided such a limit was generally available.
178NESHAP for Iron and Steel Foundries Area Sources. 40 CFR 63. Subpart ZZZZZ (Published April 22. 2004).
179Memorandum - Impact Estimates for Area Source Iron and Steel Foundries. From Conrad Chin. EPA/SPPD. To EPA
Docket Number EPA-HQ-OAR-2006-0359-0005-1. September 4. 2007. Page 4.
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7.0. RACM DEVELOPMENT FOR THE INTEGRATED IRON AND
STEEL MILLS SOURCE CATEGORY.
This section presents control measures to consider for RACM development for the Iron and Steel Mills
source category. Section 7.1 provides an overview of the Iron and Steel Mills source category. Section
7.2 provides a summary of operations and lead emission points for iron and steel mill facilities. Section
7.3 provides a summary of the control measures utilized at iron and steel mill facilities, and Section 7.4
provides a more detailed application of the RACM criteria to each identified control measure.
7.1. Overview of Source Category.
The Iron and Steel Mills source category includes plants engaged in producing steel. A fully integrated
facility produces steel from raw materials of coal, iron ore, and scrap; whereas non-integrated plants do
not have all of the equipment to produce steel from coal, iron ore, and scrap on-site.180 The
corresponding NAICS Code for the Integrated Iron and Steel Mills source category is 331111. The
NAICS Description for facilities with such NAICS Code is "establishments primarily engaged in one or
more of the following: direct reduction of iron ore, manufacturing pig iron in molten or solid form,
converting pig iron into steel, making steel, making steel and manufacturing shapes, and making steel
and forming tube and pipe.181
As of 2001, there are roughly twenty integrated iron and steel mills in the United States. The highest
geographic concentration of mills is in the Great Lakes Region. Large, fully-integrated iron and steel
mills have declined considerably in the fifteen year time period before 2001. For example, of the iron
and steel mills that were open during such fifteen year period and still open in 2001, such plants
experienced a 61 percent reduction in the number of production employees over the 15 year period.182
7.2. Facility Operations and Lead Emission Points.
Integrated iron and steel mills engage in processes that include the following process units: (1) sinter
production, (2) iron production (hot metal desulfurization), (3) steel production, (4) semi-finished
product preparation, (6) finished product preparation, and (7) handling and treatment of raw,
intermediate, and waste materials. The iron production process includes the production of iron in blast
furnaces by reduction. The steel production process includes basic oxygen process furnaces (BOPF).
The discussion of emission points for lead will be discussed by the following three categories: sinter
plants, blast furnaces, and BOPF shops.183 Sintering is a process that recovers the raw material value of
waste materials generated at iron and steel plants that would otherwise be landfilled or stockpiled. An
important function of the sinter plant is to return waste iron-bearing materials to the blast furnace to
produce iron and to also provide part or all of the flux material for the iron-making process.184
The sinter plant windbox serves as the capture system for the sintering machine and is the most critical
source of emissions in the sinter plant. After the sinter materials are mixed, they are ignited on the
180National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and Steel Plants - Background
Information for Proposed Standards. EPA-453/R-01-005 (Published January 2001). Page 2-1.
181The North American Industry Classification System Website.
182National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and Steel Plants - Background
Information for Proposed Standards. EPA-453/R-01-005 (Published January 2001). Page 2-3.
183Id. at 1-2.
184Id. at 3-1.
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surface by gas burners, and as the materials move through the sinter bed, air is pulled down through the
mixture to burn the fuel by downdraft combustions through a series of windboxes, and evacuated to a
control device. The control devices used to control lead emissions from windboxes are fabric filters and
wet scrubbers.185
The sinter plant emission points on the discharge end include sinter discharge, crusher, hot screen, sinter
cooler, and cold screen. Such emissions points are generally hooded individually with an enclosed hood
or a suspended hood and evacuated to one or more control devices. Possible control devices include
fabric filters and water sprays at various transfer points. Possible controls for storage areas include
chemical dust suppression.186
Casthouse emissions from molten iron and slag occur primarily at the tape hole of the blast furnace in
the iron trough immediately adjacent to it. Emissions also result from the runner that transports the iron
and slag and from the ladle that receives the molten iron. The capture and control systems in place for
such emissions include a combination of flame suppression and covered runners, and also evacuation of
such emissions to a control device, most commonly a fabric filter (which requires total enclosures of the
casthouse) and scrubbers.187
The BOPH primary emissions refer to those emissions leaving the mouth of the furnace vessel during
the oxygen blow that are captured by the primary hood. The associated controls for BOPH depend on
whether the BOPH is associated with an open-hood design or a closed-hood design. Open-hood BOPF
shops are controlled with scrubbers and ESP. Closed-hood designs are controlled with Venturi
scrubbers.188
The BOPF secondary emissions include a hot metal transfer, desulfurization, slag skimming, charging,
turndown, tapping, deslagging, teeming, ladle maintenance, flux handling slag handling and disposal,
and ladle metallurgy operations. Fabric filters, and less frequently, wet scrubbers, are used to control
secondary BOPF shop emissions.189
One source of secondary emissions are emissions that occur during the steps of the furnace cycle that
require the vessel to be tipped out from the hood include scrap charging, hot metal charging, sampling,
tapping, and deslagging. When the vessel is tipped, the primary control system may be rendered entirely
ineffective. Such emissions are captured and controlled by furnace enclosures and partial building
190
evacuation.
