United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 2771 1
EPA-450/"3-79-028b
November 198O
Air
Lead -Acid Battery
Manufacture -
Background Information
for Promulgated
Standards
EIS
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Errata Sheet
Lead-Acid Battery Manufacture
Background Information for
Promulgated Standards
EPA-450/3-79-028b
1. p. 1-2
2. pg. 1-7
3. pg. 1-11
In the promulgated lead emission limit column of
Table 1-1, the entry for grid casting should be
changed from 0.40 mg/dscm (0.00024 gr/dscf) to
0.40 mg/dscm (0.000176 gr/dscf), and the entry for
lead reclamation should be changed from 4.5 mg/dscm
(0.0022 gr/dscf) to 4.5 mg/dscm (0.00198 gr/dscf).
In the baseline emissions column of Table l-3b, the
entry for total emissions from the 6500 bpd plant
should be changed from 20476.6 to 27476.6. For the
grid casting facility at the 2000 bpd plant, the entry
in the proposed standards column should be changed
from 187.8 to 387.8, and the entry in the promulgated
standards column should be changed from 187.8 to 387.8.
The following substitutions should be made for the
entries in the total-scrubber-blowdown/volume, and
increase-above-baseline/volume columns of Table l-5b:
Baseline
500 bpd plant
2000 bpd plant
6500 bpd plant
Proposed standards
(revised estimate)
500 bpd plant
2000 bpd plant
6500 bpd plant
Promulgated standards
500 bpd plant
2000 bpd plant
6500 bpd plant
Total
scrubbers
blowdown
Volume
(103ga1/da.y)
0.13
0.53
1.85
3.86
13.42
44.91
0.53
2.06
7.24
Increase
above
baseline
Volume
(103gal/da.y)
3.72
12.89
43.06
0.40
1.53
5.39
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EPA-450/3-79-028b
Lead-Acid Battery
Manufacture
Background Information
for Promulgated Standards
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air, Noise, and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
November 1980
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This report has been reviewed by the Emission Standards and
Engineering Division of the Office of Air Quality Planning and
Standards, EPA, and approved for publication. Mention of
trade names or commercial products is not intended to constitute
endorsement or recommendation for use. Copies of this report
are available through the Library Services Office (MD-35),
U.S. Environmental Protection Agency, Research Triangle Park,
N.C. 27711, or from National Technical Information Services,
5285 Port Royal Road, Springfield, Virginia 22161.
Publication No. EPA-450/3-79~028b
11
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ENVIRONMENTAL PROTECTION AGENCY-
Background Information
and Final
Environmental Impact Statement
for Lead-Acid Battery Manufacture
Prepared by:
7
>1on Stc
Don R. Goodwin
Director, Emission Standards and Engineering Division
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
(Date)
1. The promulgated standards of performance limit emissions of lead from
new, modified, and reconstructed lead-acid battery manufacturing facilities.
Section 111 of the Clean Air Act (42 U.S.C. 7411), as amended, directs
the Administrator to establish standards of performance for any
category of new stationary source of air pollution that "... causes
or contributes significantly to air pollution which may reasonably be
anticipated to endanger public health or welfare."
2. Copies of this document have been sent to the following Federal
Departments: Labor, Health and Human Services, Defense, Transportation,
Agriculture, Commerce, Interior, and Energy; the National Science
Foundation; the Council on Environmental Quality; members of the State
and Territorial Air Pollution Program Administrators; the Association
of Local Air Pollution Control Officials; EPA Regional Administrators;
and other interested parties.
3. For additional information contact:
Gene W. Smith
Standards Development Branch (MD-13)
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
telephone: (919) 541-5421.
4. Copies of this document may -be obtained from:
U.S. EPA Library (MD-35)
Research Triangle Park, NC 27711
National Technical Information Service
5285 Port Royal Road
Springfield, VA 22161
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TABLE OF CONTENTS
Chapter 1. SUMMARY
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
1.2 SUMMARY OF THE IMPACTS OF THE PROMULGATED
ACTION
Chapter 2. SUMMARY OF PUBLIC COMMENTS
2.1 GENERAL
2.2 EMISSIONS CONTROL TECHNOLOGY
2.3 MODIFICATION AND RECONSTRUCTION
2.4 ECONOMIC IMPACT
2.5 ENVIRONMENTAL IMPACT
2.6 LEGAL CONSIDERATIONS
2.7 TEST METHODS AND MONITORING
2.8 REPORTING AND RECORDKEEPING
2.9 MISCELLANEOUS
Page
1-1
1-1
1-3
2-1
2-1
2-12
2-20
2-20
2-22
2-23
2-25
2-26
2-27
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LIST OF TABLES
Table
Number page
1-1 Summary of changes made to lead emission limitations
between proposal and promulgation 1-2
1-2 Control Alternatives considered for proposed action 1-4
l-3a Estimated impacts of proposed and promulgated standards
on atmospheric emissions (metric units) 1-6
l-3b Estimated impacts of proposed and promulgated standards
on atmospheric emissions (English units) 1-7
1-4 ' Comparison of ambient lead concentration impacts of
proposed and promulgated regulations 1-9
l-5a Comparison of water pollution impacts of promulgated
and proposed standards (metric units) 1-10
.l-5b Comparison of water pollution impacts of promulgated
and proposed standards (English units) 1-11
1-6 Electricity requirements for proposed and promulgated
standards 1-13
1-7 Total energy requirements for proposed and promulgated
standards 1-15
1-8' Economic impacts of proposed and promulgated standards 1-17
2-1 List of commenters on the proposed standards of
performance for lead-acid battery manufacture 2-2
V
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1. SUMMARY
On January 14, 1980, the Administrator proposed standards of performance
for lead-acid battery manufacture (45 FR 2790) under Section 111 of the
Clean Air Act. Public comments were requested on the proposal in the Federal
Register. .There were 21 commenters composed mainly of lead-acid battery
industry and State Agency representatives. Also commenting were representa-
tives of the U.S. Department of Commerce and industries not associated with
lead-acid battery manufacturing. The comments that were submitted, along
with responses to these comments, are summarized in this document. The
summary of comments and responses serves as the basis for the revisions made
to the standards between proposal and .promulgation.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
A number of changes have been made to the standards since their proposal.
The most significant of these are changes in the emission limitations for
the grid casting and lead reclamation facilities. The promulgated emission
limits for these facilities are based on levels achievable using impingement
scrubbers, while the proposed emission limits were based on levels achievable
using fabric filtration. Also, the opacity standard for lead reclamation
has been changed from 0 to 5 percent, because of the change in the emission
limit for this facility. The changes in the standards of performance for
grid casting and lead reclamation are illustrated in Table 1-1, which
presents the proposed and promulgated emissions limitations for all facilities
affected by the standards.
Another change is the redefinition of the paste mixing facility to
include several operations ancillary to paste mixing. These ancillary
operations are lead oxide storage, conveying, weighing, and metering operations;
paste handling and cooling operations; and plate pasting, takeoff, cooling,
and drying, operations.
1-1
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TABLE 1-1. SUMMARY OF CHANGES MADE TO LEAD EMISSION LIMITATIONS
BETWEEN PROPOSAL AND PROMULGATION
Affected facility
Proposed lead
emission limit
Promulgated lead
emission limit3
Lead oxide production
Grid casting
Paste mixing
Three-process operation
Lead reclamation
Other lead-emitting
operations
5.0 mg/kg (0.010 Ib/ton)
0.05 mg/dscm (0.00002 gr/dscf)
1.0 mg/dscm (0.00044 gr/dscf)
1.0 mg/dscm (0.00044 gr/dscf)
2.0 mg/dscm (0.00088 gr/dscf)
1.0 mg/dscm (0.00044 gr/dscf)
No change from proposed limit
0.40 mg/dscm (0.00024 gr/dscf)
No change from proposed limit
No change from proposed limit
4.5 mg/dscm (0.0022 gr/dscf)
No change from proposed limit
aFor lead oxide production, the emission limit is expressed in terms of lead emissions
per kilogram of lead processed.
For grid casting, paste mixing, three-process operation, lead reclamation, and other
lead-emitting facilities, emission limits are expressed in terms of lead emissions per
dry standard cubic meter of exhaust air.
1-2
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In addition, the units of the small size cutoff for the standards for
lead-acid battery manufacture have been changed from batteries per day (bpd) '
to lead throughput.. The promulgated standards will affect new, modified,
or reconstructed facilities at any plant with the. capacity to produce in one .
'day batteri.es which would contain, in total, an amount of lead greater than
or equal to 5.9 Mg (6.5 tons). This cutoff corresponds to the 500 bpd
cutoff in the proposed standards, and is based on an average battery lead
content of 11.8 kg (26 Ib) of lead per battery.
The promulgated standards will not require pressure drop monitoring and
recording for fabric filters. The pressure drop monitoring and recording.
requirement has been retained for scrubbers. However, the continuous
recording requirement has been changed to a requirement that pressure drop be
recorded every 15 minutes. Finally, because of the change in the standard
for grid casting, the minimum sampling time for this facility has been
reduced from 180 minutes to 60 minutes.
1.2 SUMMARY OF IMPACTS OF THE PROMULGATED ACTION
1.2.1 Alternatives to the Promulgated Action
The control alternatives considered for the lead-acid battery manufacture
source category are discussed in Chapter 6 of the Background Information
Document (BID) for the proposed standards (Volume I). Five regulatory
.alternatives were considered for plants larger than the small size cutoff.
The control techniques on which the alternatives were based are summarized
in Table 1-2.
