interoffice memorandum

To:	David Brymer

Air Quality Planning Division	Date:	June 3, 2009

Thru:	Robert Opiela, P.E., Technical Specialist

Technical Program Support Section

Air Permits Division

From:	Matthew Kovar, Megan Cox

Air Dispersion Modeling Team

Air Permits Division

Subject:	Modeling Analysis of Lead for Exide Technologies, Frisco
Battery Recycling Plant (RN100218643)



1.0	Project Identification Information. 

On November 12, 2008, the U.S. Environmental Protection Agency (EPA)
finalized the new 0.15 microgram per cubic meter (g/m3) NAAQS for
lead based on a rolling three-month average (73 Federal Register 66964).
In general, the rule requires source-oriented ambient air lead
monitoring by January 1, 2010, at sites with actual annual lead
emissions of one or more tons per year. Exide Technologies, Frisco
Battery Recycling Plant was identified as having emissions at or above
this level based on the reported 2007 TCEQ Emissions Inventory and/or
2006 Toxics Release Inventory. The rule further requires that this
monitoring be conducted at or near the maximum off-site ambient air lead
concentration, as predicted by modeling, that results from sources with
annual lead emissions of one or more tons. 

The TCEQ conducted air dispersion modeling of all the lead emission
sources at the site using the most current modeling parameters and
associated permitted allowable emissions rates. The TCEQ will use the
dispersion modeling results to determine the optimal location of any
required source-oriented monitors.

Since monitoring already exists at and near the Exide Technologies site,
and monitored values exceeding the new lead standard have been recorded,
the dispersion modeling results will also be used to determine the
proposed boundaries of a lead non-attainment area.

ArcReader Published Map:

 HYPERLINK "\\\\Msgiswrk\\apd\\MODEL PROJECTS\\Lead NAAQS
Analysis_2009\\Lead_NAAQS_Analysis_Results.pmf" \\Msgiswrk\apd\MODEL
PROJECTS\Lead NAAQS Analysis_2009\Lead_NAAQS_Analysis_Results.pmf 

g/m3 for a rolling three-month average. The location of the GLCmax is
the same as the location of monitor 480850009 on the north property line
of the Exide Technologies site. Predicted concentrations exceeding the
NAAQS extended approximately 1.3 kilometers (km) to the north, 0.8 km to
the south, 0.8 km to the west, and 0.4 km to the east of the site
property line. All predicted concentrations greater than the NAAQS are
located within Collin County. Table 1 lists the predicted concentrations
at the current monitor locations and proposed monitor location near the
intersection of 1st Street and Ash Street.

Table 1. Modeling Results for Lead 

Monitor ID	Averaging 

Time 	GLC 

(µg/m3)	Standard

(µg/m3)

480850009	rolling three-month	1.42	0.15

480850003	rolling three-month	0.81	0.15

480850007	rolling three-month	0.49	0.15

Proposed	rolling three-month	0.52	0.15



3.0	Land Use and Terrain. A land use/land cover analysis was performed
using AERSURFACE consistent with guidance given in the AERMOD
Implementation Guide (March 19, 2009). The recommended input data, the
National Land Cover Data 1992 archives (NLCD92), were used for this
analysis.

	Terrain elevations within the modeling domain were determined using
AERMAP (Version 09040). The input data used for this analysis were
United States Geological Survey (USGS) digital elevation models (DEMs)
for Little Elm, Frisco, Lewisville East, and Hebron data sets.

4.0	Modeling Emissions Inventory.   The modeled emission source
parameters and emission rates were provided by Exide Technologies. The
source locations were validated by ADMT using aerial photography. The
source emission rates modeled were consistent with the maximum allowable
emission rates authorized through permits 3048A and 1147A. The emission
source coordinates are in the UTM Zone 14 North, North American Datum of
1927 (NAD27) coordinate system.

Table 2. On-Property Point Source Parameter Information

ID	Easting (meters)	Northing (meters)	Stack Height (meters)	Stack Temp

(K)	Stack Exit Velocity (meters/sec)	Stack

Diameter (meters)

11	702713.06	3668796.5	16.764	369.26	12.0396	0.3048

12	702713.25	3668793.75	16.764	369.26	8.5039	0.3048

13	702713.25	3668791.5	15.8496	391.48	13.1674	0.3048

14	702721	3668792.75	16.764	327.59	27.9624	0.5334

15	702725.31	3668807.5	16.764	349.82	14.1732	0.381

16	702717.88	3668803	17.3736	369.26	13.4722	0.253

17	702728.88	3668779.5	16.764	355.37	14.0208	0.381

18	702628.13	3668767.75	30.6324	303.71	5.1206	1.6154

21	702626.88	3668739.25	31.242	304.82	16.5811	1.521

22	702685.69	3668804.25	22.86	0	15.1486	0.8108

23	702637.38	3668764.5	6.096	0	1.8288	0.3048

24	702721.88	3668782.5	16.4592	369.26	11.491	0.381

25	702721.75	3668777.75	16.4592	358.15	9.4488	0.381

26	702736.31	3668782.75	9.144	355.37	11.5824	0.1524

37	702682.56	3668810	22.86	298.15	19.6901	1.6764

38	702620.19	3668771.75	33.8328	315.37	16.7945	1.3716

39	702544.5	3668727.75	10.668	0	0.0009	1.524

45	702623.06	3668713.75	32.1564	0	14.0238	1.8044

48	702585	3668771	11.2776	0	1.6764	0.1707



 )