Other sources of secondary emissions are ancillary operations, including hot metal transfer,
desulfurization, and slag skimming. Such emissions are usually controlled by hooding ducted to a
control device separate from the primary control device.191
After hot metal is refined into steel in the BOPH, further alloy additions and refining of the steel occur
during ladle treatment and vacuum degassing. Most BOPF shops have a separate ladle metallurgy
185Id. at 4-1.
186Id. at 4-7.
187Id. at 4-9.
188Id. at 4-17.
189Id.at4-25.
190Id
52
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stations. Such emissions are generally captured and controlled from ladle metallurgy operations using a
fabric filter, although wet scrubbers are also used.
192
7.3. Identification and Summary of Possible RACM Candidates.
Table 7-3 provides a summary of control measures used in the Iron and Steel Foundries source category
for which the RACM criteria are applied in section 7.4 and the relative likelihood that each control
measure is a RACM. Specifically, each control measure is assigned a rating of 1 through 3; where the
higher the number, the more likely that the control measure is a RACM. Such assigned values are
explained in Table 7-1.
Table 7-1. General Meanings of Assigned RACM Ratings.
RACM
Rating
1
2
3
U
(+ or -)
General Meaning of RACM Rating
There is limited support for identifying the control measure as a RACM.
There is some support for identifying the control measure as a RACM; more than for a control measure
with a RACM Rating of "1."
There is substantial support for identifying the control measure as a RACM.
A "U" indicates that the likelihood that the control measure constitutes a RACM is undetermined due
to incomplete information. A corresponding "+" indicates that despite incomplete information, an
application of RACM criteria would likely suggest that the control measure is a RACM, while a "-"
indicates that despite incomplete information, an application of the RACM criteria would likely
suggest that the control measure is not a RACM.
Table 7-2. Iron and Steel Foundries Source Category - Summary of Known Control Measures and
Relative Likelihood that each Control Measure is RACM.
RACM
Rating
Control Measure
Brief Reasoning for RACM Rating
Control devices (e.g., fabric filters
and wet scrubbers) to control process
lead emissions from sinter plant
windboxes.
1. Complete adoption by sources.
2. Cost data suggest cost effective.
3. Identified as MACT roughly 8 years ago.
4. All sources are subject to state regulations or
permits that practically require such controls.
Control devices to control process
lead emissions from sinter plant
discharge end emissions points (e.g.,
discharges, crushers, hot screens,
coolers, and cold screens).
1. Almost complete adoption by sources for such
emissions points.
2. Cost data suggest cost effective.
3. Identified as MACT roughly 8 years ago.
4. All sources are subject to state regulations or
permits that practically require such controls.
1.5
Control measures to control fugitive
lead dust emissions from material
handling (i.e., material storage,
material mixing, and sinter storage) at
sinter plants.
1. Low adoption of such measures by sources.
2. No cost data identified.
3. Not required by any known federal regulations.
4. Five of the 7 operating sinter plants are subject
to a building opacity standard to limit releases of
fugitive emissions that might practically require
such controls.
Control measures (e.g., flame
suppression, covered runners, and
control devices) to control process
1. Widespread adoption of such measures by
sources.
2. Cost data suggest cost effective.
2ld. at 4-30.
53
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RACM
Rating
Control Measure
Brief Reasoning for RACM Rating
lead emissions from casthouses at
iron and steel mills.
3. Identified as MACT roughly 8 years ago.
4. 24/29 casthouses are subject to visible
emissions standards that limit the opacity of
emissions discharged from casthouse openings
that might practically require such controls.
Control devices (e.g., scrubbers and
ESPs) to control process lead
emissions from BOPF shops at iron
and steel mills.
1. Complete adoption by sources.
2. Cost data suggest cost effective.
3. Identified as MACT roughly 8 years ago.
4. All BOPH shops are subject to state regulations
or permit requirements that might practically
require such controls.
Control measures to control fugitive
process lead emissions from BOPF
shops at iron and steel mills for
various operations (e.g., hot metal
reladling, hot metal desulfurization,
skimming, charging, tapping).
1. Complete adoption by sources.
2. Cost data suggest cost effective.
3. Identified as MACT roughly 8 years ago.
4. All BOPH shops are subject to state regulations
or permit requirements that might practically
require such controls.
Control devices (e.g., wet scrubbers
and fabric filters) to control fugitive
process lead emissions from ladle
metallurgy stations at iron and steel
mills.
1. Complete adoption by sources.
2. Cost data suggest cost effective.
3. Identified as MACT roughly 8 years ago.
4. All ladle metallurgy processes are subject to
state regulations or permit requirements that might
practically require such controls.
U
Replacing old control devices with
new control devices.
1. At least two sources have been identified as
needing to replace old control devices (> 30 years
old) to meet new emission standards.
2. No cost data identified.
3. Not required by any known federal regulations.
7.4. Application of RACM Criteria to Possible RACM Candidates.
7.4.1. Control devices (e.g.. fabric Filters and wet scrubbers) to control process lead emissions from
sinter plant windboxes.