The promulgated standards correspond to Alternative III, which is based
on the use of fabric filtration to control emissions from lead oxide production,
paste mixing, three process operation, and other lead-emitting facilities,
and scrubbers typically used in the lead-acid battery manufacturing industry
to control emissions from grid casting and lead reclamation facilities. This
alternative is considered to reflect the degree of emission control achievable
through the use of the best demonstrated technology considering costs, nonair
quality health and environmental impacts, and energy requirements for lead-acid
battery manufacture. The rationale for the selection of Alternative III as
a basis for the promulgated standards is discussed in Chapter 2, Section 2.2.
1-3
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The proposed standards corresponded to Alternative I. The emission
limits and the impact analyses for this alternative had been based on the
application of fabric filters to all affected facilities; however, as noted
in the preamble to the proposed standards, the emissions limits for
Alternative I could also have been achieved using high energy venturi
scrubbers. In light of arguments presented by a number of commenters (Chapter 2,
Section 2.2), it has been determined that standards for grid casting and '
lead reclamation facilities cannot be based on the use of fabric filters.
. Therefore, the costs, and energy and water requirements of venturi scrubbers,
which would have met the proposed standards for grid casting and lead
reclamation, have been estimated.1 These estimates have been used to revise
the energy, economic, and water pollution impacts projected for Alternative I.
As noted in Volume I of the BID, growth projections for the lead-acid
battery manufacturing industry over the next five years range from 3 to
5 percent per year. The environmental, economic, and energy impacts estimated
for the promulgated standards in this chapter and in Volume I are based on
a growth rate of 3.5 percent per year.
I-2-2 Environmental Impacts of Promulgated Action
The environmental impacts of the regulatory alternatives for lead-acid
battery manufacture are discussed in Chapters 6 and 7 of the BID for the
proposed standards. The impacts of the promulgated action are summarized
and compared to the impacts of the proposed regulation in this subsection.
The differences between the impacts of the promulgated standards and the
proposed standards are due to the changes in emissions limits for grid
casting and- lead reclamation. The change in the paste mixing facility
definition and other changes are not expected to.have significant impacts on
lead emissions. The following discussion in conjucti.on with the environmental
impact analysis in'Volume I of the BID, represents the final Environmental Impact
Statement for the promulgated standards.
1.2.2.1 Air pollution impacts
The lead emission impact of the promulgated standards is compared with
the impact of the proposed standards in Table 1-3 for the 500, 2000 and
6500 bpd (5.9, 23.6 and 76.7 Mg/day or 6.5, 26.0, and 84.5 tons/day of lead)
1-5
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1-7
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model plant sizes. As shown in this table, the changes in the standards for
grid casting and lead reclamation will have only a slight impact on the
emission reduction attributable to the NSPS. The promulgated standards are
expected to reduce total lead air emissions from facilities coming on-line
during the next five years to about 3.1 Mg (3.4 tons) in the fifth year,
while the proposed standards were expected to reduce emissions from these
facilities to 2.8 Mg/yr (3.1 tons/yr). Both of these figures represent a
decrease in lead emissions of about 97 percent from the lead emissions which
would be allowed under current State Implementation Plan (SIP) limits for
particulate matter.
Table 1-4 compares the estimated ambient air lead concentration impact
of the promulgated action with that of the proposed standards. As shown in
the .table, the changes in the standards for grid casting and lead reclamation
are not expected to have a significant impact on ambient lead concentrations
in the vicinities of battery plants. The results of dispersion modelling
calculations indicate that the maximum annual ambient impact of lead emissions
from a 6500 bpd plant complying with the promulgated regulation would be
less than the national ambient air quality standard of 1.5 ug/m3 (averaged
over a calender quarter).
1.2.2.2 Water pollution impact
The estimated wastewater impact of the promulgated action is compared
with that of the proposed standards in Table 1-5. As noted in Section 1.2.1
of this chapter, the water pollution impact analysis for the proposed
standards has been revised based on the estimated effluents for venturi
scrubbers which would meet the proposed standards for grid casting and lead
reclamation.
The promulgated action is expected to result in an increase in the lead
content of wastewater of about 0.6 percent, for a typical lead-acid battery
plant. It is anticipated that, in early 1981, EPA's Office of Water and
Waste Management will propose a regulation which would require zero lead
wastewater discharge from grid casting and lead reclamation. Zero discharge
from scrubbers controlling these facilities could be accomplished by clarifying
and recycling the scrubber effluent. The cost of this treatment is estimated
1-8
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TABLE 1-4. COMPARISON OF AMBIENT LEAD CONCENTRATION IMPACTS OF
PROPOSED AND PROMULGATED REGULATIONS
Lead
. emissions
(g/sec)
Maximum ambient lead
concentration impacts (yq/m9)
Hour 24-hour
average average
Annual
average
500 BPD Plant
Baseline8
Proposed standards
Promulgated standards
0.13
0.0022
0.0024
34
1
1
19
6500 BPD Plant
Baseline
Proposed standards
Promulgated standards
0.58
0.011
0.013
88
2
2
41 8
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1 <1
1 ^. |
1 <1
No additional regulatory action.
1-9
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to be less than, one percent of the costs which would be allocable to the
recommended .NSPS for a completely modified or reconstructed 2000 battery per
day plant. *
1.2.3 Energy and Economic Impacts of Promulgated Action
1.2.3.1 Energy impacts
The energy impacts of the proposed regulation trid.the regulatory alternatives
considered for lead-acid battery manufacture are estimated in Chapter 7 of
Volume I of the BID. The estimated impacts of the proposed standards were
based on the application of fabric filters to all affected facilities. As
noted in Section 1.2.1 of this Chapter, the energy impacts for the proposed
regulation have been recalculated based on application of high energy venturi
scrubbers rather than fabric filters to grid casting and lead reclamation
exhausts. The major portion of the energy required to operate an air emission
control system for a lead-acid battery manufacturing facility is electrical
energy required to operate the fan which overcomes the pressure drop through
the system. Based on particle size data and scrubber efficiency data, it is
estimated that high energy venturi scrubbers with pressure drops of about
7.5 kPa (30 in. W.G.) would be needed to meet the emissions limitations for
grid casting and lead reclamation in the proposed regulation (Chapter 2,
Section 2.2). *
In contrast, the promulgated emission standards for grid casting and
lead reclamation are based on levels demonstrated to be achievable by
impingement scrubbing with a scrubber pressure drop of about 1.25 kPa
(5 in. W.6.). Also, the emissions limitations for paste mixing, three-process
operation, and other lead emitting facilities in both the proposed and
promulgated standards are based on the application of fabric filters with
pressure drops of about 1.25 kPa (5 in. W.6.).
The incremental electricity requirements attributable to the promulgated
regulation (Alternative III) and the proposed regulation (Alternative I) are
compared in Table 1-6. For the proposed regulation, both the original and
revised estimates of the electrical energy requirement are presented.
1-12
-------
TABLE 1-6. ELECTRICITY REQUIREMENTS FOR PROPOSED AND
PROMULGATED STANDARDS
Electricity requirements
attributable to NSPS (MWh/yr)
Plant
size
500 BPD
2000 BPD
6500 BPD
Proposed
Original estimate9
28
80
252
regulation
Revised estimate^
51
154
500
Promulgated
regulation
28
80
252
Based on fabric filter control of all affected facilities.
3Based on venturi scrubber control of grid casting and lead reclamation facilities.
1-13
-------
In addition to these electricity requirements, heat energy is expected
to be required to raise exhaust gases from paste mixing above their dewpoint
and thus prevent baghouse blinding due to excess moisture (Chapter 2, Section 2.2),
This requirement would be the same for the promulgated and proposed actions.
Total energy requirements for the proposed and promulgated regulations are
compared with plant energy requirements in Table 1-7. For the proposed
action, the original and revised estimates of total energy requirements are
presented. Process energy demands are based on reported total process
energy requirements for various plant sizes (Volume I, Chapter 7). Exhaust
energy requirements represent requirements for venting facilities to prevent
employee exposure. Baseline control energy requirements represent energy
needs for controlling emissions to the degree required under a typical SIP
particulate regulation. All electrical energy requirements in Table 1-7
are expressed in terms of the amount of heat which would be required to
generate the needed electricity (assuming an average power plant efficiency
of 34 percent).
The energy required at a new plant to operate emission control devices
installed to meet the promulgated regulation will be about 2.7 percent of
the total plant energy requirement. The total nationwide increase in
electrical energy demand attributable to the promulgated action will be
about 2.8 GWh of electricity in the fifth year after promulgation. The
fifth year nationwide energy demand increase resulting from action will be
approximately .50 PJ/hr (48 x 109 BTU/yr), or the equivalent of about
8.1 thousand barrels of oil per year.
1.2.3.2 Economic impact
The economic impacts of the proposed regulation and the regulatory
alternatives are discussed in Chapter 8 of Volume I of the BID. As noted.
above, the proposed regulation corresponded to Alternative I. The estimated
economic impact for the proposed action was based on the application of
fabric filters to all affected facilities. However, it has been determined
that the proposed emission limits for grid casting and lead reclamation
cannot be based on fabric filtration and that high energy (7.5 kPa or
30 in. W.G. pressure drop) venturi scrubbers would be required to achieve
1-14
-------
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these limits. Therefore, the economic impacts for the proposed action have
been recalculated based on the costs of venturi scrubbers for the grid
casting and lead reclamation facilities.
The costs of compliance with the promulgated regulation for new and
existing plants are compared with the revised costs for the proposed standards
in Table 1-8. For the proposed regulation, the original and revised estimates
of economic impacts are presented. The predicted annualized costs of the
promulgated action range from 8 percent lower, for existing 6500 bpd plants,
to 28 percent lower, for new 500 bpd plants, than the annualized costs which
would have resulted for the proposed standards. Also, the projected capital
costs for plants complying with the promulgated standards are much lower (18
to 40 percent) than those which would have resulted from the proposed
standards.
