Subject: Voluntary Revisions of Lead Emissions for 1996 & 1997 Perfect Equipment Company, LLC TRI Fac. ID #89431PRFCT1498K

On November 25, 1998, a "VOLUNTARY REVISION" was submitted to the EPCRA and the State of NV for this facility's 1996 and 1997 lead air emissions. This revision was submitted because additional information became available to make a more accurate engineering estimate of emissions. The effect of this revision was to reduce the annual lead air emissions reported for these years to 5.0 lbs per year.

BACKGROUND At the time the original reports were filed, annual lead emissions for these TRI reports were estimated based upon the best available information which was the facility air permit issued by the local authority. This permit cites the "Estimated Emissions" factor for lead as "0.5 lb per ton lead processed". According to the permit, this lead factor comes from EPA AP-42, Table 7.17-1. Upon this basis, the 1996 and 1997 estimated values for lead emissions were 1,000 and 603 lbs per year, respectively. The basis of estimate in the TRI reports was properly identified as "E" which indicates that the estimate is based upon "published emission factors, such as those relating release quantity to throughput".

Subsequent information became available which allowed for a more accurate estimate of lead air emissions. The facility conducted lead ambient air sampling of the workplace. This information along with the facility air discharge rate and annual hours of operation yielded a much more accurate estimate. The basis of estimate in the revised TRI reports was properly identified in the "Voluntary Revision" as "O" which indicates that the estimate is bas