The complete adoption of control devices (e.g., fabric filters and wet scrubbers) for controlling process
lead emissions from sinter plant windboxes suggests that such controls are economically feasible.
Specifically, all nine sinter plants use a control device to control process lead emissions from sinter plant
windboxes. Four plants use a fabric filter and five plants use a wet scrubber to control windbox
193
emissions.
In addition, the available data suggest that such controls are cost effective for regulating process lead
emissions. Specifically, cost-effectiveness information for PM was available for selected control
technologies in the source category of Iron and Steel Production, as shown in Table 7-3.194 This
information suggests that such controls are cost effective for regulating lead as well.
"Id. at 4-1.
4EPA CoST database.
54
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Table 7-3. Cost-Effectiveness Information for Selected Control Technologies for Controlling
Particulate Matter with respect to the Iron and Steel Production Source Category.
Control Technology
Dry Electrostatic Precipitator - Wire Plate Type
Fabric Filter - Reverse- Air Cleaned Type
Fabric Filter (Mech. Shaker Type)
Fabric Filter - (Pulse Jet Type)
Venturi Scrubber
WESP - Wire Plate Type
Cost Effectiveness
($/ton PM)
200
250
200
200
3350
350
Low/High Control
Efficiency (%)
95/98
99/99.5
99/99.5
99/99.5
25/73
99/99.5
* Rounded to the nearest $50 and escalated from 1999 to 201 1 U.S. dollars.1*
Moreover, such controls are practically required by the NESHAP for Integrated Iron and Steel Plants (40
CFR 63, Subpart FFFFF) for both new and existing sources, as such NESHAP provides emissions limits
for sinter plant windboxes. This might further provide some support that such controls are RACM, since
such controls represent MACT standards that are over 8 years old.196
State regulations and permits further suggest such controls are reasonably available. Specifically, all
sinter plants are subject to state regulations or permit requirements that practically require such control
devices for sinter plant windoxes.197
7.4.2. Control devices (e.g., fabric filters and wet scrubbers) to control process lead emissions from
sinter plant discharge end emissions points (e.g., discharges, crushers, hot screens, coolers, and
cold screens).
The almost complete adoption of control devices (e.g., fabric filters and wet scrubbers) for controlling
process lead emissions from sinter plant discharge and emission points (i.e., discharges, crushers, hot
screens, coolers, and cold screens) suggests that such controls are economically feasible. Specifically, all
9 sinter plants with discharge emission points use a control device (7 fabric filters, 1 scrubber, 1
rotozone) to control process lead emissions from discharge emissions points; all 7 sinter plants with
sinter plant crusher emission points use a control device (6 fabric filters, 1 scrubber) to control process
lead emissions from crusher emission points; all 8 sinter plants with sinter plant hot screen emission
points use a control device (6 fabric filters, 1 scrubber, 1 rotozone) to control process lead emissions
from hot screen emission points; 5 of the 8 (3 fabric filters, 1 cyclone, 1 water sprays) sinter plants with
sinter plant cooler emission points use a control to control process lead emissions from cooler emissions
points; and 5 of the 7 sinter plants with sinter plant cold screen emission points control (3 fabric filters, 2
water sprays) cold screen emission points.198
In addition, the available data suggest that such controls are cost effective for regulating process lead
emissions. Specifically, cost-effectiveness information for PM was available for selected control
195In order to escalate from 1999 dollars to 2011 dollars, used the formula and approach presented in EPA's Control Strategy
Tool (CoST) Control Measures Database (CMPB) Documentation. Page 9.
196-
197
'NESHAP for Integrated Iron and Steel Plants Major Sources. 40 CFR 63. Subpart FFFFF (Published May 20. 2003).
National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and Steel Plants - Background
Information for Proposed Standards. EPA-453/R-01-005 (Published January 2001). Page 5-1.
198Id. at 4-30.
55
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technologies in the source category of Iron and Steel Production, as shown in Table 7-3.199 This
information suggests that such controls are cost effective for regulating lead as well.
Moreover, such controls are practically required by the NESHAP for Integrated Iron and Steel Plants (40
CFR 63, Subpart EEEEE) for both new and existing sources, as such NESHAP provides PM emissions
limits for discharge ends at sinter plants. This provides some support that such controls are RACM,
since such controls represent MACT standards that are over 8 years old.200
State regulations and permit requirements further suggest such controls are reasonably available.
Specifically, sinter plants are subject to state regulations or permit requirements that practically require
such control devices to control sinter plant discharge and emission points.201
7.4.3. Control measures to control fugitive lead dust emissions from material handling (i.e., material
storage, material mixing, and sinter storage) at sinter plants.
The less widespread control of fugitive lead dust emissions from material handling (i.e., material
storage, material mixing, and sinter storage) at sinter plants suggests that such controls are not
economically feasible. Specifically, emissions from material handling are generally fugitive emissions
and are usually uncontrolled. Only one sinter plant in the country uses a fabric filter to control emissions
from material storage; the remaining plants use no control. One plant uses water sprays to wet the
materials at the various transfer points. One plant uses chemical dust suppression on the product to
control material storage.202
State regulations and permit requirements provide some support that there are control measures that
might be reasonable. Specifically, 5 of the 7 operating sinter plants are subject to state regulation or
permit requirements that require building opacity limits that might practically require such controls.203
7.4.4. Control measures (i.e.. flame suppression, covered runners, and control devices) to control
process lead emissions from casthouses at iron and steel mills.
