United Stales
KnvirnnmeiHal Piotection
Agency
(M'fice D|" Air Quality
Planning and Standards
Research Triangle Park. NC 27711
453R94024A
Final Report
lune 1W4
Air
JV EPA SECONDARY LEAD SMELTING
BACKGROUND INFORMATION
DOCUMENT FOR
PROPOSED STANDARDS
VOLUME 1
NESHAP
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EPA-j!tBt)/R-94-024a
Secondary Lead Smelting
Background Information
Document for
Proposed Standards
Volume 1
Emission Standards Division
Office of Air Quality Planning and Standards
United States Environmental Protection Agency
Research Triangle Park, North Carolina 27711
U.S. Envirohn;;r;,;: Faction Agency
Region 5,Libfj.r- , .\?j\
June 1994 —••• - - • • J"J;
77 West Jackson ..-".;--'7?rd i?th e,
Chicago, IL 60604:3590 '°0r
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DISCLAIMER
:'!•;;-; c •: \ '".':
..This, final report has been , reviewed' by - {-he-Emissions -Standards
Division, Office of Air Quality Planning and Standards, U.S.
^Environmental Protection.Agency,: -arid"approved for publication.
-.Approval does not signify;.the "contents necessarily reflect the
.views and policies of the U:-S. -Environmental -Protection Agency,
nor does mention of trade names of commercial products constitute
-endorsement of .recommendation fatt'tasei"—''^ '-' >'""'*- '-•-
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1-1
1.1 References * 1-4
\ _7. - • - ' i.- v C^ - —
2.0 PROCESS DESCRIPTION AND EMISSIONS . , 2-1
2.1 Industry :Overview . ^r.; .-2 .-. .'. . •"-. -'•. -. '. 2-1
2.1.1 .Raw Materials. -.....'. :r . . ••. .--"." . . . 274
2.1.2 Annual Lead :;Preduction . ?.'.' *-•-.-. . . 2-6
, :2.1;3 Industry-Trends ~ •. .' . .:. . . ., :.ri ':' '"•'•-" 5-6
2.2 Process Description ... .......TIC i?"... ~; .-; r;* 2-9
2.2.1 Battery Breaking and Material
Separation 2-10
2.2.2 Paste Desulfurization 2-13
2.2.3 Materials Storage 2-14
2.2.4 Furnace Charge Preparation and
Materials Handling „ 2-14
2.2.5 Smelting 2-15
2.2.6 Refining 2-26
2.2.7 Casting 2-28
2.2.8 Electrowinning ............ 2-28
2.3 Emissions and Factors Affecting Emissions ,. . 2-29
2.3.1 Process Emissions ..... 2-29
2.3.2 Process Fugitive Emissions 2-35
2.3.3 Fugitive Dust Emissions ....... 2-36
2.4 References 2-37
3.0 EMISSION CONTROL TECHNIQUES AND PERFORMANCE ... 3-1
3.1 Emission Control Techniques for Process
Sources 3-1
3.1.1 Metal HAP Control Techniques 3-3
3.1.2 Organic HAP Control Techniques .... 3-5
3.1.3 Hydrochloric Acid and Chlorine
Control Techniques 3-16
3.2 Emission Control Techniques for Process
Fugitive Sources 3-20
3.2.1 Hoods .3-20
3.2.2 Baghouses . 3-21
111
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,TABLE OF CONTENTS
..-.: T.(CONTINUED)
Page
3.2.3 Wet Scrubbers 3-23
3..2,4, Blast Furnace Charging Ventilation . . 3-28
3.3 Control Techniques for Fugitive
Dust Emissions ......... 3-30
3.3.1 Paving 3-30
3."3.2 Partial and Total Enclosure 3-30
3.3.3 Housekeeping ............. 3-32
3.4 Pollution Prevention/Source Reduction
Control Options 3-34
3.4.1 Metal HAP Emission Prevention
Through Eleetrowinning ~. . :.. . . .' . . 3-34
3.4.2 Organic HAP and Hydrochloric Acid
Emission Prevention Through
Plastic Removal .... . . . . . . . . 3-34
3.4.3 Hydrochloric Acid Emission Prevention
Through Use of Fluxing Agents . . u. . 3-34
3.4.4 Hydrochloric Acid Emission Prevention
Through Dechlorination of Flue Dust . 3-36
3.5 References 3-38
4.0 'CONTROL ALTERNATIVES ....,„... 4-1
4.1 Secondary Lead Smelter Information
Collection ........... 4-1
4.2 Baseline: Emissions ... ...... . . . . . 4-2
4.2.1 Baseline Process Emission Estimates . 4-9
4.2.2 Baseline Process Fugitive Emission
Estimates 4-11
4.2.3 Baseline Fugitive Dust Emission
; Estimates ...... 4-11
4.3 Identification of MACT Floor Controls .... 4-12
4.3.1 Candidate MACT Floor Control
Alternatives for Process Sources . . . 4-13
• • 4.3.2 Candidate MACT.Control for.Process
Fugitive Sources 4-17
4.3.3 Candidate MAGT Control for Fugitive
Dust Sources -4-1?
IV
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TABLE, pi1"'CONTENTS
(CONTINUED)
Page
.-yL">ci--r-. ;u- f
4.4 Upgrades Needed .to Meet"the MAcf Floor
Level of Control . . , , ,. ....... . , . . . . 4-21
4.4.1 Process Sources . . . . 4-21
4.4.2 Process Fugitive Sources 4-23
4.4.3 Fugitive Dust Sources ,. 4-24
• 4.5 Evaluation of a Control Option Above the
MACT Floor -. 4-24
4.6 Controlled Emissions . . . 4-24
4.6; 1 Process Emissions . ".'V 4-25
4.6.-2 -'-' Process Fugitive Emissions . .' . . 4-27
4:.6.3' Fugitive Dust Emissions 4-27
4.7 References' .'•-". .... . . ."t . . . 4-28
5.0 ENVIRONMENTAL IMPACTS OF CONTROL ALTERNATIVES . . 5-1
5.1 Hazardous Air Pollutant Impacts r 5-1
5.1.-1 - Process Sources .' . . "." ." 5-1
5.1.2 Process Fugitive Sources .,, ..... , , 5-4
5.1.3 Fugitive Dust Sources ... . . . . . 5-5
5.2 Other Air- Pollutant Impacts ..^.V. 5-6
5.2.1 Lead and PM . . . . ,....._., .,. . . . 5-6
5.2.2 CO, THC, CQ/2i anfl Nox "• ^ - •'• • • • 5-6
5.2.3 Sulfur Dioxide .......„...'.. 5-9
5.3 Water Consumption Impacts . . ."".". . . . . . 5-9
5.3.1 Impacts from Fugitive Dust Control . . 5-9
5.3.2 Impacts from Wet Scrubbers 5-10
5.4 Solid Waste Disposal Impacts "I 5-11
5»4:1 Flue Dust . . . :';."".' 5-11
- 5.4.2 Slag . . . . . . '!"„.:'! , . 5-11
: 5.4*3 Scrubber Sludge "..;./.. .' . 5-12
• • 5.4.4 Water Treatment 'Plarit Sludge 5-12
5.4.5 Battery Recycling '.-?,- 5-12
5.5 Energy Impacts 5-13
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TABLE OF CONTENTS
(CONTINUED)
Page
5.6 Irreversible and Irretrievable Commitment
of Resources . .' . V -. 5-13
5.7 References 5-14
6.0 COST IMPACTS OF CONTROL ALTERNATIVES 6-1
6.1 Smelting Furnace Process Sources . . . ... 6-3
6.1.1 Metal HAP's 6-3
6.1.2 Organic HAP's 6-3
6.1.3 Hydrochloric Acid and Chlorine .... 6-4
6.2 Process Fugitive Sources 6-5
6.3 Fugitive Dust Sources ............ 6-6
6.4 References • * 6-8
7.0 CONTINUOUS MONITORING 7-1
7.1 Metal HAP's ......... 7-1
7.2 Organic HAP's 7-2
7.3 Hydrochloric Acid and Chlorine ....'... 7-3
7.4 References ,: . 7-5
APPENDIX A - Emissions and Performance Data from Secondary
Lead Smelter Test Program
APPENDIX B - Secondary Lead Smelter Test Program Overview
APPENDIX C - Secondary Lead Smelter Database with Estimated
Default Valves
APPENDIX D - Baseline Emission Estimation Procedures
APPENDIX E - Control Cost Estimation Procedures
VI
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LIST OF-TABLES
. f|
Page
2-1 U. S. Secondary Lead Smelters Grouped According
to Annual Lead Production Capacity . 2-7
2-2 Summary of Typical Uncontrolled Organic Emissions
from Smelting Furnaces 2-31
3-1 Summary of Emission Source Types, Pollutants,
and Controls 3-2
3-2 Design and Operating Parameters of the Process
Baghouse Tested by the EPA '. 3-4
3-3 Summary of Process Baghouse and Scrubber Exhaust
Lead Concentrations ..... 3-6
3-4 Summary of Process Baghouse Exhaust Lead
Concentration Data ................ 3-7
3-5 Summary of EPA Data for Uncontrolled and Controlled
THC Emissions ....... 3-9
3-6 Operating Temperatures and Residence Times for
Afterburners Controlling Blast Furnaces at
Secondary Lead Smelters 3-11
3-7 Wet Scrubbers Tested by the EPA for Organic HAP
and HC1/C12 Control . 3-14
3-8 Results of Dioxin, Furan, and THC Emission
Measurements Across Wet Scrubbers .. 3-15
3-9 Summary of HC1 and Cl2 Emission Concentrations . . 3-17
3-10 Design and Operating Parameters of Process .. _ ,..-.,.
Fugitive Baghouses Tested by the EPA- . . . . . . Y 3-22
3-11 Summary of Process Fugitive Baghouse Lead " "
Emission Concentrations 3-24
3-12 Summary of EPA and Compliance Data for Process
Fugitive Baghouse Lead Emissions ........... 3-25
3-13 Design Information for Scrubbers Used to Control
Refining Kettles 3-27
3-14 Summary of Fugitive Dust Emission Control
Strategies 2-21.
VII
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LIST OF TABLES
(CONTINUED)
4-1 Process Source Emission Controls in Use at
Secondary Lead Smelters 4-3
4-2 Process Fugitive and Fugitive Dust Emission
Controls in Use at Secondary Lead Smelters .... 4-5
4-3 Summary of Baseline Hazardous Air Pollutant
Emissions 4-7
4-4 Process Emission Control Combinations 4-14
4-5 Estimated Emissions Under the Candidate MACT
Control Alternatives 4-26
j
5-1 Summary of Hazardous Air Pollutant Emission
Reductions for Candidate MACT Control
Alternatives 5-2
5-2 Summary of Control Alternative Impacts for
Other Air Pollutants 5-7
6-1 Estimated Cost Impacts for the Candidate MACT
Control Alternatives 6-2
Vlll
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LIST OF FIGURES
Page
2-1 Locations of Secondary Lead Smelters
In the United States 2-2
2-2 A Lead-Acid Storage Battery .* 2-5
2-3 Annual Production, Consumption, and Average Price
of Lead 2-8
2-4 Simplified Process Flow Diagram for Secondary
Lead Smelting , 2-11
2-5 Schematic Cross-Section of a Hammermill Crusher . 2-12
2-6 Cross-Sectional View of a Typical Stationary
Reverberatory Furnace . >. .. 2-16
2-7 Cross-Section of a Typical Blast Furnace . , . . . 2-19
2-8 Side View of a Typical Rotary Reverberatory
Furnace , 2-22
2-9 Schematic Cross-Sectional View of an Electric
Furnace for Processing Slag , 2-25
2-10 Cross-Section of a Typical Refining Kettle .... 2-27
IX
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1.0 INTRODUCTION
National emission standards for hazardous air
pollutants (NESHAP) are under development for the secondary
lead smelting industry under authority of section 112(d) of
the Clean Air Act as amended in 1990. This background
information document (BID) provides technical information
and analyses used in the development of the proposed
secondary lead smelter NESHAP.
•>
The information presented in this BID was collected
through a number of different activities associated with
this project beginning in February 1991. A literature
review was conducted of information previously compiled on
the secondary lead smelting industry. In May 1991, the
Environmental Protection Agency (EPA) met with
representatives of the secondary lead smelting industry.
State agencies and regional EPA officials were contacted for
information on smelters located in their jurisdictions,
including copies of air emission permits and recent stack
testing data. Using this information, representative
smelters that were considered to be well-controlled were
identified and were selected for site visits by EPA
representatives.
Questionnaires were developed and sent to smelter
operators in February 1992 and in February 1993. A testing
program was initiated in November 1992 and emission
measurements were conducted at six secondary lead smelters.
A proposed regulatory strategy was developed from the
information collected from the above sources. This proposed
strategy was presented to representatives of the secondary
lead smelting industry in a meeting held in October 1993.
Comments and other information received from industrv as an
1-1
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outcome of that meeting were incorporated in the proposed
rule for secondary lead smelters. The EPA will evaluate
public comments received on the proposed rule and all
comments will be considered in the development of the final
NESHAP.
The purpose of the BID is to document the EPA's
information about hazardous air pollutants (HAP's) from
secondary lead smelters, the demonstrated technologies
available to control HAP emissions, and the costs and
environmental impacts of applying these technologies. The
economic impacts of applying these technologies are
contained in a separate document.^ The rationale for the
proposed regulation and the EPA's final regulatory decisions
are presented in the preamble to the proposed regulation,
including the selection of sources to be regulated, format
of standards, emission limits, and recordkeeping and
reporting requirements.
Chapter 2.0 of the BID describes the secondary lead
smelting industry, its processes and equipment, and typical
air emissions. Chapter 3.0 describes the performance of the
emission control techniques used by the secondary lead
smelting industry and presents a summary of the results of
the EPA-sponsored testing program. The database of
information on existing secondary lead smelters is described
in chapter 4.0, along with baseline estimates of emissions
and estimates of emissions under a candidate maximum
achievable control technology (MACT) control alternative.
Chapter 5.0 summarizes the environmental impacts of adopting
the candidate MACT control alternative as the basis for
limiting emissions. Chapter 6.0 summarizes the cost impacts
of adopting the candidate MACT control alternative.
Finally, chapter 7.0 describes monitoring technologies that
are applicable to this industry for demonstrating continuous
compliance with numerical emission limits.
Supplementary information for this BID is presented in
several appendices. Complete results of the EPA-sponsored
tasting program ara presented in appendix A. Appendix 3
1-2
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describes the EPA testing program to collect the emissions
data described in chapter 3.0 and in appendix A. Appendix C
contains a copy of the secondary lead smelter database,
including default values estimated for missing data.
Appendix D describes the methodology used for estimating
baseline emissions. Appendix E provides the methodology
used for estimating the cost impacts of applying the
candidate MACT control technology.
1-3
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1.1 REFERENCES
Economic Impact Analysis of the Secondary Lead Smelters
NESHAP (Draft Report). U.S. Environmental Protection
Agency. Research Triangle Park, North Carolina.
Publication No. EPA-453/D-94-010. February 1994.
70 pp.
1-4
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2.0 PROCESS DESCRIPTION AND EMISSIONS
This chapter describes the secondary lead smelting
industry, and provides information on unit operations,
processes, and air emissions. Section 2.1 provides an
overview of the industry, including the number, sizes, and
locations of plants. Section 2.2 describes the processes
involved in secondary lead smelting and types of lead
smelting furnaces. Section 2.3 describes typical emissions
i
from secondary lead smelters and the factors affecting them.
2.1 INDUSTRY OVERVIEW
The secondary lead smelting industry produces elemental
lead and lead alloys by reclaiming lead, mainly from scrap
automobile batteries. Smelting furnaces include blast,
reverberatory, rotary, and electric furnaces. Smelting is
the reduction of lead compounds to elemental lead in a high-
temperature furnace. It requires the application of
substantially higher temperatures [1,200 to 1,260 °C
(2,200 to 2,300 °F)] than those required for melting
elemental lead [327 °C (621 °F)]. Secondary lead may be
refined to produce soft lead (which is nearly pure lead) or
alloyed to produce hard lead alloys.