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the promulgation is expected to range from 23 cents per battery, for a new
6500 bpd plant, to 54 cents per battery, for a completely reconstructed or
modified 500 bpd plant. The average incremental cost associated with the
promulgated regulation will be about 29 cents per battery, which amounts to
about 1.6 percent of the wholesale price of a battery. The total nationwide
capital cost of the installed emission control equipment necessary to meet
the promulgated regulation for all new, modified, or reconstructed facilities
coming on-line over the next five years will be about $8.2 million. The
total annualized cost of operating this equipment in the fifth year after
promulgation will be about $3.9 million.
1.2.4 Other Environmental Concerns
1.2.4.1 Irreversible and irretrievable commitment of resources
The extent to which the proposed standards for lead-acid battery
manufacture would have involved a tradeoff between lead air pollution
reduction and energy losses is discussed in Section 7.6.1 of Chapter 7 of
the BID for the proposed standards. There are no significant changes to the
impacts discussed in this section.
1-16
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1.2.4.2 Environmental Impact of delayed standards
The impacts of a delay in setting new source performance standards for
lead-acid battery manufacture are discussed in Section 7.6.2 of Chapter 7 of
Volume I. There has been no significant change to this impact.
1.2.4.3 .Environmental impact of no standard
The environmental impacts of not setting new source performance standards
for lead-acid battery manufacture are discussed in Chapter 7, Section 7.6.3
of Volume I of the BID. These impacts have not changed significantly since.
proposal. .
1-18
-------
1.3 REFERENCES FOR CHAPTER 1
1.
Memo from Battye, W., GCA/Technology Division to Vatavuk, W., EPA
Economic Analysis Branch. October 13, 1980. Revised control costs for
grid casting and lead reclamation facilities. (Docket No. IV-B-11)
1-19
-------
-------
.2. SUMMARY OF PUBLIC COMMENTS
A list of commenters, their affiliations, and the EPA docket number
assigned to each comment is shown in Table 2-1. Twenty-one letters commenting
on the proposed standards and the Background Information Document for the
proposed standards were received. The comments have'been combined
into the following nine categories:
.1. General
2. Emission Control Technology
3. Modification and Reconstruction
4, Economic Impact
5. Environmental Impact
6. Legal Considerations
7. Test Methods and Monitoring
8. Reporting and Recordkeeping
9. Miscellaneous
The comments and issues are discussed, and responses are presented in
the following sections of this chapter. A summary of the changes to the
regulation is presented in Section 1.2 of Chapter 1.
2.1 GENERAL
Comment: The proposed standards exempted facilities at any plant with
a production capacity of less than 500 bpd. Some commenters felt that the
number of batteries which can be produced at a plant was not the appropriate
criterion on which to base the size cutoff. It was pointed out that lead-acid
batteries are produced in a variety of sizes, and that emissions from battery
production are probably related more to the amount of lead used to produce
batteries than to the number of batteries produced.
Response: These are considered to be reasonable .comments. Economic
impacts of standards as well as emissions are expected to be related to the
amount of lead used in a particular battery production operation rather than
/
2-1
-------
TABLE 2-1. LIST OF COMMENTERS ON THE PROPOSED STANDARDS OF PERFORMANCE
FOR LEAD-ACID BATTERY MANUFACTURE
Docket number0
IV-D-1
IV-D-2
IV-D-3 '
IV-D-4
IV-D-5
IV-D-6
IV-D-7
IV-D-8
Commenter and affiliation
Mr. James H. Hazelwood
Georgia Marble Company
2575 Cumberland Parkway, Northwest
Atlanta, Georgia 30339
Mr. James K. Hambright, Director
Department of Environmental Resources
Bureau of Air Quality
P.O. Box 2063
Harrisburg, Pennsylvania 17120
Mr. Thomas Hatterscheide
Gould, Incorporated
P.O. Box 43140
St. Paul, Minnesota 55164
Mr. Richard A. Lei by
Assistant Safety Director
East Penn Manufacturing Company, Inc.
Main Office
Lyon Station, Pennsylvania 19536
Mr. John 'A. Bitler
Vice President, Environmental Resources
General Battery Corporation
Box 1262
Reading, Pennsylvania 19603
Mr. William V. Skidmore
Acting Deputy General Counsel
U.S. Department of Commerce
Washington, D.C. 20230
Mr. Edwin H. Seeger
Prather, Seeger, Doolittle and Farmer
1101 Sixteenth Street, Northwest
Washington, D.C. 20036
Mr. W. R. Johnson
Environmental Activities Staff
General Motors Corporation
General Motors Technical Center
Warren, Michigan 48090
The identification code for the lead-acid battery manufacture docket is OAQPS-79-1.
2-2
-------
Table.2-1. (continued)
Docket number9
IV-D-9
rv-D-io
IV-D-11
IV-D-12
IV-D-13
IV-D-14
IV-D-15
IV-D-16
Commenter and aff11i ati on
Mr. Robert L. Grunwell, President
The Hydrate Battery Corporation
3220 Odd Fellows Road
Lynchburg, Virginia 24506
Mr. Richard A. Valentinetti
Chief, Air and Solid Waste Programs
Agency of Environmental Conservation
State Office Building
Montpelier, Vermont 05602
Mr. Sudhir Jagirdar, P.E.
Senior Sanitary Engineer
State of New York
Department of Environmental Conservation
202 Mamaroneck Avenue
White Plains, New York 10601
Mr. Harry H. Hovey, Jr.
Director, Division of Air
State of New York
Department of Environmental Conservation
50 Wolf Road
Albany, New York 12233
Mr. Jack Boys
Presto!ite Battery Division
511 Hamilton Street
Toledo, Ohio 43694
Mr. James F. McAvoy, Director
Environmental Protection Agency
State of Ohio
Box 1049
Columbus, Ohio 43216
Mr. Charles C. Miller
Director, Air and Land Quality Division
Iowa Department of Environmental Quality
900 East Grand Avenue
Des Moines, Iowa 50310
Mr. W. M. Pallies
Manager, Health and Safety
Exide Corporation
P.O. Box 336
Yardley, Pennslyvania 19067
2-3
-------
Table 2-1. (continued)
Docket number
IV-D-17
IV-D-18
IV-D-19 ,
IV-D-20
IV-D-25
Commenter and affiliation
Mr. J. M. Beaudoin, Manager
Health, Safety, and Environmental Control
Globe-Union Incorporated
5757 North Green Bay Avenue
Milwaukee, Wisconsin 53201
Mr. John M. Daniel
State Air Pollution Control Board
Room 1106
Ninth Street Office Building
Richmond, Virginia 23219
Mr. Roger Winslow, President
Voltmaster Company, Incorporated
P.O. Box 388
Corydon, Iowa 50060
Mr. Ray Donnelly, Director
Office of Legislation and Interagency Programs
U.S. Department of Labor
Occupation Safety and Health Administration
Washington, D.C.' 20210
Mr. Carl C. Mattia
Manager, Environmental Activities
The PQ Corporation
P.O. Box 840
Valley Forge, Pennsylvania 19482
aThe identification code for the lead-acid battery manufacture docket
is OAQPS-79-1.
2-4
-------
to the number of batteries produced. At the time of proposal, it was
estimated that odd-size lead-acid batteries represent a very small share of
the lead-acid battery market; however the comments received on the proposed
standards indicate that a significant number of odd-sized batteries are
produced. Industrial batteries, which can be as much as 50 times larger
; than automobile batteries, are estimated to represent about 7 percent of
total U.S. lead-acid battery production.1
The small size cutoff for the promulgated regulation is expressed in
terms of lead throughput. The promulgated standards will affect new,
modified, and reconstructed facilities at any plant with the capacity to
produce in one day batteries which would contain, in total, an amount of
lead greater than or equal to 5.9 Mg (6.5 tons). This cutoff is equivalent
to the 500 bpd cutoff for plants producing typical automobile batteries.
The level is based on an average battery lead content of 11.8 kg (26 Ib) of
lead per battery.
Comment: Ore commenter questioned whether plant capacity is to be
determined based on the maximum demonstrated production rate or the estimated
maximum production rate, for the purposes of the small size cutoff.
Response: For tne purposes of the small size cutoff, the parameter to
be used to determine the production capacity of a plant is the design
capacity. The design capacity is the maximum production capability of the
plant and can be determined using the design specifications of the plant's
component facilities, .taking into account process bottlenecks. The design
capacity of a plant can be confirmed by checking production records. The
figure cited as a plant's production capacity should not be less than the
maximum production rate in the plant's records.
Comment: Several 'commenters felt that the 500 bpd cutoff should be
raised to 2000 bpd. This contention was based on the factthat Federal
regulations which set minimum standards for State implementation plans
(SIPs) for the lead NAAQS do not require ambient air quality monitoring or
atmospheric dispersion analyses for plants smaller than 2000 bpd (40 CFR 51.80(a)(l)
and 51.84(-a)). The commenters considered these cutoffs to be indicative of
decision by EPA that battery plants smaller than 2000 bpd are not material
.contributors to lead air pollution.
2-5
-------
Response: It should be noted that the Federal regulations to which the
commenters referred only set minimum standards for a lead SIP. Also, as
discussed in Section 2.6 of this chapter, the regulatory approach for NAAQS
regulations promulgated under Section 109 of the Clean Air Act differs from
that for standards of performance promulgated under Section 111 of the Act.
