United States
Environmental Protection
Agency
Office of Air Quality :
Planning and Standards
Research Triangle Park NC 27711
EPA-45O/3-84-009
May 1984
Air
Review of New
Source Performance
Standards for
Secondary Brass
And Bronze Plants
-------
-------
EPA-450/3-84-009
Review of New Source Performance
Standards for Secondary Brass
And Bronze Plants
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
May 1984
-------
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, North Carolina 27711; or, for a fee, from the National Technical Information Services, 5285
Port Royal Road, Springfield, Virginia 22161.
-------
TABLE OF CONTENTS
Section Title Page
1 EXECUTIVE SUMMARY 1-1
1.1 Regulatory History of Current Standard 1-1
1.2 Industry Outlook 1-1
1.3 Control Technology 1-2
1.4 Compliance Test Data 1-2
1.5 Economic Considerations Affecting the NSPS 1-3
2 INDUSTRY DESCRIPTION 2-1
2.1 Introduction 2-1
2.2 Background Information 2-2
2.3 Brass and Bronze Production 2-2
2.4 References for Chapter 2 2-16
3 SUMMARY OF CURRENT STANDARDS . 3-1
3.1 New Source Performance Standards 3-1
3.2 State Regulations 3-2
3.3 References for Chapter 3 3-4
4 STATUS OF CONTROL TECHNOLOGY . . . 4-1
4.1 Emissions Potential " 4-1
4.2 Control Technology 4-4
4.3 References for Chapter 4 4-5
5 EMISSION TEST RESULTS 5-1
5.1 Analysis of Emission Tests 5-1
5.2 Other Atmospheric Emissions 5-3
5.3 Water Discharges and Solid Waste Generation 5-3
5.4 References for Chapter 5 5-3
-------
TABLE OF CONTENTS
Section Title
6
6.1
6.2
6.3
6.4
COST ANALYSIS 6-1
Reverberatory Furnaces 6-2
Electric Furnaces ,. 6-2
Retrospective Analysis of Original Economic Impact
Projections 6-4
References for Chapter 6 6-7
7
7.1
ENFORCEMENT ASPECTS 7-1
References for Chapter 7 7-2
-------
LIST OF TABLES
Table 2-1 Brass and Bronze Alloys, Chemical Specifications, and
Product Characteristics 2-3
Table 2-2 End Uses of Brass and Bronze . 2-4
Table 2-3 Producers of Brass and Bronze, February 1983 ..... 2-5
Table 2-4 Secondary Brass and Bronze Facilities Subject to the
New Source Performance Standards 2-7
Table 3-1 Summary of State Regulations for Secondary Brass and
Bronze Production Processes ... 3-3
Table 5-1 Emission Test Results of Secondary Brass and Bronze
Facilities 5-2
Table 6-1 Model Plants 6-3
Table 6-2 Prices for Brass and Bronze Ingots . . . .... . . . 6-6
x
LIST OF FIGURES
Page
Figure 2-1 Brass and Bronze Annual Ingot Shipments, 1971-1982 . . 2-9
Figure 2-2 Schematic of a Typical Secondary Metal Blast Furnace
or Cupola 2-12
Figure 2-3 Schematic of a Stationary Reverberatory Furnace . . . 2-13
Figure 2-4 Electric Furnace Types 2-15
-------
-------
1. EXECUTIVE SUMMARY
1.1 REGULATORY HISTORY OF CURRENT STANDARD
The new source performance standards (NSPS) for secondary brass and
bronze ingot production plants were proposed on June 11, 1973, and
promulgated by the Environmental Protection Agency (EPA) on March 8,
1974 (40 CFR 60, Chapter 1, Subpart M). The secondary brass and bronze
NSPS applies to reverberatory and electric furnaces of 1,000 kg (2,205 Ib)
or greater production capacity and to blast (cupola) furnaces of 250 kg/h
(550 Ib/h) or greater production capacity that were constructed or
modified on or after June 11, 1973. The standards state that exhaust
gases discharged to the atmosphere from reverberatory furnaces must not
contain particulate matter in excess of 50 mg/dscm (0.022 gr/dscf) and
must not exhibit 20 percent opacity or greater. The standards also
state that exhaust gases from electric and blast (cupola) furnaces must
not exhibit 10 percent opacity or greater.
The objective of this report is to review the NSPS for secondary
brass and bronze ingot production plants and to assess the need for
revision on the basis of developments that have occurred since the
original NSPS was promulgated in 1974 and since the last review in 1979.
The following paragraphs summarize the results and conclusions of the
review.
1.2 INDUSTRY OUTLOOK
In 1973, approximately 258,500 Mg (285,000 tons) of brass and
bronze ingot were produced at 60 plants. By 1982, production had declined
to 154,200 Mg (170,000 tons), and 37 plants were in operation. Despite
this decline, five rotary reverberatory furnaces and one electric induction
furnace have been installed since the NSPS was proposed and are therefore
1-1
-------
subject to its provisions. Most of this growth has occurred since the
NSPS was reviewed in 1979; only two reverberatory furnaces were reported
subject to the NSPS in 1979. No blast (cupola) furnaces have become
subject to the NSPS. No furnaces of any type have become subject to the
NSPS through modification or reconstruction.
Growth in the number of affected reverberatory and electric furnaces
is expected to continue. These new furnaces will absorb capacity lost
when plants close; provide production flexibility to make plants more
competitive; replace outdated, inefficient equipment; and provide production
facilities near market areas. No new blast (cupola) furnaces are expected.
The notably high growth projections in the number of electric induction
furnaces reflects the development of a new process in which brass is
continuously cast from an electric furnace in the form of a strip.
1.3 BEST DEMONSTRATED CONTROL TECHNOLOGY (BDT)
The original standard was based on the use of fabric filter control
technology to control emissions from reverberatory furnaces captured
during charging and melting. No significant changes have occurred in
control technology for the affected sources. Wet scrubbers typically
are unable to provide the level of control required under the NSPS and
have problems with water pollution and solid waste generation. Electro-
static precipitators (ESP's) have difficulty in collecting metal oxides
because of the relatively high resistivity of such particles. Therefore,
fabric filters continue to be considered BDT.
Some emissions generated during charging and tapping of reverberatory
furnaces escape capture and control. No mass emission data are available
for these emissions. However, visible emissions observations made
during this review indicate that these emissions are not significant.
Therefore, no BDT has been identified for control of these emissions.
Compliance test results, State and local control agency inspection
reports, and unofficial observations made during plant visits in this
review show all operating NSPS facilities are in compliance with the
NSPS.
1-2
-------
1.4 COMPLIANCE TEST DATA
The furnaces subject to the NSPS at four of the five plants are the
rotary reverberatory type; the fifth plant has an electric induction
furnace. One of the rotary furnaces subject to the NSPS has not been
placed in operation and has not been tested for compliance. The other
four rotary furnaces have been tested and are currently in compliance
with the 50 mg/dscm (0.022 gr/dscf) particulate emission standard and
the 20 percent opacity limit set in the NSPS. The electric furnace has
been tested and is currently in compliance with the 10 percent opacity
limit set for electric furnaces and the particulate emission rate set
for reverberatory furnaces in the NSPS.
One electric furnace not currently subject to the NSPS was tested
and found to have a particulate emission rate below the standard set for
reverberatory furnaces.
1.5 ECONOMIC CONSIDERATIONS AFFECTING THE NSPS
To estimate the economic consequences of the NSPS, model plant
descriptions were developed based on representative NSPS plants to serve
as a basis for estimating costs. The capital and annualized costs for
the control system for each model plant were estimated using guidelines
in the GARD Manual and information supplied by industry. Costs were
updated to December 1982 dollars using the Chemical Engineering plant
cost index.
The average cost effectiveness of particulate matter control for
reverberatory furnaces is $135 per ton over uncontrolled emission levels,
and the average cost effectiveness of particulate matter control for
electric furnaces is $1,500 per ton over uncontrolled emission levels.
An analysis of the economic impact of the NSPS on the brass and bronze
industry indicates that the rate of decline in the total industry had
not been accelerated by the NSPS and that the control cost associated
with the NSPS has resulted in a maximum product price increase of only
0.4 percent.
1-3
-------
-------
2. INDUSTRY DESCRIPTION
2.1 INTRODUCTION
On June 11, 1973, the EPA proposed new source performance standards
for the secondary brass and bronze industry. These standards established
particulate matter emission limits and required testing and reporting of
particulate matter and visible emissions for affected facilities that
were built, reconstructed, or modified on or after June 11, 1973. The
facilities affected by these regulations are reverberatory, electric,
and blast (cupola) furnaces.
At the time of NSPS development, there were approximately 60 secondary
brass and bronze ingot production plants operating throughout the United
States with the majority located in the northeast and north central
industrial belts.1 The yearly production of ingot from these plants was
approximately 272,000 Mg (300,000 tons).1 The secondary brass and
bronze industry was selected for NSPS development because individual
facilities can be significant sources of particulate matter emissions.