There are 23 secondary lead smelters in the
United States. The actual number of operating plants varies
as plants open and close in response to fluctuations in the
market price of lead. As of December 1993, 16 smelters were
operating and 7 had shut down operations but had not sold
their processing equipment and could therefore restart when
economic conditions improve.1 Figure 2-1 shows the location
of secondary lead smelters in the United States.
The secondary lead industry is distinct from other
industries that produce lead and lead produces, such as
2-1
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1. Sanders Lead Co., Troy, Alabama
2. GNB, Inix, Vemon, California
3. RSR Corp., Gty of Industry, California
4. Gulf Coast Recycling, Inc., Tampa, Florida
5. GNB, Inc. Columbus, Georgia
6. Exide Corp., Muncic, Indiana
7. Refined Metals Corp., Beech Grove, Indiana
8. RSR Corp.. Indianapolis, Indiana
9. Delatte Metals, Ponchatoula, Louisiana
10. Schuylldll Metals Corp., Baton Rouge, Louisiana
11. Gopher Smelting & Refining, Inc., Eagan, Minnesota
12. Doe Run Co- Boss, Missouri
13. Schuylkin Metals Corp., Forest City. Missouri
14. RSR Corp., Middletown, New York
15. Master Metals, Inc., Cleveland, Ohio
16. East Penn Manufacturing Co., Inc., Lyon Station, Pennsylvania
17. Exide Corp., Reading, Pennsylvania
18. General Smelting & Refining Co., College Grove, Tennessee
19. Refined Metals Corp., Memphis, Tennessee
20. GNB, In
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primary lead smelting and lead remelting. Secondary lead
smelting and refining is listed under Standard Industrial
Classification code 3341-Secondary Smelting and Refining of
Nonferrous Metals.3 Lead remelting is included in the same
code as secondary smelting, but lead rolling, drawing, and
extruding are listed under a separate code. Primary lead
smelting and refining are also listed under a separate code.
Primary lead smelters recover lead from a concentration
of mined lead-bearing ore. Sintering machines, blast
furnaces, and refining kettles are used to process the ore
and refine the recovered metal.4 There are currently only
three primary lead smelters operating in the United States.5
Primary and secondary lead smelters produce the same product
(i.e., refined lead); therefore, they tend to compete for
the same markets.2
Lead remelters produce lead by melting scrap lead metal
without reducing lead compounds and do not operate blast,
reverberatory, rotary, or electric smelting furnaces.
Remelters melt purchased lead bullion or scrap metal of
known composition for use in specific molded or fabricated
lead end-products such as solder or sheet lead, or for
additional refining into specialty alloys. Sources of scrap
lead metal include lead-sheathed cable, used solder,
babbitt-metal, and type metals. The lead scrap is often
mixed with other types of metal, such as lead-sheathed
copper cable. The lower melting point of lead is used to
separate the lead from these other metals. There are
approximately 70 lead remelters in the United States.
Some secondary lead smelters and remelters offer a
"tolling service," where a customer delivers scrap lead to
the smelter or remelter and receives the recovered lead and
pays only for the service of having the lead processed and
cast into ingots or blocks. Some secondary lead smelters
that are located with a battery manufacturer operate in this
manner.2
2-3
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2.1.1 Raw Materials
Lead-acid batteries represent about 90 percent of the
raw materials at a typical secondary lead smelter, although
this percentage may vary from one plant to the next. The
majority of these batteries are automotive, truck, and boat
batteries, which are often referred to as starting,
lighting, and ignition batteries. A small percentage are
industrial batteries or uninterruptible power supply (UPS)
batteries. Industrial and UPS batteries are commonly
nickel-cadmium or nickel-iron batteries. Non-lead-bearing
batteries, such as nickel-cadmium or nickel-iron batteries,
are screened out at most facilities.
A typical automotive lead-acid battery weighs about
18 kilograms (kg) [40 pounds (Ib)] and contains about 9.5 kg
(21 Ib) of lead and 5.5 kg (12 Ib) of sulfuric acid
electrolyte, with the remaining weight attributed to
separators and case materials. By mass, about 60 percent of
the lead in a lead-acid battery is in the form of lead oxide
and lead sulfide paste and about 40 percent is in the form
of lead metal grids and posts.6 Figure 2-2 illustrates the
construction of a lead-acid storage battery.7
The U. S. Department of Commerce estimates that nearly
all lead-acid batteries are recycled.** Similarly, a study
sponsored by the Battery Council International (BCI) found
that 97.8 percent of batteries were recycled in 1990,
compared to 88.6 percent in 1987.9 The same report
estimated that 87 million batteries were available for
recycling in 1990, up from 77.7 million in 1987.
Historically, -the battery recycling rate has been positively
correlated with the price of lead and fluctuates in response
to price changes.2
Other types of lead-bearing raw materials recycled by
secondary lead smelters include drosses (lead-containing by-
products of lead refining), which may be purchased from
companies that perform lead alloying or refining bur nor
smelting; battery plant scrap, such as defective grids or
paste; and scrap lead, such as old pipes or rcof flasn^.-.g.
2-4
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Cell Cow
Vent Plug
Terminal Post
Gasket
Visual Level Fill
Grid Strap
Grid
Protected Cell Connector
Se« Section A
Bridge
Plastic Casing
Sediment Chamber
Section A - Components of a Battery Element
Separators
Positive Grid Group
Negative Grid Group
Cell Terminal
Grid Strap
Positive Grid
Negative Grid
at!
C!
Figure 2-2. A ieaci-acid storage bacterv
2-5
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Other scrap lead sources include cable sheathing, solder,
and babbitt-metal.
2.1.2 Annual Lead Production
In 1990, primary and secondary smelters in the United
States produced 1,255,000 megagrams (Mg) (1,380,000 tons) of
lead. Secondary lead smelters produced 860,000 Mg
(946,000 tons) or about 69 percent of the total refined lead
produced in 1990, and primary smelters produced 395,000 Mg
(434,000 tons).8 Table 2-1 lists U. S. secondary lead
smelters according to their annual lead production capacity.
In 1990, domestic lead consumption was 1,276,000 Mg
(1,403,000 tons); 94 percent of the lead consumed was
produced in the United States. Lead consumption is expected
to expand by approximately 1.8 percent per year through
1995. The largest U. S. lead-consuming industry is lead-
acid storage battery manufacturing, which accounted for
79 percent of lead consumption in 1990.8 Lead is also used
in the production of ammunition, pigments, lead-based
solder, sailboat keels, and fabricated products, including
lead sheet, extrusions, and plumbing and roofing supplies.
Most remelters that process scrap also produce lead
products, thereby operating as both producers and consumers
of recovered lead. Annual production and consumption of
primary and secondary lead and the annual average price of
lead are illustrated in figure 2-3 for the years 1984
through 1995.
2.1.3 Industry Trends
The trend in the U. S. secondary lead industry is
toward fewer but larger smelters as smaller smelters close
and the remaining smelters increase capacity. However, as
noted above, the number of plants actually in operation at
any one time fluctuates. Some plants may temporarily shut
down when the price of lead drops or when batteries are hard
to obtain, but then restart as the price recovers or
batteries become available.
In 1980, between 50 and 66 secondary lead smelters,
owned by 26 companies, were operating in che Uni-aci Stat:as
2-6
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TABLE 2-1. U. S. SECONDARY LEAD SMELTERS GROUPED
ACCORDING TO ANNUAL LEAD
PRODUCTION CAPACITY
Smelter Location
Small-Capacity Group: [less than 20,000 Mg (22,000 tons)]
Delatte Metals Ponchatoula, LA
General Smelting & Refining Co. College Grove, TN
Master Metals, Inc. Cleveland, OH
Metals Control of Kansas Hillsboro, KS
Metals Control of Oklahoma Muskogee, OK
Medium-Capacity Group; [20,000 to 75,000 Mg
(22,000 to 82,000 tons)]
Doe Run Co. Boss, MO
East Penn Manufacturing Co. Lyon Station, PA
Exide Corp. Muncie, IN
Exide Corp. Reading, PA
GNB, Inc. Columbus, GA
GNB, Inc. Frisco, TX
Gulf Coast Recycling, Inc. Tampa, FL
Refined Metals Corp. Beech Grove, IN
Refined Metals Corp. ' Memphis, TN
RSR Corp. City of Industry, CA
RSR Corp. Middletown, NY
Schuylkill Metals Corp. Forest City, MO
Tejas Resources, Inc. Terrell, TX
Large-Capacity Group: [greater than 75,000 Mg (82,000 tons)
Gopher Smelting & Refining, Inc. Eagan, MN
GNB, Inc. Vernon, CA
RSR Corp. Indianapolis, IN
Sanders Lead Co. Troy, AL
Schuylkill Metals Corp. Baton Rouge, LA
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and secondary lead production was 676,000 Mg (744,000 tons).
In 1983, only 43 secondary lead smelters, owned by
27 companies, were in operation.10 Since 1983, 24 of these
43 smelters have closed permanently and several of the
remaining operating smelters have changed owners.
A 1985 study predicted that future secondary lead
smelter construction was unlikely.10 In fact, seven new
small- to medium-size secondary lead smelters have been
constructed since the 1985 study, one of which is owned and
operated by a primary lead producer. However, several of
these smelters closed after operating for only a short time.
Electrowinning and electrorefining are electrolytic
recycling processes for recovering lead from scrap batteries
and are alternatives to the pyrometallurgical methqds
currently used in the United States. However,
electrowinning and electrorefining have not yet been
demonstrated on a commercial scale in the United States and
are still largely experimental. Several bench-scale
projects performed by the Bureau of Mines of the U. S.
Department of the Interior have investigated the feasibility
of these processes.11'12 A full-size electrowinning cell
(process unit) has been constructed in Italy to demonstrate
and study electrowinning, but a complete full-size plant has
not yet been constructed.13 Currently, no plants in the
United States are using or are planning to use
electrowinning in the foreseeable future.
2.2 PROCESS DESCRIPTION
The secondary lead smelting process consists of
(1) breaking lead-acid batteries and separating the lead-
bearing materials from the other materials (including
plastic and acid electrolyte); (2) melting lead metal and
reducing lead compounds to lead metal in the smelting
furnace; and (3) refining and alloying the lead to customer
specifications. The reduction of lead compounds to lead
metal in the smelting furnace is the process that
distinguishes a lead smelter from a lead remelter. If a
facility does not perform chis function, then it is not: a
2-9
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smelter. These steps are outlined in the process flow
diagram in figure 2-4 and are described in more detail in
the sections below.
2.2.1 Battery Breaking and Material Separation
Automotive batteries are broken using either
hammermills, saws, shears, or some combination of the above.
The batteries may be punctured to allow the acid to drain
before they are broken.14 A hammermill consists of a
rotating horizontal shaft that has several rows of weights
(hammers) attached to it (figure 2-5). The hammers are
hinged so that they swing out as the shaft rotates.
Batteries are fed into the top of the mill and are smashed
against a strike plate by the hammers. The pieces fall
through a sizing grate at the bottom of the mill. ,The
hammermill is enclosed in an acid-resistant housing and may
be vented to an air pollution control device for the control
of acid mist.
Battery saws are slow-speed saws used to saw the top
off the battery case. A battery shear uses a large steel
blade to slice off the top of the battery case. After they
are sawed or sheared, the batteries are conveyed to a
tumbler, which separates the battery plates from the cases.
A tumbler is a rotating horizontal cage that allows the
plates to fall through slots in the side of the cage; the
empty cases are discharged through the end.15 The plates
are sent to raw materials storage and the cases are sent to
a hammermill for crushing to remove the lead posts and
reduce the volume of the plastic.
Following a hammermill, a sink/float separator is used
to separate the lighter polypropylene plastic of the battery
cases from the lead-bearing battery components and
separators and the hard rubber that is found in older
battery cases. The polypropylene plastic is then usually
washed, loaded into the back of a trailer using an air
blower, and sold for recycling.6
Battery plates, posts, hard rubber, and separators may
be sent ciiractly to the raw materials storage area or uiay
2-10
-------
Batteries Arrive
by Truck
Tear
Recycling
Battery
Breaking
Add to
Water Treatment
or Recycling
Other Lead-
Bearing Material!
and Scrap
Grid Metal,
Hard Rubber,
Separator!
Material!
Storage
Charge
Preparation
Smelting
Furnace
Refining/
Alloying
Casting
OPTIONAL
LeadPute
Paste
Dciulfurization
— Slag
•*• Disposal
Finished
Product
Figure 2-4. Simplified process flow diagram for
secondary lead smelting.
2-11
-------
Whole Batteries
Horizontal
Shaft
Broken Batteries
Figure 2-5. Schematic cross-section of a hammermill
crusner.
2-12
-------
undergo further processing involving the separation of lead
oxide paste from the lead grid metal for paste
desulfurization (described below).
Screw conveyors are used to transfer the materials
coming out of the materials separation process to either raw
materials storage or to paste desulfurization.
Large industrial and UPS batteries are disassembled by
hand and the lead-bearing materials are sent directly to the
materials storage area.
2.2.2 Paste Desulfurization
Paste desulfurization involves the chemical removal of
sulfur from the lead battery paste. The process improves
furnace efficiency by reducing the need for fluxing agents
to reduce lead-sulfur compounds to lead metal. The process
also reduces sulfur dioxide (SO2) furnace emissions.
However, SO2 emissions reduction is usually a less important
consideration because many plants that perform paste
desulfurization are also equipped with SO2 scrubbers. About
one-half of smelters perform paste desulfurization.
Paste desulfurization requires the separation of the
lead sulfate and lead oxide paste from lead grid metal,
polypropylene plastic cases, separators, and hard rubber
battery cases. This is accomplished by placing the broken
battery materials on a screen and washing them with water
jets to remove the pastes. The pastes are washed through
the screens to settling chambers.
Lead oxide (PbO) and lead sulfate (PbSO4) are removed
from the settling chambers by screw conveyors as a lead
slurry. This lead slurry is mixed with either ammonium
carbonate [(NH4)2CO3] or sodium carbonate (Na2CO3). The
PbSO4 reacts with the carbonate compounds to produce lead
carbonate (PbC03). The mixture of PbCO3 and PbO is
dewatered and concentrated in a filter press or densifying
tower (a tall settling chamber) and is then ready to be used
as a furnace feed material.16 The ammonium sulfate
C(NH4)2SO4] or sodium sulfate (Na2SO4) produced as a by-
product of pasta desulfurization may be sold as a raw
2-13
-------
material to chemical manufacturing industries or may be
disposed of as a nonhazardous solid waste.
2.2.3 Materials Storage
Lead-bearing raw materials are stored at secondary lead
smelters in bins or enclosures such that they are protected
from the wind to prevent the entrainment of lead-bearing
dust. Broken battery components, slag from the furnaces,
and drosses may be stored in three-sided bins at some
smelters. These bins may or may not be located under a
roof. If these materials are stored outside, they are
usually kept wet to prevent the formation of dust. Several
smelters store all of their lead-bearing raw materials in
enclosed buildings. These buildings may or may not be
vented to a control device.
One smelter has minimized the amount of lead-bearing
materials that must be stored at the smelter by breaking
batteries only on an as-needed basis to keep pace with
furnace production. In addition, raw materials from the
broken batteries are stored in plastic bags placed inside
steel feed tubs before being charged to the furnace. All
materials handling at this facility is totally enclosed
inside a building and there is no outside storage of raw
materials.^7
2.2.4 Furnace Charge Preparation and Materials Handling
Furnace charge materials consist of lead-bearing raw
materials, lead-bearing slag and drosses, fluxing agents,
and coke. Fluxing agents consist of iron, silica sand, and
limestone [calcium carbonate (CaCC>3) ] or soda ash (Na2CC>3) .