The small size cutoff for the standards of performance for lead-acid battery
manufacture is based on a thorough analysis of the economic impacts of these
standards. The analysis indicated that the economic impact of standards on
plants smaller than about 250 bpd could be severe, but showed that the
economic impact would be reasonable for plants with capacities greater than
or equal to 500 bpd. None of the commenters submitted information indicating
that the economic impact of standards might be severe for plants in the 500
to 2000 bpd size range. Therefore, although the small size cutoff is now
expressed in terms of lead throughput rather than battery production, the
level of the cutoff remains at the lead throughput capacity which corresponds
to a production capacity of 500 bpd.
Comment: One commenter stated that the choice of a size cutoff of
500 bpd appears to be arbitrary.
Response: As noted above, the size cutoff of 500 bpd (5.9 Mg/day or
6.5 tons/day of lead) is based on a thorough economic impact analysis of the
new source performance standards.
Comment: One commenter stated that, as the regulation is written, the
standards of performance would not apply to facilities at plants producing
only lead-acid battery components, such as grids.
Response: Standards of performance for lead-acid battery manufacture
have been developed as a result of determination made by the Administrator
that lead-acid battery manufacturing plants contribute significantly to air
pollution, which may reasonably be anticipated to endanger* public health or
welfare. No such determination has been made for plants producing only
certain battery components. In fact, it is not expected that such plants
will be constructed, because of the high cost of transporting lead
components from plant to plant. EPA will review this regulation four years
2-6
-------
after the date of .promulgation. If battery component plants become prevalent,
consideration will be given 'at that time to applying this regulation to such
plants.
Comment: Another commenter felt that the stack gas concentration
standards for grid casting, paste mixing, three-process operation, lead '
reclamation, and other lead-emitting facilities do not allow for differences
in the quantity of emissions between small plants and large plants. This
commenter recommended that the emissions limits for these facilities be
expressed in terms of allowable lead emissions per lead throughput, rather
than in terms of exhaust gas lead concentration.
Response: The airflow rate from a particular type of facility increases
with the production capacity of the facility. Because the standards for
grid casting, paste mixing, three-process operation, lead reclamation;, and
other'lead-emitting facilities limit lead concentration in airstreams, the
allowable lead emissions from these facilities increase as the airflow rates
increase. Thus, the exhaust gas concentration standards mentioned by the
commenter allow for emissions differences between large and small plants.
Comment: Several commenters contended that the 0 percent opacity
standard is impractical. These commenters were concerned that emissions
from facilities which emit fine particles would exceed 0 percent opacity.
.Also, some were concerned that emissions from facilities controlled by
fabric filters would exceed 0 percent opacity during fabric filter cleaning.
However, one commenter stated that the 0 percent opacity standard appears to
be achievable for all affected facilities.
Response: The 0 percent opacity standard for lead oxide manufacturing,
.grid casting,'paste mixing, three-process operation and "other lead emitting"
facilities is considered reasonable. Lead oxide manufacturing, grid casting,
paste mixing, and three-process operation facilities were observed by EPA to
have emissions with 0 percent opacity for periods of 3 hours and 19 minutes,
7 hours and 16 minutes, 1 hour and 30 minutes, and 3 hours and 51 minutes,
respectively. For grid casting, the observations were made at a facility
controlled by an impingement scrubber. For lead oxide production and
three-process operation facilities, the observation periods included fabric
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filter cleaning phases. Also, under the promulgated standards, compliance
with the opacity standard is to be determined by taking the average opacity
over a 6-minute period, according to EPA Test Method 9, and rounding the
average to the nearest whole percentage. The rounding procedure is specified
in order to allow occasional brief emissions with opacities greater than
0 percent, which may occur during fabric filter cleaning.
A standard of 0 percent opacity was also proposed for lead reclamation
facilities. Emissions with opacities greater than 0 percent were observed
from the lead- reclamation facility tested by EPA, which was controlled by an
impingement scrubber. However, because the proposed emission limit for lead
reclamation was based on transfer of fabric filtration technology, the
0 percent opacity standard was considered reasonable. As noted in Section 2.2
of this chapter, the final emission limit for lead reclamation is based on
the demonstrated emission reduction capabilities of the impingement scrubber
system tested by EPA. Therefore, the opacity standard for lead reclamation
has also been changed. The final opacity standard is 5 percent, based on
observations at the facility tested by EPA. Emissions from this facility
were observed for 3 hours and 22 minutes, and, during this period, emissions
ranging from 5 to 20 percent opacity were observed for a total of about
11 minutes. The highest 6-minute average opacity during the 3 hour and
22 minute observation period was 4.8 percent. Therefore, the 5 percent
opacity standard for lead reclamation is considered reasonable.
Under the general provisions applicable to all new source performance
standards (40 CFR 60.11), an operator of an affected facility may request
the Administrator to determine the opacity of emissions from the affected
facility during the initial performance test. If the Administrator finds
that an affected facility is in compliance with the applicable standards for
'which performance tests are conducted, but fails to meet an applicable
opacity standard, the operator of the facility may petition the Administrator
to make an appropriate adjustment to the opacity standard for the facility.
Comment: Some commenters stated that EPA should established a
relationship between opacity and emissions before setting opacity standards.
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Response: Opacity limits are being promulgated in addition to mass
emission limits because the Administrator believes that opacity limits
provide the only effective and practical method for determining whether emission
control equipment, necessary for a source to meet the mass emission limits,
is continuously maintained and operated properly. It has not been the
Administrator's position that a single, constantly invariant and precise
correlation between opacity and mass emissions must be identified for each
source under all conditions of operation. Such a correlation is unnecessary
to the opacity standard, because the opacity standard is set at a level such
that if the opacity standard is exceeded for a particular facility, one
would expect that the applicable emission limitation will also be exceeded.
Furthermore, as noted above, a mechanism is provided in the general provisions
whereby the operator of a facility can request that a separate opacity
standard be set for that facility if, during the initial performance test,
the Administrator finds that the facility is in compliance with all applicable
performance standards but fails to meet an applicable opacity standard.
Comment: Some commenters felt that additional testing should be conducted
before standards are promulgated. Several felt that the Administrator
should conduct tests of emissions from Barton lead oxide manufacturing
process, rather than base a standard for this process on tests of a ball
mill lead oxide process. This comment is discussed in Section 2.2 of this
chapter. One commenter contended that the EPA data base is narrow, and that '
tests should be conducted to determine the variability of the efficiency of
emission control systems.
Response: The Administrator has determined that the data base developed
by EPA provides adequate support for the promulgated new source performance
standards. Standards promulgated under Section lll(b) of the Clean Air Act
are intended to require the best demonstrated control technology, considering
cost, nonair quality health and environmental impact, and energy impacts.
Thus, the promulgated standards are based on tests of facilities which have
been determined by EPA to be well controlled and typical of facilities used
in the industry. As noted by some commenters, EPA has not tested emissions
from facilities producing maintenance-free or low-maintenance batteries or
Barton lead oxide production facilities. Differences between such facilities
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and the facilities tested by EPA are discussed in detail below and in
Section 2.1 of this chapter. These differences are not expected to have a
significant effect on the controlled lead concentrations achievable using
the emission control techniques tested by EPA. Commenters did not refer to
nor is EPA aware of any other specific process variations which might influence
emissions. In order to allow for variations which may occur between emission
concentrations from a particular type of facility, the promulgated lead
emissions limits are set above the levels shown to be achievable in EPA
tests.
Comment: Some commenters stated that changes have occurred in the
lead-acid battery manufacturing industry, which may influence emissions,
since the EPA tests were conducted. The changes cited by the commenters
were the production of maintenance-free and low-maintenance-batteries, and
the increasing of volumes of air ventilated from facilities in order to meet
more stringent OSHA standards regulating in-plant lead levels.
The commenters briefly described the difference between maintenance-free
or low-maintenance batteries and normal-maintenance batteries. The only
substantial difference is that a calcium-lead alloy is used to make low-maintenance
and maintenance-free batteries, while standard batteries are made using an
antimonial lead alloy. This difference influences the grid casting and lead
reclamation facilities, where molten lead is processed. The major change is
in the makeup of the dross which must be removed from molten lead in these
facilities. For grid casting, the calcium alloy also requires the'use of
soot as a mold release agent. For the antimonial lead alloy used in standard
batteries, either soot or sodium silicate can be used.
The commenters stated that exhaust volumes for lead-acid battery facilities
have been increased a a result of the revised OSHA standards. One commenter
contended that this change will increase the concentration of uncontrolled
emissions.
Response: The different makeup of dross in grid casting and lead
reclamation facilities producing maintenance-free and low maintenance batteries
is not expected by EPA to cause noticeable differences in lead emissions
between these facilities and facilities producing standard lead-acid batteries.
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The commenters did not give reasons why this difference might be expected to
affect emissions. Dross consists of contaminants in the molten lead alloy
which float to the surface and must periodically be removed. The presence
of a dross layer has an impact on emissions, in that the dross layer serves
to reduce fuming from the molten lead. However, this will occur regardless
of'the composition of the dross layer. Also, because the dross layer is
made up chiefly of contaminants from the lead, the entfainment of dross
particles in air exhausted from grid casting or lead reclamation facilities
will not significantly affect lead emissions. Thus, the .effect of the dross
layer composition on emissions is expected to be much less than the effects
of process operation parameters, such as the frequency of dross removal and
the temperature of the molten lead alloy.
The use of soot rather than sodium silicate as a mold release agent in '
grid casting will not affect uncontrolled lead emissions from this facility.
However, the presence of entrained soot in uncontrolled grid casting'emissions
may require the use of scrubbers rather than fabric filters to control these
emissions. .This problem is discussed in detail in Section 2.2 of this
chapter.