Uncontrolled reverberatory furnaces can emit as much as 32 kg of particulate
matter per Mg (70 Ib/ton) of metal produced.2 The mass rate of particulate
matter emissions from blast (cupola) furnaces is approximately equal to
that from reverberatory furnaces; the mass rate of particulate matter
from electric furnaces is typically far lower than that from reverberatory
or blast.2 An uncontrolled 45-Mg (50-ton) capacity, rotary reverberatory
furnace is capable of emitting 1,300 Mg/yr (1,440 tons/yr) of particulate
matter.3 The NSPS limits these emissions to approximately 11 Mg/yr
(12 tons/yr).3
The Clean Air Act Amendments of 1977 require that the EPA Administrator
review NSPS at least every 4 years to assess the need for possible
revision of standards [Section lll(b)(l)(B)].4 This report presents the
2-1
-------
findings of the second review of the NSPS for the secondary brass arief
bronze industry. The review was conducted by examination of current
secondary brass and bronze literature, discussions with regional EPA
offices and State and local air pollution control agencies, discussions
with emission control equipment vendors, visits to new and modified
secondary brass and bronze facilities, and discussions with brass and
bronze ingot trade associations.
2.2 BACKGROUND INFORMATION
Secondary brass and bronze plants generally produce brass and
bronze ingots weighing 13.6 kg (30 lb).5-9 However, there is a new
process, associated with electric induction furnaces, for continuously
casting the product in the form of rod rather than ingot. This technology
makes possible the continuous rolling of strip significantly faster than
by other processes. Classically, when copper is alloyed with zinc, the
product is termed brass, and when copper is alloyed with tin, the product
is termed bronze. Other copper alloys are identified by the alloying
metals such as aluminum bronze and silicon bronze. Table 2-1 lists the
12 categories of brass and bronze that have been designated by the Brass
and Bronze Ingot Institute. The table also shows subcategories of the
alloys along with the chemical specifications and characteristics of
each.
Because of their high strength, workability, corrosion resistence,
and other desirable physical characteristics, the copper-base alloys are
used in a wide variety of products found in the marketplace. Table 2-2
lists the principal categories of end uses for brass and bronze.
2.3 BRASS AND BRONZE PRODUCTION
2.3.1 Industry Characterization
Secondary brass and bronze companies are usually small, individually
owned firms consisting of one plant. A few are subsidiary operations of
large mining companies or of conglomerates.10
Currently, 37 secondary brass and bronze plants are in operation;
these plants are listed in Table 2-3. Of these plants, five have facilities
that are subject to the NSPS. Table 2-4 lists these five plants and
gives a brief description of the affected facilities. Two of the five
2-2
-------
OJ
ft
rH
O
HH
f~T
t— i
rv
UJ
o
Si
^£
X
o
1—
o
o
o
sc.
a.
o
z
"*
**
z
o
r-H
<
HH
o
LU
t/)
_J
«s£
O
HH
UJ
O
-
w_
o
3j!
UJ
M
o
cc
CQ
O
z
CO
CO
""•*•
o;
CQ
r-i
i
r»
41 41 01
N N N
e c c
o o o
oi 41 e e c
N N M- ••• •«-
C C *J *J -U
£ £ -o .g „
•o -a TJ
e c 10 a n
«r— •*• 41 41 01
< ca < ca u
rH |H CM CM CM
•a
41
C
U
>
•5
IO
01
• •
41
5
41
a
£
O O
ff> |H
a a o p o
p r> en tn <*•
|H fH CM
O P O P P
p f*» in f^ tn
fH
P P P P P
§m in co rH
03
1- *J O! .
Ul C C ^«
C 10 •»- tn
01 *> e E
CL Ul f 41
X •»- jC *J
Stn u in
,
IH u S tn
P P P p
in r^ en in
|H
p p p m
in to r> to
p p P m
m ^ PO CM
p p p p
in en IH to
co co co r*-»
tn in
tn in
s- s-
ul tn
ul to ^ 13
a a 41 oi
i. i. i. i.
.a .a i i
•o -o s s
s. i. tn ui
13 -O 13 T3
JJ J J J
< CO < 03
^ ^ in in
in
co in
Ol Ol
• - wi
C i—
o o
i. a.
in -a
c
>> ^
pf) rt CM CM
.P
fH
P
rH
p in p p
in in to to
01 01 01
1*4 N N
e c c
o o o
j> -a ^
41 01 01
tn in in
41 41 Ol
c c c
Ol Ol O) Ol
N C C C
0 E E S
oi 01 01 ai
in e c c
M 4, 4, 4,
CO *J 4J *J
Ol tn in ui
C 1 1 1
s = xx
< < m u
01
O)
C CO
10 »-
Si O •
+J *J 41
0) I.
C *J 3 •
41 C *J
S- 10 10
in ui 4>
41 in E
f 1_ *J
in
C in f
oi tn 01
*J 41 -f-
c .c
f "a
01 S. 13
•r- 10 C
z i to
in p
p PI
p P
CM ^
P P P P
en p fH IH
fH fH iH
p p p p
en IH <«• f
p p p p
co en in >H
CO CO CO CO
01 01 01 01
c c c c
o o o o
s!i§
1111
««
< ca cj p
en en en en •
tn *J
41 C
•f- CO
•taJ -P
£. Ul
41 •<—
a. ui
O 41
s- t-
O. 1
c
f O
10 i-
u in
f o
C t-
u u
41
E "O
C
4-> 10
C
01 f
F- tn
u u
X (0
LU -U
P P P P
CM to P tn
rH rH CM CM
P P P P
p to co ot
CM fH
p p p m
en in «± f-i
p p p p
CM m *r ui
P P P tn
f>. p rp to
in to to to
41 01
ui in M rM
tn tn c c
CO 10 O O
41 41 41 41
U U U U
C C C C
4> 41 « 41
TJ •a "o "a
P3 (0 IO
-------
TABLE 2-2. END USES OF BRASS AND BRONZE5-10,13
Housing industry
Plumbing and heating equipment
Valves and pipe fittings
Electrical housewares
Lighting and wiring equipment
Ornamentation
Refrigeration machinery
Transportation industry
Engines and turbines
Ai rcraft
Ships and boats
Consumer goods
Electric motors and generators
Musical instruments
Photographic equipment
Office and computing equipment
Military
Ordnance
Signal equipment
Other
Construction and mining equipment
Industrial machinery
Medical equipment
Grave markers
2-4
-------
TABLE 2-3. PRODUCERS OF BRASS AND BRONZE, FEBRUARY 198310,14,15
1. American Brass Incorporated, P.O. Box 185, Headland, Alabama 36345
2. ASARCO Incorporated, San Francisco, California
3. The G.A. Avril Company, Brass & Bronze Ingot Division, Box 66
Winton Place Station, 4445 Kings Run Drive, Cincinnati, Ohio 45232
4. Bay State Refining Company, Incorporated, P.O. Box 269, Chicopee,
Massachusetts 01021
5. Belmont Smelting & Refining Works, Incorporated, 330 Belmont Avenue,
Brooklyn, New York 11207
6. Bohn Aluminum and Brass, Adrian, Michigan
7. Bridgeport Brass, Indianapolis, Indiana
8. Brush Wellman Incorporated, 17876 St. Clair Avenue, Cleveland, Ohio
44110—El more, Ohio Plant
9. W.J. Bullock, Incorporated, Box 539, Fairfield, Alabama 35064
10. Harry Butter & Company, Incorporated, 151 Mt. Vernon Street, Dorchester,
Massachusetts 02125
11. Cabot Berylco Industries, Incorporated, Alloy Division, P.O. Box 1462,
Reading, Pennsylvania 19603
12. Cerro Metals, Newark, California
13. Cerro Metals, Bellefonte, Pennsylvania 16823
14. Chase Brass and Copper, Montpelier, Ohio
15. Chase Brass and Copper, Solon, Ohio
16. Chicago Extruding Metals, Chicago, Illinois
17. Colonial Metals Company, P.O. Box 311, Second & Linden Streets,
Columbia, Pennslyvania 17512
18. Federal Metal Company, 7250 Division Street, Bedford, Ohio 44146
19. N. Kamenske & Company, Incorporated, Box 724, 5 Otterson Court, Nashua,
New Hampshire 03061
(continued)
2-5
-------
TABLE 2-3. (continued")
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
Kearny Smelting & Refining Corporation, 936 Harrison Ave., Kearny,
New Jersey 07029
H. Kramer & Company, P.O. Box 7, No. 1 Chapman Way, El Segundo,
California 90246
H. Kramer &.Company, 1339-1345 W. 21st Street, Chicago, Illinois
60608
R. Lavin & Sons, Incorporated, 3426 S. Kedzie Avenue, Chicago,
Illinois 60623
Li barman S. Gittlen Metal Company, Grand Rapids, Michigan
Milward Alloy Incorporated, Lockport, New York
Mishawaka Brass Manufacturing Incorporated, 1928 Mick Court, Mishawaka,
Indiana 46544
National Metals, Incorporated, Box 102, Leeds, Alabama 35094
New England Smelting Works, Incorporated, 502 Union Street, West
Springfield, Massachusetts 01089
North American Smelting Company, Marine Terminal, Wilmington, Delaware
19899
North Chicago Refining & Smelting Incorporated, 2028 S. Sheridan Road,
North Chicago, Illinois 60064
Phelps Dodge Industries, Incorporated, Lee Bros., P.O. Box 1229,
Anniston, Alabama 36201
River Smelting & Refining Company, P.O. Box 5755, Cleveland, Ohio
44101
Roessing Bronze Company, P.O. Box 60, Mars, Pennslyvania 16046
S-G Metals Industries, Incorporated, 2nd & Riverview, Kansas City,
Kansas 66110
I. Schumann & Company, 22500 Alexander Road, Bedford, Ohio" 44146
Sipi Metals Corp., 1720 N. Elston Avenue, Chicago, Illinois 60622
Specialloy Incorporated, 4025 S. Keeler Avenue, Chicago, Illinois
60632
2-6
-------
TABLE 2-4. SECONDARY BRASS AND BRONZE FACILITIES SUBJECT
TO THE NEW SOURCE PERFORMANCE STANDARD5-9
Plant/location
Furnace type/size
Compliance
status
Comments
American Brass, Inc.