Fluxing agents are added to blast and rotary furnaces to
promote the conversion of lead compounds to lead metal and
the removal of impurities through slag formation. Coke is
used as fuel in blast furnaces and as a reducing agent in
reverberatory and rotary furnaces. The charge materials
vary depending on the furnace type and on the particular
practices of the plant operators.
The majority of secondary lead smelters use front-end
loaders to handle raw materials, broken battary ccmponen-cs,
2-14
-------
fluxing agents, and reverberatory and blast furnace slag.
Feed hoppers and pan- or belt-type conveyors are often used
in furnace charging to carry materials to the furnace feed
chute. At most smelters, flue dust collected by the air
pollution control devices is handled in sealed screw
conveyors and is sent directly to a reverberatory or
agglomerating furnace. (An agglomerating furnace is a small
furnace used to melt flue dust into a solid mass.) Drosses
from refining kettles are handled in drums or tote boxes by
forklift trucks.
One plant has developed a materials handling system
that uses feed tubs and overhead cranes to move lead-bearing
materials within the plant. Enclosed silos fitted with
sealed conveyors are used for storing and transferring flue
dust and fluxing agents. This system minimizes the need for
front-end loaders or forklift trucks to move materials
within the plant.17
2.2.5 Smelting
Smelting is performed in reverberatory, blast, rotary,
or electric furnaces. There are currently about
15 reverberatory furnaces, 24 blast furnaces, 5 rotary
furnaces, and 1 electric furnace in the secondary lead
smelting industry.
Blast and reverberatory furnaces are currently the most
common types of smelting furnaces in the industry. Although
some new plants are using rotary furnaces, the industry
still relies primarily on blast and reverberatory furnaces.
2.2.5.1 Reverberatorv Furnaces. A reverberatory
furnace (figure 2-6) is a rectangular refractory-lined
furnace. Internal dimensions vary from 1 to 6 meters (m)
[3 to 19 feet (ft)] in width, from 2 to 12 m (6 to 39 ft) in
length, and from 1 to 3 m (3 to 10 ft) in height.18 The
roof and the floor (or hearth) are both arched and slope
toward the lead tap, which is usually located on the side of
the furnace.
Reverberatory furnaces are operated on a continuous
basis. Natural gas- or fuel oil-fired jets iccarea a^ one
2-15
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end of the furnace or at the sides are used to heat the
furnace and charge material to an operating temperature of
about 1,100 °C (2,000 °F). Oxygen enrichment may be used to
decrease the combustion air requirements. Reverberatory
furnaces are maintained at negative pressure by an induced
draft fan.
Reverberatory furnace charge materials include battery
grids and paste, battery plant scrap, rerun reverberatory
furnace slag, flue dust, drosses, iron, silica, and coke. A
typical charge over one hour may include 8.4 Mg (9.3 tons)
of grids and paste, to produce 5.6 Mg (6.2 tons) of lead per
hour. Limestone and soda ash are not typically added to a
reverberatory furnace, especially if it is collocated with a
blast furnace.
Charge materials are often fed to a natural gas- or
oil-fired rotary drying kiln, which dries the material and
then transfers it directly to the furnace. The temperature
of the drying kiln is about 200 °C (400 °F) and the drying
kiln exhaust is drawn directly into the reverberatory
furnace or ventilated to a control device., From the rotary
drying kiln, the feed is either dropped into the top of the
furnace through a charging chute, or fed into the furnace
at fixed intervals with a hydraulic ram. In furnaces that
use a feed chute, a hydraulic ram is often used as a stoker
to move the material down the furnace.
Reverberatory furnaces are used to produce a soft
(nearly pure) lead product and a lead-bearing slag. This is
done by controlling the reducing conditions in the furnace
so that lead components are reduced to metallic lead bullion
while at the same time the alloying elements (antimony, tin,
arsenic) in the battery grids, posts, straps, and connectors
are oxidized and removed in the slag. The reduction of
PbSO4 and PbO is promoted by the carbon-containing coke
added to the charge material:
PbSO4 + C -» Pb + CO2 + SO2
2PbO + C - 2Pb + CO2
2-17
-------
The PbSO4 and PbO also react with the alloying elements
to form lead bullion and oxides of the alloying elements
which are removed in the slag.19
The molten lead collects in a pool at the lowest part
of the hearth. Slag collects in a layer on top of this pool
and retards further oxidation of the lead. The slag is made
up of molten fluxing agents such as iron, silica, and lime,
and typically has significant quantities of lead.18
Slag is usually tapped continuously and lead is tapped
intermittently.18 The slag is tapped into a crucible. The
slag tap and crucible are hooded and vented to a control
device. Reverberatory furnace .slag usually has a high lead
content (as much as 70 percent by weight6) and is used as
feed material in a blast or electric furnace to recover the
lead content. Reverberatory furnace slag may also be rerun
through the reverberatory furnace during special slag
campaigns before being sent to a blast or electric
furnace.18
Lead may be tapped into a crucible or directly into a
holding kettle. The lead tap is usually hooded and vented
to a control device.
2.2.5.2 Blast Furnaces. A blast furnace (figure 2-7)
is a vertical furnace that consists of a crucible with a
vertical cylinder affixed to the top. Furnace diameters
range from 0.7 to 1.2 m (2 to 4 ft) and heights from 2.4 to
3.0 m (8 to 10 ft).18 The crucible is refractory-lined and
the vertical cylinder consists of a steel water-jacket.
Oxygen-enriched combustion air is introduced into the
furnace through tuyeres located around the base of the
cylinder.
Charge materials are pre-weighed to ensure the proper
mixture and then introduced into the top of the cylinder
using a skip hoist, a conveyor, or a front-end loader. The
charge fills nearly the entire cylinder. Charge material is
added periodically to keep the level of the charge at a
consistent working height while lead and slag are tapped
from the crucible.
2-18
-------
Charge Hopper
Exhaust Offtake to Afterburner
Charge
Cool Water
Lead Spout
Lead Well and Siphon
Working Height
of Charge
2.4 to 3.0 m
Diameter at Tuyeres
••— 68 to 120cm —»
Hot Water
Cool Water
Jigure 2-7
-rcss-seccion of cyp:.cal blast:
2-19
-------
Coke is added to the charge as the primary fuel,
although natural gas jets may be used to start the
combustion process. Once started, combustion is self-
sustaining as long as there is sufficient coke in the charge
material. Combustion occurs in the layer of the charge
nearest the tuyeres.
At smelters that operate only blast furnaces, the
lead-bearing charge materials may include broken battery
components, drosses from the refining kettles, agglomerated
flue dust, and lead-bearing slag. A typical charge over
one hour may include 4.4 Mg (4.8 tons) of grids and paste,
0.3 Mg (0.3 tons) of coke, 0;1 Mg (0.1 tons) of calcium
carbonate, 0.06 Mg (0.07 tons) of silica, 0.4 Mg (0.5 tons)
of cast iron, and 0.2 Mg (0.2 tons) of rerun blast>furnace
slag, to produce 3.3 Mg (3.7 tons) of lead per hour. At
smelters that also have a reverberatory furnace, the charge
materials will also include lead-bearing reverberatory
furnace slag.
Blast furnaces are designed and operated to produce a
hard (high alloy content) lead product by achieving more
reducing furnace conditions than those typically found in a
reverberatory furnace. Fluxing agents include iron, soda
ash, limestone, and silica (sand). The oxidation of the
iron, limestone, and silica promotes the reduction of lead
compounds and prevents oxidation of the lead and other
metals.19 The soda ash enhances the reaction of PbSC>4 and
PbO with carbon from the coke to reduce these compounds to
lead metal.20
The lead tapped from a blast furnace has a higher
content of alloying metals (up to 25 percent) than lead
produced by a reverberatory furnace. In addition, much less
of the lead and alloying metals are oxidized and removed in
the slag, so the slag has a low metal content (e.g., 1 to
3 percent1^) and frequently qualifies as a nonhazardous
solid waste.
Because air is introduced into the blast furnace at the
tuyeres, blast furnaces are operated at positive pressure.
2-20
-------
The operating temperature at the combustion layer of the
charge is between 1,200 and 1,400 °C (2,200 and 2,600 °F),
but the temperature of the gases exiting the top of the
charge material is only between 400 and 500 °C (750 and
950 °F).
The molten lead collects in the crucible beneath a
layer of molten slag. As in a reverberatory furnace, the
slag inhibits the further oxidation of the molten metal.
Lead is tapped continuously and slag is tapped
intermittently, slightly before it reaches the level of the
tuyeres. If the tuyeres become blocked with slag, they are
manually or automatically "punched" to clear the slag. A
sight glass on the tuyeres allows the furnace operator to
monitor the slag level and ensure that they are clear of
slag.
At most facilities, the slag tap is temporarily sealed
with a clay plug, which is driven out to begin the flow of
slag from the tap into a crucible. The slag tap and
crucible are enclosed in a hood, which is vented to a
control device.
A weir dam and siphon in the furnace are used to remove
the lead from beneath the slag layer.^ Lead is tapped from
a blast furnace into either a crucible or directly to a
refining kettle designated as a holding kettle. The lead in
the holding kettle is kept molten before being pumped to a
refining kettle for refining and alloying. The lead tap on
a blast furnace is hooded and vented to a control device.
2.2.5.3 Rotary Furnaces. Rotary furnaces (sometimes
referred to as rotary reverberatory furnaces) (figure 2-8}
are used at only a few secondary lead smelters in the
United States. However, several recently constructed
smelters have rotary furnaces. Rotary furnaces have two
advantages over other furnace types: it is easier tc adjust
the relative amount of fluxing agents because the furnaces
are operated on a batch rather than a continuous basis, and
they achieve better mixing of the charge materials than do
blast or reverberatory furnaces.
2-21
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Hygiene Hood
Rotaiy Furnace Shell /
Drive Train
Figure 2-8. Side view of a typical rotary
reverberator*/ furnace .
2-22
-------
A rotary furnace consists of a steel drum that is
1.8 to 4.5 m (6 to 14 ft) in diameter and 2.5 to 6 m (8 to
19 ft) in length.18 The steel drum is refractory-lined and
mounted on rollers. Variable-speed motors are used to
rotate the drum. An oxygen-enriched natural gas or fuel oil
jet at one end of the furnace heats the charge material and
the refractory lining of the drum. The connection to the
flue is located at the same end as the jet.
A sliding door at the end of the furnace opposite from
the jet allows charging of material to the furnace. Charge
materials are typically placed in the furnace using a
retractable conveyor or charge bucket, although other
methods are possible.
As noted, rotary furnaces are operated on a batch
basis. Each batch takes 5 to 12 hours to process, depending
on the size of the furnace. Like reverberatory furnaces,
rotary furnaces are operated at a slight negative pressure.
Lead-bearing raw materials charged to rotary furnaces
include broken battery components, flue dust, and drosses.
Rotary furnaces can use the same lead-bearing raw materials
as reverberatory furnaces, but they produce slag that is
relatively free of lead, less than 2 percent.21 As a
result, a blast furnace is not needed for recovering lead
from the slag, which can be disposed of as a nonhazardous
waste.
Fluxing agents for rotary furnaces may include iron,
silica, soda ash, limestone, and coke. The fluxing agents
are added to promote the conversion of lead compounds to
lead metal. The coke is used as a reducing agent rather
than as a primary fuel. A typical charge may consist of
11 Mg (12 tons) of wet battery scrap, 0.7 Mg (0.8 tons) of
soda ash, 0.5 Mg (0.6 tons) of coke, and 0.5 Mg (0.6 tons)
of iron. This charge will yield approximately 8 Mg (9 tons)
of lead product.21 The lead produced by rotary furnaces is
a semi-soft lead with an antimony content somewhere between
that of lead from reverberatory and blast furnaces.
2-23
-------
Lead and slag are tapped from the furnace at the
conclusion of the smelting cycle. The rotation of the
furnace is halted during these operations. Lead and then
slag are tapped into crucibles from a single taphole located
at the edge of the furnace shell. Slag may also be removed
through the charging door. Preliminary dressing may also be
performed in rotary furnaces, with the drosses being removed
through the charging door. Lead and slag tapping operations
are hooded and vented to control devices.
2.2.5.4 Electric Furnaces. An electric furnace
consists of a large, steel, kettle-shaped container that is
refractory-lined (figure 2-9). A cathode extends downward
into the container and an anode is located in the bottom of
the container. Second-run reverberatory furnace slag is
charged into the top of the furnace. Lead and slag are
tapped from the bottom and side of the furnace,
respectively. A fume hood covering the top of the furnace
is vented to a control device.22
In an electric furnace, electric current flows from the
cathode to the anode through the scrap charge. The
electrical resistance of the charge causes the charge to
heat up and become molten. There is no combustion process
involved in an electric furnace as there is in a blast or
reverberatory furnace.2 2
There is only one electric furnace in operation in the
U. S. secondary lead industry. It is used to process
second-run reverberatory furnace slag, and it fulfills the
same role as a blast furnace used in conjunction with a
reverberatory furnace. However, the electric furnace has
two advantages over a blast furnace. First, because there
are no combustion gases, ventilation requirements are much
lower than for blast or reverberatory furnaces. Second, the
conditions inside the electric furnace are more reducing
than a blast furnace and the electric furnace produces a
glass-like, nearly lead-free slag that is nonhazardous.
2-24
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2.2.6 Refining
Refining consists of removing impurities and adding
alloying metals to the molten lead obtained from the
smelting furnaces to meet a customer's specifications.
Refining kettles are used for the purifying and alloying of
molten lead.
The exact number of refining kettles in use is not
known/ but a typical secondary lead smelter operates 5 to
14 kettles, depending on the overall size of the smelter.
There are an estimated 170 refining kettles operating at
secondary lead smelters.
A refining kettle is an open-top, kettle-shaped
container that may hold from 18 to more than 225 Mg (20 to
250 tons) of lead and is constructed of cast iron or
steel.^8 Tne kettle is seated in a refractory-lined furnace
and indirectly heated from below with a natural gas- or oil-
fired burner (figure 2-10). Consequently, combustion gases
do not come in contact with the molten lead and are
exhausted through a separate stack. Refining kettles are
typically covered with cabinet-type hoods that are vented to
an air pollution control device.
Lead is charged to the refining kettle as either molten
lead or as cooled lead bullion. Molten lead may be tapped
directly from a smelting furnace or mechanically pumped from
another refining kettle. Reagents and alloying metals are
added to the refining kettle and an agitator is used to mix
them into the molten lead. Impurities are removed as
drosses, which collect on the surface of the molten lead.
The specific impurities removed are dependent on the
reagents used and the temperature of the molten lead, which
is adjusted to promote certain reactions.18
Drosses are usually skimmed from the surface of the
molten lead by a worker using a shovel or similar
instrument. Automatic dressing machines are available but
have not yet been adopted at many smelters in the
United States. Drosses removed from the refining kettle are
placed in core boxes or drums. Certain dross zypes
2-26
-------
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(antimony, arsenic, etc.) are recycled to the smelting
furnace for recovery of their lead and alloy metals. Other
types of drosses, such as copper or zinc drosses, may be
sold rather than recycled at the smelter.18
A separate mobile dressing hood is often used during
drossing to capture emissions. The dressing hood usually
covers the container into which the drosses are placed.
2.2.7 Casting
After the lead metal has been refined and alloyed,
molten lead is pumped from the refining kettle into a mold
for 2,000 Ib hogs, or to a casting machine for casting into
65 Ib ingots. Other shapes and sizes are possible but are
less common. Casting machines usually use water-cooled
molds to harden the lead quickly. Casting operations are
usually not hooded or vented to a control device.
2.2.8 Electrowinning
Electrowinning is an emerging technology that is being
developed as an alternative to conventional smelting.
However, as noted above, this technology has not yet been
proven to be industrially feasible.
