www.all4inc.comKimberton, PA | 610.933.5246Columbus, GA | 706.221.7688

Climate Change Update:What Lies Beyond GHG Reporting

for the Lead Industry

Neal Lebo | nlebo@all4inc.com | 610.933.5246 x 113May 10, 2013

Presented by All4 Inc.

2 Your environmental compliance is clearly our business.2

Climate Change Regulatory Activity Measurement and Reporting Permitting/Standards Actions to Consider

Agenda

3 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

4 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.

5 Your environmental compliance is clearly our business.5

National GHG Actions May 2010: Prevention of Significant Deterioration (PSD)

and Title V Greenhouse Gas Tailoring Rule (GHG Tailoring Rule).

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.

6 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. Construction without GHG PSD permit.

Climate Change Adaptation Plans. Federal agencies evaluate risks and vulnerabilities. Develop plans to manage effects of climate change on

the agency’s mission, programs, and operations.

7 Your environmental compliance is clearly our business.7

National GHG Actions What hasn’t happened:

Over a year later new EGU GHG standard not final. U.S. EPA also committed to, but has not acted on,

GHG standards for: 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.

8 Your environmental compliance is clearly our business.8

Regional market-based regulatory programs. Additional annual reporting requirements. Permit application requirements. Challenging U.S. EPA authority to regulate.

Overturn Massachusetts v. EPA. Legality of the Tailoring Rule.

State GHG Actions

9 Your environmental compliance is clearly our business.9

Measurement and Reporting What gases are considered GHG?

• Six (6) recognized greenhouse gases (GHG) Carbon dioxide (CO2) Methane (CH4) Nitrous oxide (N2O) Hydrofluorocarbons (HFC) Perfluorocarbons (PFC) Sulfur hexafluoride (SF6)

10 Your environmental compliance is clearly our business.10

Measurement and Reporting 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 GWP

CO2 1

Methane 21

N2O 310

HFC-32 650

PFC-14 6,500

SF6 23,900

11 Your environmental compliance is clearly our business.11

Measurement and Reporting Emissions measured in CO2 equivalency (CO2e).

Each gas placed on CO2e basis by multiplying GWP. For GHG Reporting Rule emissions are measured

in metric tons.1 metric ton = 2,204.62 lbs

For GHG Tailoring Rule emissions are measured in short tons.1 short ton = 2,000 lbs1 short ton = 0.907186 metric tons

12 Your environmental compliance is clearly our business.12

Measurement and Reporting 40 CFR Part 98 – Mandatory Greenhouse Gas Reporting.

Subpart A - General Provisions Subparts C to UU - Specific Source Categories

Lead smelters that emit ≥ 25,000 mtCO2e/yr combined from all listed sources must report.

Subpart C – Stationary Combustion Sources Subpart R – Lead Production

Confidential Business Information (CBI) Determinations. Class of 2013 Class of 2015

13 Your environmental compliance is clearly our business.13

Measurement and Reporting EPA’s Facility Level Information on GreenHouse

gases Tool (FLIGHT). First two years of reported data publicly available.

2010 annual emissions 2011 annual emissions

14 Your environmental compliance is clearly our business.14

Measurement and Reporting 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 ?

15 Your environmental compliance is clearly our business.15

Measurement and Reporting Part 98 Lead Production Emissions Calculation:

CO2 = 3.67 * 0.91 * Mass of Feed * %Carbon Content

% Carbon Content: Provided by supplier. Collect and analyze at least 3 representative sample

each year.

16 Your environmental compliance is clearly our business.16

Measurement and Reporting % Carbon Content – what we have seen.*

2010 2011 2012

0.3%

3.4%

0.9%

Lead Scrap Carbon ContentAnnual Average

Sample 1 Sample 2 Sample 3

2.0%

21.5%

5.0%

Lead Scrap Carbon ContentIndividual Samples Within Year

* Examples – Not Real Data

17 Your environmental compliance is clearly our business.17

Measurement and Reporting Concerns:

Public data available to stakeholders. Permitting. Applicability under future standards. Lead-Carbon battery technology.

18 Your environmental compliance is clearly our business.18

GHG Permitting Currently must address GHG in all applications.

Demonstrate PSD status. Best Available Control Technology (BACT) analysis.

Full GHG emission inventories required in renewal applications. “Major source” label for another pollutant.

Tailoring Rule Step 4 by April 2016. Thresholds could be lowered.

19 Your environmental compliance is clearly our business.19

GHG Standards NSPS/NESHAP requirements.

Output based standard in current EGU proposal. Questionable GHG control technologies. Energy efficiency requirements.

Introduced in “Boiler MACT.” Could be part of Step 4. Could be added to existing standards.

20 Your environmental compliance is clearly our business.20

Actions to Consider Review what has been submitted.

Amend if you find errors. Assure representative carbon content data.

Increase sample frequency. Measure and sample more categories.

Develop industry or facility-specific direct emission factors. Emission test data.

www.all4inc.comKimberton, PA | 610.933.5246Columbus, GA | 706.221.7688

Questions?

Neal Lebo | nlebo@all4inc.com | 610.933.5246 x 113

All4 Inc.2393 Kimberton Road

P.O. Box 299Kimberton, PA 19442

www.all4inc.com