Headland, Alabama
2 rotary reverberatory/ In cpmplv
40,000 kg (88,000 Ib) anceD
Plant con-
structed in
1978
National Metals, Inc.
Leeds, Alabama'
1 rotary reverberatory/ In complr
1,800 kg (4,000 Ib) ance
Furnace
installed
in 1977
Federal Metals, Inc.
Bedford, Ohio
1 rotary reverberatory/ Not in
18,000 kg (40,000 Ib) operation
Furnace
installed
in 1981
I. Schumann and Co.
Bedford, Ohio
1 rotary reverberatory/ In compli-
45,400 kg (100,000 Ib) ance
Furnace
installed
in 1982
Chase Brass and
Copper
Solon, Ohio
1 electric induction/ In compli-
10,000 kg (22,000 Ib) ance
Plant con-
structed in
1980
Compliance with particulate matter and visible emission standards are
determined by EPA Reference Methods 5 and 9, respectively (40 CFR 60,
.Appendix A).
Visible emissions not determined during compliance testing.
2-7
-------
plants are new plants (built since the NSPS was proposed), and three are
existing plants that have installed new furnaces. Four of the plants
have reverberatory (rotary) furnaces, and the fifth uses an electric
induction furnace. All of the facilities are equipped with baghouses
for emission control, and all operational facilities are currently
considered to be complying with the NSPS.5-9
Even though there has been an increase in the past 4 years in the
number of affected facilities subject to the NSPS, the industrywide
production of ingot is declining.16 Figure 2-1 shows the downward trend
in the production of brass and bronze ingot as recorded by the Bureau of
Mines in 1983.16 Contacts with regional EPA offices and State and local
air pollution control agencies revealed that some plants are closing and
most are on reduced schedules.17 The Brass and Bronze Ingot Institute
attributes this decline to product substitutions and recently depressed
economic conditions and does not expect growth in the industry in the
foreseeable future.18 However, additional affected facilities are
expected to be installed by viable firms, despite this downtrend, to
absorb capacity lost when other firms shut down; to provide production
flexibility within a plant; to replace outdated, inefficient equipment;
and to provide production facilities near market areas.19,20
2.3.2 Process Description
The brass and bronze manufacturing industry basically consists of
three operations: raw materials collection and preparation, metal melting
and ingot production, and metal product fabrication. The NSPS for
secondary brass and bronze facilities is specific to furnaces used in
raw material preparation and ingot production; therefore, fabrication
will not be discussed in this review.
The following sections will discuss raw materials, material preparation,
and melting as they relate to particulate emissions in the brass and
bronze ingot production process.
2.3.2.1 Raw Materials. The raw materials used in the secondary
brass and bronze ingot industry consist mainly of brass and bronze
scrap. Both industrial and domestic scrap are used. Industrial scrap
includes pieces, chips, and shavings of alloy materials, such as those
which result from product fabrication. This scrap is free of impurities
2-8
-------
OJ
co
en
CO
CJt
a
CO
CO
o:
«=c
LU
10
t*«
cr>
in
— cr>
oo
i—i
i
s=
j
CVJ C\J
o in
tn vo
(SN01 1HOHS QNVSnOHl) SNOi
QNVSflOHi
2-9
-------
and requires little preparation before charging into melting furnaces.
Domestic scrap includes items that are being recycled, such as radiators,
cartridge cases, and railroad boxes. This scrap usually contains significant
amounts of undesirable materials, such as oil, grease, paint, insulation,
and chemicals. For these reasons, domestic scrap may require cleaning
before charging to furnaces.
2.3.2.2 Materials Preparation. The purpose of material preparation
is to produce a charge for the furnace that will yield the desired alloy
in the most effective manner. These processes may be either mechanical,
hydrometallurgical, or pyrometallurgical. The first two processes are
not considered in this description since they are not sources of particulate
emissions.
Pretreatment by pyrometallurgical "methods" may include any of the
following methods: sweating, burning, drying, blasting furnaces, and
cupola. Use of any of these methods will produce particulate emissions;
however, only blast furnaces and cupolas are subject to NSPS. A brief
description of each method is given below.
Sweating furnaces may be used to remove low-melting point metals,
such as lead, solder, and babitt metal. This is done by heating the
scrap in a furnace, which causes the low-melting components to be separated
from the desirable metals. Carefully controlled burning is usually
performed for removal of insulation from wire or cable. Toxic substances
such as polyvinyl chloride can be released during this process. Drying
furnaces are used to vaporize substances such as cutting fluids from
machine shop scrap. The temperature of this operation is critical since
excessively high temperatures cause unwanted oxidation on the surface of
the metal chips.21
The terms "blast furnace" and "cupola" are often used interchangeably.
However, the cupola is used to melt down metals or reduce metal oxides,
while the blast furnace is used for reduction of metal oxides or smelting
virgin ores. Both furnaces are also used to recover metal from skimmings
and slags. Because of the difference in the composition of the interacting
atmosphere, these reducing operations cannot be done in reverberatory or
refining furnaces.22
2-10
-------
In both blast and cupola furnaces, coke is used as both fuel and
reducing agent. The resulting product (black copper or cupola melt) is
impure and must be refined to produce brass and bronze ingot. A schematic
of a blast furnace is shown in Figure 2-2. The blast furnace and cupola
operate on a continuous feed basis with charge material, coke, and
fluxes introduced at the top. Finished metal is drawn from the bottom,
generally on an intermittent basis. Slag is usually tapped on a continous
basis through a separate spout at a level immediately above the metal
pouring height.23
2.3.2.3 Melting. Brass and bronze are usually heated in large
natural- gas- or oil-fired reverberatory furnaces or electric arc or
induction furnaces. Indirect-fired furnaces are sometimes used for
specific foundry applications but are not covered under the NSPS because
of their small size and emission potential.
Any furnace in which the burne'r flames and/or hot gases come in
direct contact with the charged material is considered to be a reverberatory
furnace. Figure 2-3 is a schematic of a typical stationary reverberatory
furnace. Reverberatory furnaces may also be the rotating, rocking, or
tilting type. All reverberatory furnaces operate in the batch mode.
The charge material and fluxes may be introduced before firing or may be
added periodically throughout the heat. The fuel burned is either oil
or natural gas.23
Stationary furnaces are usually larger, 100- to 200-Mg (110- to
220-ton) capacity, than the other types of reverberatory furnaces, which
have capacities ranging from 18.9 to 45 Mg (1.0 to 50 tons).5-8
In all cases, when the charge attains the proper heat and impurities
have been drawn off into the slag, the molten metal is tested for its
alloy composition. Adjustments are made as needed, and the metal is
brought to the ideal pouring temperature for the specific alloy by
regulation of the fuel burners. At this point, metal pouring begins.24
Electric furnaces are mainly used for special purpose alloys.
Major advantages of the electric furnace over fuel-fired furnaces are
better furnace atmosphere control and high-temperature operation.
Temperatures as high as 3300°C (6000°F) are possible for special processes.
Heating may be accomplished by an arc, by induction, or by resistance
2-11
-------
CHARGING DOOR
COKE CHARGES
METAL CHARGES
COKE BED
WIND BOX
SLAG
SPOUT
SUPPORTS
TUYERES
TO CONTROL DEVICE(S)
AND STACK(S)
STACK ZONE
PREHEAT ZONE
MELTING ZONE
•TAPPING
SPOUT
Figure 2-2. Schematic of a typical secondary
metal blast furnace or cupola.
2-12
-------
(O
S_
Ol
0)
s_
(0
in
as
M-
O
CJ
4->
(C
-------
(see Figure 2-4). In all cases, charging and pouring are generally done-
through the top of the furnace.25
Indirectrfired furnaces (crucible or pot furnaces) are usually
significantly smaller than reverberatory furnaces and are similar in
function to electric furnaces. Crucibles may be the tilting, pit, or
stationary type and include the small, low-temperature pot furnaces.
Charge materials are introduced through the top of the furnace along
with inert fluxes. Finished alloys are removed from the furnaces through
the top, either by tilting and pouring or by the use of ladles. Generally,
crucible furnaces are used to heat metals up to 1300°C (2400°F). Pot
furnaces are used only for temperatures up to about 760°C (1400°F).27
2-14
-------
-------
2.4 REFERENCES FOR*CHAPTER 2
1. U.S. Environmental Protection Agency. Air Pollution Engineering
Manual, 2nd Edition. Office of Air and Water Programs, Research
Triangle Park, N.C. AP-40 1973. pp. 269-283.
2. U.S. Environmental Protection Agency. Compilation of Emission
Factors, Part B. Office of Air and Waste Management, Research
Triangle Park, N.C. AP-42 1977. p. 7.9-2.
3. Memorandum from Keller, P., and D. Atkinson, MRI, to Iversen, R.,
EPArlSB. May 31, 1983. Tabular cost memo for secondary brass and
bronze review.
4. United States Congress. Clean Air Act, as amended August 1977.
42 U.S.C. 1857 et seq. Washington, D.C. U.S. Government Printing
Office. November 1977.