Electrowinning uses titanium anodes coated with
insoluble lead dioxide (PbO2) and cathodes of corroding
grade lead to recover lead from lead battery paste. The
lead battery paste is prepared for electrowinning by
leaching with (NH4)2CO3 and ammonium bisulfite f(NH4)2HSO3]
to convert PbSO4 and PbO into PbC03, which is acid-soluble.
The PbCO3 is dissolved in fluorosilic acid (I^SiFs), which
serves as the electrolyte solution. The anode and cathode
are immersed in the electrolyte solution and an electric
current is passed between them. Lead dissolved in the
electrolyte is deposited on the cathode in the form of
nearly pure (99.99 percent) lead metal.11/12
Electrowinning is intended to replace smelting furnaces
that are used to reduce lead compounds from battery pastes
to lead metal. A plant using electrowinning would replace
nearly all of its smelting furnaces with reaction vessels
and electrolytic cells. Refining kettles would still be
2-28
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required for melting lead metal grids and posts, casting
lead anodes and ingots, and alloying lead to customer
specifications. A small rotary smelting furnace would still
be used for recycling flue dusts and drosses.23
The reduction in combustion processes at this type of
plant would significantly reduce the potential for air
emissions and, therefore, the need for the baghouses and
scrubbers found at conventional secondary lead smelters. A
mist eliminator could be used for the battery breakers, as
is done at conventional smelters, and wet scrubbers could be
used for the reaction vessels. In addition, the decreased
use of smelting furnaces would also significantly reduce
waste slag by-products.23
2.3 EMISSIONS AND FACTORS AFFECTING EMISSIONS
Hazardous air pollutants and criteria pollutants are
emitted from secondary lead smelters as (1) process
emissions from the main smelting furnace exhaust,
(2) process fugitive emissions from smelting furnace
charging and tapping and lead refining, and (3) fugitive
dust emissions from materials storage and handling and
vehicle traffic. This section describes typical emissions
and the factors that influence the magnitude of these
emissions. Combustion gases from refining kettle heaters do
not contain HAP's, so these emissions are not included in
this discussion.
Estimates of typical process and process fugitive
emissions are based on the results of an EPA-sponsored
testing program. Detailed results of this testing program
are presented in chapter 3.0. Estimates of typical fugitive
dust emissions are based on published emission factors, and
the development of these estimates is described in
chapter 4.0.
2.3.1 Process Emissions
Process emissions (i.e., those emitted from the
smelting furnace's main exhaust) contain metal HAP's,
organic HAP's, hydrochloric acid (HC1), and chlorine (C12).
Process emissions also contain dioxins/furans and cri~aria
2-29
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pollutants, including particulate matter (PM), volatile
organic compounds [expressed as total hydrocarbons (THC)],
carbon monoxide (CO) and SO2- Metal HAP's are found in the
PM fraction of emissions and organic HAP's in the THC
fraction of emissions. Sulfur dioxide, like HC1, is emitted
as an acid gas.
2.3.1.1 Metal HAP's and PM. All smelting furnaces are
sources of metal HAP's and PM. The metal HAP's are
predominantly compounds of lead, antimony, and arsenic, with
lesser amounts of compounds of manganese, cadmium, nickel,
and mercury. The quantity and quality of metal HAP and PM
emissions are independent of smelting furnace type and
configuration.
Lead compounds constitute about 70 percent by%weight of
total metal HAP emissions. Uncontrolled emissions are on
the order of 36 megagrams per year (Mg/yr) [40 tons per year
(tpy)], for a smelter of about 50,000 Mg/yr (55,000 tpy)
lead production capacity, but controlled emissions are
typically less than 1 Mg/yr (1 tpy). Uncontrolled PM
emissions from a 50,000 Mg/yr smelter are about 2,700 Mg/yr
(3,000 tpy), but controlled emissions are about 1.5 Mg/yr
(1.6 tpy). Metal HAP's are about 40 percent by weight of
controlled PM emissions; the remaining 60 percent are poorly
characterized but are believed to be primarily mineral
compounds and "soot."
2.3.1.2 Organic HAP's. THC. and CO. Organic HAP
emissions from smelting furnaces typically consist of
varying amounts of carbon disulfide, 1,3-butadiene, methyl
chloride, benzene, styrene, toluene, and formaldehyde. The
quantities of organic HAP, THC, and CO emissions are
dependent on furnace type. Table 2-2 summarizes the organic
HAP, THC, and CO emissions from the major furnace
configurations.
Blast furnaces are substantially greater sources of
organic HAP and related emissions than are reverberatory or
rotary furnaces. Low exhaust temperatures from the charge
column [about 430 °C (800 °F)] result in the formation cf
2-30
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TABLE 2-2. SUMMARY OF TYPICAL UNCONTROLLED ORGANIC
EMISSIONS FROM SMELTING FURNACES (Mg/yr)
Smelting furnace
type
Blast
Rotary
Reverberatory
Reverberatory/ blast
with combined flow
Electric
Organic
HAP's
100
6
N/A
1
N/A
THC
280
34
8
2
N/A
CO
1,800
20
8
12
10
N/A = No data available.
2-31
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products of incomplete combustion from the organic material
in the feed material. Uncontrolled organic HAP emissions
from a 50,000 Mg/yr blast furnace that charges broken
battery components are about 100 Mg/yr (110 tpy), depending
on furnace size. Uncontrolled organic HAP emissions may be
somewhat less for a blast furnace that charges only
reverberatory furnace slag as the lead-bearing feed material
because this material should have a lower organic content
than broken battery components.
Uncontrolled CO and THC emissions from a typical blast
furnace are about 1,800 Mg/yr (2,000 tpy) and 280 Mg/yr
(310 tpy), respectively. Organic HAP emissions are about
20 percent, by weight, of the THC emissions from a blast
furnace.
Controlled blast furnace organic HAP, CO, and THC
emissions are dependent on the add-on controls that are
used, which may be anywhere from 80 to 99 percent effective
at reducing emissions. (Emission control techniques are
described in chapter 3.0).
Rotary and reverberatory furnaces have much higher
exhaust temperatures than blast furnaces, about 980 to
1,200 °C (1,800 to 2,200 °F), and have much lower organic
HAP, CO, and THC emissions because of more complete
combustion. Organic HAP emissions from a typical rotary
furnace (15,000 Mg/yr capacity) are about 6 Mg/yr (7 tpy)
with no add-on controls. Carbon monoxide and THC emissions
are about 20 Mg/yr (22 tpy) and 34 Mg/yr (38 tpy),
respectively. The majority of these emissions occur during
furnace charging when the furnace's burner is cut back and
the temperature is reduced. Emissions drop off sharply when
charging is completed and the furnace is brought to normal
operating temperature.
Organic emissions from reverberatory furnaces are even
lower than those from rotary furnaces because reverberatory
furnaces are operated continuously rather than on a batch
basis. The peaks in organic emissions from rotary furnaces
that occur just after charging are not present in
2-32
-------
reverberatory furnaces because of the continuously high
exhaust temperature. Carbon monoxide and THC emissions are
about 8 Mg/yr (9 tpy) and 8 Mg/yr (9 tpy), respectively, for
a typical reverberatory furnace. No data are available on
organic HAP emissions from a reverberatory furnace alone,
but the ratio of organic HAP's to THC is probably similar to
that of a rotary furnace.
Organic emissions from collocated reverberatory and
blast furnaces are dependent on how the process emission
streams from the two furnaces are controlled. If the two
furnaces exhaust through independent stacks, then organic
emissions are essentially the same as those of the blast and
reverberatory furnaces described above. However, if the
blast furnace emissions are combined with the hot exhaust
gases from the reverberatory furnace prior to cooling, then
emissions will be more similar to those of a reverberatory
furnace. The organic compounds in the blast furnace exhaust
will be more completely destroyed by the hot reverberatory
furnace exhaust at a combined temperature of about 930 °C
(1,700 °F) . Organic HAP emissions from a combined
reverberatory and blast furnace are less than l Mg/yr
(1 tpy). Carbon monoxide and THC emissions are about
12 Mg/yr (13 tpy) and 2 Mg/yr (2 tpy), respectively.
No data are available for organic HAP or THC emissions
from the electric smelting furnace. However, the electric
smelting furnace processes only reverberatory furnace slag,
which is essentially free of organic material and,
therefore, it should have very low organic HAP and THC
emissions. Typical CO emissions from the electric smelting
furnace are about 10 Mg/yr (11 tpy).24 These low CO
emissions indicate complete combustion, supporting the
presumption that emissions of organic HAP's and THC from the
electric smelting furnace are low.
2.3.1.3 Hydrochloric Acid. Chlorine, and Sulfur
Dioxide. All smelting furnaces that process broken
batteries are potential sources of HC1, Cl2, and SO2
emissions. The polyvinyl chloride (PVC) plastic separators
2-33
-------
in the batteries are the chlorine source for HC1 and C12
emissions. Although relatively high HC1 emissions were
measured from some furnaces, very little Cl2 was present.
Emissions of HCl vary by furnace type. Blast and rotary
furnaces have much lower emissions of HCl [less than 1 Mg/yr
(1 tpy) per furnace] than reverberatory furnaces [about
100 Mg/yr (110 tpy)]. Chlorine emissions are less than
0.1 Mg/yr (0.1 tpy) from blast and rotary furnaces and are
2.5 Mg/yr (2.7 tpy) from reverberatory furnaces.
Blast and rotary furnaces are operated with limestone
or soda ash added to the feed material as a fluxing agent to
promote the reduction of lead compounds to lead metal and to
promote the removal of impurities through slagging. These
fluxing agents also react with chlorine to form calcium
chloride (CaCl2) or sodium chloride (NaCl) salts and prevent
the chlorine from being emitted as HCl. Reverberatory
furnaces typically do not add these fluxing agents to the
feed material and, therefore, have higher uncontrolled HCl
emissions.
The one electric furnace in use is not a source of HCl
emissions because no battery components containing PVC
separators are processed in the furnace. This electric
furnace processes only slag from a reverberatory furnace to
which fluxing agents are added. Any chlorine present in the
slag would be bound as salt and not emitted as HCl.
The source of SC>2 in smelting furnace emissions is the
sulfur contained in the lead-sulfate paste found on the
battery grids. Emissions of SO2 are independent of smelting
furnace type but are influenced by whether or not paste
desulfurization is performed on the material charged to the
furnace. Uncontrolled emissions from a typical furnace
charging untreated battery components are between 1,500 and
2,500 Mg/yr (1,600 to 2,700 tpy), depending on furnace size.
Paste desulfurization can reduce SO2 emissions by as much as
80 percent.
2.3.1.4 Dioxins/Furans. Smelting furnaces are sources
of dioxins and furans and the quantity of emissions is
2-34
-------
dependent on furnace type. Blast furnaces are greater
sources of dioxin/furan emission than rotary or
reverberatory furnaces. Emissions of 2,3,7,8-
tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD), which is a HAP,
from a blast furnace controlled by an afterburner operating
at a temperature of 700 °C (1,300 °F) are about 0.07 gram
per year (g/yr). Emissions of 2,3,7,8-TCDD from a rotary
furnace are less than 0.002 g/yr. Estimates of 2,3,7,8-TCDD
emissions from reverberatory furnaces are unavailable, but
2,3,7,8-TCDD emissions from a blast and reverberatory
furnace with a combined flow are also less than 0.002 g/yr.
2.3.2 Process Fugitive Emissions
Process fugitive emissions contain metal HAP's and,
under limited circumstances, may also contain organic HAP's,
but do not contain HCl or Cl2-
2.3.2.1 Metal HAP's and PM. The largest sources of
process fugitive emissions are furnace charging, slag
tapping, and agglomerating furnace operation. Lesser
sources are lead tapping and kettle refining. Battery
breaking and lead casting have fewer emissions. Battery
breakers are mechanical devices rather than combustion
sources. The particles emitted by a battery breaker are
larger than those emitted by a combustion source and they
settle out of the air quickly. These particles are also
controlled by demister pads installed on most battery
breakers to control acid mist emissions. Lead casting is
not a substantial source of emissions because the molten
lead is well below the fuming temperature of lead.
Total uncontrolled metal HAP emissions from all process
fugitive sources at a typical smelter may be from 7 to
30 Mg/yr (8 to 32 tpy), depending on smelter capacity.
Uncontrolled PM emissions range from 18 to 75 Mg/yr (20 to
81 tpy). Controlled metal HAP and PM emissions are
typically less than 1 Mg/yr and 3 Mg/yr (1 tpy and 3 tpy),
respectively.
2.3.2.2 Organic HAP's and THC. Organic HAP's and THC
may be found in the process fugitive amissions stream zr~:n
2-35
-------
blast: furnace charging. Emissions result from an improper
balance between the ventilation rate for the hood over the
furnace charging chute and the off-take from the furnace top
to the afterburner, resulting in process emissions being
drawn into the process fugitive control system. The
escaping organic HAP and THC emissions may be as high as
53 Mg/yr (58 tpy) and 250 Mg/yr (280 tpy), respectively.
These estimates are based on measurements made at one
facility at which this problem was detected. Organic HAP
and THC emissions from a properly balanced system are less
than 0.5 Mg/yr (0.5 tpy) and 2 Mg/yr (2 tpy), respectively.
2.3.3 Fugitive Dust Emissions
Fugitive dust emissions contain metal HAP's and PM, but
not organic HAP's or HC1. Fugitive dust emissions^are
dependent on the size of the facility and the fugitive dust
controls and practices in place at each facility. These
emissions cannot be measured and can only be roughly
estimated using emission factors and facility specific data.
Estimated fugitive dust emissions are typically from 1 to
8 Mg/yr (1 to 9 tpy) of metal HAP's and 3 to 23 Mg/yr (3 to
25 tpy) of PM, taking into account facility size and the
fugitive dust controls that are typically in use at each
facility.
2-36
-------
2.4 REFERENCES
1. Economic Impact Analysis of the Secondary Lead Smelters
NESHAP (Draft Report). U. S. Environmental Protection
Agency. Research Triangle Park, North Carolina.
Publication No. EPA-453/D-94-010. February 1994.
p. 6.
2. Office of Policy, Planning and Evaluation,
U. S. Environmental Protection Agency. States' Efforts
to Promote Lead-Acid Battery Recycling. Prepared for
the Office of Solid Waste, U. S. Environmental
Protection Agency. November 1991. 53 pp.
3. Executive Office of the President, Office of Management
and Budget. Standard Industrial Classification Manual,
1987. Springfield, Virginia. National Technical
Information Service. 1987. pp. 177-178.
4. Office of Air and Radiation. Compilation of Air
Pollutant Emission Factors, Volume 1: Stationary Point
and Area Sources, Fourth Edition. U. S. Environmental
Protection Agency. Publication No. AP-42. September,
1985. pp. 7.6-1 through 7.6-15.
5. Gruber, W. Lead-Acid Battery Recycling. El Digest.
January 1991. pp. 18 through 27.
6. Radian Corporation. Trip report for EPA visit to GNB,
Inc., Vernon, California. Prepared for the
U. S. Environmental Protection Agency. Research
Triangle Park, North Carolina. Contract
No. 68-02-4378. May 1991. 15 pp. plus attachments.
7. Lead-Acid Battery Manufacture - Background Information
for Proposed Standards. U. S. Environmental Protection
Agency. Research Triangle Park, North Carolina.
Publication No. EPA-450/3-79-028a. November 1979.
pp. 3-10 to 3-11.
8. Larrabee, D. A. Lead. In: U.S. Industrial Outlook
1991. Washington, D.C., U. S. Department of Commerce,
International Trade Administration. 1991. pp. 15-11
to 15-12.
9. Smith, Bucklin & Associates, Inc., Market Research and
Statistics Division. 1990 National Recycling Rate
Study. Prepared for Battery Council International.
Chrcago, Illinois. May 1992. 10 pp.
2-37
-------
10. Rives, G. D., and A. J. Miles, Radian Corporation.
Control of Arsenic Emissions from the Secondary Lead
Smelting Industry - Technical Document. Prepared for
U. S. Environmental Protection Agency. Research
Triangle Park, North Carolina. May 1985. pp. 2-5
through 2-7.
