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Lead in Air

SIP Toolkit - Strategies and Technologies to Reduce Emissions

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Each SIP must contain an enforceable control strategy to ensure attainment and
maintenance of all the NAAQS. According to 40 CFR 51.110(a), a control strategy must be selected "that provides the degree of emissions reductions necessary for attainment and maintenance of the national ambient air quality standards. The emission reductions must be sufficient to offset any increases in air quality concentrations that are expected to result from emission increases due to projected growth of the population, industrial activity, motor vehicle traffic, or other factors." In general, a control strategy will consist of emission limitations applicable to all sources within specified categories. The selected sets of emission limitations are established based on the judgement that they are adequate to bring about the NAAQS attainment.

Any State containing an area designated nonattainment for lead must develop and submit a Part D SIP. The general Part D plan provisions are contained in Section 172(c) of the Act. Among other things, Section 172(c) specifies that Part D SIPs include reasonably available control measures (RACM) [which includes reasonably available control technology (RACT), provide for reasonable further progress (RFP), and contain contingency measures. EPA guidance related to RACM (including RACT), RFP and contingency measures for lead nonattainment areas is described in the November 12, 2008 Lead Standard (PDF) (99pp, 665k) final rulemaking notice.  

RACM/RACT

The EPAs historic definition of RACT is the lowest emissions limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility. EPA is recommending a threshold for RACT analysis such that at least all stationary sources emitting 0.5 tpy or more of lead should undergo a RACT review.  Smaller sources should also be included if necessary to demonstrate attainment.

In considering what level of control is reasonable, EPA is not adopting a specific dollar per ton cost threshold for RACT. 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, EPA believes 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. 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.

RFP

The EPA believes that RFP for lead nonattainment areas should be met by the strict adherence to an ambitious compliance schedule which is expected to periodically yield significant emission reductions, and to the extent appropriate, linear progress. The EPA recommends that SIPs for lead nonattainment areas provide a detailed schedule for compliance of RACM (including RACT) and accurately indicate the corresponding annual emission reductions to be achieved. In reviewing the SIP, EPA believes that it is appropriate to expect early implementation of less technology-intensive control measures (e.g., work practices to control fugitive dust emissions at the stationary sources) while phasing in the more technology-intensive control measures, such as those involving the installation of new hardware. The EPA believes that the expeditious implementation of RACM/ RACT at affected sources within the nonattainment area is an appropriate approach to assure attainment of the lead NAAQS in an expeditious manner.

Contingency Measures

Section 172(c)(9) of the Act defines contingency measures as measures in a SIP which are to be implemented if an area fails to maintain RFP or to attain the NAAQS by the applicable attainment date. Upon determination by the Administrator that the area has failed to (1) maintain reasonable further progress or (2) attain the lead NAAQS by the applicable statutory deadline, contingency measures become effective without further action by the State or the Administrator. Contingency measures should consist of available control measures that are not included in the primary control strategy. After EPA determines that a lead nonattainment area has failed to maintain RFP or timely attain the lead NAAQS, EPA generally expects all actions needed to affect full implementation of the measures to occur within 60 days after EPA notifies the state of such failure. The state should ensure that the measures are fully implemented as expeditiously as practicable after the requirement takes effect.

Contingency measures are important for lead nonattainment areas, which may violate the NAAQS generally due to emissions from stationary sources, for several reasons. First, process and fugitive emissions from these stationary sources, and the possible re-entrainment of historically deposited emissions, have historically been difficult to quantify. Therefore, the analytical tools for determining the relationship between reductions in emissions, and resulting air quality improvements, can be subject to some uncertainties. Second, emission estimates and attainment analysis can be influenced by overly optimistic assumptions about fugitive emission control efficiency.