The widespread use of control measures (i.e., flame suppression, covered runners, and control devices)
to control process lead emissions from casthouses at iron and steel mills suggests that such control
measures are economically feasible. Specifically, 12 of the 20 iron and steel mills use flame suppression
at casthouses to control process lead emissions; 15 of the 20 iron and steel mills use covered runners at
casthouses to control process lead emissions; and 13 of the 20 iron and steel mills evacuate process lead
emissions to a control device (12 fabric filters, 1 scrubber).204
In addition, the available data suggest that the control devices used are cost effective for regulating
process lead emissions. Specifically, cost-effectiveness information for PM was available for selected
control technologies in the source category of Iron and Steel Production, as shown in Table 7-3, where
199EPA CoST database.
200NESHAP for Integrated Iron and Steel Plants Major Sources (40 CFR 63. Subpart FFFFFX
201National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and Steel Plants - Background
Information for Proposed Standards. EPA-453/R-01-005 (Published January 2001). Page 5-1.
202Id. at 4-7 to 4-8.
203Id.at5-l.
204Id. at 4-10.
56
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cost-effectiveness values for fabric filters, ESPs and scrubbers all seem reasonable when used.205 This
information suggests that such controls are cost effective for regulating lead as well.
Moreover, such controls are practically required by the NESHAP for Integrated Iron and Steel Plants (40
CFR 63, Subpart EEEEE) for both new and existing sources, as such NESHAP provides PM emissions
limits for casthouses at blast furnaces. This might further provide some support that such controls are
RACM, since such controls represent MACT standards that are over 8 years old.206
State regulations and permit requirements suggest that such controls measures are reasonable.
Specifically, 24 of the 29 casthouses are subject to visible emission standards by state regulations or
permits that limit the opacity of emissions discharged from casthouse openings, and therefore that might
practically require such control measures.207
7.4.5. Control devices (e.g., scrubbers and ESPs) to control process lead emissions from BOPF shops at
iron and steel mills
The complete adoption of control measures to control process lead emissions from BOPH shops at iron
and steel mill suggests that such controls are economically feasible. Specifically, all BOPH shops at iron
and steel mills use a capture system and control device to control process lead emissions from BOPF
shops. Specifically, all 16 open-hood BOPF shops use control devices (8 Venturi scrubbers, 8 ESPs) to
control such emissions, and all 8 of the closed-hood BOPH shops use control devices (8 Venturi
scrubbers) to control such emissions.208
In addition, the available data suggest that such controls are cost effective for regulating process lead
emissions. Specifically, cost-effectiveness information for PM was available for selected control
technologies in the source category of Iron and Steel Production, as shown in Table 7-3, where cost-
effectiveness values for fabric filters, ESPs and scrubbers are reasonable when used.209 This information
suggests that such controls are cost effective for regulating lead as well.
Moreover, such controls are practically required by the NESHAP for Integrated Iron and Steel Plants (40
CFR 63, Subpart EEEEE) for both new and existing sources, which provides PM emissions limits for
BOPFs. This might further provide some support that such controls are RACM, since such controls
represent MACT standards that are over 8 years old.210
State regulations and permit requirements suggest that such controls measures are reasonable.
Specifically, all BOPH shops are subject to states regulations or permit requirements that might
practically require such controls.211
205EPA CoST database.
206NESHAP for Integrated Iron and Steel Plants Major Sources. 40 CFR 63. Subpart FFFFF (Published May 20. 2003).
207Id.at5-l.
208Id. at 4-20 to 4-21.
209EPA CoST database.
210NESHAP for Integrated Iron and Steel Plants Major Sources. 40 CFR 63. Subpart FFFFF (Published May 20. 2003).
21 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and Steel Plants - Background
Information for Proposed Standards. EPA-453/R-01-005 (Published January 2001). Page 5-9.
57
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7.4.6. Control measures to control fugitive process lead emissions from BOPF shops at iron and steel
mills for various operations (e.g., hot metal reladling, hot metal desulfurization, skimming,
charging, tapping).
The widespread use of control measures to control fugitive process lead emissions from BOPH shops at
iron and steel mills for various operations (e.g., hot metal reladling, hot meal desulfurization, skimming,
charging, and tapping) suggests that such measures are economically feasible. Generally, iron and steel
mills use control measures to control process fugitive lead emissions from BOPH shops for hot metal
reladling, hot metal desulfurization, skimming, and charging. Specifically, 22 of the 23 BOPHs control
such emissions for hot metal reladling (13 fabric filters, 4 fabric filters with hoods, 2 fume suppression,
1 flame suppression, 1 with two fabric filters); 23 of the 23 BOPHs control such emissions for hot metal
desulfurization (17 fabric filters, 5 fabric filters with hoods, 1 with two fabric filters); 17 of the 23
BOPHs control such emissions for skimming (12 fabric filters, 5 fabric filters with hoods); 21 of the 23
BOPHs control such emissions for charging (4 fabric filters, 6 fabric filters with hoods, 5 scrubbers, 6
electrostatic precipitators).212
Moreover, such controls are practically required by the NESHAP for Integrated Iron and Steel Plants (40
CFR 63, Subpart EEEEE) for both new and existing sources, which provides PM emissions limits for
each hot metal transfer, skimming, and desulfurization operation. This provides support that such
controls are RACM, since such controls represent MACT standards that are over 8 years old.213
State regulations and permit requirements suggest that such controls measures are reasonable.