11. Lee, A. Y., E. R. Cole, Jr., and D. L. Paulson.
Electrolytic Method for Recovery of Lead from Scrap
Batteries: Scale-up Study Using 20-Liter
Multielectrode Cell. Bureau of Mines, U. S. Department
of the Interior. Washington, D.C. Report of
Investigations No. 8857. 1987. 20 pp.
12. Phillips, T. A. Economic Evaluation of an Electrolytic
Process to Recover Lead from Scrap Batteries. Bureau
of Mines, U. S. Department of the Interior.
Washington, D.C. Information Circular No. 9071. 1986.
19 pp.
13. Memorandum from Froiman, G., Chemical Engineering
Branch, U. S. Environmental Protection Agency, Office
of Pesticides and Toxic Substances, to Brooks, E.,
Chemical Control Division, U. S. Environmental
Protection Agency. Office of Pesticides and Toxic
Substances. August 14, 1990. Substitute Technology
for Lead Smelting.
14. Kawalec, J. A Modern and Low-Pollutant Secondary Lead
Smelter to Be Set Up in Hungary. In: Hazardous Waste
Detection, Control, Treatment: Proceedings of the 1987
World Conference on Hazardous Waste. R. Abbou, ed.
Budapest, Hungary. Elsevier Science Publishers B.V.
October 25-27, 1987. pp. 1263 through 1274.
15. Cooperative Assessment Program Manual for the Secondary
Lead Smelting Industry. Washington, D.C. Occupational
Safety and Health Administration. 1983. pp. IV-4 and
IV-A4.
16. Strait, R., S. Walata, and B. Newman, Alliance
Technologies. Addendum to Secondary Lead Smelter
Analysis Contained in the March 1990 Cost Assessmenr of
Regulatory Alternatives for Lead National Ambient Air
Quality Standards. Prepared for the U.S. Environmental
Protection Agency. Research Triangle Park, North
Carolina. EPA Contract No. 68-D1-0097. January 1991.
Report No. Ch-90-68. pp. 2-13 through 2-17.
2-38
-------
17. Radian Corporation. Trip report for
U. S. Environmental Protection Agency to Tejas
Resources, Inc., Terrell, Texas. Prepared for the
U. S. Environmental Protection Agency. Research
Triangle Park, North Carolina. EPA Contract
No. 68-D1-0117. January 1992. 11 pp. plus
attachments.
18. Smith, R. C., and M. R. Daley. Domestic Secondary Lead
Industry: Production and Regulatory Compliance Costs.
Bureau of Mines, U. S. Department of the Interior.
Washington, D.C. Information Circular No. 9156. 1987.
18 pp.
19. Prengaman, R. D. Reverberatory Furnace - Blast Furnace
Smelting of Battery Scrap at RSR, Inc., In: Lead-Zinc-
Tin '80. Cigan, J. M., T. S. Mackey, and T. J. O'Keefe
(eds.). Warrendale, Pennsylvania. The Metallurgical
Society of AIME. February 1980. pp. 985 through 1002.
20. Egan, R. C., M. V. Rao, and K. D. Libsch. Rotary Kiln
Smelting of Secondary Lead. In: Lead-Zinc-Tin '80.
Cigan, J. M., T. S. Mackey, and T. J. O'Keefe (eds).
Warrendale, Pennsylvania. The Metallurgical Society of
AIME. February 1980. pp. 953-973.
21. Lyons, L. A. and D. B. Gilbert. The New Secondary Lead
Smelter of Simsmetal Pty., Ltd., Brooklyn, Victoria,
Australia. In: Advances in Extractive Metallurgy and
Refining, Proceedings of the Third International
Symposium. M. J. Jones, ed. London, Institution of
Mining and Metallurgy. April 18-20, 1977. pp. 105
through 110.
22. Fontainas, L. J., and R. H. Maes. A Two-Step Process
for Smelting Complex Pb-Cu-Zn Materials. In: Lead-
Zinc-Tin '80, Cigan, J. M., T. S. Mackey, and T. J.
O'Keefe (eds.,). Warrendale, Pennsylvania. The
metallurgical Society of AIME. February 1980. pp. 375
through 393.
23. Lake Engineering Inc. Comparison of Ambient Air
Quality Impacts from Battery Recycling Plants:
Electrowinning Technology Versus Conventional Secondary
Lead Smelting. Report No. 499.11.15. Atlanta,
Georgia. December 1990. 15 pp.
24. METCO Environmental. Source Emissions Survey of
Quemetco Incorporated, Indianapolis, Indiana. October
1988. 19 pp. plus appendices.
2-39
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3.0 EMISSION CONTROL TECHNIQUES AND PERFORMANCE
This chapter describes the emission control techniques
used at secondary lead smelters and the performance of these
techniques in reducing emissions of metal HAP's, organic
HAP's, and acid gases. The discussion of control techniques
is organized by emission source (e.g., process sources,
process fugitive sources, and fugitive dust sources). The
discussion presents emissions data from controlled and
uncontrolled sources to demonstrate the performance
capability of the techniques. Table 3-1 summarizes the
specific emission source types, associated pollutants, and
applicable controls (including pollution prevention options)
that are discussed in this chapter.
Sections 3.1, 3.2, and 3.3 describe the performance of
emission control techniques for process emission sources,
process fugitive emission sources, and fugitive dust
emission sources, respectively. Section 3.4 describes
pollution prevention techniques that are being applied in
secondary lead smelting or that are being investigated as
alternatives to add-on emission control technology.
The performance data presented in this chapter for
process and process fugitive emission sources were collected
during an EPA-sponsored testing program at six secondary
lead smelters. A detailed summary of the data is presented
in appendix A. An overview of the testing program,
including a test matrix and descriptions of the testing
locations and test methods is included in appendix B.
3.1 EMISSION CONTROL TECHNIQUES FOR PROCESS SOURCES
Smelting furnace exhausts contain metal HAP's, organic
HAP's, and HC1/C12- Separate emission control techniques
are used for each class of pollutants. The following
3-1
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sections describe the performance of the applicable controls
for each pollutant class.
3.1.1 Metal HAP Control Techniques
Baghouses are currently the only technology used to
control metal HAP process emissions from smelting furnaces.
Many baghouses on smelting furnaces are followed by wet
scrubbers for acid gas control; however, no significant
additional removal of metal HAP's is achieved.
The main design and operating parameters that affect
baghouse performance are type of cleaning mechanism, bag
material, pressure drop, air-to-cloth (A/C) ratio, and
temperature. One of the most important parameters is
baghouse temperature. Several of the metal HAP's found in
smelting furnace emissions (including lead, antimony, and
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arsenic compounds) have detectable vapor pressures at
typical flue gas temperatures, and the gas stream must be
cooled in order to promote condensation of these metals for
removal in the baghouse. Cooling also reduces the volume of
gas that must be treated by the baghouse. However, cooling
below the acid dew-point can cause moisture condensation
that may cause bag-blinding and corrosion of the baghouse
and ductwork. Therefore, baghouses are typically operated
at a temperature of about 120 °C (250 °F) to promote metal
condensation while also preventing acid condensation. To
achieve a proper baghouse operating temperature, exhaust
gases are conditioned (cooled) prior to entering the
baghouse using one or more of the following methods:
• radiation using cooling loops;
• evaporation using water sprays; and
• dilution with ambient or sanitary air.
To evaluate the performance of baghouses in the control
of metal HAP's, the EPA measured lead emissions using EPA
reference method 12 at the inlets and outlets of the process
baghouses located at three secondary lead smelters. The
design and operating parameters of these baghouses are
summarized in table 3-2. These baghouses represent a range
of design and operating parameters ana are reprasaricac- ,-a z_
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industry. The control of lead was used as a surrogate for
the control of metal HAP's because lead compounds are the
most prevalent metal HAP and lead is found in the same
particle size fraction as other metal HAP's. Therefore, the
control efficiency for lead is indicative of the control
efficiency for total metal HAP's. The results of the EPA
lead measurements are summarized in table 3-3.
Compliance data were also obtained from smelter
operators and the States for lead concentrations in exhaust
from baghouses controlling smelting furnaces. These data
are summarized in table 3-4, along with the EPA-collected
data. Based on EPA test results and the compliance data
collected from industry, baghouses controlling lead smelting
furnaces are capable of achieving an outlet lead
concentration of less than 2.0 milligrams per dry standard
cubic meter (mg/dscm) [0.00087 grains per dry standard cubic
foot (gr/dscf)] (as a surrogate for metal HAP's) and greater
than 98 percent control of lead. Several of the smelters in
table 3-4 show lead emissions greater than 2.0 mg/dscm;
however, all but one of these smelters (RSR-IN) have shut
down operations and RSR-IN has upgraded it's air pollution
controls since these data were collected. Each of the
baghouses tested by the EPA was followed by a wet scrubber
for acid gas control. The lead concentration measured at
the scrubber outlet is also presented in table 3-3, above.
Some of the lead compliance data presented in table 3-4 were
also determined at the outlet to an acid gas scrubber.
However, the data collected by the EPA and provided by the
industry indicate that no additional metal control is
achieved across acid gas scrubbers that follow baghouses.
3.1.2 Organic HAP Control Techniques
Blast furnaces are the only smelting furnace type with
appreciable organic HAP emissions. Reverberator-/, rotary,
and electric furnaces do not have appreciable organic HAP
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organic HAP emissions have been applied in the secondary
lead industry.
The EPA is using THC as a surrogate pollutant for all
organic HAP's. The EPA has concluded from data collected at
sewage sludge incinerators that control of THC, which is
readily measured using standard EPA test methods, is
indicative of the control of total organic HAP's.24'25
Table 3-5 summarizes available data on uncontrolled and
controlled THC emissions from blast, reverberatory/blast,
reverberatory, and rotary furnaces.
Two control technologies are available for controlling
organic HAP emissions from blast furnaces: afterburners and
gas stream blending with a reverberatory furnace. If the
blast furnace is not collocated with a reverberatory
furnace, an afterburner is the only control option.
However, if the blast furnace is collocated with a
reverberatory furnace, gas stream blending is a more cost-
effective control technique for these facilities. These
technologies are discussed below.
The EPA also evaluated the effect of acid gas wet
scrubbers on THC and dioxin/furan emissions. The
dioxin/furan and THC data measured at the scrubber inlet and
outlets are presented below in the section on wet scrubbers.
3.1.2.1 Afterburners. Although afterburners are
installed primarily to control CO emissions, they also
achieve significant control of organic HAP emissions from
blast furnaces. Afterburner destruction efficiency is
directly related to afterburner temperature, residence time,
and turbulence. Increases in any of these parameters will
increase efficiency.
The EPA evaluated the efficiency of afterburners for
controlling THC (as a surrogate for organic HAP's) by
measuring uncontrolled and controlled THC emissions from the
blast furnace at Schuylkill Metals using standard EPA test
methods.
The afterburner controlling this blast furnace had a
retention time of 2.5 seconds and an average operating
3-8
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temperature of 700 oc (i/30o °F). It controlled a stream
with a volumetric flow rate of 160 dry standard cubic meters
per minute (dscmm) [5,800 dry standard cubic feet per minute
(dscfm)] and an uncontrolled THC concentration of about
3,000 to 3,500 parts per million by volume (ppmv), as
propane. No information was available on the turbulence of
the afterburner. This afterburner was typical of those
controlling blast furnaces in this industry; three blast
furnaces at other smelters are controlled by afterburners
with equal or higher temperatures but shorter residence
times and ten blast furnaces are controlled by afterburners
with lower temperatures and equivalent or shorter residence
times. The operating temperatures and residence times of
the afterburners currently in use are summarized iff
table 3-6.
The results of the EPA testing at Schuylkill Metals are
presented in table 3-5, above. During the second run, the
temperature controller on the afterburner malfunctioned,
causing a temperature drop and an increase in THC emissions.
The average destruction efficiency of the afterburner during
the first and third runs was 90 percent and the average
outlet THC concentration was 296 ppmv in the first run and
364 ppmv in the third run, as propane, corrected to
4 percent CO2 for dilution. The average afterburner
temperature was the same in the first and third runs [700 °C
(1300 °F)] and there were no differences in furnace or
afterburner operation during these two runs. Therefore, the
20-percent difference in THC concentration appears to be
representative of normal variation in outlet THC
concentration from a blast furnace controlled by this
technology.
The highest reported afterburner temperature in use by
a secondary lead smelter is 370 °C (1,600 °F) and the
residence time of this unit is 1.5 seconds. No emissions
data are available for this unit; however, previous EPA.
studies have demonstrated that the destruction efficiencv of
3-10
-------
TABLE 3-6.
OPERATING TEMPERATURES AND RESIDENCE TIMES
FOR AFTERBURNERS CONTROLLING BLAST
FURNACES AT SECONDARY LEAD SMELTERS
Facility ID
2
3
6
8
12
13
16
27
28
Furnace ID
1
2
3
4
1
1
2
1
1
1
2
1
1
1
Operating
temperature
670
670
670
670
650
730
730
650
870
590
590
700
590
650
Residence
time
(seconds)
N/Aa
N/A
N/A
N/A
N/A
0.7
0.7
N/A
r.s
2.5
2.5
2.5
N/A
2.0
a N/A = Residence time not available.
3-11
-------
an afterburner operated at 870 oc an(j a residence time of
0.7 seconds is 98 percent.27 Based on an uncontrolled THC
concentration of 3,500 ppmv, the predicted outlet THC
concentration from a blast furnace controlled with an
afterburner at 870 °C would be 70 ppmv.
In summary, the data available to the EPA indicate that
afterburners controlling organic HAP emissions from blast
furnaces are capable of achieving outlet THC concentrations
of 70 to 360 ppmv, depending on temperature and residence
time. These outlet THC concentrations correspond to organic
HAP destruction efficiencies of 98 and 90 percent,
respectively, and are achievable by afterburners currently
in use in the secondary lead industry.
3.1.2.2 Gas Stream Blending. Where blast furnaces are
collocated with reverberatory furnaces, gas stream blending
is an efficient option for controlling organic HAP
emissions. In this technology, the blast furnace exhaust,
which is a relatively cool and low-volume emission stream,
is combined with the larger-volume and hotter exhaust from
the reverberatory furnace. The organic compounds present in
the blast furnace exhaust are combusted by the heat and
turbulence of the reverberatory exhaust. Important design
and operating parameters in gas stream blending are the same
as those for afterburners: temperature, residence time, and
turbulence.
To evaluate the performance of gas stream blending in
controlling smelting furnace organic HAP emissions, the EPA
measured THC emissions from the combined blast and
reverberatory furnaces at East Penn Manufacturing Company.
The system tested by the EPA consisted of a blast furnace
with a volumetric flow rate of 110 dscmm (3,900 dscfm) and a
reverberatory furnace with a volumetric flow rate of
570 dscmm {20,000 dscfm). The streams were combined and
vented to a mixing chamber with a retention time of
2.5 seconds. The average temperature of the combined sir32m
at the inlet to the mixing chamber was 790 °C '-'1-160 °F%
3-12
-------
The average outlet temperature of the combined stream was
930 °C (1,700 °F). The THC concentration was measured at
the blast furnace outlet and at the mixing chamber outlet.
The THC concentration could not be measured at the
reverberatory furnace outlet, but the THC concentration is
presumed to be very low because of the high operating
temperature of this furnace. The results of this testing
are presented in table 3-5, above.
These test results demonstrate that gas stream blending
is capable of achieving a THC outlet concentration of
20 ppmv or less, as propane, at 4 percent CC>2, and
98 percent destruction of THC. Three other smelters that
operate collocated reverberatory and blast furnaces also use
this control technology.
3.1.2.3 Wet Scrubbers. Smelting furnaces typically
process feed material containing chlorinated hydrocarbon
compounds such as PVC plastic battery separators and,
therefore, are potential sources of dioxin/furan emissions.
