This document summarizes regulatory actions related to greenhouse gas (GHG) reporting and permitting requirements for the lead industry. It discusses the EPA's GHG reporting rule, permitting thresholds, and potential future performance standards. The presentation recommends that lead facilities review their GHG reporting submissions, ensure representative carbon content data from feed materials, and consider developing direct emission factors to quantify GHG emissions.

1. Climate Change Update:
What Lies Beyond GHG Reporting
for the Lead Industry
Presented by All4 Inc.
Neal Lebo | nlebo@all4inc.com | 610.933.5246 x 113
May 10, 2013
www.all4inc.com
Kimberton, PA | 610.933.5246
Columbus, GA | 706.221.7688

2. Agenda
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Climate Change Regulatory Activity
Measurement and Reporting
Permitting/Standards
Actions to Consider
Your environmental compliance is clearly our business.

3. Strong Words
“If Congress won’t act soon to protect future generations, I
will. I will direct my Cabinet to come up with executive
actions we can take, now and in the future, to reduce
pollution, prepare our communities for the consequences of
climate change, and speed the transition to more sustainable
sources of energy.”
“I’m also issuing a new goal for America: Let’s cut in half the
energy wasted by our homes and businesses over the next 20
years.”
President Barack Obama, February 12, 2013
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Your environmental compliance is clearly our business.

4. National GHG Actions
October 2009: Mandatory Reporting of
Greenhouse Gases Rule.
 December 2009: Endangerment Finding - GHG
threaten health & human welfare.
 April 2010: Light Duty Vehicle Rule - First rule to
control GHG emissions.
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Your environmental compliance is clearly our business.

5. National GHG Actions
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May 2010: Prevention of Significant Deterioration (PSD)
and Title V Greenhouse Gas Tailoring Rule
(GHG Tailoring Rule).
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January 2011: Step 1 - GHG air permitting began for facilities
that would otherwise require permitting.
July 2011: Step 2 - GHG permitting began for all facilities that
would emit more than 100,000 tons of CO2e per year and
facilities that undergo modification that would increase
emissions by 75,000 tons of CO2e per year.
July 2012: Step 3 amendments and streamlining options.
Your environmental compliance is clearly our business.

6. National GHG Actions
March 2012: Proposed New Source Performance
Standards (NSPS) to control GHG from new fossil
fuel-fired electric utility generating units (EGUs).
 December 2012: First GHG enforcement.
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Climate Change Adaptation Plans.
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Construction without GHG PSD permit.
Federal agencies evaluate risks and vulnerabilities.
Develop plans to manage effects of climate change on
the agency’s mission, programs, and operations.
Your environmental compliance is clearly our business.

7. National GHG Actions
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What hasn’t happened:
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Over a year later new EGU GHG standard not final.
U.S. EPA also committed to, but has not acted on,
GHG standards for:
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Existing EGUs by May 26, 2012.
New/existing petroleum refineries by November 10, 2012.
During a recent interview U.S. EPA Administrator
Nominee Gina McCarthy suggested that “it’s
really states that develop their own processes” for
existing plants.
Your environmental compliance is clearly our business.

8. State GHG Actions
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Regional market-based regulatory programs.
Additional annual reporting requirements.
Permit application requirements.
Challenging U.S. EPA authority to regulate.
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Overturn Massachusetts v. EPA.
Legality of the Tailoring Rule.
Your environmental compliance is clearly our business.

9. Measurement and Reporting
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What gases are considered GHG?
• Six (6) recognized greenhouse gases (GHG)
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Carbon dioxide (CO2)
Methane (CH4)
Nitrous oxide (N2O)
Hydrofluorocarbons (HFC)
Perfluorocarbons (PFC)
Sulfur hexafluoride (SF6)
Your environmental compliance is clearly our business.

10. Measurement and Reporting
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Global Warming Potential (GWP)
A measure of how much a given mass of GHG is
estimated to contribute to global warming. It is a
relative scale which compares the gas in question
to CO2.
GHG
CO2
1
Methane
21
N2O
310
HFC-32
650
PFC-14
6,500
SF6
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GWP
23,900
Your environmental compliance is clearly our business.