5. Letter and attachments from Horton, T., National Metals, Inc., to
Farmer, J. R., EPA:ESED. May 9, 1983. Response to Section 114
information request.
6. Letter and attachments from Singh, A., and Sabatka, M., Federal
Metals, Inc., to Farmer, J. R. , EPArESED. May 9, 1983. Response
to Section 114 information request.
7. Letter and attachments from Oberlin, J. P., I. Shumann and Company,
to Farmer, J. R., EPA:ESED. May 5, 1983. Response to Section 114
information request.
8. Letter and attachments from Sherman, G. , American Brass, Inc., to
Farmer, J. R., EPA:ESED. May 5, 1983. Response to Section 114
information request.
9. Letter and attachments from Brown, L., Chase Brass and Copper Co.,
to Farmer, J. R., EPA:ESED. April 12, 1983. Response to Section 114
information request.
10. Keitz, E. L. and K. J. Brooks. A Review of Standards of Performance
for New Stationary Sources-Secondary Brass and Bronze Plants.
Prepared for U.S. Environmental Protection Agency. Research Triangle
Park, N.C. Publication No. EPA-450/3-79-011. June 1979.
11. Keitz, E. L. and K. J. Brooks. A Review of Standards of Performance
for New Stationary Sources—Secondary Brass and Bronze Plants.
Prepared for U.S. Environmental Protection Agency. Research Triangle
Park, N.C. Publication No. EPA-450/3-79-011. June 1979. p. 4-7.
12. Telecon. Keller, P., MRI, with Maudlin, R., Brass and Bronze Ingot
Institute. April 21, 1983. Brass and bronze alloy numbers and
•classifications.
2-16
-------
13. JACA Corporation. Retrospective Analysis of the Economic Impact of
NSPS in the Brass and Bronze Industry. Prepared for U.S. Environmental
Protection Agency. Research Triangle Park, N.C. Project
No. EPA 68-02-3812. June 1983.
14. Letter and attachments from Butterman, W., U.S. Bureau of Mines, to
Hester, C., MRI. January 31, 1983. Recent information on copper,
brass,, and bronze.
15. Memorandum from Keller, P., MRI, to project file 7704-L. May 31, 1983.
Plants in operation.
16. Letter and attachment from Bowman, P. B., Brass and Bronze Ingot
Institute, to Atkinson, R. D., MRI. February 11, 1983. p. 2. U.S.
Bureau of Mines Brass and Bronze Ingot Industry shipment report.
17. Memorandum from Keller P., MRI, to project file 7704-L. May 31, 1983.
Plant closings and reduced schedules.
18. Telecon. Maudlin, R., Brass and Bronze Ingot Institute, with
Hester, C., MRI. January 26, 1983. Industry status.
19. Memo and attachments from Keller, P., MRI, to Iversen, R., EPA:ISB.
May 23, 1983. Report of visit to I. Schumann and Company, Bedford,
Ohio.
20. Memo and attachments from Keller, P., MRI, to Iversen, R., EPA:ISB.
July 6, 1983. Report of visit to Chase Brass and Copper, Solon,
Ohio.
21. Reference 10, p. 4-21.
22. Reference 10, p. 4-22.
23. Reference 10, p. 4-24.
24. Reference 10, p. 4-26.
25. Reference 1, p. 272.
2-17
-------
-------
3. SUMMARY OF CURRENT STANDARDS
3.1 NEW SOURCE PERFORMANCE STANDARDS
3.1.1 Summary of New Source Performance Standards •
The affected facilities under the NSPS for secondary brass and
bronze ingot production processes are reverberatory and electric furnaces
of 1,000 kg (2,205 Ib) or greater production capacity and blast (cupola)
furnaces of 250 kg/h (500 Ib/h) capacity that were built, modified, or
reconstructed on or after June 11, 1973.1 The term "modified facility"
applies to facilities to which physical or operational changes have
caused an increase in the emission rate of any pollutant. The term
"reconstructed facility" applies when the replacement cost of components
exceeds 50 percent of the cost of building a comparable new facility
(40 CFR 60).
Owners and operators of affected facilites are required to control
particulate matter and limit opacity. The standards state that exhaust
gases discharged to the atmosphere from revereberatory furnaces must not
contain particulate matter in excess of 50 milligrams per dry standard
cubic meter (mg/dscm) (0.022 grains per dry standard cubic feet [gr/dscf]),
and must not exhibit 20 percent opacity or greater. The standards also
state that exhaust gases from electric and blast (cupola) furnaces must
not exhibit 10 percent or greater opacity. No mass emission standard
for electric and blast (cupola) furnaces is included in the NSPS.
3.1.2 Testing and Monitoring Requirements
The owner or operator of an affected facility is required to conduct
a performance test and furnish the Administrator with a written report
of the test results.
3-1
-------
Test methods to be used to determine compliance with the NSPS are':
1. Method 5 for the concentration of particulate matter and the
associated moisture content;
2. Method 1 for sample and velocity traverses;
3. Method 2 for velocity and volumetric flow rate;
4. Method 3 for gas analysis; and
5. Method 9 for visible emission observations.
For Method 5, the sampling time for each run must be at least
120 minutes, and the sampling rate must be at least 0.9 dscm/h (0.53 dscfm).
The Administrator may approve shorter sampling times when they are
necessitated by process conditions.
Secondary brass and bronze plants are not required to use continuous
monitoring systems.
3.2 STATE REGULATIONS
Secondary brass and bronze ingot production plants are currently
operating in 13 States. Table 3-1 summarizes particulate emission
regulations applicable in these States to new secondary brass and bronze
ingot production processes in the absence of NSPS. The most stringently
expressed State standard is 45 mg/dscm (0.02 gr/dscf) (New Jersey),
which is slightly lower than the 50 mg/dscm (0.022 gr/dscf) limit for
reverberatory furnaces established by the NSPS. Ohio, Michigan,
Pennsylvania, and certain districts in California require the use of
best available control technology (BACT) on new sources. This requirement
has, in some cases, resulted in a State enforcing more stringent emission
and opacity limits than those required by the NSPS.2
Using the process weight rate equation shown in Table 3-1, a furnace
with a process weight rate of 0.9 Mg/h (1 ton/h) would be allowed to
emit 1.9 kg/h (4.1 Ib/h) per hour of particulate matter. By comparison,
the NSPS limits these emissions to between 0.5 and 0.7 kg (1.0 and
1.5 Ib) per hour (based on typical air stream flow rates in the secondary
brass and bronze industry).3
All 13 States limit visible emissions to less than 20 percent
opacity for new facilities and to 40 percent opacity or less for existing
facilities. Most States have been delegated enforcement authority for
3-2
-------
TABLE 3-1. SUMMARY OF STATE REGULATIONS FOR SECONDARY BRASS
AND BRONZE PRODUCTION PROCESSES5
State
Alabama
California3
Bay Area
SCAQMDC
Delaware
11 1 inois
Indiana
Kansas
Massachusetts
Michigan
New Hampshire
New Jersey
New York
Ohio3
Pennsylvania3
No. plants
4
2
1
1
6
2
1
3
2
1
1
2
7
4
Regulation
E = 4.1 x po.6?b
E = 4.1 x P°-67
Table 405(a)
Table (Reg. 5, Sec. 4.1, Type 2)
E = 4.1 x P°-67
E = 4.1 x P°-67
E = 4.1 x P°-67
0.06 gr/dscf
E = 4.1 x P°*67
E = 4.1 x po.67
0.02 gr/dscf
E = 4.1 x P°-67
E = 4.1 x P°-67
0.02 to 0.04 gr/dscf (dependent
on air flow)
bRequire best available control technology (BACT) for new source.
E = allowable emission rate in Ib/h.
CP = process weight rate in tons/h.
.Reference 7.
States that have not accepted NSPS delegation.
3-3
-------
the NSPS for the secondary brass and bronze' ingot production industry
(see Table 3-1). Those States that have not accepted delegation of the
NSPS, Delaware and Kansas, state that they do not have the money or
personnel at this time to enforce the NSPS regulations.4,5
3.3 REFERENCES FOR CHAPTER 3
1. U.S. Environmental Protection Agency. Code of Federal Regulations.
Title 40, Chapter I, Subchapter 3, part 60. Washington, D.C.
Office of the Federal Register. July 1, 1981.
2. Memo from Keller, P., MRI, to Iversen, R., EPA:ISB. April 18, 1983.
Minutes of Meeting with Cleveland Division of Air Pollution Control.
3. Background Information for Proposed New Source Performance Standards,
Volume 1: Main Text, U.S. Environmental Protection Agency Office of
Air and Water Programs Research Triangle Park, N.C. June 1973.
61 p.
4. Telecon. Keller, P.,. MRI, with Cotter, J. , Kansas Department of
Health and Environment. April 21, 1983. Enforcement authority.
5. Telecon. Keller, P., MRI, with Peronti, J., Delaware Air Resources.
April 21, 1983. Enforcement authority.
6. State Air Laws. Volumes 1, 2, and 3, Environment Reporter.
7. Rules and Regulations. South Coast Air Quality Management District.
El Monte, California. May 1976. pp. IV-4 and IV-5.
3-4
-------
4. STATUS OF CONTROL TECHNOLOGY
4.1 EMISSIONS POTENTIAL
4.1.1 Emissions From Materials Preparation
Pyrometallurgical processes (sweating, wire burning, drying, and using
blast or cupola furnaces) all create air pollutants to some degree.