In order to characterize these emissions from typically
controlled smelters, the EPA measured dioxin/furan emissions
at the baghouse outlets at three smelters. Because some
smelters, including those tested, are also controlled by
acid gas scrubbers, dioxin/furan emissions were also
measured at the scrubber outlets. At two of the smelters,
THC emissions were also measured at the scrubber inlets and
outlets. The design and operating parameters of these
scrubbers and the sources they control are described in
table 3-7, along with typical controlled SC>2 concentrations.
The concentrations of total dioxins and furans,
2,3,7,8-TCDD, and THC at the scrubber inlets and outlets are
presented in table 3-8.
Dioxin/furan emissions, measured as total dioxins,
total furans, and 2,3,7,8-TCDD, were highest from the blsst:
furnace at Schuylkill Metals. Emissions of 2,3,7,8-TCDD,
•
which is a HAP, were below the recognized de minimis
emission level of 0.5 g/yr for this pollutant.23 The
scrubber at: Schuylkill Metals reduced dioxin/zuran emiss
3-13
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by about 90 percent from the levels at the scrubber inlet.
No reductions in dioxin/furan emissions were measured across
the scrubbers at the other two smelters.
There was no significant reduction in THC emissions
across the scrubbers at which THC emissions were measured.
There is a slight reduction at East Penn Manufacturing, but
the difference in THC emissions at the inlet and outlet is
probably not significant relative to the variability in the
measurement methodology at lower THC concentrations. There
was no reduction in THC emissions across the scrubber at
Tejas Resources.
The data on dioxin/furan and THC emissions indicate
that acid gas scrubbers do not provide any significant
reduction in organic emissions and there is no significant
difference in organic emissions between smelters fitted with
scrubbers and those without.
3.1.3 Hydrochloric Acid and Chlorine Control Techniques
Smelting furnaces that process automotive-type
batteries are potential sources of HC1/C12 emissions from
the combustion of the PVC plastic separators found in these
batteries. Smelting furnace emissions of HC1 and Cl2 can be
controlled through fluxing with soda ash or limestone or by
wet acid-gas scrubbers. The EPA evaluated the performance
of these techniques at four smelters, three controlled by a
combination of fluxing and scrubbers and one controlled only
by fluxing. The configurations tested, the controls used,
and the results of the HC1/C12 emission measurements are
summarized in table 3-9.
3.1.3.1 Fluxing. The addition of soda ash or
limestone fluxing agents to the furnace charge material is
performed primarily to increase furnace productivity;
however, it also reduces HC1/C12 emissions. The soda ash
and limestone react with the available chlorides from the
PVC plastic battery separators in the feed material to form
salts (NaCl or CaCl2), which are stable at typical furnace
temoeratures. These salts are then removed from the furnaca
3-16
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during slagging. This process is described in more detail
in Section 3.4 of this chapter.
The HC1/C12 emissions data in table 3-8 show that
HC1/C12 emissions measured before the acid gas scrubber were
significantly higher from the reverberatory/blast furnace
than from the blast, rotary, or reverberatory furnaces.
These differences are due to whether fluxing agents (soda
ash or limestone) were added to the charge materials. Soda
ash was added to the blast furnace but not to the
reverberatory furnace in the reverberatory/blast
configuration at East Penn Manufacturing. Nearly all of the
PVC separators from automotive batteries were fed to the
reverberatory furnace. Soda ash or limestone was added to
each of the other furnaces tested. The typical fluxing rate
was about 25 kg of soda ash or limestone per Mg of broken
battery components charged to the blast furnaces and the
rotary furnace. The fluxing rate at RSR was between 10 and
20 kg of soda ash per Mg of feed material.
Emission levels of HC1/C12 were associated with the
amount of fluxing agents added to the furnace. Emissions of
HC1/C12 were lowest at Schuylkill Metals and Tejas
Resources. Emissions measured at the scrubber inlet were
less than 1 mg/dscm. Emissions were significantly higher at
East Penn and RSR: 273 mg/dscm and 117 mg/dscm,
respectively, at the scrubber inlet. At East Penn, the
HC1/C12 emissions are most likely due to the chlorides in
the reverberatory furnace charge materials because no soda
ash or limestone was added to the reverberatory furnace. At
RSR, the emissions were lower than at East Penn but greater
than at Schuylkill and Tejas. Soda ash is added to the
furnace at RSR in lesser amounts than at Schuylkill and
Tejas. Emissions were especially high during the first run
at RSR because the furnace had just been restarted and a
slag layer sufficient to control HC1/C12 emissions had not
yet formed.
The HC1/C12 emissions data demonstrate that these
emissions are ralacaci co the amount or fluxing agent.3 aac.ec
3-18
-------
to smelting furnaces. Emissions of HC1/C12 are
significantly higher from those furnaces that do not add
soda ash or limestone fluxing agents to the feed material.
The emissions data also demonstrate that HC1/C12 emissions
from all furnace types can be reduced by adding fluxing
agents to the charge materials.
3.1.3.2 Wet Scrubbers. Wet scrubbers are capable of
controlling HC1/C12 emissions, although they are installed
at secondary lead smelters to control SO2 emissions.
Important parameters that affect the performance of
scrubbers in controlling acid gases are the scrubber type,
scrubber media, and liquid-to-gas ratio.
To evaluate the performance of scrubbers in controlling
smelting furnace HC1/C12 emissions, the EPA measured
scrubber inlet and outlet HC1 and Cl2 concentrations at
three secondary lead smelters. The design and operating
parameters of these scrubbers are described in table 3-7,
above.
The uncontrolled and controlled HC1/C12 emissions data
from these tests are summarized in table 3-9, above. At the
blast furnace and rotary furnace smelter, average HC1/C12
concentrations were less than 1 mg/dscm (0.00044 gr/dscf) at
the scrubber inlet. At these lower concentrations, there
was no additional HC1/C12 control measured across the
scrubbers. These scrubbers were, however, effective in
controlling SO2- Therefore, the low HC1/C12 removal
efficiency of these scrubbers is likely due to the low inlet
loadings.
At the reverberatory/blast smelter, the HC1/C12
emissions at the scrubber inlet were substantially higher
than these at the other smelters because of the absence of
fluxing in the reverberatory furnace. The scrubber at this
facility achieved greater than 99 percent control of the
HC1/C12 emissions, and the outlet concentration was about
1 mg/dscm. The scrubber was capable of achieving the same
HC1/C12 emission level as fluxing. For those smelters that
do not wish to add fluxing agents to their furnaces, weu
3-19
-------
scrubbers are an equally effective alternative control
strategy.
3.2 EMISSION CONTROL TECHNIQUES FOR PROCESS FUGITIVE
SOURCES
Process fugitive sources of metal HAP emissions are
smelting furnace charging, lead tapping, slag tapping,
refining operations, agglomerating furnaces, and casting
machines. Blast furnace charging is also a potential source
of organic HAP emissions. Metal HAP emissions from process
fugitive sources are controlled by enclosing the source in a
hood and ventilating the hood to a baghouse or, in some
cases, a wet scrubber. Organic HAP emissions from blast
furnace charging are controlled through proper ventilation
of the blast furnace charging chute.
Most secondary lead smelters combine the emissions from
more than one process fugitive source and vent the combined
emissions to one or more sanitary baghouses. Process
fugitive emissions may also be combined with furnace process
emissions and controlled by the furnace process baghouse.
The following sections describe the performance of
hoods, baghouses, and wet scrubbers for the control of
process fugitive metal HAP emissions and the role of proper
ventilation in the control of organic HAP emissions from
blast furnace charging.
3.2.1 Hoods
The two most important factors in determining the
effectiveness of hoods in capturing process fugitive
emissions are the degree of enclosure and the face velocity.
The most effective and economical hood designs completely
enclose the source and have minimal openings. Openings
needed for access to the enclosed emission source should be
provided with doors whenever possible. Enclosure hoods
minimize the exhaust volume required and also minimize che
effect of possible crossdrafts.
Face velocity is the air speed at the hood openings
necessary to overcome opposing air currents and to prevent
contaminated air from flowing our of the hooci through ~ha
3-20
-------
openings. The Occupational Safety and Health Administration
(OSHA) recommends face velocities for hoods controlling
process fugitive emission sources at secondary lead smelters
to be in the range of 75 to 150 meters per minute (m/min)
(250 to 500 feet per minute [fpm]).29
The EPA visited 16 smelters during this study. The
process fugitive hoods observed during these visits were all
enclosure type hoods with doors over the access and
maintenance openings. The face velocities of the hoods
measured at one smelter were greater than the minimum
recommended by OSHA for these sources. Face velocity data
were not available or collected for hoods at other smelters,
but they are assumed to be comparable based on similarities
in hood design and ventilation system capacity.
3.2.2 Baqhouses
Baghouses are used to control metal HAP emissions from
nearly all process fugitive sources. The baghouse design
and operating parameters that affect performance are nearly
the same for process fugitive baghouses as for process
baghouses: cleaning mechanism, bag material, pressure drop,
and A/C ratio. Temperature is not as important a factor for
process fugitive baghouses as for process baghouses because
there is no potential for acid condensation within the
baghouse. Therefore, most process fugitive baghouses are
operated at ambient temperatures.
To evaluate the performance of baghouses in the control
of metal HAP's from process fugitive emission sources, the
EPA measured lead emissions at the inlets and outlets of six
process fugitive baghouses located at three secondary lead
smelters. The design and operating parameters of the
baghouses that were tested are summarized in table 3-10.
These baghouses represent a range of design and operating
parameters and are representative of the process fugitive
baghouses used in this industry. The control of lead was
used as a surrogate for the control of metal HAP's because
lead compounds are the most prevalent metal HAP and lead is
found in the same particle size fraction as other metal
3-21
-------
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HAP's. The results of the EPA lead measurements are
summarized in table 3-11.
The average lead concentration at the outlet of the six
baghouses tested was 0.83 mg/dscm (0.00036 gr/dscf) and all
baghouses were able to achieve a lead emission concentration
less than 2.0 mg/dscm (0.00087 gr/dscf). The No. 3 sanitary
baghouse at East Penn Manufacturing, however, had
substantially higher lead emissions (1.8 mg/dscm) and a
lower efficiency (70 percent compared to 95 to 99 percent)
than the other baghouses tested. The baghouse appeared to
be well-operated and well-maintained, and the pressure drops
across each cell of the baghouse were comparable to those
measured at the other baghouses. This baghouse did,
however, have a significantly lower inlet PM grain ^Loading
than the other baghouses, 8.4 mg/dscm of PM compared to a
range of 30.5 to 104 mg/dscm.
Data obtained from compliance tests provided by smelter
operators and the States demonstrate process fugitive
baghouse performance levels that are comparable to the level
demonstrated during the EPA-sponsored tests. The compliance
data obtained from the industry are summarized in
table 3-12, along with the EPA-collected data.
3.2.3 Wet Scrubbers
At three secondary lead smelters, wet scrubbers rather
than baghouses are used to control the process fugitive
emissions from refining kettles. The design specifications
of these scrubbers are summarized in table 3-13. No
performance data are available for these specific scrubbers,
but performance data are available for scrubbers controlling
grid casting machines and lead remelting pots at battery
manufacturing plants. These sources have emission stream
characteristics, including uncontrolled lead emissions,
similar to those from refining kettles.
The EPA measured the performance of low-energy
scrubbers controlling grid casting machines and lead
remelting pots in the development of emission standards for
lead-acid battery manufacturing promulgated in 1982. :o T^e
3-23
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EPA measured emissions from a grid casting machine
controlled by a Roto-Clone® impingement and entrainment
scrubber with a pressure drop of 5 inches of water and a
liquid-to-gas ratio of 2.6 liters per cubic meter (1/m3)
(20 gallons per 1,000 acf). Uncontrolled lead emissions
were 3 to 14 mg/dscm—comparable to the uncontrolled process
fugitive lead emissions measured by the EPA at secondary
lead smelters, which ranged from 6 to 83 mg/dscm.
Controlled lead emissions from the Roto-Clone® were 0.2 to
0.4 mg/dscm and collection efficiency was greater than
90 percent.
The EPA also measured emissions from lead remelting
kettles controlled by a cascade scrubber with a pressure
drop of 2 to 3 inches of water and a liquid-to-gas ratio of
0.53 to 0.70 1/m3 (4 to 5 gallon/1,000 acf). Uncontrolled
lead emissions were 175 to 293 mg/dscm, which are higher
than the uncontrolled process fugitive lead emissions
measured by the EPA at secondary lead smelters. Controlled
lead emissions from the cascade scrubber ranged from 2.2 to
4.3 mg/dscm and the collection efficiency was greater than
98 percent.30
The data from grid casting machines and remelting
kettles on controlled lead emissions and collection
efficiency indicate that scrubbers have the potential to
control refining kettle emissions to levels that are
comparable to the control achievable by a baghouse. Those
refining kettles currently controlled by a scrubber should
be able to meet an emission standard that is based on the
performance of a baghouse.
3.2.4 Blast Furnace Charging Ventilation
The THC testing performed at Schuylkill Metals
indicated that organic HAP emissions can escape through
blast furnace charging systems and, therefore, avoid
treatment in the afterburner. Schuylkill Metals uses a
rotating drum to charge feed material into the furnace
column. The drum is enclosed in a hood ventilated to the
process baghouse. The THC emission rara measured at.
3-23
-------
Schuylkill Metals was 4.6 kg/hr at the afterburner outlet,
but was 34 kg/hr at the stack, after the furnace charging
process fugitive emissions had been combined with the
process emissions. This increase indicated that about 30
kg/hr of THC and, therefore, substantial organic HAP's, were
bypassing the afterburner. These emissions were due to an
imbalance between the air flow rates for the hood over the
charging system and the off-take to the afterburner. These
emissions were eventually corrected by adjusting the dampers
controlling the relative ventilation rates between the
charging hood and the top of the blast furnace, although no
follow-up THC measurements were performed.
The EPA measured the THC emission rate in the charging
hood ventilation system at two additional blast furnaces in
order to better characterize potential THC emissions from
blast furnace charging hoods. Emissions were measured using
EPA reference method 25A over two 3-hour runs at each
facility. At the GNB facility in Columbus, Georgia, the
blast furnace is charged through a simple opening in the
side of the furnace that is enclosed in a hood. The THC
emission rates in the charging ventilation system at GNB
were 0.19 and 0.11 kg/hr (0.086 and 0.050 lb/hr).32 At the
Gulf Coast Recycling facility in Tampa, Florida, a similar
charge opening is enclosed in a hood but also has a door
over the charge opening that is opened only during charging.
The THC emission rates in the charging ventilation system at
this facility were 0.035 and 0.026 kg/hr (0.016 and
0.012 lb/hr).33
The THC emissions were substantially lower from the
furnace fitted with the door, but it could not be determined
if the difference was due to the door or simply normal
variation in emissions from these charging ventilation
systems. The THC emission rate from both furnaces was less
than 1 percent of the THC emissions from the charging chute
at Schuylkill Metals.
3-29
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3.3 CONTROL TECHNIQUES FOR FUGITIVE DUST EMISSIONS
Control of fugitive dust includes the control of
emissions from vehicle traffic on roadways, material storage
and handling, and furnace charge preparation. Area fugitive
emission control techniques include roadway paving, partial
and total enclosure of select process and storage areas, and
good housekeeping practices. Table 3-14 summarizes the
control strategies for the various fugitive dust emission
sources at secondary lead smelters.
Observations of operating lead smelters have shown that
when these controls are applied in a conscientious and
consistent manner, it is possible to achieve a level of
control at which there are no visible emissions from the
storage, handling, and processing areas of the smelter.
Moreover, equivalent levels of control can be achieved
regardless of whether the smelter is using partial
enclosures and good housekeeping or whether the smelter is
using total enclosures that are ventilated to a control
device.34/35
3.3.1 Paving
Paving is the covering of a surface subject to vehicle
traffic with either concrete, asphalt, or some other
consolidated material. Paving facilitates the control of
surface dust, which reduces the potential for re-entrainment
or transfer of dust to other areas by vehicle traffic.