It is acknowledged that the exhaust volumes at the facilities tested by
EPA may not have been sufficient for the attainment of the 50 yg/m3 OHSA
in-plant lead concentration standard. At the time of the tests conducted by
EPA the OSHA standard was 200 yg/m3. However, higher exhaust'volumes would
cause a decrease in the concentration of uncontrolled emissions rather than
an increase. Also, the additional lead particles captured as a result of
the higher exhaust volumes will consist mainly of large particles which are
readily captured by control systems.
Comment: One commenter stated that there is a trend in the lead-acid
battery manufacturing industry to the use of finer lead oxide in battery
pastes in order to increase battery efficiency. The commenter also contended
that this particle size change will influence the collection efficiency
attainable, with fabric filters.
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Response: Lead emissions from lead-acid battery manufacture are generated
by two mechanisms. Lead oxide fumes are produced in welding, casting, and
reclaiming operations, and to a certain extent in lead oxide production.
Agglomerates of lead and lead oxide particles are emitted from operations
involving the handling of lead oxide, lead oxide paste, and lead grids. The
particles which are most difficult to capture are the fume particles. The
emission rate and characteristics of these fume particles are not dependent
on the size of the lead oxide particles used in battery pastes, but on the
temperature of the lead during the operations from which they are emitted.
For these reasons, trends in the industry to the use of smaller lead oxide
particles are not'expected to change the particle size distributions of
emissions in such a way that collector performance will be affected.
2.2 EMISSION CONTROL TECHNOLOGY
Comment: Several commenters thought that the proposed standards would
have required the use of fabric filtration to control emissions.
Response: The proposed standards would not have required that specific
control technology be used for any affected facility, nor will the promulgated
standards require'specific control techniques. Rather, the standards set
emission limits which have been demonstrated to be achievable by the use of
the best control systems considering costs, energy impacts and nonair quality
environmental impact. The standards do not preclude the use of alternative
control techniques, as long as the emission limits are achieved.
Comment: The selection of fabric filtration as the best system of
emission reduction for grid casting and lead reclamation facilities was
criticized by a number of commenters. These facilities are normally uncontrolled
or controlled by impingement scrubbers. The commenters pointed out that
only one grid casting facility in the United States is controlled by a
fabric filtration system and that this system has been plagued by fires.
They explained that the surfaces of exhaust ducts for grid casting and lead
reclamation operations become coated with hydrocarbons and other flammable
materials. For grid casting, these include bits of cork from the molds,
oils used for lubrication, and soot, which is often used as a mold release
agent. For lead reclamation, hydrocarbons from plastic and other contaminants
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charged with lead scrap become entrained in exhaust gases and deposit on the
walls of exhaust ducts. These materials are readily ignited by sparks
which, the commenters contended, are unavoidable. The commenters stated
that fires started in the exhaust ducts will generally propagate to the
control system. One commenter indicated that problems caused by such fires
are not generally severe for scrubbers, but fires would cause serious damage
and emissions excursions if fabric filters were used. The commenters stated
that spark arresters would not solve the fire problem, because they too
would become coated with flammable materials which would be ignited by
. sparks.
Apart from the problem of fires, commenters contended that contaminants
present in the exhaust gases from grid casting and lead reclamation would
cause frequent bag blinding if fabric filters were applied to these facilities.
In addition to the materials listed above, sodium silicate, which is often
used as a mold release agent for grid casting, was cited by the commenters
as an extremely hygroscopic compound which would cause bag blinding.
Commenters also felt that the EPA particle size and emissions test data
did not support the contention made by EPA that a fabric filter could achieve
99 percent emission reduction for emissions from grid casting and lead
reclamation.
Response: Based on the information available when standards for lead-acid
battery manufacture were proposed, EPA had concluded that fabric filtration
could be used to control emissions from grid casting and lead reclamation,
and that 99 percent collection efficiency could be attained. The problem of
bag blinding could be avoided by keeping the exhaust gases from these facilities
at temperatures above their dewpoints. Also, it was thought that exhaust
duct fires could be prevented by the use of spark arresters. Therefore, the
proposed standards for grid casting and lead reclamation were based on tests
of uncontrolled emissions from these facilities, and on fabric filter
efficiencies demonstrated for the three-process operations for facility and
for industries with emissions of similar character to those from lead-acid
battery manufacture. In Tight of the point made by commenters that spark
arresters would not prevent fires, EPA has concluded that the standards for
grid casting and lead reclamation facilities should not be based on fabric
fi1ters.
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The proposed emission limitations for grid casting and lead reclamation
could probably be achieved using a high energy scrubber such as a venturi;
however, because of the particle size of emissions from these facilities, a
scrubber pressure drop of about 7.5 kPa (30 in. W.6.) would be required.2'5
The energy requirement to overcome this pressure drop is not considered
reasonable for these facilities. The emission limits for paste mixing,
three-process operation, and other lead-emitting facilities are based on the
application of fabric filters with average pressure drops of about 1.25 kPa
(5 in. W.G.). Thus, the electricity requirement per unit volume of exhaust
gas to operate venturi scrubbers for the grid casting and lead reclamation
facilities would be roughly six times the electricity requirement per unit
volume to control other plant exhausts.
The Administrator has determined that, for the lead-acid battery
manufacturing industry, impingement scrubbers operating at a pressure drop
of about 1.25 kPa (5 in. W.6.) represent the best system of emission
reduction considering costs, nonair quality health and environmental impact
and energy requirements for grid casting and lead reclamation. Therefore,
in the promulgated standards, the emission limitations for grid casting and
lead reclamation have been raised to levels which have been shown to be
achievable in tests of scrubbers controlling these facilities. This change
represents a change from the regulatory alternative chosen from the proposed
standards. The environmental, economic, and energy impacts of the alternative
which has been chosen for the promulgated standards are discussed in Chapter 8
of Volumes I. ,It is estimated that standards based on the application of
impingement scrubbers to grid casting and lead reclamation facilities will
result in a 50 percent decrease in NSPS electricity requirements from standards
requiring venturi scrubbers for these facilities, while having only a slight
impact on the emission reduction attributable to the NSPS. (Chapter 1,
Tables 1-3, 1-4, and 1-6).
EPA measured lead emissions from two grid casting facilities (Volume I,
Chapter 4 and Appendix C). One of these facilities was uncontrolled, and
the other was controlled by an impingement scrubber. The average lead
concentration in the exhaust from the uncontrolled facility was 4.37 mg/dscm
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(19.1 x 10 gr/dscf). Average uncontrolled and controlled lead emissions
from the scrubber controlled facility were 2.65 mg/dscm (11.6 x 1(T4 gr/dscf)
and 0.32 mg/dscm (1.4 x 10'4 gr/dscf), respectively. The promulgated
standard for grid casting, 0.4 mg/dscm (1.76 x 10"4 gr/dscf), is based on
the controlled lead emission rate for this facility. The facility is considered
typical, of grid casting facilities used in the lead-acid battery manufacturing
industry. EPA is. not aware of any process variations which would result in
a significant increase in the emission concentration achievable using a
scrubber control system. However, in order to allow for variations in grid
casting emissions, the promulgated lead emission limit has been set above
the level shown to be achievable in the EPA test.
Grid casting test results were also submitted by two commenters. Data
submitted by one commenter for a grid casting facility show average
uncontrolled lead emissions of about 2 mg/dscm (9 x 10~4 gr/dscf).6 The
test method used to collect these data is similar to Method 12. Data submitted
by the other commenter showed average uncontrolled lead emissions of about
1.1 mg/dscm (4.7 x 10~4 gr/dscf); however, the test method used to gather
these data is not known.7
Lead reclamation emissions were measured by EPA for a facility controlled
by an impingement scrubber (Volume I, Chapter 4 and Appendix C). Average
lead concentrations in^the inlet and outlet streams from the scrubber were
227 mg/dscm (990 x 10'4 gr/dscf) and 3.7 mg/dscm (16 x 10~4 gr/dscf). The
standard for lead reclamation, 4.5 mg/dscm (19.8 x 10"4 gr/dscf), is based
on the controlled emission rate measured for this.facility. This facility
is considered typical of lead reclamation facilities used in the lead-acid
battery manufacturing industry. EPA is not aware of any process variations
which would result in a significant increase in the emission concentration
achievable using a scrubber control system. In order to allow for variation
in lead reclamation emissions, the promulgated lead emission standard has
been set above the emission level shown to be achievable in the EPA test.
Comment: Several commenters criticized the choice of fabric filtration
as the best system of emission reduction for the entire paste mixing cycle.
The paste mixing operation is a batch operation consisting of two phases:
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charging and mixing. The paste mixing facility is generally controlled by
impingement scrubbing, although fabric filtration is often used to control
exhaust from the charging phase. The commenters felt that if fabric
filtration were to be used for the entire cycle, the moisture present in the
exhaust during the mixing phase would cause bag blinding. Therefore, they
requested that the emission limit for paste mixing be raised to a level
achievable using impingement scrubbers.
Response: If fabric filters are used to meet the emission limit, bag
blinding can be prevented by keeping paste mixer exhausts at temperatures
above their dew points. The energy which would be required to heat the
exhaust gases and the costs for providing insulation for ducts and fabric
filters applied to paste mixing facilities were taken into consideration in
the energy and economic analyses for the new source performance standards.
