FACT SHEET Proposed Amendments to Air Toxics Standards for Lead Acid Battery Manufacturing Plants ACTION • On February 11, 2022, the U.S. Environmental Protection Agency (EPA) proposed to amend the 2007 National Emission Standards for Hazardous Air Pollutants (NESHAP) for Lead Acid Battery (LAB) Manufacturing Area Sources. In addition, the action proposes to update the 1982 New Source Performance Standards (NSPS), also known as the 1982 Standards of Performance for Lead Acid Battery Manufacturing Plants (subpart KK). • The LAB manufacturing source category includes any plant that produces lead acid batteries and their processes, including grid casting, paste mixing, lead oxide manufacturing, three- process operations (battery assembly) and lead reclamation. • The LAB manufacturing source category includes 40 facilities and 39 of these plants are area sources; all are subject to both the NESHAP and NSPS. o One major source was identified due to potential to emit (PTE) only; permit emission limits are equal to, or lower than, the limits in the NESHAP. o The facility is covered by the NSPS. • Following the technology review for the NESHAP and NSPS review conducted under the Clean Air Act (CAA), EPA is proposing to: o Revise lead emission limits for grid casting and lead reclamation operations for both the area source NESHAP (that applies to all new and existing area source facilities) and in the new NSPS update (subpart KKa) that applies to new, reconstructed, or modified sources; o Revise lead emission limits for paste mixing at large facilities (with capacity to process in one day an amount of lead greater than or equal to 150 tons) for both the NESHAP (that applies to new and existing large facilities) and for the new NSPS subpart that applies to new, reconstructed, or modified sources at large facilities; o Require periodic compliance testing of once every five years; o Establish work practices to minimize fugitive lead dust emissions; o Require bag leak detection systems for facilities with capacity to process - in one day - an amount of lead greater than or equal to 150 tons; o Increase inspection frequency of fabric filters that do not have secondary filters or bag leak detection systems; o Electronic reporting; and o Removal of exemptions for periods of startup, shut down, and malfunctions. • EPA is also proposing a revision to the applicability provisions in the area source NESHAP for facilities that make lead bearing battery parts or process input material, including, but not limited to, grid casting facilities and lead oxide manufacturing facilities. 1 ------- • EPA will accept comment on the proposed amendments for 60 days after publication in the Federal Register. TECHNOLOGY REVIEW • The CAA requires EPA to assess, review and revise air toxics standards, as necessary, taking into account developments in practices, processes, and control technologies. The technology review of the standards for lead acid battery manufacturing facilities did identify several developments, as described above, that would further reduce lead emissions beyond the original NESHAP. BACKGROUND • The CAA requires EPA to regulate toxic air pollutants, also known as air toxics, from categories of industrial facilities in two phases. • The first phase is "technology-based," where EPA develops standards for controlling the emissions of air toxics from sources in an industry group or "source category." For major sources, EPA must establish maximum achievable control technology (MACT) standards These MACT standards are based on emissions levels that are already being achieved by the best-controlled and lower-emitting sources in an industry. • For area sources, the CAA provides that, in lieu of setting MACT standards, the EPA may promulgate standards for area sources, "which provide for the use of generally available control technology (GACT) or management practices by such sources to reduce emissions of hazardous air pollutants." In developing such standards, the EPA evaluates the control technologies and management practices that reduce HAP emissions that are generally available. The 2007 NESHAP for LAB manufacturing area sources were established as GACT standards. • Also, every eight years after setting MACT or GACT standards, the CAA section 112 requires EPA to review and revise the standards, if necessary, to account for improvements in air pollution controls, practices, or processes. • With regard to the NSPS, CAA section 111 requires EPA to determine the best system of emission reduction (BSER) for the source category and the degree of emission limitation achievable through application of the BSER (taking into account the cost of achieving such reduction and any non-air quality health and environmental impact and energy requirements). EPA must then promulgate standards of performance for new sources that reflect that level of stringency. The 1982 NSPS were established based on BSER available at that time. • The CAA section 111 requires EPA to, "at least every eight years review and, if appropriate, revise," the NSPS. The EPA reviews available data and information to determine if BSER has changed and, if so, proposes revised standards to reflect such changes. 2 ------- HOW TO COMMENT • EPA will accept comment on the proposal for 60 days after publication in the Federal Register. • Comments, identified by Docket ID No. EPA-HQ-OAR-2021-0619, may be submitted by one of the following methods: o Go to https://www.reeulations.gov/ and follow the online instructions for submitting comments, o Send comments by email to: a-and-r-docket@epa.gov, Attention Docket ID No. EPA- HQ-OAR-2021-0619. • Out of an abundance of caution for members of the public and our staff, the EPA Docket Center and Reading Room are closed to the public, with limited exceptions, to reduce the risk of transmitting COVID-19. Our Docket Center staff will continue to provide remote customer service via email, phone, and webform. o We encourage the public to submit comments via https://www.regulations.gov/ or email, as there may be a delay in processing mail and faxes. Hand deliveries and couriers may be received by scheduled appointment only, o For further information on EPA Docket Center services and the current status, please visit us online at https://www.epa.eov/dockets. o For additional information, including the full EPA public comment policy, please visit https://www.epa.eov/dockets/commentine-epa-dockets. FOR MORE INFORMATION • Interested parties can download a copy of the proposed rule notice from EPA's website at the following addresses: https://www.epa.eov/stationarv-sources-air-pollution/lead-acid- battery-manufacturine-area-sources-national-emission and https://www.epa.eov/stationarv-sources-air~pollution/lead-acid~batterv-manufacturine~ new-source-performance-standards • Today's action and other background information are also available either electronically at https://www.reeulations.eov/. EPA's electronic public docket and comment system, o Materials for this proposed action can be accessed using Docket ID No. EPA-HQ- OAR-2021-0619. • For further technical information about the proposed rules, contact Amanda Hansen, EPA's Office of Air Quality Planning and Standards, at (919) 541-3165 or hansen.amanda(S>epa.eov. 3 ------- |