10	702642.65	3668770.8	4.572	28.956	24.384	-2

27	702733.81	3668767.5	4.572	0.9144	0.9144	0

28	702756.31	3668782	4.572	0.9144	0.9144	0

35	702654.26	3668740.35	4.572	22.86	30.48	-2

36	702645.75	3668754.8	4.572	32.004	15.24	-2

41	702518.28	3668768.73	0.3048	94.488	21.336	40

42	702625.1	3668693.38	0.3048	80.772	44.196	-2

43	702702.77	3668745.25	0.3048	62.484	39.624	-2

44	702590.79	3668760.22	3.9929	24.384	41.148	-2

52	702631.81	3668765.63	4.572	21.336	16.764	-2

53	702615.56	3668762.28	1.8288	16.764	19.812	-2

	

Table 4. On-Property Source Allowable Emission Rates

Scenario

ID	Pollutant 	Averaging

Time	Emission Rates

(lb/hr)

10	Lead	1-hr	0.27

11	Lead	1-hr	0.05

12	Lead	1-hr	0.03

13	Lead	1-hr	0.05

14	Lead	1-hr	0.03

15	Lead	1-hr	0.05

16	Lead	1-hr	0.02

17	Lead	1-hr	0.05

18	Lead	1-hr	0.12

21	Lead	1-hr	0.25

22	Lead	1-hr	0.08

23	Lead	1-hr	0.03

24	Lead	1-hr	0.006

25	Lead	1-hr	0.004

26	Lead	1-hr	0.001

27	Lead	1-hr	0.001

28	Lead	1-hr	0.001

35	Lead	1-hr	0.27

36	Lead	1-hr	0.01

37	Lead	1-hr	0.16

38	Lead	1-hr	0.29

39	Lead	1-hr	0.12

41	Lead	1-hr	0.07

42	Lead	1-hr	0.07

43	Lead	1-hr	0.07

44	Lead	1-hr	0.03

45	Lead	1-hr	0.35

48	Lead	1-hr	0.06

52	Lead	1-hr	0.01

53	Lead	1-hr	0.32



5.0	Building Wake Effects (Downwash).  Input data to Building Profile
Input Program Prime (BPIP-PRM Version 04274) were provided by Exide
Technologies. The building locations were validated by ADMT using aerial
photography.

6.0	Meteorological Data.

Surface Station and ID: Dallas/Fort Worth, TX (Station #: 03927)

Upper Air Station and ID: Stephenville, TX (Station #: 13091)

Meteorological Dataset: 1985, 1987, 1988, 1989, 1990

Profile Base Elevation:  551 feet

The AERSURFACE analysis conducted of the area surrounding the Exide
Technologies site resulted in a calculated roughness length of 0.129
meters. Since the AERSURFACE analysis used land cover data from 1992 and
since the area near the site has become more developed and urbanized
since 1992 based on comparing the land cover data to 2008 aerial
photography, a representative roughness length for the area would be
approximately 0.5 meters. For this reason, the meteorological data set
used for this analysis was developed using a roughness length of 0.5
meters.

 	

7.0	Receptor Grid. The receptor grid used in the modeling analysis
consisted of receptors with 100 meter spacing and extended approximately
5 kilometers (km) from the Exide Technologies site property line in all
directions. Discrete receptors were used for the locations of the three
existing monitoring stations and the location of a proposed monitoring
station near the intersection of 1st Street and Ash Street. The purpose
of the receptor grid was to determine a representative maximum
ground-level concentration and the extent of ground-level concentrations
at or above half of the lead NAAQS standard. 

8.0	Model Used and Modeling Techniques. AERMOD (Version 07026) was used
in a refined screening mode. For refined screening, National Weather
Service (NWS) meteorological raw input data are used with generalized
surface characteristics of the application site. Since the current
version of AERMOD is not capable of calculating rolling three-month
average concentrations, the EPA post processor LeadPost was used. The
input values to LeadPost are monthly average values at each receptor in
the POSTFILE output format from AERMOD.

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nearby source of lead emissions is approximately 50 km from the Exide
Technologies site with annual reported emissions approximately ten
percent of the annual emissions reported by Exide Technologies. Due to
the great distance to the Exide Technologies site and the small reported
emission, no other sources of lead emissions would have a significant
contribution near the Exide Technologies site or the modeling domain
used for this analysis.

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June 3, 2009 

Modeling Analysis of Lead for Exide Technologies, Frisco Battery
Recycling Plant