Sweating is carried out at medium temperatures to remove low melting point
metals such as lead, solder, and babbit metal from radiators and other
scrap. Metal fume losses are very low; however, fume and combustion
products of antifreeze residues, soldering salts, and hose connections
can be released.1 Discussions with State and local air pollution control
agencies revealed that most companies are eliminating the need for sweating
furnaces by being more selective in scrap selection or by introducing dirty
scrap directly into the melting furnaces.2,3
The potential fugitive particulate matter emission factor for uncon-
trolled wire burning is 6.88 kg of particulate matter per megagram of scrap
processed (13.75 lb/ton).4 In addition, the emissions from this incinera-
tion process may contain significant amounts of hazardous and/or toxic
substances such as reactive hydrocarbons, fluorides, and the combustion
products of common polymers such as polyvinyl chloride.2 Because wire
burning is potentially a large source of particulate matter emissions as
well as the other pollutants mentioned above, many secondary brass and
bronze facilities no longer accept this type of scrap.2
A heated rotary dryer is often used to vaporize excess cutting fluids
from machine shop chips or borings. This drying operation creates hydro-
carbon emissions. The potential fugitive particulate matter emission factor
for rotary dryers is the same as that for wire burning; however, the nature
4-1
-------
of the combustion process determines the degree to which tile's e- emissions
are oxidized.4
Preparation of materials in blast furnaces and cupolas results in
emissions that are similar to emissions from the smelting/melting furnaces
(discussed in the next section). However, since blast furnaces and
cupolas are generally used to concentrate low-grade scrap, slag, and
skimming, emissions'from these sources have a higher percentage of
nonmetallic particles than do emissions from smelting/melting furnaces.
4.1.2 Emissions From Smelting
Air pollutants emitted from secondary brass and bronze smelting
furnaces consist of products of combustion, dusts, and metallic fumes.
The particulate matter comprising the dust and fume load varies according
to the fuel, alloy composition, type of furnace, melting temperature,
and other operating factors. In addition to fly ash, carbon, and
mechanically produced dust, furnace emissions generally contain fumes
resulting from oxidation and condensation of the more volatile elements,
including zinc, lead, and others. An analysis of the dust collected by
a secondary brass and bronze plant baghouse indicated the presence of
the following constituents:5
Component
Zinc
Lead
Tin
Copper
Chlorine
Sulfur
Particulate composition,
percent by weight
45.0-77.0
1.0-12.0
0.3-2.0
0.05-1.0
0.5-1.5
0.1-0.7
Zinc and other fumes are 0.03 to 0.5 urn in diameter.5
Direct-fired furnaces of the reverberatory and rotary type produce
larger quantities of metallic fumes, such as zinc and lead oxide, than
do the indirect-fired furnaces. This is due to the introduction of the
hot burner flames and gases directly on the charge, resulting in vaporiza-
tion of larger quantities of the lower boiling point metals. Other
factors causing relatively large concentrations of zinc fumes in furnace
gases are discussed in the following sections.
4-2
-------
The fuel used in the various furnaces can have important effects on
the types of emissions from brass and bronze facilities. The use of oil
requires careful control techniques to minimize pollutants such as
smoke, soot, and unburned fuel particles. Gas is often more trouble-free,
both in minimizing emissions and supplying the proper combustion conditions.
4.1.2.1 Charging. Charging emissions are dependent on the condition
of the scrap, location of the charging doors, percentage of volatile
alloy constituents, and upon whether the entire charge is made at the
beginning of the heat or at intervals during the melt. Even if scrap
has been pretreated to remove contaminants, particulate and unburned
hydrocarbon emissions can still occur during charging. Overhead charging
doors, used in stationary reverberatory furnaces (which are being replaced
by rotary reverberatory furnaces) permit losses of hot gases, fly ash,
and fume into the plant when charges are loaded at intervals during the
heat. End and side charging doors in rotary-type furnaces permit
significantly less escape of furnace gases during charging.6 All reverbera-
tory furnaces subject to the NSPS are rotary-type furnaces, which charge
via end doors.
4.1.2.2 Melting. The furnace is closed for the meltdown process.
Increased zinc oxide emissions can result from improper combustion,
overheating of the charge, and heating the charge too fast.7 The use of
nonuniform scrap can also increase emissions.
4.1.2.3 Refining. Refining, a chemical process of purification,
is that cycle of smelting in which impurities and other constituents of
the charge, present in excess of specifications, are reduced or removed.
Refining methods vary depending on the type of furnace, composition of
the scrap, and the desired alloy, but the basic approach is the same for
all. The chemicals used in refining, commonly termed fluxes, may be
gaseous, liquid, or solid. Compressed air is the most extensively used.
flux. Blowing air into the molten metal bath causes a selective oxidation
of metals in accordance with their position in the electromotive series.
Air blowing also oxidizes the remaining impurities. The metal oxides
are entrapped in the slag covering or entrained in the furnace exhaust
gases. Nitrogen is sometimes used to remove gases and oxides or to
mechanically and buoyantly lift foreign matter from the metal bath.
4-3
-------
Zinc is partially oxidized during this'process, but this is an unavoidable
loss. Solid fluxes as a whole do not contribute to air pollution.
Rather they have a generally beneficial effect on the quality of stack
emissions by preventing excessive volatilization losses.8
4.1.2.4 Alloying. Alloy modifications are made during the heating
process by the addition of virgin metals or scrap. This can cause an
increase in fume emissions. The formation of fumes increases as the
percentage of volatile constituents increases. Due to its very low
boiling point, zinc is the most serious problem, with the rate of zinc
loss being approximately proportional to the zinc percentage in the
alloy.7
4.1.2.5 Pouring. Physical methods of pouring the molten alloy
into molds vary; however, in all cases, metal oxide fumes are emitted
when the hot molten metal is poured through the air. For a given percentage
of zinc, an increase in temperature of 56°C (100°F) increases the rate
of loss of zinc about three times.7 Other dust may be produced, depending
upon the type of linings or coverings associated with the mold as it is
filled with hot molten metal.9
4.2 CONTROL TECHNOLOGY
4.2.1 Control of Particulate Matter Emissions During Charging, Melting, and
Refining
Particulate matter emissions are captured with either side draft
hooding or charging enclosures. There are three basic types of primary
control equipment used to control this captured particulate matter from
the exhaust gases of ingot production processes: wet scrubbers, ESP's,
and baghouses. Of these, baghouses are BDT for reverberatory, electric,
and blast (cupola) furnaces.
Of the 37 secondary brass and bronze plants currently in operation,
3 use only wet scrubbers, 1 uses wet scrubbers and ESP's, 1 uses an ESP,
1 uses wet scrubbers and baghouses, 30 use only baghouses, and 1 minor
source is uncontrolled. All five plants having NSPS affected facilities
use only baghouses as the primary means of particulate control (see
Table 2-4). The infrequent use of wet scrubbers and ESP's is mainly due
to their inability to remove metal fumes, such as zinc oxide, as efficiently
4-4
-------
as baghouses can. Wet scrubbers typically are unable to provide the
level of control required under the NSPS and have the disadvantages of
relatively high power consumption, maintenance requirements, and water
and solid waste pollution. Electrostatic precipitators have difficulty
in collecting metal oxides because of the relatively high resistivity of
such particles.10
Typical fabric filters used in the secondary brass and bronze
industry have volumetric capacities ranging from 5 to 15 standard cubic
meters of air per second (10,000 to 25,000 standard cubic feet per
minute). The air-to-cloth ratio of baghouses used in the secondary
brass and bronze industry can range from 1:1.5 to 5:1. Fabric filters
typically have particulate removal efficiencies in excess of 99 percent
and have relatively low pressure drop and power requirements.10-15
Fabric filters are considered best demonstrated technology (BDT) for the
control of particulate emissions in the secondary brass and bronze
industry. Fabric filters on affected facilities are typically made of
®
Nomex and cleaned by the shaker method.
4.2.2 Control of Particulate Matter Emissions During Pouring
The NSPS does not apply during periods of pouring. Although specialized
hooding systems, made of such materials as canvas, are used to capture
these emissions, their effectiveness is limited. This is because personnel
need access to the pouring area, thus preventing the optimum location of
hoods. Observations made during plant visits indicate the magnitude of
these uncaptured emissions is not significant.
4.2.3 Control of Unregulated Pollutants
The NSPS does not include specific limits for each pollutant emitted
from secondary brass and bronze plants. Metal oxides such as lead oxide
are the major unregulated pollutants. Control of metal oxides is
efficiently accomplished with baghouse technology, which is currently
BDT for particulate matter emission control.
4.3 REFERENCES FOR CHAPTER 4
1. Keitz, E. L. and K. J. Brooks. A Review of Standards of Performance
for New Stationary Sources—Secondary Brass and Bronze Plants.
Prepared for U.S. Environmental Protection Agency. Research Triangle
Park, N.C. Publication No. EPA-450/3-79-011. June 1979. p. 4-21.
4-5
-------
2. Telecon. Keller, P., MRI, to Wood, B., Alabama Air Pollution Control"
Commission. February 24, 1983. Pretreatment of scrap used in
secondary brass and bronze facilities in Alabama.
3. Telecon. Keller, P., MRI, to Seaman, D., Cleveland Division of Air
Pollution Control. February 24, 1983. Pretreatment of scrap used
in secondary brass and bronze facilities in Ohio.