These costs and energy requirements are considered reasonable. In addition,
data submitted by one commenter show that the standard for paste mixing is
achievable using scrubbers. Tests were conducted of emissions from two
scrubber controlled paste mixing facilities, using methods similar to
Method 12. .These tests indicated average controlled lead emissions of
0.04 mg/dscm (0.19 x 10"4 gr/dscf) and 0.07 mg/dscm (0.30 x 10"4 gr/dscf)
for the two facilities.8,9 Both of these average concentrations are well
below the 1 mg/dscm (4.4 x 10~4 gr/dscf) standard for paste mixing.
Comment: Some commenters contended that EPA test data did not
adequately support the statement that 99 percent collection efficiency could
be achieved for paste mixing emissions. The commenters felt that the
standard for paste mixing should be relaxed.
Response: The standard for paste mixing is considered achievable.
Emissions from a paste mixing facility controlled by an impingement scrubber
were tested by EPA. The average uncontrolled lead concentration from this
facility was 77.4 mg/dscm (338 x 10"4 gr/dscf). Thus, the promulgated
regulation is expected to require about 98,7 percent control of lead
emissions from paste mixing. EPA tests of a fabric filtration system
controlling a three-process operation showed an average lead collection
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efficiency of 99.3 percent. This fabric filtration system underwent bag
cleaning during testing. Also, EPA tests and statements, made by several
commenters indicate that the particle size distribution for paste mixing
emissions is similar to that for three-process operation emissions.
Emissions from paste mixing are made up of lead oxide agglomerates, while
emissions from three-process operation facilities are made up mainly of
agglomerates with some fumes and some other large particles. The above data
clearly show that efficiencies greater than 98.7 percent can be achieved for
paste mixing emissions.
In addition, EPA tests of a controlled paste mixing facility indicate
that the 1 mg/dscm standard for paste mixing is achievable. EPA conducted
tests at a plant where paste mixing emissions were controlled by two separate
systems. At this plant, paste mixing required a total of 21 to 24 minutes
per batch. During the first 14 to 16 minutes of a cycle (the charging
phase), exhaust from the paste mixer was ducted to a fabric filter which
also controlled emissions from the grid slitting (separating) operation.
During the remainder of the cycle (mixing), paste mixer exhaust was ducted
to an impingement scrubber which also controlled emissions from the grid
casting operation. Uncontrolled or controlled emissions for the paste mixer
alone were not tested. The average concentration of lead in emissions from
the fabric filtration system used to control charging emissions was 1.3 mg/dscm
(5.5 x 10 gr/dscf). The average lead content of exhaust from the scrubber
used to control mixing emissions was 0.25 mg/dscm (1.1 x 10"4 gr/dscf). The
average lead concentration in controlled emissions from this facility was
about 0.95 mg/dscm (4.2 x 10~4 gr/dscf) which is slightly below the emission
limit of 1 mg/dscm (4.4 x 10" gr/dscf). A lower average emission concentration
could be achieved, by using fabric filtration to control emissions from all
phases of paste mixing.
Also, as noted above, one commenter submitted data showing that the
standard for paste mixing is achievable using impingement scrubbing to
control emissions from the entire cycle.
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Comment: Several commenters criticized the fact that the standard for
lead oxide production is based on tests conducted at a ball mill lead oxide
production facility, but will apply to Barton lead oxide production
facilities as well as ball mill facilities. Some commenters stated that the
particle size of lead oxide to be collected depends on the type of oxide
produced. One commenter stated that Barton facilities are more commonly
used to produce lead oxide than ball mill facilities.
Response: However, in both the ball mill process and the Barton
process, all of the lead oxide product must be removed from an air stream.
In the ball mill process, lead pigs or balls are tumbled in a mill, and the
frictional heat generated by the tumbling action causes the formation of
lead oxide. The lead oxide is removed from the mill by an air stream. In
the Barton process, molten lead is atomized to form small droplets in an air
stream. These droplets are then oxidized by the air round them.
EPA tests on a Barton process indicated that Barton and ball mill
processes have similar air flow rates per unit production rate (Appendix C
of the BID, Volume I). Because these air streams carry all of the lead
oxide produced, the concentrations of lead oxide in the two streams must
also be similar.
Data submitted by one commenter indicate that the percentage of fine
particles in lead oxide produced by the Barton process is similar to the
percentage of fine particles in lead oxide produced by the ball mill. 10
These data were obtained by placing samples of captured ball mill and Barton
oxides in a Coulter, particle counter. The size distributions measured by
this technique are representative of the size of the product oxide, rather
than the airborne oxide entering the collector. However, the similarity of
the percentages of small particles for ball mill and Barton oxides suggest a
similarity in the percentages of small particles in the feed streams to the
collectors for these two processes.
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The similarities between the concentrations and particle size distributions
of the oxide bearing air streams in the Barton and ball mill processes ,
support EPA's contention that a similar level of emission control could be
achieved for a Barton process as has been demonstrated for the ball mill
process. Also, no test data, were submitted by the commenters to show that
the standard for lead oxide production cannot be achieved by a well controlled
Barton process. It should be noted that, .'to allow for variations in lead
oxide manufacturing emissions, the promulgated standard has been set above
the emission rate shown to be achievable in the EPA ball mill facility test.
Comment: Several commenters felt that the standard for lead oxide
production was too stringent. These commenters stated that engineering
calculations using typical fabric filter and cyclone efficiencies indicate
that the standard for lead oxide production would not be met by a facility
controlled by a cyclone -and a fabric filter in series.
Response:- The emission limit for lead oxide production of 5 milligrams
of lead per kilogram of lead processed is considered reasonable. The limit
is based on results of tests of emissions from a ball mill lead oxide production
facility with a fabric filter control system. The test showed an average
controlled emission rate of 4.2 mg/Kg (8.4 Ib/ton) for this facility. The
emission limit for lead oxide.production of 5 milligrams of lead per kilogram
of lead processed is considered reasonable. The limit is based on results
of tests of emissions from a ball mill lead oxide production facility with a
fabric filter control system. The test showed an average controlled emission
rate of 4,2 mg/kg (8.4 Ib/ton) for this facility. In estimating the emission
reduction which could be achieved for a lead oxide production facility, the
commenters used typical fabric,filter and cyclone efficiencies. It should
be noted that uncontrolled dust streams from lead oxide production are
extremely concentrated. At such concentrations, fabric filter and cyclone
reduction capabilities are higher than under typical conditions.
Comment: Several commenters stated that the emission limit for the
three-process operation was not supported by the BID for the proposed standards.
However, one commenter stated that the emission limit appears achievable.
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Response: The limit for the three-process operation is based on the
results of EPA tests conducted at four plants where fabric filtration was
used to control three-process operation emissions. Each of the sets of
tests conducted by EPA showed average controlled lead concentrations below
the proposed limit. The standard for the three-process operation has been
set well above the average emission concentration detected in all of the EPA
tests. Therefore, the lead emission.limit for the three-process operation
facility is considered reasonable.
2.3 MODIFICATION AND RECONSTRUCTION
Comment: One commenter questioned whether the standards would apply to
modified or recontructed facilities at .a pi ant.where production capacity is
increased from below the small size cutoff to above the cutoff as a result
of the modification or reconstruction.
Response: Circumstances under which an "existing facility" may become
an affected facility (a facility which must be in compliance with applicable
standards) are described in the modification and reconstruction provisions
for new source performance standards (40 CFR 60.14, 60.15). For the purposes
of these provisions, an existing facility is defined as "any apparatus of a
type for which a standard is promulgated (§60.2(aa))." A lead-emitting
operation at a lead-acid battery plant-which is smaller than the size cutoff
(5.9 Mg/day or,6.5 tons/day of lead throughput) is of a type for which a
standard is promulgated and is, therefore, an existing facility. Upon
undergoing "modification" or "reconstruction" (defined in §60.14 and §60.15),
such a facility would be considered as an affected facility if, during its
modification or reconstruction, the production capacity of the plant
containing the facility is increased above the small size cutoff.
2.4, ECONOMIC IMPACT
Comment: One commenter contended that new source performance standards
would impose a substantial and burdensome cost of the lead-acid battery
manufacturing industry. Another stated that battery sales have fallen by
25 percent in recent years.
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Response: The economic impacts of new source performance standards on
the lead-acid battery manufacturing industry are analyzed and described in
detail in Volumes I and II of the BID. These impacts are summarized in
Chapter 1. The projected economic impacts are considered reasonable. The
expected annualized cost of compliance with the promulgated standards at a
typical affected plant is expected to be only about 1.6 percent of the
wholesale price of a battery; and the economic impact analysis indicates
that this cost could be passed on with little effect on sales.
The market for lead-acid batteries is tied to the automobile market for
both original equipment and replacement batteries. The 25 percent drop in
sales cited by the second commenter results from the recent decline in the
demand, for domestic automobiles. This decline is not expected to continue
and the sales of the domestic automobile industry are expected to increase
in the near future.
Comment: Several commenters contended that the cost of compliance with
OSHA standards was not adequately addressed in Volume I of the BID. The
commenters also felt that the OSHA standards would require higher ventilation
rates than are currently needed, and would thus cause the costs of compliance
with, new source performance standards to be higher than the estimates made
by EPA.
Response: The OSHA compliance costs presented in Volume I are based on
the capital and operating control costs which were expected to be required
to meet the employee exposure standards of 200 yg/m3 originally proposed by
OSHA in 1975. The controls include employee care, general plant maintenance,
and local ventilation of in-plant lead emission sources. On November 14, 1978,
OSHA promulgated an employee exposure standard of 50 yg/m3. However, the
controls necessary to comply with this standard are expected to be similar
to those which would have been necessary for the originally proposed 200 yg/m3
standard.11,12 In addition, the economic impact projected .for the OSHA
standards in Volume I may be higher than the actual economic impact, because,
in a number of cases, work practices can be used to achieve the OSHA standard
in place of technological controls.