Specifically, all BOPH shops are subject to states regulations or permit requirements that might
practically require such controls.214
7.4.7. Control devices (e.g., wet scrubbers and fabric filters) to control fugitive process lead emissions
from ladle metallurgy stations at iron and steel mills.
The complete adoption of control devices (e.g., wet scrubbers and fabric filters) to control fugitive
process lead emissions from ladle metallurgy stations at iron and steel mills suggests that such controls
are economically feasible. All ladle metallurgy stations at iron and steel mills control process lead
emissions with control devices (3 wet scrubbers, 21 fabric filters).215
In addition, the available data suggest that such controls are cost effective for regulating process lead
emissions. Specifically, cost-effectiveness information for PM was available for selected control
technologies in the source category of Iron and Steel Production, as shown in Table 7-3, where cost-
effectiveness values for fabric filters, ESPs and scrubbers are reasonable when used.216 This information
suggests that such controls are cost effective for regulating lead as well.
Moreover, such controls are practically required by the NESHAP for Integrated Iron and Steel Plants (40
CFR 63, Subpart EEEEE) for both new and existing sources, as such NESHAP provides PM emissions
212Id. at 4-30.
213NESHAP for Integrated Iron and Steel Plants Major Sources. 40 CFR 63. Subpart FFFFF (Published May 20. 2003).
214National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and Steel Plants - Background
Information for Proposed Standards. EPA-453/R-01-005 (Published January 2001). Page 5-12.
215Id. at 4-35 to 4-37.
216EPA CoST database.
58
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limits for each ladle metallurgy operation. This might further provide some support that such controls
are RACM, since such controls represent MACT standards that are over 8 years old.
217
State regulations and permit requirements suggest that such control measures are reasonable.
Specifically, all ladle metallurgy stations are subject to state regulations or permit requirements that
might practically require such controls.218
7.4.8. Replacing Old Control Devices with New Control Devices.
The age and recent identification of plants that need to replace old control devices with new control
devices to meet emission standards suggests that such a measure may become more economically
feasible. Specifically, scrubbers over 30 years old have been identified to be replaced in order to meet
emission limits at two plants.219
217NESHAP for Integrated Iron and Steel Plants Major Sources. 40 CFR 63. Subpart FFFFF (Published May 20. 2003).
218National Emission Standards for Hazardous Air Pollutants (NESHAP) for Integrated Iron and Steel Plants - Background
Information for Proposed Standards. EPA-453/R-01-005 (Published January 2001). Page 5-15.
219Economic Impact Analysis of Final Integrated Iron and Steel NESHAP. EPA 452/R-02-009 (Published September 2002).
Page 3.
59
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8.0. RACM DEVELOPMENT FOR FUGITIVE DUST CONTROL
MEASURES
Sections 4 through 7 supported RACM development with respect to certain source categories -
Secondary Lead Smelting, Lead Acid Battery Manufacturing, Iron and Steel Foundries, and Iron and
Steel Mills. Such previous sections generally provided an undetermined likelihood that fugitive dust
control measures would be RACM for most of the source categories. This section applies the RACM
criteria to fugitive dust control measures to glean what considerations are most vital for determining
whether fugitive dust control measures, in general, are reasonably available.
8.1. The Economic Feasibility of Fugitive Dust Control Measures.
Support documents drafted from information collection requests for NESHAP development for the
Secondary Lead Smelting, Lead Acid Battery Manufacturing, and Iron and Steel Foundries suggest that
fugitive dust control measures are most economically feasible for the largest emitting sources.
Table 8.1 shows the average lead emissions emitted per facility for a given source category. Such table
indicates that on average, there is 3 to greater than 10 times more lead being emitted per secondary lead
smelting facility than from any typical source from one of other source categories included in Table 8.1.
Table 8.2 shows the extent to which facilities have adopted fugitive dust control measures, as indicated
from the most recent information collection requests for NESHAP development. The source category of
secondary lead smelting is the only source category with sources to have adopted several fugitive dust
control measures. This suggests that fugitive dust controls are most economically feasible for sources
that emit a high level of emissions.
Table 8-1. Calculation of the Average Annual Lead Emissions Emitted per Facility in a Given
Source Category.
Source Category
Iron and Steel Foundries
Secondary Lead Smelting
Lead Acid Battery
Manufacturing
Annual
Emission
(Tons/Year)
220
83
14
17
% of Total
Emissions from
All Source
Categories221
6.05
3.21
1.24
Number of
Sources
> 2000 222
15 ^
60 224
Calculated
Average Lead
Emissions per
Facility
(Tons/Year)
0.04
1.00
0.12
220The Regulatory Impact Analysis of the Proposed Revisions to the National Ambient Air Quality Standards for Lead
(Published October 2008). Page 7.
221Id
222National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page
1-2.
223Memorandum - Draft Summary of the Technology Review for the Secondary Lead Smelting. From Mike Burr. ERG. To
Chuck French. EPA/OAOPS. April 2011.