Therefore, paved surfaces have fewer fugitive dust emissions
than unpaved surfaces.
3.3.2 Partial and Total Enclosure
Partial enclosures include three-sided material storage
bins and three-sided buildings that minimize wind erosion,
minimize drying of storage piles, and prevent crossdrafts
that may reduce the capture efficiency of hoods. Total
enclosure is defined as a building with a roof and walls
that extend from the roof-line to the ground on all sides of
the building, with openings only for doorways.
Totally enclosed area fugitive sources may be
ventilated ~o a baghousa. This may be the same baghouse
-------
TABLE 3-14.
SUMMARY OF FUGITIVE DUST EMISSION
CONTROL STRATEGIES
Emission source
Control strategy
Paved roadways
Unpaved roadways
Wind erosion from storage
piles
Material handling
Vacuuming
Sweeping and vacuuming
Low-pressure washing
High-pressure washing
Wet suppression and paving
Wet suppression
Partial enclosure
(three sides)
•i
Total enclosure
Wet suppression
Partial enclosure
(three sides)
Total enclosure
3-31
-------
used to control process fugitive sources such as refining
kettles and furnace tapping and charging. Performance data
for baghouses controlling lead emissions from building
ventilation are included in the presentation of data for
baghouses controlling process fugitive emissions in
section 3.2, above. If an enclosure is ventilated, a
minimum air exchange rate of 10 changes per hour is needed
for efficient capture and removal of fugitive emissions
released within the enclosure.36 A total enclosure that is
ventilated to a baghouse is estimated to be 90-percent
efficient in controlling area fugitive emissions from
material handling, storage piles, and smelting activities.37
3.3.3 Housekeeping
Housekeeping practices include wet suppression,, power
washing, and area vacuuming to control fugitive dust
emissions from storage areas, process areas, and plant yards
and roadways.
Wet suppression is the application of water to paved
and unpaved surfaces and storage piles to control dust.
When the surface material is wetted, dust is agglomerated
into larger particles that are less easily entrained by air
currents. Wet suppression can be accomplished manually or
by automatic sprinkler systems that use a timer to initiate
wetting. Chemical dust suppressants, surface active agents
(surfactants), and/or foaming agents can be added to water
to increase the efficiency of wet suppression and to
decrease the quantity of water needed.3** The use of wet
suppression, however, is limited in freezing weather because
of the potential for ice formation.
Wet suppression can be effective in controlling area
fugitive emissions. Reported values for the efficiency of
wet suppression for fugitive particulate emission control
range from 45 to 100 percent, depending on the emission
source and the frequency of wetting.39 Continuous wetting
of a paved roadway achieved a 93-percent reduction in
measured lead emissions compared to a dry roadway at a
secondary lead smelter.40 Chemical suppressants appiiec -.:
-------
unpaved roads at the rate of 1.3 liters per square meter
(0.3 gallons per square yard) retain an efficiency of
98 percent one week after application and 90 percent one
month after application, provided no new roadway dust is
deposited on the treated roadway.41 Chemical suppressants
that form a crust on undisturbed storage piles are
90-percent effective for up to 60 days in reducing wind
erosion emissions.41 However, data are not available on the
effectiveness of chemical suppressants on reducing emissions
from active storage piles or material handling.
Power washing is the application of jets of water to
paved surfaces at a sufficient pressure, typically 100 to
500 pounds per square inch (psi), to loosen lead-bearing
surface material and move it to a collection point,, such as
a sump or drain. Power washing is not appropriate for
unpaved surfaces because it will soften and remove the
roadway material. Power washing is 85-percent effective in
reducing surface lead dust loadings and, therefore,
emissions from paved surfaces.42 Power washing equipment
may also be used to wash vehicles before they leave certain
areas of the plant to prevent the transfer of lead-bearing
contaminants.
Runoff from wet suppression and power washing must be
collected and treated on-site in accordance with EPA
regulations for managing and treating stormwater runoff
(40 CFR 122, 123, 124).
Area vacuuming is the use of mobile units that use air
jets or brushes to loosen dust on paved surfaces; the dust
is then picked up by a vacuum and recovered in a filter.
Area vacuuming can reduce surface lead dust loadings by
83 percent and is, therefore, equivalent to power washing
for area fugitive emission control.42 Area vacuuming should
be distinguished from street sweepers, which rely primarily
on brushes rather than vacuums to collect the lead-bearing
material. Straet sweepers may actually contribute to
fugitive dust emissions by entraining dust.43
3-33
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3.4 POLLUTION PREVENTION/SOURCE REDUCTION CONTROL OPTIONS
Pollution prevention/source reduction is the use of
process modifications or alternative processing technologies
to reduce air pollutant emissions from the source rather
than through the use of add-on controls. Several pollution
prevention and source reduction control options have been
investigated or applied to the secondary lead smelting
industry.
3.4.1 Metal HAP Emission Prevention Through Electrowinnincr
Electrowinning has the potential to replace smelting
furnaces for converting lead compounds to elemental lead and
reducing HAP emissions associated with conventional smelting
furnaces. This process is described in chapter 2.0.
However, electrowinning has not been demonstrated on a
commercial basis anywhere in the world.
3.4.2 Organic HAP and Hydrochloric Acid Emission Prevention
Through Plastic Removal
Plastic separators and hard rubber battery cases are
sources of organic HAP and HC1/C12 emissions from smelting
furnaces. Technology is available to remove plastic
separators—but not hard rubber—from furnace feed
materials. Removal of PVC separators and hard rubber may
decrease organic HAP and HC1 emissions, but no data are
available to confirm this. Recycling options for the
recovered materials are limited. The recovered materials
may be used in asphalt roofing shingles; however, recovered
materials that are not recycled need to be disposed of as
solid waste or, if contaminated with lead, as hazardous
waste.
3.4.3 Hydrochloric Acid Emission Prevention Through Use of
Fluxing Agents
When added to the furnace feed material, soda ash and
limestone bind chlorides into the slag as NaCl or CaCl2
salts and reduce the formation and emission of HC1/C12
during" smelting. The EPA has analyzed the reactions rha-c
should take place in the furnaces at high temperatures to
account for this emission reduction. In the analysis, me
3-34
-------
main assumption is that the chemical reactions will proceed
in the direction of increasing entropy at typical furnace
temperatures (greater than 1,100 °C).
The source of chlorides in the furnace is the PVC
separators. However, polyethylene (which contains no
chlorides) has replaced PVC as a separator material in most
battery manufacturing.44 The amount of PVC in smelting
furnace feed material should decline as older batteries are
replaced with those that have other types of separators.
Polyvinyl chloride is a polymer chain, with the
repeated segment being:
H H
i i
i i
—c —c—
I I
I I
H Cl
The combustion products of this polymer are carbon dioxide
(CO2), water (H2O), HC1, and C12.
At lower temperatures, such as those found in the flue
duct, lead and chlorine will react to form PbCl2, which will
accumulate in the flue dust. Because flue dust is recycled
back to the furnace, chlorine will build up in the system
unless it is removed in the slag or emitted to the
atmosphere. When the PbCl2 is recycled back to the furnace,
the following reaction will occur at the high temperatures
found in the furnaces:
PbCl2 —> Pb + C12
If CaCO3 is present, it will preferentially react with the
available chlorine:
2CaCO3 + 2C12 —> 2CaCl2 + 2CO2 + O2
If HC1 is present from the combustion, the chemical reaction
in the furnace is:
CaCC>3 + 2HC1 —> CaCl2 + 2C02 + 2H2O
Sulfates are present in the feed material as PbSO4. It is
possible that the CaCC>3 will have reacted with sulfatas zz
form calcium sulfate (CaSCU) before coming in contact with
the C12 or HC1. In this case, the chlorine will replace the
sulfate:
3-35
-------
+ C12 —> CaCl2 + SO2 + O2, or
CaSO4 + 2HC1 —> CaCl2 + SO2 + 2H2O
If the lead has reacted with chlorine and comes in contact
with the CaCO3 or CaSC>4 before breaking down, the reaction
is:
PbCl2 + CaC03 —> CaCl2 + PbCO3
PbCl2 + CaSO4 —> CaCl2 + PbSO4
For each of these reactions, analogous reactions occur when
Na2CO3 rather than CaCC>3 is added to the furnace:
2Na2CO3 + 2C12 —> 4NaCl + 2CO2 + O2
Na2CO3 + 2HC1 —> 2NaCl + CO2 + H2O
Na2SO4 + PbCl2 —> 2NaCl + PbSO4
Na2SO4 + C12 —> 2NaCl + SO2 + O2
2Na2S04 + 4HC1 —> 4NaCl + 2SO2 + 2H2O + O2
In each of these reactions, the products include a salt
in which the chlorides remain bound. These salts will
remain in the slag and are removed from the furnace in
normal slagging. Because the chlorides are bound into and
removed from the furnace in the slag, they cannot be emitted
as HC1 or C12.
3.4.4 Hydrochloric Acid Emission Prevention Through
Dechlorination of Flue Dust
Chlorides are found in the flue dust of secondary lead
smelters in the form of PbCl2. Because the flue dust is
recycled to the smelting furnace, the chlorides accumulate
in the system comprising the smelting furnace and baghouse.
If the chlorides are not removed from the system via the
slag, then they are eventually emitted to the atmosphere as
either C12 or HC1. These emissions can be prevented by
removing the chlorides from the flue dust before the flue
dust is recycled to the smelting furnace.
The same technology used to perform paste
desulfurization can be used to remove chlorides from flua
dust. Paste desulfurization is described more fully in
chapter 2.0. The flue dust is added to the paste that is tc
be processed in the paste desulfurization system. The flue
lust containing ?bCl2 is sixac with vauar tc fcr~ a slurry
3-36
-------
and is then mixed with Ha.2c°3 ^n a large reactor vessel.
The products of this reaction include solid PbCO3 and
dissolved NaCl. The PbCO3 is separated from the NaCl using
a filter press. The PbCO3 is returned to the smelting
furnace to recover the lead, and the water containing the
NaCl is sent to a wastewater treatment plant.
Excess unreacted Na2CC>3 is added to the smelting
furnace along with the treated flue dust and battery paste.
This excess Na2CO3 will also promote HC1 and Cl2 emissions
reductions through the same mechanisms described above for
fluxing agents. Dechlorination of flue dust is being used
by at least one secondary lead smelter and is reported to be
at least 80-percent effective in removing chlorides from the
flue dust.45/46
3-37
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3.5 REFERENCES
1. Source Emissions Survey of Quemetco, Incorporated.
City of Industry, California. File Number 90-91.
Metco International. June 1990. 17 pp.
2. Report of AB2588 Air Pollution Source Testing at the
GNB Incorporated, Metals Division, Los Angeles,
California. Engineering-Science, Incorporated.
November 14-20, 1990. 253 pp.
3. Master Metals Incorporated Cleveland, Ohio. Furnace
and Fugitive Baghouses Particulate, Sulfur Dioxide and
Lead Emission Evaluation. Envisage Environmental
Incorporated. March 12, 1991. 72 pp.
4. Summaries of Air Test Results for Interstate Lead
Company, Leeds, Alabama. June 1987, March 1988,
February 1989, and December 1989.
5. A Report of Source Testing for Particulate, Lead, and
S02 Performed at the General Smelting and Refining
Company Plant Located in College Grove, Tennessee.
Franklin S. Ward. February 8, 1992.
6. Compliance Test Report. Determination of Particulate,
Lead, Sulfur Dioxide Emissions and the Visual Opacity
of Emissions, Exide Corporation, Muncie, Indiana.
WW Engineering and Science. March 1993. 238 pp.
7. Source Emissions Survey of Quemetco, Incorporated
Process Stack and Sanitary Stack. City of Industry,
California. File Number 90-16. Metco Environmental.
March 1990. pp. 1 through 17.
8. Summaries of Air Test Results for GNB, Incorporated.
Frisco, Texas. 1987, 1990, and 1991.
9. Source Emissions Survey of Quemetco Incorporated.
Indianapolis, Indiana. File Number 88-141. Metco
Environmental. October 1988.
10. Report of Particulate/Lead/SO2 Emissions Tests for
Refined Metals Corporation. Memphis, Tennessee.
Environmental Monitoring Laboratories. July 25, 26,
and 29, 1991.
3-38
-------
11. Roy F. Western, Inc. Emission Test Report: HAP
Emission Testing on Selected Sources at a Secondary
Lead Smelter—Tejas Resources, Inc., Terrell, Texas.
Draft. Six Volumes. Prepared for the U. S.
Environmental Protection Agency. Research Triangle
Park, North Carolina. Contract No. 68-D1-0104.
December 1992.
12. Roy F. Weston, Inc. Emission Test Report: HAP
Emission Testing on Selected Sources at a Secondary
Lead Smelter—Schuylkill Metals Corporation, Forest
City, Missouri. Draft. Six Volumes. Prepared for the
U. S. Environmental Protection Agency. Research
Triangle Park, North Carolina. Contract No. 68-D1-0104.
January 1993.
13. Roy F. Weston, Inc. Summary of Results, Draft Data
Tables: HAP Emission Testing on Selected Sources at a
Secondary Lead Smelter—East Penn Manufacturing
Company, Lyon Station, Pennsylvania. Prepared' for the
U. S. Environmental Protection Agency. Research
Triangle Park, North Carolina. Contract
Nos. 68-D1-0104 and 68-D2-0029. May 1993.
14. Summary of Compliance Source Testing Program Data for
Particulate and Elemental Lead Emissions from Stack
No. 1: Blast Furnace Nos. 1 and 2 and Agglomeration
Furnace Baghouse—Sanders Lead Company, Troy, Alabama,
January 13, 1990.
15. Source Test Report. Source Emission Testing of the
Sanitary and Main Stack Exhausts at Revere Smelting and
Refining (RSR) Corporation, Middletown, New York.
A.E. Galson. Galson Project #GE-060. January 1991.
18 pp.
16. Stack Sampling Emission Report and Visible Emission
Tests—Gulf Coast Lead Company, Tampa, Florida. Air
Observations. February 1990. 28 pp.
17. Secondary Lead Smelter Arsenic, Cadmium, and Lead
Emissions, General Battery Corporation, Reading,
Pennsylvania. U. S. Environmental Protection Agency.
Research Triangle Park, North Carolina. EMB Report
No. 83-SLD-2. June 1983. p. 2-12.
18. Results of the October 3, 1991 Particulate, Lead, and
Visible Emission Compliance Test at the Gopher Smelting
and Refining Company. Intarpoll Laboratories,
Incorporated. Report Number 1-3428. October 15, 1991.
3-39
-------
19. Report of Air Emissions Tests for Refined Metals
Corporation Secondary Lead Smelter, Memphis, Tennessee.
Environmental Monitoring Laboratories. November 15
and 16, 1990. 48 pp.
20. Summary of Compliance Source Testing Program Data for
Particulate and Elemental Lead Emissions from Stack
No. 5: Blast Furnace Nos. 3 and 4 and Alloying
Operations Baghouse System—Sanders Lead Company, Troy,
Alabama. July 25, 1990.
21. Determination of Particulates, Metals, and Chlorides
Emissions from Reverberatory Furnace. A Compliance
Test for MoDNR Permit Conditions and New Source
Performance Standards. The Doe Run Company Resource
Recycling Division Buick Facility. Aeromat
Engineering. May 1992. 97 pp.
22. Particulate Emission Testing for Ross Metals,
Incorporated Rossville, Tennessee. Air Systems
Testing, Incorporated. October 3, 1990. 59 pp.
23. Report of Particulate/Lead/SO2 Emissions Tests for
Refined Metals Corporation. Beech Grove, Indiana.
Environmental Monitoring Laboratories. January 28, 29,
and 30, 1992.