In Volume I of the BID, the statement is made that a change in the OSHA
standards could cause the control costs for the new source performance
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standards to increase substantially. However, the facility exhaust rates
used to estimate the costs of achieving the NSPS were set at levels which
would provide good ventilation for the facilities under consideration. The
exhaust rates were chosen to achieve a face velocity of 250-300 ft/min for
hoods, and 300-350 ft/min for slot-type vents. ' One industry representa-
tive stated that face velocities have been increased from 150-200 ft/min to
350-500 ft/min in order to reduce lead levels in the working zone to below
1 ^
50ug/m3. Thus, although the ventilation rates used in the industry to
comply with the current OSHA standards may be much higher than those which
have been used in the past, they are not much higher than the ventilation
rates used to calculate the economic impacts of the promulgated new source
performance standards. Thus, it is not expected that the change in the OSHA
standards would have a significant impact on the results of the economic
impact-analysis for the NSPS.
Comment: One commenter stated that the new source performance standards
would indirectly require the installation of stacks which would meet the
criteria specified by EPA Reference Method 1 for sampling and gas velocity
measurements. The commenter stated that the impacts of this requirement
were not addressed.
Response: The costs of stacks which meet EPA Method 1 criteria are not
considered attributable to new source performance standards. Under SIP
regulations, most States require an initial performance test for any new
source. Therefore, in the absence of the promulgated standards, most new
facilities would nonetheless be required to have stacks.
2.5 ENVIRONMENTAL IMPACT
Comment: A number of commenters stated that lead-acid battery manufacture
accounts for a small percentage of total nationwide lead emissions and
contended, for this reason, that, new source performance standards for lead-acid
battery manufacture should not be set. One commenter cited data which
indicate that lead emissions from lead-acid battery manufacture accounted
for only about 0.32 percent of industrial lead emissions or about 0.014. percent
of total nationwide lead emissions in 1975.
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Response: It is acknowledged that lead-acid battery plants account for.
a relatively small share of total nationwide atmospheric lead emissions. In
1975, about 95 percent of U.S. lead emissions resulted from the production
of alkyl lead gasoline additive, the burning of leaded gasoline, and the
disposal- of crankcase oil from vehicles which burn leaded gasoline. These
emissions will be reduced substantially as the use of alkyl lead gasoline
additives is curtailed. Another 1 percent of nationwide lead emissions is
from mining and smelting operations, which are generally located in remote
areas. Because lead-acid battery plants are generally located in urban
areas -- near the markets for their batteries lead emissions from lead-acid
battery manufacture may reasonably be anticipated to endanger public health
or welfare. Therefore, the Administrator considers the development of new
source performance standards.for lead-acid battery manufacture to be justified.
Comment: Several commenters recommended that the grid casting facility
be removed from the list of affected facilities. According to EPA estimates,
grid casting accounts for about 3.2 percent of overall uncontrolled battery
plant lead emissions. The commenters stated that it is unreasonable to
require sources to control facilities generating such a small percentage of
total plant emissions.
Response: Although grid casting is small source of emissions relative
to other facilities, it is not an insignificant source. Lead emissions from
this facility are controlled at a number of existing plants. Also, if other
facilities at a plant were controlled to the extent required under the new
source performance standards, but grid casting facilities were left
uncontrolled, emissions from grid casting would amount to about 50 percent
of the total plant lead emissions. Therefore, the standard for grid casting
is considered environmentally beneficial. Also, the costs and energy
requirements of controls for this facility have been included in the energy
and economic impact analyses of the new source performance standards and are
considered reasonable.
2.6 -LEGAL CONSIDERATIONS
Comment: One comment which involved legal considerations was that, if
fabric filtration is considered the best available control technology for a
facility, then an equipment standard f-equiring fabric filtration should be set for
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that facility rather than a performance standard. The commenter pointed out .
that, under Section lll(h) of the Clean Air Act, the Administrator is empowered
to promulgate a'design, equipment, work practice, or operational standards,
or combination thereof.
Response: Section lll(h) states that an equipment standard may be
promulgated only if the Administrator determines that it is not feasible to
prescribe or enforce a standard of performance. Thus, because performance
standards are feasible for the lead-acid battery manufacture source category,
the Administrator has no reason to promulgate equipment standards for this
source category.
Comment: Another comment which involved legal considerations was that,
because a National Ambient Air Quality Standard for lead has been established,
new source performance standards regulating lead emissions would be redundant
and unnecssary.
Response: It should be noted that the purposes of standards of performance
for new sources promulgated under Section 111 of the Clean Air Act differ
from the purposes of national ambient air quality standards, which are
promulgated under Section 109 of the Act. National ambient air quality
standards are established to protect the public health or welfare. Under
Section 109 of the Clean Air Act, national ambient air quality standards are
to be set at levels such that the attainment and maintenance of the standards
are requisite to protect the public health or welfare..
New source performance standards promulgated under Section 111 of the
Clean Air Act are not designed to achieve any specific air quality levels,
but are instead established to enhance air quality. Under Section 111,
such standards are to reflect the degree of emission limitation achievable
through application of the best demonstrated technological system of
emission reduction considering cost, any nonair quality health and environ-
mental impact, and energy requirements.
Congress expressed several reasons for requiring the setting of new
source performance standards reflecting the degree of emission reduction
achievable through application of the best demonstrated control technology.13
First, national standards are needed to avoid situations where some States
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may attract industries by relaxing standards relative to other States.
Second, because the national ambient air quality standards create air quality
ceilings which are not to be exceeded, stringent standards for new sources
enhance the potential for. long term growth. Third9 stringent standards may
help achieve long-term cost savings by avoiding the need for expensive
retrofitting when pollution ceilings may be reduced in the future. Fourth,
the standard-setting process should create incentives for improved technology.
2.7 TEST METHODS AND.MONITORING
2.7.1. Reference Method 12
Comment: A number of commenters felt that Reference Method 12 was
cumbersome and recommended the development of a simpler screening method.
The commenters stated that a battery plant may have as many as two dozen
stacks and that, at an average cost of $6000 per stack test, the cost of
testing an entire plant could be extremely high.
Response: Because controlled emission levels are expected to be near
'the emission limits for facilities affected by the regulation, a screening
method less accurate than Method 12 would not be suitable for determining
compliance with the lead-acid battery manufacture regulation. Also, the per
plant costs of conducting performance tests using Method 12 are not expected
to be as high as the commenters expected. .Although existing plants often
have a large number of stacks, it is expected that, for newly constructed,
modified, or reconstructed plants or facilities, emissions will be ducted to
a small number of stacks. In addition, the estimate of $6000 per stack for
a compliance test applies only for plants where one or two stacks are to be
tested. For plants with a large number of stacks, the cost per stack should
decrease considerably.
Comment: One commenter recommended that the minimum sampling time for
Method 12 be extended. Others stated that the minimum sampling time for
grid casting in the proposed regulation was too long.
Response: For tests with Method 12, the minimum amount of lead needed
for good sample recovery and analysis is 100 yg. The minimum sampling rates
and times ensure that enough lead will be collected. For grid casting, the
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minimum sampling time has been changed from 180 minutes, in the proposed
regulation, to 60 minutes, in the promulgated action. The change reflects
the alteration in the standard for grid casting.
2.7.2 Reference Method 9
Comment: Two commenters expressed concern that Method 9 is not accurate
enough to be used to enforce a standard of 0 percent opacity. One commenter
stated that it is difficult to discern the difference between 0 percent
opacity and 1 percent opacity for a given reading.
Response: No single reading is made to the nearest percent, rather,
readings are to be recorded in increments of 5 percent opacity and averaged
over a period of 6 minutes (24 readings). For the regulation for lead-acid
battery manufacture, the 6 minute average opacity figure is to be rounded to
the nearest whole number. The opacity standard for lead-acid battery manu-
facture is based on opacity data taken for operating facilities, and these
data have shown that this standard can be met (Section 2.1 of this chapter).
2.8 REPORTING AND RECORDKEEPING
Comment: A number of commenters contended that the proposed pressure
drop monitoring and recording requirement for control systems would not
serve to insure proper operation and maintenance of fabric filters. The
commenters pointed out that a leak in a fabric filter would not result in a
measurable difference in the pressure drop across the filter. One commenter
suggested that the pressure drop monitoring requirement be replaced by an
opacity monitoring requirement. Another commenter suggested that the pressure
drop requirement be replaced by a requirement of visible inspection of bags
for leaks.
Response: Based on the arguments presented by these commenters, it is
agreed that proposed pressure monitoring requirement for fabric filters
would not serve its intended purpose. Therefore, this requirement has been
eliminated. However, pressure drop is considered to be a good indicator of
proper operation and maintenance for scrubbers. Therefore, the pressure
drop monitoring and recording requirement for scrubbers has been retained.
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The pressure drop monitoring requirement for fabric filters has not
been replaced by another monitoring requirement. The cost of opacity
monitoring equipment may in some cases be comparable to the cost of emission
control systems for lead-acid battery manufacturing facilities.17 This cost
is considered unreasonable. Although periodic visual inspection of bags
would provide an indication of bag integrity, visual records would not be
useful to EPA in the enforcement of the promulgated standards.
Comment: A number of commenters stated that while pressure drop
monitoring is useful for scrubbers, continuous recording of pressure drop
would be unnecessary and expensive. Some commenters questioned whether a
device which cyclically monitors the pressure drop across several emission
control systems would be considered a continuous recorder for the systems.