224Memorandum - Lead Acid Battery Manufacturing Area Source Category Additional Information to Support Proposed
Rule. From Nancy Jones. EC/R. To U.S. EPA Docket Number EPA-HQ-OAR-2006-0897. February 28. 2007.
60
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Table 8-2. Extent of Known Adoption of Fugitive Dust
Smelting, Lead Acid Battery Manufacturing, and Iron
Control Measures in the Secondary Lead
and Steel Foundry Source Categories.
Paving unpaved roads
Cleaning paved road
Chemical stabilization of unpaved
roads
Paving of entire facility grounds
Cleaning of building roofs and
exteriors
Enclosure hoods and partial
enclosures for storage areas
Wet suppression on storage piles
Negative pressure total enclosures
for storage areas
Vehicle washing at each facility exit
Vehicle washing inside building
Use of daily ambient monitoring to
diagnose activities that lead to
NAAQS exceedances for lead.
Secondary Lead
„ ... 225
Smelting
Adoption by all sources
Adoption by all sources
No known adoption
Adoption by several sources
Adoption by several sources
Adoption by all sources
Adoption by all sources
Adoption by 11 of the 14
sources
Adoption by all sources
Adoption by several sources
Adoption by several sources
Lead Acid Battery
Manufacturing
No known
widespread
adoption228
No known adoption
No known adoption
No known adoption
No known adoption
No known adoption
No known adoption
No known adoption
No known adoption
No known adoption
No known adoption
Iron and Steel
T^ j • 227
Foundries
No known adoption
No known adoption
No known adoption
No known adoption
No known adoption
No known adoption
No known adoption
No known adoption
No known adoption
No known adoption
No known adoption
8.2. The Capital Costs, Annualized Costs, and Cost Effectiveness of Fugitive Dust Control
Measures.
Cost-effectiveness data for fugitive dust control measures are not well-developed. This might be due to
the fact that the cost effectiveness of a specific fugitive dust control measure is highly variable from
plant-to-plant. The cost effectiveness will depend on many variables that can change from plant-to-plant
with even similar levels of emissions, such as the length of roads to be paved, the historic use of
emissions that might already be deposited around the plant, etc.
However, the available cost-effectiveness data indicate that process emission control measures are much
more cost effective (by a factor of 2-4) than fugitive dust control measures. Table 8.3 displays the cost-
effectiveness data for three fugitive dust control measures averaged for all sources in all source
categories compared to cost effectiveness of mechanical shaker type fabric filters at iron and steel
foundries, iron and steel mills, and lead processing facilities.229 Such comparison indicates the fugitive
dust control measures are much less cost effective than the use of fabric filters.
225Memorandum - Draft Summary of the Technology Review for the Secondary Lead Smelting. From Mike Burr. ERG. To
Chuck French. EPA/OAQPS. April 2011.
226Memorandum - Lead Acid Battery Manufacturing Area Source Category Additional Information to Support Proposed
Rule. From Nancy Jones. EC/R. To U.S. EPA Docket Number EPA-HQ-OAR-2006-0897. February 28. 2007..
227National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Iron and Steel Foundries - Background
Information for Proposed Standards. Document # EPA-HQ-OAR-2006-0359-0056-0002-1 (Published December 2002). Page
1-2.
228One battery manufacturing facility - the Exide Battery Manufacturing facility in Salina, KS - has paved unpaved roads to
control fugitive emissions. Stephanie Doolan / EPA Region 7.
229EPA CoST database.
61
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Table 8-3. Cost Effectiveness of Fugitive Dust Control Measures Compared to Fabric Filters.
Control Measure
Vacuum Sweeping Paved Roads
Hot Asphalt Paving of Unpaved
Roads
Chemical Stabilization of
Unpaved Road
Fabric Filter (Mech. Shaker
Type)
Fabric Filter (Mech. Shaker
Type)
Fabric Filter (Mech. Shaker
Type)
Source Category
Average of all
Average of all
Average of all
Average of Iron
and Steel
Foundries
Iron and Steel
Production
Lead Processing
Cost Effectiveness
($/ton PM)
550
700
3200
200
200
450
Control
Efficiency
(%)
50.0
66.6
37.5
99.5
99.5
99.5
* Rounded to the nearest $100 and escalated from 1999 to 201 1 U.S. dollars/'"
8.3. Fugitive Dust Control Measures Adopted in Federal and State Regulations.
The extent to which state and federal regulations require fugitive dust control measures further suggest
that such control measures are more reasonable for larger sources. Table 8.4 shows the extent of
adoption of several fugitive control measures by California's SCAQMD and the NESHAPs for
Secondary Lead Smelting Major Sources, Lead Acid battery Manufacturing Area Sources, Iron and
Steel Foundry Area Sources, and Iron and Steel Foundry Major Sources. Several fugitive dust control
measures are adopted by the NESHAP for Secondary Lead Smelting for Major Sources, where the
average lead emissions per facility are highest; whereas no fugitive dust control measures are adopted by
the NESHAP for Lead Acid Battery Manufacturing for Area Sources, where the average lead emitted
per facility is smaller. Moreover, no fugitive dust control measures are required by the NESHAP for Iron
and Steel Foundries Area Sources, but there is at least a limit that applies to fugitive dust lead emissions
in the NESHAP for Iron and Steel Foundries Major Sources. This further indicates that the amount of
lead emissions emitted for a facility is a key consideration when determining whether fugitive dust
control measures are reasonable.