11. Measurement and Reporting
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Emissions measured in CO2 equivalency (CO2e).
Each gas placed on CO2e basis by multiplying GWP.
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For GHG Reporting Rule emissions are measured
in metric tons.
1 metric ton = 2,204.62 lbs
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For GHG Tailoring Rule emissions are measured in
short tons.
1 short ton = 2,000 lbs
1 short ton = 0.907186 metric tons
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Your environmental compliance is clearly our business.

12. Measurement and Reporting
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40 CFR Part 98 – Mandatory Greenhouse Gas Reporting.
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Lead smelters that emit ≥ 25,000 mtCO2e/yr combined
from all listed sources must report.
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Subpart C – Stationary Combustion Sources
Subpart R – Lead Production
Confidential Business Information (CBI) Determinations.
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Subpart A - General Provisions
Subparts C to UU - Specific Source Categories
Class of 2013
Class of 2015
Your environmental compliance is clearly our business.

13. Measurement and Reporting
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EPA’s Facility Level Information on GreenHouse
gases Tool (FLIGHT).
First two years of reported data publicly available.
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2010 annual emissions
2011 annual emissions
Your environmental compliance is clearly our business.

14. Measurement and Reporting
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Part 98 Combustion Emissions Calculation:
CO2/CH4/N2O = 1x10-3 * Fuel (SCF) * HHV * Emission Factor
? CCF ? MCF ? MMCF ?
CO2/CH4/N2O = 1x10-3 * Fuel (Therms) * 0.1 * Emission Factor
? Dth ? MDth ? MMDth ?
CO2/CH4/N2O = 1x10-3 * Fuel (MMBtu) * Emission Factor
? MBtu ? CBtu ? Btu ?
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Your environmental compliance is clearly our business.

15. Measurement and Reporting
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Part 98 Lead Production Emissions Calculation:
CO2 = 3.67 * 0.91 * Mass of Feed * %Carbon Content
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% Carbon Content:
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Provided by supplier.
Collect and analyze at least 3 representative sample
each year.
Your environmental compliance is clearly our business.

16. Measurement and Reporting
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% Carbon Content – what we have seen.*
Lead Scrap Carbon Content
Annual Average
3.4%
0.9%
0.3%
2010
2011
2012
Lead Scrap Carbon Content
Individual Samples Within Year
21.5%
5.0%
2.0%
Sample 1
Sample 2
Sample 3
* Examples – Not Real Data
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Your environmental compliance is clearly our business.

17. Measurement and Reporting
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Concerns:
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Public data available to stakeholders.
Permitting.
Applicability under future standards.
Lead-Carbon battery technology.
Your environmental compliance is clearly our business.

18. GHG Permitting
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Currently must address GHG in all applications.
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Full GHG emission inventories required in renewal
applications.
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“Major source” label for another pollutant.
Tailoring Rule Step 4 by April 2016.
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Demonstrate PSD status.
Best Available Control Technology (BACT) analysis.
Thresholds could be lowered.
Your environmental compliance is clearly our business.

19. GHG Standards
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NSPS/NESHAP requirements.
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Questionable GHG control technologies.
Energy efficiency requirements.
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Output based standard in current EGU proposal.
Introduced in “Boiler MACT.”
Could be part of Step 4.
Could be added to existing standards.
Your environmental compliance is clearly our business.

20. Actions to Consider
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Review what has been submitted.
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Assure representative carbon content data.
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Increase sample frequency.
Measure and sample more categories.
Develop industry or facility-specific direct
emission factors.
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Amend if you find errors.
Emission test data.
Your environmental compliance is clearly our business.

21. Questions?
Neal Lebo | nlebo@all4inc.com | 610.933.5246 x 113
All4 Inc.
2393 Kimberton Road
P.O. Box 299
Kimberton, PA 19442
www.all4inc.com
www.all4inc.com
Kimberton, PA | 610.933.5246
Columbus, GA | 706.221.7688