These commenters also asked how often such a recorder would have to monitor
the pressure drop across a particular control device to be considered a
continuous recorder for that device. One cqmmenter suggested the substitution
of periodic manual recording of pressure drop for the continuous pressure
drop recording requirement. Another commenter questioned the purpose of
requiring pressure drop monitoring and recording without a requirement that
action be taken at certain pressure drop levels.
Response.: The purpose of pressure drop recording requirements is to
allow the verification by EPA regional enforcement personnel that emission
control systems are properly operated and maintained. The costs of pressure
drop recording devices were analyzed and are considered reasonable.17 The
point of what sort of device would satisfy the recording requirement has
been, clarified in the promulgated standards. It has been determined that
for the purposes of this regulation a device which records pressure drop at
least every 15 minutes would accomplish the same purposes' as a continuous
pressure drop recorder. Manual pressure drop recording would not ensure
proper operation and maintenance of a control system.
2.9 MISCELLANEOUS
Comment: A number -of commenters recommended that the definition of the
paste mixing facility be expanded to include operations ancillary to paste
mixing, such as lead oxide storage, conveying, weighing, and metering operations;
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paste handling and cooling operations; and plate pasting, takeoff, cooling,
and drying operations. The commenters stated that paste mixing and operations
ancillary to the paste mixing operation are generally interdependent, in
that one operation is not run without the others. Also, emissions from
paste mixing and ancillary operations are often ducted to the same control
device. The commenters were concerned that a minor change made to a paste
mixing machine could cause the machine to be affected by the promulgated
standards under the reconstruction provisions applicable to all new source
performance standards. They stated that the recommended change would avoid
this possibility.
Response: These comments are considered reasonable. The operations
ancillary to paste mixing were not intended to be considered separate
facilities, and the definition recommended by the commenters for the paste
mixing facility is considered an appropriate definition. Therefore, this
recommendation has been adopted in the promulgated regulation. Because the
standard which was proposed for paste mixing is identical to that which was
proposed for operations ancillary to paste mixing (other lead-emitting
operations), this change will not affect the environmental impacts of the
standards.
Comment: One commenter recommended that the operations comprising the
three-process operation facility be treated separately. The commenter
stated that emissions concentrations may differ for the three operations.
Response: In the development of the new source performance standards,
it was found that the operations which make up the "three-process operation"
are generally ducted to a common control device.
Comment: One commenter stated that the standards for lead-acid battery
manufacture should also cover battery reclaiming operations.
Response: New, modified, and .reconstructed lead battery reclaiming
operations are covered by new source performance standards for secondary lead
smelters, which were promulgated March 8, 1974, and regulate parti oil ate
emissions. Because most lead emissions from secondary lead smelters are in
the form of particulate matter, the particulate standards serve to. regulate
lead emissions as well. The possibility of revising the standards to regulate
sulfur oxide emissions is currently being studied by EPA.
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Comment: Another commenter recommended that precautions be taken to
prevent fugitive emissions resulting from the handling of material collected
by fabric filters. The commenter cited as an example a plant at which the
fabric filter catch is conveyed to storage containers using flexible canvas
ducts. These allow the reentrainment into the atmosphere of dust collected
by the fabric filter.
- Response: Lead emissions from the handling of captured particulate
matter are not expected to be significant in comparison with process
emissions. Also, the means of handling captured particulate"matter would
vary from plant to plant. Thus, the Administrator did not consider the
development of national standards for such emissions to be justified.
Cpmmejrt: A revised version of the CRSTER dispersion model was used to
assess the ambient air impact of standards of performance for lead-acid
battery manufacture. One commenter stated that the CRSTER model, as documented
by its users manual (EPA-480/2-77-013), does not address a number of important
factors, including aerodynamic building and stack tip downwash, transitional
plume rise, spatial separation of emission points, and the fact that most
battery plant exhaust gases are discharged at ambient or near ambient temperatures.
The commenter also-stated that EPA new source review guidelines provide for
the use of meteorological data for five years; while for the model lead-acid
battery plants, the model was run using data for only one year.
ResP°nse: The revised CRSTER model used in the development of the new
source performance standards was not fully, described in Volume I of the BID.
In fact, all of the factors mentioned by the commenter are addressed in the
revised model which is described in the docket for the proposed standards
(see docket item no. II-B-24). Since the modeling was performed for a hypothetical
plant, there was no requirement to use multiple years of meteorological
data. As was pointed out, direct extrapolation of the results to an actual
plant should not be attempted. If an actual plant were to be modeled,
multiple years of meteorological data would be required.
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Comment: In the preamble to the proposed standards, the public was
specifically invited to submit comments with supporting data on acid mist
control. Only one comment was received regarding the acid mist issue. The
commenter did not refer specifically to acid mist emission's from lead-acid
battery manufacturing, but made the general statement that EPA should devote
more attention to all sulfuric acid emissions and effluents.
Response: Since no evidence was submitted which indicated that
sulfuric acid mist emissions from lead-acid battery manufacture may
reasonably be anticipated to contribute significantly to air pollution,
there is no basis for regulation of sulfuric acid mist emissions from this
industry at this time.
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2.10 REFERENCES FOR CHAPTER 2
. 1. Economic Impact StatementInorganic Lead. Prepared by D.B. Associates
for the Occupational Safety and Health Administration. Washington, D.C.
February 1977. p. 5-42.
2. Letter and attachments from Hatterscheide, I.E., 'Gould, Inc. to Central
Docket Section, EPA. March 6, 1980. p. 15. Public comment. (Docket
No. IV-D-3) .
3. Letter and attachments from Beaudoin, J.M., Globe-Union, Inc. to Central
Docket Section, EPA. March 13, 1980. Figure 2. Public comment.
(Docket No. IV-D-17)
4. Lead-Acid Battery Manufacture Background Information for Proposed
Standards. U.S. Environmental Protection Agency. EPA-450/3-79-028a.
November 1979.
5. Memo from Battye, W., GCA/Technology Division to Fitzsimons, J.G., EPA.
April 18, 1980. 7p. Pressure drop requirements to achieve 99 percent
control of grid casting and lead reclamation emissions. (Docket No. IV-B-6)
6. Letter and attachments from St. Louis, R., Pennsylvania Department of
Environmental Resources. June 9, 1976. 27p. Report of Emissions
Testing. (Docket No. IV-D-27)
7. Reference 2. pp. 7,8.
8. Letter and attachments from Hambright, J.K. Pennsylvania Department of
Environmental Resources to central Docket Section, EPA. March 6, 1980.
Enclosure 5. Public comment. (Docket No. IV-D-2)
9. Report of Emission Testing Performed December 10, 1975 on Entoleter
Scrubber, Presto!ite Battery Division., Eltra Corp. Temple, Pennsylvania.
Spotts, Stevens, and McCoy, Inc. January 15, 1976. 24p. (Docket No. IV-D-27)
10. Reference 2. pp. 13, 14.
11. Occupational Safety and Health Administration, Department of Labor.
Occupational Exposure to Lead Attachments to the Preamble for the
Final. Standard. Federal Register. Washington, D.C. 43(225):45585-54488,
54503-54506. November 1978. .
12. National Institute for Occupational Safety and Health. The Industrial
Environment its Evaluation and Control. Washington, D.C. U.S.
Government Printing Office, 1973. p. 597-608.
13. Ferris, W. Battery Plant Ventilation Study. Prepared by AB Machine
and Equipment Co., inc., Memphis, Tennessee for PEDCo Environmental *
Cincinnati, Ohio. October 27, 1980. (Docket No. II-A-1)
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References (continued)
14. Telephone conversation between Battye, W., GCA/Technology Division and
Ferris, W., Battery Equipment Service Co., Bradenton, Florida. July 3, 1980.
'(Docket No. IV-E-8)
15. Telephone conversation between Battye, W., GCA/Technology Division and
Hatterscheide, T.E., Gould, Inc. April 7, 1980. (Docket No. IV-E-5) .
16. Committee on Interstate and Foreign Commerce, House of Representatives.
Clean Air Act Amendments of 1977, Report No. 95-294. Washington, D.C.
, U.S. Government Printing Office, 1977. pp. 184-186.
17. Memo from Battye, W., GCA/Technology Division to Fitzsimons, J.G., EPA.
August-15, 1980. Cost of opacity monitors for lead-acid battery manufacturing
facilities. (Docket No. IV-D-8)
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
i. REPORT NO.
EPA-45D/3-79-028b
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Lead-Acid Battery Manufacture
for Promulgated Standards
- Background Information
5. REPORT DATE
November 1980
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, NC 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3057
12. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air,. Noise and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD COVERED
Draft
14. SPONSORING AGENCY CODE
EPA/200/04
is. SUPPLEMENTARY NOTES volume I discussed the proposed standards and the resulting environ-
mental and economic effects. -Volume II contains a summary of public comments, EPA re-
sponses and discussion of the differences between the proposed and promulgated standard
16. ABSTRACT
Standards of performance for the control of emissions from lead-acid battery
manufacturing plants are being promulgated under the authority of Section 111 of the
Clean Air Act. These standards would apply to new, modified, or reconstructed
facilities at any lead-acid battery manufacturing plant with the capacity to produce
in one day batteries which would contain in total an amount of lead greater than or
equal to 5.9 Mg (6.5 tons). This document contains information on the public comments
made after proposal, EPA responses and differences between the proposed and
promulgated standards.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Air pollution
Pollution control
Standards of performance
Lead-acid battery manufacturing plants
Lead ' "
).IDENTIFIERS/OPEN ENDED TERMS
c. . COS AT I Field/Group
Air Pollution Control
13B
8., DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (ThisReport)'
Unclassified
21. NO. OF PAGES
56
2O. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77)
PREVIOUS EDITION.IS OBSOLETE
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