Specific Technologies and Documents

National Emission Standards for Hazardous Air Pollutant Emissions for Primary Lead Processing

On November 15, 2011, EPA finalized the National Emission Standards for Hazardous Air Pollutant (NESHAP) Emissions for Primary Lead Processing This action finalizes amendments to the NESHAP that include revision of the rules title and applicability provision, revisions to the stack emission limits for primary lead smelters, work practice standards to minimize fugitive dust emissions, and the modification and addition of testing and monitoring and related notification, recordkeeping, and reporting requirements. It also finalizes revisions to the regulatory provisions related to emissions during periods of startup, shutdown, and malfunction and makes minor non-substantive changes to the rule. Currently, the only remaining facility in the U. S. in this source category is the Doe Run Companys Herculaneum, Missouri facility.

Compliance for the existing source must be demonstrated by January 17, 2012, for the main stack emissions, and no later than November 15, 2013, for the furnace area and refinery and casting emissions, and the quarterly compliance testing requirements.

National Emissions Standards for Hazardous Air Pollutants: Secondary Lead Smelting; Residual Risk and Technology.

On January 5, 2012, EPA finalized the National Emission Standards for Hazardous Air Pollutants (NESHAP) from Secondary Lead Smelters . These final amendments include revisions to the emissions limits for lead compounds; revisions to the standards for fugitive emissions; the addition of total hydrocarbon and dioxin and furan emissions limits for reverberatory and electric furnaces; the addition of a work practice standard for mercury emissions; the modification and addition of testing and monitoring, recordkeeping, and reporting requirements; related notifications; and revisions to the regulatory provisions related to emissions during periods of startup, shutdown, and malfunction.

For existing sources, compliance with the requirements of the revised NESHAP from Secondary Smelters must be demonstrated by no later than January 5, 2014. New sources must demonstrate compliance no later than January 5, 2012.

Iron and Steel Mills

On May 20, 2003, the EPA promulgated national emission standards for hazardous air pollutants (NESHAP) for integrated iron and steel manufacturing facilities. The final standards establish emission limitations for hazardous air pollutants (HAP) emitted from new and existing sinter plants, blast furnaces, and basic oxygen process furnace (BOPF) shops. The final standards implement section 112(d) of the Clean Air Act (CAA) by requiring all major sources to meet HAP emission standards reflecting application of the maximum achievable control technology (MACT). The final rule includes particulate matter (PM) emission limits and opacity limits as well as operating limits for capture systems and control devices. Particulate matter and opacity serve as surrogate measures of HAP emissions.

For existing sources (those constructed or reconstructed before July 13, 2001) the compliance date was May 22, 2006. For new sources (those constructed on or after July 13, 2001), the compliance date was May 20, 2003 or upon initial startup, whichever was later. The standards were amended in 2006 to add a new compliance option, revise emission limitations, reduce the frequency of repeat performance tests for certain emission units, add corrective action requirements, and clarify monitoring, recordkeeping, and reporting requirements.

Iron and Steel Foundaries

On April 22, 2004 the EPA promulgated national emission standards for hazardous air pollutants (NESHAP) for iron and steel foundries. The EPA has identified iron and steel foundries as a
major source of hazardous air pollutant (HAP) emissions. These standards implement section 112(d) of the Clean Air Act (CAA) by requiring all major sources to meet HAP emissions standards reflecting application of the maximum achievable control technology (MACT).

The final rule includes emissions limits for metal and organic HAP as well as operating limits for capture systems and control devices. Particulate matter (PM) and opacity serve as surrogate measures of metal HAP emissions; emissions limits for total metal HAP are included as alternatives to the PM limits.The final rule covers emissions from metal melting furnaces, scrap preheaters, pouring areas, pouring stations, automated conveyor and pallet cooling lines that use a sand mold system, automated shakeout lines that use a sand mold system, and mold and core making lines. The final rule also covers fugitive emissions from foundry operations.

For existing sources (those that commenced construction or reconstruction before December 23, 2002) the compliance date was April 23, 2007. For new sources (those that commenced construction or reconstruction on or after December 23, 2002), the compliance date was April 22, 2004. The final rule was amended in 2005 and 2008.

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