4. U.S. Environmental Protection Agency. Compilation of Air Pollutant
Emission Factors, Supplement No. 9, Third Edition (including
supplements 1-7) Office of Air and Waste Management, Research
Triangle Park, N.C. AP-42. July 1979. p. 7.9-7.
5. PEDCo Environmental, Incorporated. Technical Guidance for Control
of Industrial Process Fugitive Particulate Emissions. Prepared for
U.S. Environmental Protection Agency. Research Triangle Park, N.C.
Publication No. EPA-450/3-77-010. March 1977. p. 2-208.
6. Midwest Research Institute. Handbook of emissions, Effluents, and
Control Practices for Stationary Particulate Pollution Sources.
Prepared for Division of Process Control Engineering National Air
Pollution Control Administration, United States Department of
Health, Education and Welfare. Cincinnati, Ohio. Contract No. CPA
22-69-104. November 1970. pp. 402-404.
7. U.S. Environmental Protection Agency. Air Pollution Engineering
Manual, 2nd Edition. Office of Air and Water Programs, Research
Triangle Park, N.C. AP-40. 1973. p. 270.
8. Reference 1, p. 4-40.
9. Reference 6, p. 405.
10. Reference 7, p. 282.
11. Letter and attachments from Horton, T., National Metals, Inc., to
Farmer, J. R., EPArESED. May 9, 1983. Response to Section 114
information request.
12. Letter and attachments from Singh, A., and Sabatka, M., Federal
Metals, Inc., to Farmer, J. R., EPA:ESED. May 9, 1983. Response
to Section 114 information request.
13. Letter and attachments from Oberlin, J. P., I. Schumann and Company,
to Farmer, J. R., EPA:ESED. May 5, 1983. Response to Section 114
information request.
14. Letter and attachments from Sherman, G., American Brass, Inc., to
Farmer, J. R., EPA:ESED. May 5, 1983. Response to Section 114
information request.
4-6
-------
15. Letter and attachments from Brown, L., Chase Brass and Copper Co.,
to Farmer, J. R., EPA:ESED. April 12, 1983. Response to Section 114
information request.
4-7
-------
-------
5. EMISSION TEST RESULTS
5.1 ANALYSIS OF EMISSION TESTS
Since the NSPS was proposed on June 11, 1973, six facilities in
five plants have become subject to its provisions. Two of these plants
(American Brass, Inc., and Chase Brass & Copper in Solon, Ohio) were
constructed since the NSPS proposal. Three plants (National Metals,
Inc., Federal Metals, Inc., and I. Schumann & Company) have installed
new furnaces. Particulate emission rates and visible emission readings
from affected furnaces at these plants and from one. electric furnace not
affected (Chase Brass & Copper in Montpelier, Ohio) are given in Table 5-1
and are discussed below.
5.1.1 Reverberatory Furnaces
Furnaces subject to the NSPS at four of the five plants are the
rotary reverberatory type. As can be seen from Table 5-1, each of the
operating furnaces is in compliance with both the 50 mg/dscm (0.022 gr/dscf)
particulate matter emission standard and the 20 percent visible emis.sion
standard. Plant visit to I. Schumann & Company confirmed the low opacity
from their facility.
5.2.1 Electric, Blast, and Cupola Furnaces
Currently one electric furnace (at Chase Brass & Copper) and no
blast or cupola furnaces are subject to the NSPS. Table 5-1 shows the
electric furnace is in compliance with the 10 percent opacity limit. A
plant visit to Chase Brass & Copper (Solon, Ohio) verified the low
opacity of emissions from this facility. The particulate emission rate
from this affected facility is well below the 50 mg/dscm (0.022 gr/dscf)
emission limit applicable to reverberatory furnaces. The particulate
emission rate from an electric furnace (at Chase Brass & Copper, Montpelier,
5-1
-------
cu
u
C 01
CO 3
•r- +J
r— CO
Q.-P
E 01
O
O
W
1
CO
to
LU
(—1
1 ^}
1 — 1 Ol
_l i—O
1— 1 Or—
0 S- 0
,
—
a;
c CL
^* S— ^"}
LU 3 -P
U_
.
rH
LO
LU
.J
CQ
S- 5-
O O
•P -P
CO cO
S- S-
cu cu
JO JO
S- £-
>
CU CD
O£. C£.
,
U CO
C E
H-( CO
o
*» CO
01 i —
01
CSJ
0
o
«
o
s«^
ID
.
•st-
^*j
i.
O
•P
CO
S-
O)
^2
S-
Ol
>
CD
•
U
C
1 — 1
*> CO
01 E
i— CO
CO -Q
•P CO
CD r—
s <
r^ ~
CO 01
C 73
O CD
•r- CD
•P —1
CO
73
CD CD CD -:
•POO, 73
01 C C +J CU (J
O> CO CO U -P -i— CU
•P «r- -r- . cu o s- 01
i— i— •"-> C ^2 C
-p a. Q. ja oo co rti
CD E E 3Q- CU4-X:
>, O O 01 00 S- U
u u z cu cu
•p -p J= J= >,
o c c: oo 3-pc
Z I— I I— i Z. -P CO
-p •» .
Q.-P >>
CD > cu o"
Ol Ol Ol 01 i — Ol
3 3 3 3 CD 3 O
O O O O > O -P
-C .C JC -C •<- JC
Ol O) Ol Ol -P O)73
CO CO CO CO O CO CD
m cQ CQ CQ CU i"» -P
Q. U
01 0) 3
CD -C 73
S- -P C
73 >> 0
0) +J -+J U
C T- CD CO
•r- U C
-P E CO 73 73 CD
O O OS- O.CCDO)
Z CU O CO > J3
-P S-
CD -P ID CD 01
73 C Ol CO
CD 01 .a j=
U 73 0
S- 0 -P
CD -C CD 01
73 O. -P S- CD
CD /•"» X~N ^— ^ CD CU -P
-p •* 10 co o s: 3
Ol CM ID O CM CD
CU O O O CD 01 (J
-P O O O 73UEC
c c cu co
•p o o o co cu i— E
cu ^ ^-s ^ s- .a s-
>, /~s CD 0 0
ID CO f~- 4- 4- S- 4-
-P . . . u . CD a. s-
o ID CM o 01 >,CK: at
Z iH 73 -P >, O.
•V. -r- < +?
S- (J Q. T- S
O) CO LU CJ CD
a. co c
CM O >, Q.
>, >, CM .a o o
S- S_ 0 -P C
O O • C 73 "
•p -p o cu a> -P -
CO CO C C V^UCOIS-
S- S- UO UO S-T-CDCD
CD CD •!- •r- T- -i— E CD E -P >
^2 -Q S--P S--P UQ.S- > o)73 CUTS -v. r- 1 cu c rn
CD CD i — Ci — C O)|73fO
Q£ Qi UJ •<- LU •<- El E
C >j S- .
0 O -P 0 73
un •!—•!— 4- cu
1 .p O S- O)
1 U CO CD O)
>, 3 Q. 0. (O
S- S- S- 73 0 JD
U CD CU O C 01 CD
c a. 0.0 4->T-73T-s_
i— i • a. D-'I— to c .e
O O O-C S-OCO-PC.
"Oooo oo cu-r- cucu
01 T- .i- ^JS-CUOCUU
COO O T- S- CDUCO CO
•P c 01^: oicu >CDS--POIE
cu- c« 010 01 -r- cui — ccos-
S73 C073 CO COi — QiLUCCDJIIO
S-ES-S--S-0) 034-
i—O 30 CQC COD. T-O-S-S-
C04— JZ4— O -P •• O1CDCDCU
S-73 (J73 CUi — CUC OO 0101-PQ-
CUCU OOCU O1O O1O Q. -r— .Q r—
73CQ CQ COOO COS OO E3-P-C
CU • -C .C ZLU004-T-
U_ H- 1 O O CO ^ U
5-2
-------
Ohio) not subject to the NSPS is also presented. The participate emission
rate from this facility is also well below the emission limit applicable
to reverberatory furnaces.
5.2 OTHER ATMOSPHERIC EMISSIONS
None of the plants having affected facilities pretreat the scrap
before charging. All five plants use a charging material containing
less than 10 percent lead, two reporting only trace amounts of lead in
the charging material. Cadmium, mercury, arsenic, and chromium are
reported to be present in only trace amounts in charging material for
all affected facilities.9-13
5.3 WATER DISCHARGES AND SOLID WASTE GENERATION
No wastewater discharges are produced by the plants having affected
facilities. Solid waste products including zinc oxide (baghouse dust)
at all affected facilities and slag at one affected facility are collected
and sold.9-13
5.4 REFERENCES FOR CHAPTER 5
1. Telecon. Moore, B., EPArRegion IV, with Keller, P., MRI. February 10,
1983. Brass and bronze plants in Region IV.
2. Telecon. Wood, W., Alabama Air Pollution Control Commission, with
Keller, P., MRI. February 14, 1983. Furnace type, control equipment,
and emission rates for brass and bronze plants in Alabama.
3. Telecon. Wood, W., Alabama Air Pollution Control Commission, with
Keller, P., MRI. May 18, 1983. Opacity data for American Brass,
Inc.
4. Telecon. Mr. Hudo, Alabama Air Pollution Control Commission, with
Keller, P., MRI. February 14, 1983. Emission and control data for
National Metals, Inc., Leeds, Alabama.
5. Telecon. Wood, W., Alabama Air Pollution Control Commission, with
Keller, P., MRI. April 14, 1983. Opacity data for National Metals,
Inc., Leeds, Alabama.