Moreover, California's SCAQMD Rule 1420, requires secondary lead smelting and lead acid battery
manufacturing facilities to implement several fugitive dust control measures. The fact that California
requires such adoption might suggest that fugitive dust control measures are not out of economic reach
for small lead acid battery area sources. However, California's SCAQMD Rule 1420.1 applies only to
large secondary lead smelting sources, and requires even more stringent fugitive dust control measures
than Rule 1420, which further suggests that fugitive dust control measures are more cost effective for
the largest lead emitting sources.
In order to escalate from 1999 dollars to 2011 dollars, used the formula and approach presented in EPA's Control Strategy
Tool (CoST) Control Measures Database (CMDB) Documentation. Page 9.
62
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Table 8-4. Extent of Known Adoption of Fugitive Dust Control Measures in Selected Federal and
State Regulations
Paving unpaved
roads
Cleaning paved
road (e.g., vacuum
sweeping)
Chemical
stabilization of
unpaved roads
Paving of entire
facility grounds
Cleaning of
building roofs and
exteriors
Enclosure hoods
and partial
enclosures for
storage areas
Wet suppression
on storage piles
Cleaning of
pavement around
operation / storage
area
1997
NESHAP
Secondary
Lead
Smelting
for Major
Sources231
Adopted
Adopted
Not adopted
Not adopted
Not adopted
Adopted
Adopted
Adopted
NESHAP Lead
Acid Battery
Manufacturing
Areas Sources
232& NESHAP
Iron and Steel
Foundries
Area
Sources233
Not adopted
NESHAP
Iron and Steel
Foundries
Major
Sources234
Not adopted
California's
SCAQMD Rule for
Lead Processing
Facilities
(includes Lead
Acid Battery
Manufacturing
Secondary Lead
Smelting, Iron and
Steel Foundries),
Rule 1420 235236
Not adopted
Requires that
surfaces that
accumulate lead-
containing dust due
to traffic be washed,
vacuumed once /
week or chemically
suppressed.
Not adopted
Not adopted
Not adopted
Requires that dust
forming material to
be stored in an
enclosed storage
area.
Not adopted
Requires surfaces
that accumulate lead
dust due to foot
traffic be washed,
vacuumed, or wet-
California's SCAQMD
Rule for Lead from
Large Lead Acid
Battery Recycling
Facilities, Rule 1420.1.
237, 238
Requires paving facility
grounds.
Requires frequent
cleaning by wet wash or
vaccum of such areas.
Not adopted
Requires paving facility
grounds.
Requires frequent
cleaning of building
roofs and exteriors.
Requires total enclosures
under negative pressure
for several areas.
Requires total enclosures
under negative pressure
for several storage areas.
Requires frequent
cleaning of such areas by
wet wash or vacuum.
231NESHAP for Secondary Lead Smelting. 40 CFR 63. Subpart X (Published June 13. 1997).
232NESHAP for Lead Acid Battery Manufacturing Plants. 40 CFR 63 Subpart PPPPPP (Published July 16. 2007)..
233NESHAP for Iron and Steel Foundries Area Sources. 40 CFR 63. Subpart ZZZZZ (Published April 22. 2004).
234NESHAP for Iron and Steel Foundries Major Sources. 40 CFR 63. Subpart EEEEE (Published April 22. 2004).
235California (South Coast Air Quality Management District). Rule 1420 - Emission Standards for Lead (Published
September. 1992).
236The fugitive dust control requirements of California's SCAQMD Rule 1420 only apply to facilities that exceed specified
processing thresholds (more than 2 tons of lead per year).
237California (South Coast Air Quality Management District). Rule 1420.1 - Emission Standards for Lead from Large Lead
Acid Battery Recycling Facilities (Adopted November 5. 2010).
238California (South Coast Air Quality Management District). Rule 1420.1 - Emission Standards for Lead from Large Lead
Acid Battery Recycling Facilities (Adopted November 5. 2010). Note that
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Negative pressure
total enclosures
Vehicle washing at
each facility exit
Vehicle washing
inside building
Daily ambient
monitoring to
diagnose activities
that lead to
NAAQS
exceedances for
lead
Limit for fugitive
dust emissions
Storage , disposal,
recovery, or
recycling of lead
or lead-containing
wastes generated
from
housekeeping
activities using
practices that do
not lead to fugitive
lead-dust
emissions
1997
NESHAP
Secondary
Lead
Smelting
for Major
Sources231
Not adopted
Not adopted
Not adopted
Not adopted
Not adopted
Not adopted
NESHAP Lead
Acid Battery
Manufacturing
Areas Sources
232& NESHAP
Iron and Steel
Foundries
Area
Sources233
Not adopted
NESHAP
Iron and Steel
Foundries
Major
234
Sources
Adopted an
opacity limit
that applies to
fugitive dust
sources.