6. Telecon. Seaman, D., Cleveland Office of Ohio EPA, with Keller, P.,
MRI. February 16, 1983. Emission and opacity data for brass and
bronze plants in Ohio.
7. Letter and attachments from Seaman, D., Cleveland Division of Air
Pollution Control, to Atkinson, D., MRI. April 13, 1983. Source
test results for I. Schumann & Co., and Chase Brass and Copper.
5-3
-------
8. Letter and attachments from Majewsky, D., Northwest Ohio EPA to
Keller, P., MRI. June 13, 1983. May 20, 1982, and January 14,
1975, stack test for Chase Brass and Copper Company in Montpelier,
Ohio.
9. Letter and attachments from Sherman, G., American Brass, Inc., to
Farmer, J. R., EPAtESED. May 5, 1983. Section 114 information
request.
10. Letter and attachments from Morton, T., National Metals, Inc., to
Farmer, J. R., EPA:ESED. May 9; 1983. Section 114 information
request.
11. Letter and attachments from Singh, A., and Sabatka, M., Federal
Metals, Inc., to Farmer, J. R., EPA:ESED. May 9, 1983.
Section 114 information request.
12. Letter and attachments from Oberlin, J. P., I. Schumann & Co., to
Farmer, J. R., EPA:ESED. May 5, 1983. Section 114 information
request.
13. Letter and attachments from Brown, L., Chase Brass and Copper Co.,
to Farmer, J. R. , EPA.-ESED. April 12, 1983. Section 114 information
request.
5-4
-------
6. COST ANALYSIS
«
The purpose of this chapter is to present updated capital and
annualized costs for control systems used to achieve the NSPS and to
discuss the cost effectiveness of any proposed changes to the NSPS. To
estimate the economic consequences of the NSPS, model plant descriptions
were developed to serve as a basis for estimating costs. The model
plant descriptions are summarized in Table 6-1 and are representative of
plants currently subject to the NSPS.1-5 No model plant description is
presented for blast (cupola) furnaces because none are currently subject
to NSPS or are expected to become subject in the future. The updated
costs, including capital costs and annualized costs, of control equipment
for typical affected facilities are also shown in Table 6-1. These
costs were updated to December 1982 dollars using the Chemical Engineering
plant cost index and company data.1-6
The capital cost of a control system includes all the cost items
necessary to design, purchase, and install the particular device or
system. The capital cost includes the purchased costs of the major
control device and auxiliaries such as fans and instrumentation; the
equipment installation cost including foundations, piping, electrical
wiring, and erection; and the cost of engineering construction overhead
and contingencies.
The annualized cost of a control system is the cost to the company
to own and operate the system. The annualized costs include direct
operating costs, such as labor, utilities, and maintenance; and capital
related charges, such as depreciation, interest, administrative overhead,
property taxes, and insurance.
6-1
-------
6.1 REVERBERATORY FURNACES
Most States use the same process weight equation to establish a
mass emission standard of approximately 63.6 mg/dscm (0.028 gr/dscf) for
reverberatory furnaces. Because this is so near the level of the NSPS,
there is unlikely to be a discernable difference in the emission rate of
a furnace complying with the typical State limit and an otherwise identical
furnace complying with the NSPS. The capital and annualized costs of
air pollution control equipment and associated ductwork, pumps, etc.,
necessary for a typical plant to meet either the most common SIP or the
NSPS are approximately $514,000 and $190,000, respectively (see Table 6-1).
Because there is no significant difference in either the emission
rates or control equipment costs for facilities meeting the predominant
State standard and those complying with the NSPS, there is no incremental
cost effectiveness. However, the cost effectiveness of the NSPS and
predominant State limit compared to uncontrolled is estimated to be
$135 per ton based on the uncontrolled emission factor given in AP-42.7
6.2 ELECTRIC FURNACES
Most States apply the same process weight equation used to determine
emission limits for reverberatory furnaces to also determine emission
limits for electric furnaces. Since typical electrical furnaces process
brass and bronze at the same rate as typical reverberatory furnaces, the
same predominant State standard applies, 63.6 mg/dscm (0.028 gr/dscf).
Because this mass emission standard is based on the use of the same
control technology as the 10 percent visible emission limit under the
NSPS, no additional capital expenditures are necessary to meet the NSPS
limit over those necessary to comply with these State requirements.
If the same mass emission limit set by the NSPS for reverberatory
furnaces were applied to electric furnaces, no additional capital expendi-
tures beyond those necessary for typical SIP compliance would be required
since the two standards would limit emissions to essentially the same
level. The capital and annualized costs for control to meet either the
most common SIP or the NSPS reverberatory limit are approximately $290,000
and $135,000, respectively (see Table 6-1). Because there would be no
significant difference in either capital costs for air pollution control
equipment or emission rates for identical furnaces under the NSPS and
6-2
-------
fO
V)
f—
^^
LU
— J
ca
>
0 CO >,^
tO f^ l~" NS"S, f3
e .— .a cn o
O <: ro E -P
in
in
E -0 /-^
LU i ai s-
!= r- S- >,
O r— >,-^
U O \ C
c i- cn o
ID -P E P
TJ
CO
o co
o -a
_Q
S- 5 E E
•i- O E 4-
<***
/•"-N
•* in
CO C
N O
•p- -p
oo v — '
CO
Q.
>}
4-x
CU
u
ro
C
S-
3
u_
4-
/•—^
rH CM
rH rH
^— ^
O O
rH <^"
oo «=t-
rH rH
O
O
00
*•,
cn
CO
rH
O
O
»^
n
^^
rH
LO
U i-
••- CO
£— 4-J
O r—
ro -i-
LU 4-
O O
O O
CM O
r* *,
rH CM
^^
**~s
/^%
ID O
=3- LO
^s—y
1
£_
CU
^* ^>
CO S-
5- O
-P
>, (0
S- S-
ro cu
P ,o
0
DS
cn
l£) I —
*— •
,*^
r^*s m
oo cn
0
o
CO
*-.
LO
oo
i-H
O
0
f.
O
<7>
CM
U S-
•r- O)
S- -P
r^ r—
rO •!-
LJ_ 4-
O 0
O LO
LO r-»
*•
CO
rH
'*+-S
s~**
LO o
t^J- LO
•»«— *
c
o
• r—
-p
u
3
73
C
•P—
(J
.r™
S-
-p
(J
CO
(—
LU
O
+J
•a
cu
ra
T3
Q.
3
C
cu
cu
.a
UJ CO
i >
*-t ro
oo
CL. in
00 -P
Z to
o
CO O O
-P in
cn i-
o • o
•p 1— -p
ro rO
-P 3 U
U C -i-
CO ro t3
•>-} E c
-Q T—
3 a
in o£ u
"^ *r—
>>C3 E
i— O
-p co c:
c: J= o
cu -p u
S- CO
5- 73
3 C Cn
O ro C
• in c 5-
00 -P O 01
C -r- O)
CU ro -P C
O i — ro •!-
c Q. E cn
cu s- c
S- 4- O LU
CO O 4-
4- C •—
CU Ul T- rO
S- C 0
0 >>'r-
0 -i- S_ E
+J +j +j CO
ro in -e
S- S- 3 0
cu co -a
4- a. c en
a> o T- c
S- •!-
i — cn m
i— ro c 3
•FT U •!-
rO 'r— in CM
•p a. 3 oo
cu >, cn
T3 -P 73 rH
CU
CO C -P £_
S- O ro CO
O r~" f^
S 73 3 E
CO (J CO
S- to i — U
O ro ro CO
LL. CD O Q
ro x: u T:
.
c
o
+J
o
r^
o
CM .
CU
E
3
in
rO
C
O
+J
U
73
C
*!—
U
• !_
£_
^_>
U
CO
CO
i- c: c
o o o
4- .•!-•!-
to P .p
• - CO ro ro
C Q." 5- S-
o >j co ai
•P -P Q. Q.
\ O O
X5 CO
, — O 4- 4-
(000
0 C
O S- S- S-
CO 3 >, >,
4- \, \
4- J= J=
O -C
•POO
>> O O O
S- -Q ID UD
ro *» **
-P S- •* •*
o o
E E
4. 73 4- 4-
O S- U U
4— ro in in
~^y
J- .C 0 0
O ro O O
-P -P O O
U in •< »
ro CO r->
4- 4- CM rH
U
C in 4- 4-
O 73 O O
• r- ^N^
in s- S ^
in cn o O
E CM 4- 4-
CO CM
0 S- S-
C . -r- T-
ro O ro ro
CO CO CO CO
E E E E
3333
in to in to
in to in in
<
-------
the predominant SIP, there would be no incremental cost effectiveness.
The cost effectiveness of either the most common SIP or the NSPS reverbera-
tory limit applied to electric furnaces is estimated to be $1,500 per
ton compared to uncontrolled. This value is based on the AP-42 emission
factor for uncontrolled electric furnaces.7
6.3 RETROSPECTIVE ANALYSIS OF ORIGINAL ECONOMIC IMPACT PROJECTIONS
The original economic impact analysis of the NSPS, performed in
1973 by the EPA, used a "model plant" approach. Three reference furnace
sizes were distinguished: 20, 50, and 75 tons.
Representative income statements for the model plants were developed
in the original analysis using representative values for plant operating
hours, investment requirements, operating costs, and product prices.
The annualized and capital control cost estimates were compared to the
income statement items to estimate impacts in terms of: the percent
reduction in earnings and cash flow (assuming all costs are absorbed),
the percent increase in prices (assuming all costs are passed on), and
the increase in new plant investment requirements.