Not adopted
California's
SCAQMD Rule for
Lead Processing
Facilities
(includes Lead
Acid Battery
Manufacturing
Secondary Lead
Smelting, Iron and
Steel Foundries),
Rule 1420 235 236
mopped once per
week or chemically
suppressed
Not adopted
Not adopted
Not adopted
Requires 24 hour
monitoring (once
very six days) if a
facility processes
more than 2 tons of
lead per year and
emits lead equal to
or greater than 0.5
Ibs/day.239
Requires an opacity
limit where
emissions cannot
exceed 0.5 or 10
percent opacity for
more than three
aggregate minutes in
any 60-minute
period.
Adopted.
California's SCAQMD
Rule for Lead from
Large Lead Acid
Battery Recycling
Facilities, Rule 1420.1.
237, 238
Requires total enclosures
under negative pressure
for several areas.
Not adopted
Not adopted
Requires 24 hour
monitoring once every
three days, and daily
monitoring if an
exceedance is revealed.
Not adopted
Not adopted.
239Facilities processing between 2-10 tons of lead per year may be exempted if modeling shows they are below half the
standard.
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8.4. Implications for RACM Development for Fugitive Dust Control Measures.
Available cost information suggests that process emission control measures (e.g., fabric filters) are
generally 2 to 4 times more cost effective than fugitive dust control measures. Moreover, the extent of
adoption of fugitive dust control measures by sources and federal/state regulations suggests that the most
important consideration in determining whether fugitive dust control measures are reasonably available
for a given source in a corresponding source category is the average amount of emissions emitted per
source in a given source category. Specifically, as the average amount of emissions per source in a given
source category increases, the more likely that fugitive dust control measures might be reasonably
available.
Nevertheless, additional considerations may suggest that fugitive dust control measures are reasonably
available for sources that have already adopted more cost-effective process emission controls (e.g.,
fabric filters). For example, EPA has indicated that where essential reductions are difficult to achieve
because many sources are already being controlled, the cost per ton of control may necessarily be higher
and be considered reasonable.240 Consequently, if a source has adopted process emission controls, but is
still contributing to a lead NAAQS violation, then fugitive dust controls might be the only viable option
to eliminate the NAAQS violation and may, therefore, be reasonable despite being less cost effective
than the initial cost of process emissions controls.
Also, additional considerations may suggest that fugitive dust control measures are RACM for sources
that are area sources or smaller emitting sources. For example, the fact that an area source is in an area
with more serious air quality problems may make it more reasonable and appropriate for such areas to
impose emission reduction requirements that are less cost effective.241 Consequently, if an area source is
contributing to a lead NAAQS violation, and there are no other viable sources from which emissions can
be reduced to get the area within attainment, then imposing less cost effective control measures to
smaller area sources might be more reasonable and appropriate. Moreover, EPA has indicated that a
large amount of historically deposited lead might increase the reasonableness of fugitive dust control
measures.242
In addition, EPA encourages the development of innovative measures not previously employed which
may also be technically and economically feasible.243 Therefore, the fact that fugitive dust control
measures have not been adopted by many facilities or federal/state regulations does not preclude the
240"In addition, where essential reductions are more difficult to achieve (e.g., because many sources are already controlled),
the cost per ton of control may necessarily be higher." National Ambient Air Quality Standards for Lead: Final Rule. 73 FR
66964. 67036 (Published November 12. 2008).
241 "Areas with more serious air quality problems typically will need to obtain greater levels of emissions reductions from
local sources than areas with less serious problems, and it would be expected that their residents could realize greater public
health benefits from attaining the standard as expeditiously as practicable. For these reasons, we believe that it will be
reasonable and appropriate for areas with more serious air quality problems and higher design values to impose emission
reduction requirements with generally higher costs per ton of reduced emissions than the cost of emissions reductions in areas
with lower design values." Id. at 67036
242"Some emissions that contribute to violations of the Lead NAAQS may also be attributed to smaller area sources. At
primary lead smelters, the process of reducing concentrated ore to lead involves a series of steps, some of which are
completed outside of buildings, or inside of buildings that are not totally enclosed. Over a period of time, emissions from
these sources have been deposited in neighboring communities (e.g., on roadways, parking lots, yards, and off-plant
property). This historically deposited lead, when disturbed, may be re-entrained into the ambient air and may contribute to
violations of the Lead NAAQS in affected areas. "Id.
243"EPA also encourages the development of innovative measures not previously employed which may also be technically
and economically feasible." IxL
65
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possibility that such fugitive dust control measures are RACM. For example, many control measures
such as bins, hoppers, totes, plastic curtains, moving stockpiles away from doors and traffic lanes, and
soil stabilization measures (e.g., landscaping of areas where lead emissions have been historically
deposited) are all measures that, on their faces, seem inexpensive and could lessen emissions.
Consequently, such measures might constitute RACM, especially when emission reductions are
necessary to attain the NAAQS and the availability of other control measures to implement is limited.
California's SCAQMD Rule 1420.1 requires a list of many such fugitive dust control measures that
facilities might consider. 244 A list of many of the fugitive dust control measures specified by Rule
1420.1 is provided in 4.4.9 of this document and in Table 8.4 of this document.
244California (South Coast Air Quality Management District). Rule 1420.1 - Emission Standards for Lead from Large Lead
Acid Battery Recycling Facilities (Adopted November 5. 2010).
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United States Office of Air Quality Planning and Standards EPA-457/R-12-001
Environmental Protection Air Quality Policy Division March 2012
Agency Research Triangle Park, NC
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