Reductions in earning and cash flow were determined by the addition
of NSPS control costs to the baseline operating costs of each plant and
recalculating earnings and cash flow after tax. The percent price
increases were estimated through the expression of annualized control
costs as a percent of model plant revenues.
The findings of the original analysis were that the economic impact
of the NSPS on affected brass and bronze plants would be very small. If
all costs were to be paid by the firms rather than passed to their
customers in the form of increased prices, earnings would decline by
about 5 or 6 percent while cash flow would decrease about 1 or 2 percent.
More likely, however, prices would be increased, and the extent of such
price increases would be about 0.4 percent.
A retrospective analysis of the economic impact of the NSPS on the
brass and bronze industry was conducted in 1983 as part of this review.10
The review was conducted to judge the accuracy of the original EPA
analysis and to project future (5-year) economic impacts of the NSPS on
the brass and bronze industry. New costs were not obtained during the
6-4
-------
review; rather the original EPA estimates were updated using appropriate
indices.
The findings of this analysis are:
1. An analysis of brass and bronze price trends during the 10 years
preceding proposal of the NSPS and extending through the 7 years following
proposal of the standards, indicates that NSPS cost impacts have not
contributed to price escalation in the brass and bronze industry (see
Table 6-2).
2. However, the control costs associated with the standard resulted
in a product price increase of 0.4 percent for typical furnaces. The
product price impact will remain at this level in the near future (next
5 years), assuming .that the standard will not be changed from its form
as promulgated in 1974.
3. In recent years, the rate of decline in brass and bronze production
has become smaller, indicating that the rate of decline in total industry
output has not been accelerated by the NSPS.
6-5
-------
TABLE 6-2. PRICES FOR BRASS AND BRONZE INGOTS10
(Cents per pound)
Year
1963
1964
1965
1966
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
Current9
32.00
35.14
41.02
50.34
44.79
44.26
51.92
56.35
52.94
51.90
66.02
84.49
65.87
70.03
69.68
72.76
92.75
106.11
Price index
91.3
93.8
96.4
98.8
100.0
102.6
108.5
116.6
118.7
123.5
132.8
171. 9
185.6
195.9
209.0
227.1
259.3
286.4
Constant'
100.38
107.29
121.87
145.92
128.28
123.55
137.05
138.41
127.73
120.36
142.38
140.77
101.64
102.38
95.48
91.76
102.44
106.11
.Prices not adjusted for inflation.11
^Reference 12.
Prices adjusted for inflation and expressed in 1980
dollars.13
6-6
-------
6.4 REFERENCES FOR CHAPTER 6
1. Letter and attachments from Sherman, G., American Brass, Inc., to
Farmer, J. R., EPA:ESED. May 5, 1983. Response to Section 114
information request.
2. Letter and attachments from Morton, T., National Metals, Inc., to
Farmer, J. R., EPA:ESED. May 9, 1983. Response to Section 114
information request.
3. Letter and attachments from Singh, A., and M. Sabatka, Federal
Metals, Inc., to Farmer, J. R., EPA:ESED. May 9, 1983. Response
to Section 114 information request.
4. Letter and attachments from Oberlin, J. P., I. Schumann and Co., to
Farmer J. R. , EPA:ESED, May 5, 1983. Response to Section 114
information request.
5. Letter and attachments from Brown, L. G., Chase Brass and Copper
Co., to Farmer, J. R. , EPA:ESED. April 12, 1983. Response to
Section 114 information request.
6. Economic Indicators: Chemical Engineering. May 16, 1983. p. 7.
7. U.S. Environmental Protection Agency. Compilation of Air Pollutant
Emission Factors, Third Edition, Supplement No. 9. Office of Air
and Waste Management, Research Triangle Park, N.C. EPA Publication
No. AP-42. July 1979. p. 7.9-5.
8. Memorandum from Keller, P., and D. Atkinson, MRI, to Iversen, R.,
EPA:ISB. May 31, 1983. Tabular cost memo for secondary brass and
bronze NSPS review.
9. R. B. Neveril, CARD, Inc. Capital and Operation Cost of Selected
Air Pollution Control Systems. U.S. Environmental Protection
Agency. Research Triangle Park, N.C. EPA Publication No. EPA-450/
5-80-002. December 1978. pp. 3-11 to 3-14, 3-17, 4-36, 4-37
4-39, 4-22, 4-29, 4-30, 4-35 to 4-37, 4-46, 4-58, 4-50, 4-59, 4-61,
4-66, 4-73, 5-26, 5-32, B-2.
10. JACA Corporation. Retrospective Analysis of the Economic Impact of
NSPS in the Brass and Bronze Industry. Prepared for U.S. Environmental
Protection Agency. Research Triangle Park, N.C. Project No.
EPA 68-02-3812. June 1983.
11. American Metals Market. "Metal Statistics 1981." Page 83. Average
annual prices for 85-5-5-5 brass ingot.
12. Council of Economic Advisors. "Economic Report of the President."
February 1983. Producer price index for metals and metal products.
p. 231.
6-7
-------
13. Telecon: Keller, P., MRI, with Castello, T. , JACA Corp. July 27, 1983.
Information concerning the JACA retrospective analysis of the economic
impact of NSPS in the brass and bronze industry.
6-8
-------
7. ENFORCEMENT ASPECTS
All five facilities subject to the NSPS are currently in compliance
with the NSPS and applied State regulations. Company personnel contacted
on plant visits and in writing indicated that they have no problems
complying with the NSPS. Discussions with EPA regional offices and
State and local agencies indicate that there are no major problems in
enforcing the NSPS for the secondary brass and bronze industry.1-3
Of the five facilities currently subject to the NSPS, two are
located in Alabama and three are located in Ohio (see Table 2-4). Both
States have accepted delegation of enforcing the NSPS for the secondary
brass and bronze industry. Plants operating in Alabama are required to
use sound engineering emission capture practices to control particulate
matter emissions.1 New plants operating in Ohio are required to comply
with the State's BACT standard in addition to any applicable NSPS. In
accordance with this standard, new electric furnaces in brass and bronze
plants are required to meet the 50 mg/dscm (0.022 gr/dscf) mass standard,
currently only applied to reverberatory furnaces under the NSPS. New
facilities are also required by Ohio to meet the opacity limit evidenced
during the compliance test, resulting in a 0 percent opacity standard
for the two operational facilities.2 Ohio and Alabama personnel stated
that continuous monitoring and reporting are not necessary at this time.4,5
The NSPS is written to cover reverberatory, electric, and blast
(cupola) furnaces that are used in brass and bronze ingot production
plants. One prototype facility, located in Ohio, uses an electric
furnace to continuously cast rod instead of batch casting ingot. The
State of Ohio considers this furnace to be subject to the NSPS.
The NSPS does not cover fugitive emissions; however, both Alabama
and Ohio require specialized hooding for the capture of these emissions,
7-1
-------
which are ducted to a common baghouse with affected facilities. Emissions
from these baghouses are required to meet NSPS and State standards.
7.1 REFERENCES FOR CHAPTER 7
1. Telecon. Keller, P., MRI, with Wood, B., Alabama Air Pollution
Control Commission. April 14, 1983. Alabama enforcement of NSPS
and State standards.
2. Memo from Keller, P., MRI, to Iversen, R., EPA:ISB. April 18, 1983.
Minutes of meeting with Cleveland Division of Air Pollution Control.
3. Telecon. Keller, P., MRI, with Moore, B. EPArRegion IV. February 10,
1983. Compliance status of secondary brass and bronze facilities in
Region IV.
4. Telecon. Keller, P., MRI, with Wood, B., Alabama Air Pollution
Control Commission. May 12, 1983. Alabama monitoring and reporting
requirements.
5. Telecon. Keller, P., MRI, with Seaman, D., Cleveland Division of
Air Pollution Control. May 13, 1983. Ohio monitoring and reporting
requirements.
7-2
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/3-84
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
Review of New Source Performance Standards for
Secondary Brass and Bronze Plants
5. REPORT DATE
-May TS84
6. PERFORMING ORGANIZATION CODE
1, AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-02-3817
12. SPONSORING AGENCY NAME AND ADDRESS
Director for Air Quality Planning and Standards
Office of Air, Noise, and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This report presents the findings of the second 4-year review of the new
source performance standard for secondary brass and bronze production plants.
Information is presented concerning industry growth, control technology, compliance
status, and the costs associated with compliance.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATI F;ieid/Group
Brass and Bronze
NSPS
Air Pollution
Pollution Control
Emission Standards
Particulate Matter
Air Pollution Control
13b
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (This Report!
Unclassified
21. NO. OF PAGES
50
20. SECURITY CLASS IThispage)
Unclassified
I 22. PRICE
i
EPA Form 2220-1 (Rev. 4-77)
PREVIOUS EDITION IS OBSOLETE
-------
-------
-------
=' CD
Is
tw =5a ^
«MS«
3SS2.S
a' §•.= «
IFhl
fa . o.,o
VI" ~^^ W
w ^?5 ra W
^ H c 3'
tic 3 ^
gg|j
023.3
• so o
lifk
-• sf g
as Is
— o a a
Hit
s-«^
3 H! o
O.H 3
3g f
— 2. o
II f
~ ra
o a S"
fl I
til
Z3 =;'tD
O O Q.
is
7
o
8
MIQ
------- |