24. Polta, R., J. Buresh, J. Rupprecht, and D. Quast.
Stack Sampling for THC and Specific Organic Pollutants
at MWCC Incinerators. Metropolitan Waste Control
Commission. St. Paul, Minnesota. Report
No. QC-91-217. July 1991. 91 pp.
25. Memorandum from Palmer, B., Radian Corporation, to
Streit, G., EPA/ISB. May 20, 1994. Documentation of
MACT floor emission limits for HAP emissions from
smelting furnaces and process fugitive sources at
secondary lead smelters.
26. Pacific Environmental Services, Inc. Draft Final
Report—Test Preparation, Emission Testing, and Total
Hydrocarbon Testing at a Secondary Lead Smelter: RSR
Corporation, Middletown, NY. Prepared for the U. S.
Environmental Protection Agency. Research Triangle
Park, North Carolina. Contract No. 68-D2-0162.
September 1993. 36 pp. plus appendices.
27. Memorandum and attachments from Farmer, J.R., U. S.
Environmental Protection Agency, to distribution.
Thermal Incinerators and Flares. Augusr 22, 1330.
29 pp.
3-40
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28. Documentation of De Minimis Emission Rates - Proposed
40 CFR Part 63, Subpart B Background Document.
U. S. Environmental Protection Agency. Research
Triangle Park, North Carolina. Publication No. EPA-
453/R-93-035. February 1994. p. 7a.
29. Cooperative Assessment Program Manual for the Secondary
Lead Smelting Industry. Occupational Safety and Health
Administration. Washington, D.c. 1983. 83 pp.
30. U.S. Environmental Protection Agency. Lead-Acid
Battery Manufacture-Background Information for Proposed
Standards. Publication No. EPA-450/3-79-028a.
Research Triangle Park, NC. November 1979. pp 3-8
through 3-11, 4-2 through 4-6, and 4-27 through 4-29.
31. Report on Compliance Testing Performed for RSR
Corporation, Dallas, Texas, conducted at Quemetco,
Inc., Indianapolis, Indiana. CAE Project No. 5633.
Clean Air Engineering. May 6, 1991. pp. 1-1 through
1-7, and 2-1.
32. Pacific Environmental Services, Inc. Draft Final
Report—Total Hydrocarbon Testing at a Secondary Lead
Smelter: GNB, Columbus, GA. Prepared for the U. S.
Environmental Protection Agency. Research Triangle
Park, North Carolina. Contract No. 68-D2-0162.
November 1993. 22 pp. plus appendices.
33. Pacific Environmental Services, Inc. Draft Final
Report—Total Hydrocarbon Testing at a Secondary Lead
Smelter: Gulf Coast Recycling, Tampa, Florida.
Prepared for the U. S. Environmental Protection Agency.
Research Triangle Park, North Carolina. Contract
No. 68-D2-0162. November 1993. 22 pp. plus
appendices.
34. Radian Corporation. Trip report for EPA visit to East
Penn Manufacturing Co., Inc., Lyon Station,
Pennsylvania, September 26, 1991. Prepared for the
U. S. Environmental Protection Agency. Research
Triangle Park, North Carolina. Contract
No. 68-02-4378. June 1992. 18 pp.
35. PEI Associates, Inc. Level III Inspection of GNB,
Incorporated, Columbus, Georgia. Prepared for the
U. S. Environmental Protection Agency, Region IV,
Atlanta, Georgia. Contract No. 68-02-4466.
September 1990. 12 pp. plus 3 appendices.
J-41
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36. Marinshaw, R. and C. Cowherd (Midwest Research
Institute). Sealing Feasibility Study: Source
Identification for a New Lead Standard. Prepared for
U. S. Environmental Protection Agency. Research
Triangle Park, North Carolina. EPA Contract
No 68-02-4395. September 1990. p. 16.
37. Rives, G. D. and A. J. Miles (Radian Corporation).
Control of Arsenic Emissions from the Secondary Lead
Smelting Industry - Technical Document. Prepared for
U. S. Environmental Protection Agency. Research
Triangle Park, North Carolina. EPA Contract
No. 68-02-3816. March 1985. p. 3-10.
38. Marinshaw, R. and C. Cowherd (Midwest Research
Institute). Sealing Feasibility Study: Source
Identification for a New Lead Standard. Prepared for
U. S. Environmental Protection Agency. Research
Triangle Park, North Carolina. EPA Contract
No. 68-02-4395. September 1990. p. 5-7.
•\
39. Rives, G. D. and A. J. Miles (Radian Corporation).
Control of Arsenic Emissions from the Secondary Lead
Smelting Industry - Technical Document. Prepared for
U. S. Environmental Protection Agency. Research
Triangle Park, North Carolina. EPA Contract
No. 68-02-3816. March 1985. p. 3-28.
40. Fuchs, M. R., M. J. Krall, and G. D. Rives (Radian
Corporation) Secondary Lead Smelter Test of Area
Source Fugitive Emissions from Arsenic, Cadmium, and
Lead: Chloride Metals, Tampa, Florida, Volume I.
Prepared for U. S. Environmental Protection Agency.
Research Triangle Park, North Carolina. EMB Report 84
SLD3. March 1985. p. 2-5.
41. Marinshaw, R. and C. Cowherd (Midwest Research
Institute). Sealing Feasibility Study: Source
Identification for a New Lead Standard. Prepared for
U. S. Environmental Protection Agency. Research
Triangle Park, North Carolina. EPA Contract
No. 68-02-4395. September 1990. pp. 14-16.
42. Elliott, J. A. and A. J. Miles (Radian Corporation).
Evaluation of Implemented Process and Fugitive Lead
Emissions Controls at the Refined Metals Corporation,
Memphis, Tennessee. Prepared for U. S. Environmental
Protection Agency. Atlanta, Georgia. September 1989.
p. 4-7.
3-42
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43. Marinshaw, R. and C. Cowherd (Midwest Research
Institute). Sealing Feasibility Study: Source
Identification for a. New Lead Standard. Prepared for
U. S. Environmental Protection Agency. Research
Triangle Park, North Carolina. EPA Contract
No. 68-02-4395. September 1990. p. 7.
44. Strzempko, S. J. and Choi, M. W. Battery Separators:
Past, Present and Future. The Battery Man.
35(3):15-21. March 1993.
45. Letter and attachments from Tapper, J., Gopher Smelting
and Refining Company, to Streit, G., EPA/ISB.
December 23, 1993. 3 pp. MACT standards and
description of dechlorination system.
46. Results of the October 22, 1993 HC1 Emission
Engineering Test at the Main Stack at the Gopher
Smelting & Refining Plant in Eagan, Minnesota.
Interpoll Laboratories, Inc. Report No. 3-1490.
November 1993. 10 pp. plus appendices.
3-43
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4.0 CONTROL ALTERNATIVES
This chapter describes how HAP emissions from
individual smelters were affected under different
alternatives for a candidate maximum achievable control
technology (MACT) standard. Section 4.1 describes how
information was collected on each smelter. This information
i
served as the basis for estimating the impacts of a MACT
standard for HAP's. Section 4.2 describes how baseline
emissions were estimated for each smelter for process,
process fugitive, and fugitive dust HAP emissions.
Section 4.3 describes how candidate MACT floor controls were
identified for process, process fugitive, and fugitive dust
sources. Section 4.4 describes the upgrades needed to meet
the candidate MACT floor level of control. Section 4.5
describes a level of control more stringent than the floor
and the upgrades needed to meet that level of control.
Finally, section 4.6 describes the emissions under the
candidate MACT control alternatives. (Emissions reductions
under the MACT control alternatives are presented in
chapter 5.0, Environmental Impacts.)
4.1 SECONDARY LEAD SMELTER INFORMATION COLLECTION
Information was collected on all secondary lead
smelters in order to estimate emissions and to analyze the
environmental and cost impacts of the candidate MACT control
alternative described in section 4.3. Detailed information
was collactad for each of the 23 smelters through plane
visits, questionnaires, discussions with Stata and local air
pollution control officials, and previously published ?r
•iccumer.rad. inf crnation ^n -aach faciii'tv. 1~ "cos ';r-^r~ :
4-1
-------
particular piece of information could not be obtained for a
facility, a default value was developed from information
known for other similar smelters and scaled according to
each smelter's production capacity.1/2
Information was collected on all potential HAP emission
sources and air pollution controls at each smelter. This
information included, among other things, airflows,
operating temperatures, pollutant concentrations, and
control device design and operating parameters. Information
was also collected on several types of emission sources that
are not included in the proposed regulation.
The information collected for each smelter and the
estimated default values can be found in appendix C.
Information that is considered confidential business
information is blacked out.
Table 4-1 summarizes the smelting furnace information
and furnace emission controls for each secondary lead
smelter. The process fugitive and fugitive dust emission
controls at each smelter are summarized in table 4-2. The
facility identification numbers in tables 4-1 and 4-2 and
appendix C are not consecutive because the original database
contained information about some smelters that have since
closed permanently. The original database also contained
information on other facilities that were later found not to
meet the definition of a secondary lead smelter.
Information on these facilities has been removed.
4.2 BASELINE EMISSIONS
Baseline emissions are defined as the emissions that
would occur in the absence of any additional Federal
regulations, and they take into account limits imposed by
current Federal, State, or local regulations, including
emission permit limitations.
Baseline HAP emissions were estimated for each model
plant for process, process fugitive, and fugitive dust
emissions. These estimates are presented in table 4-3. The
methodologies for developing these estimates are summarized
below. A more derailed explanation of how chese esci-aazas
4-2
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TABLE 4-1. PROCESS SOURCE EMISSION CONTROLS IN USE
AT SECONDARY LEAD SMELTERS
Facility Smelting furnace
ID type (number)
Production
capacity
(Mg/yr)*
Process emission
controls15
2 Blast (4) 110,000
3 Reverberatory (1) 120,000
Blast (1)
4 Reverberatory (1) 70,000
5 Blast (1) 30,000
6 Blast (2) 20,000
8 Reverberatory (1) 110,000
Blast (1)
9 Blast (1) 30,000
10 Reverberatory (1) 110,000
'Electric (l)
12 Blast (1)
13 Reverberatory (1)
Blast (2)
14 Reverberatory (2)
Blast (1)
15 Reverberatory (1)
Blast (1)
16 Blast (1)
Afterburner and
baghouse
Afterburner,
baghouse, and SO2
scrubber
Baghouse and SO2
scrubber
Baghouse
Afterburner and
baghouse
>
Combined flow,
afterburner,
baghouse, and SO2
scrubber
Baghouse
Baghouse
17 Reverberatory (1)
19 Rotary (2)
20 Rotary (1) 20,000
10,000 Afterburner and
baghouse
100,000 Afterburner and
baghouse
90,000 Combined flow,
afterburner, and
baghouse
80,000 Baghouse
40,000 Afterburner ,
baghouse, and SC>2
scrubber
70,000 Baghouse
30,000 Baghouse
Afterburner,
baghouse . and
scrubber
4-3
-------
TABLE 4-1. PROCESS SOURCE EMISSION CONTROLS IN USE
AT SECONDARY LEAD SMELTERS (CONCLUDED)
Production
Facility Smelting furnace capacity
ID type (number) (Mg/yr)a
Process emission
controls13
22 Reverberatory (1)
Blast (1)
23 Reverberatory (2)
Blast (2)
25 Blast (1)
2 6 Reverberatory (1)
Blast (1)
27 Blast (1)
28 Reverberatory (1)
Blast (1)
29 Rotary (2)
80,000 Combined flow,
afterburner,
baghouse, and SC>2
scrubber
100,000 Combined flow,
afterburner,
baghouse, and SO2
scrubber
20,000 Baghouse
30,000 Baghouse
*
20,000 Afterburner and
baghouse
50,000 Afterburner,
baghouse, and SO2
scrubber
20,000 Baghouse and SO2
scrubber
a Rounded to the nearest 10,000 Mg.
k Combined flow (i.e., gas stream blending) means that blast
and reverberatory furnace exhaust are combined while
reverberatory furnace exhaust is still hot in order to
achieve control of organic compounds.
4-4
-------
TABLE 4-2.
PROCESS FUGITIVE AND FUGITIVE DUST
EMISSION CONTROLS IN USE AT
SECONDARY LEAD SMELTERS
Facility
ID
2
3
4
5
6
8
9
10
12
13
14
15
16
17
19
Process
fugitive
emission
controls
Hoods and
baghouse
Hoods and
baghouse
Hoods and
baghouse
Hoods and
baghouse
Hoods and
baghouse or
scrubbera
Hoods and
baghouse
Hoods and
baghouse
Hoods and
baghouse
Hoods and
baghouse
Hoods and
baghouse
Hoods and
baghouse
Hoods and
baghouse ,
except on
furnace
charging
Hoods and
baghouse
Hoods and
baghouse
Hoods and
baghouse
Fuaitive Dust Emission
Wet
suppression?
Yes
No
Yes
Yes
Yes
No
No
Yes
No
Yes
No
Yes
Yes
Yes
No
Pavement
cleaning?
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Controls
Total
enclosure?
No
No
No
No
' No
Yes
Yes
Yes
Yes
No
• Yes
No
No
No
No
4-5
-------
TABLE 4-2.
PROCESS FUGITIVE AND FUGITIVE DUST
EMISSION CONTROLS IN USE AT
SECONDARY LEAD SMELTERS (CONCLUDED)
Facility
ID
Process
fugitive
emission
controls
Fugitive Dust Emission Controls
Wet Pavement Total
suppression? cleaning? enclosure?
20 Hoods and
baghouse or
scrubbera
No
No
Yes
22
23
25
26
27
28
29
Hoods and
baghouse
Hoods and
baghouse
Hoods and
baghouse or
scrubber3
Hoods and
baghouse
Hoods and
baghouse
Hoods and
baghouse
Hoods and
baghouse
No
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
1
NO
Yes
No
Yes
a Scrubber is used in place of a baghouse to control
particulate emissions from refining kettles.
4-6
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were developed is presented in appendix D.
4.2.1 Baseline Process Emission Estimates
Baseline process emission estimates were developed for
metal HAP's, organic HAP's, and HC1/C12.
4.2.1.1 Metal HAP's. Baseline estimates for process
emissions of metal HAP's were developed using two
alternative approaches. The first approach relied on the
use of emission limits for PM and lead as surrogates for
metal HAP's. Metal HAP emissions were estimated from PM and
lead emissions using ratios developed from stack testing
data. Baseline emissions estimated under this approach
represented the maximum capacity of each smelter to emit
metal HAP's under current Federally enforceable emission
limits. All secondary lead smelters are subject to, the
current NSPS for secondary lead smelters under 40 CFR 60,
subpart L, with a PM concentration limit of 50 mg/dscm.
However, some are subject to more stringent emission limits
for PM or lead (such as might be found in State permits).
The second approach, which produced substantially lower
emission estimates, used actual stack test data for PM and
lead emissions obtained for the majority of facilities.
Most smelters are achieving much better PM and lead control
in practice than required by existing emission limitations.
This is because secondary lead smelters must also comply
with the National Ambient Air Quality Standard (NAAQS) for
lead. In addition, the original NSPS emission level was
based on the use of a high-energy scrubber to control
particulate emissions.3 However, all smelters are currently
using baghouses that achieve a greater level of control for
particulate emissions.
To account for this greater level of control, baseline
metal HAP emission estimates were also developed, based on
actual performance determined from stack testing data.
These estimates of actual emissions are also included in
table 4-3 and were usad as the baseline for astimatir.g
emission reductions, presented in chapter 5.0. Actual
3iuj.33icns or metal HAP's from -smelting zurnacas ~r3
4-9
-------
generally less than 10 percent of emissions estimated from
emission limits. The potential for reductions of metal HAP
emissions from smelting furnaces is therefore significantly
less than indicated by the baseline emissions estimate based
on emission limits.
The methodology and data used to estimate baseline
metal HAP emissions are described in more detail in
attachments A and B of appendix D.
4.2.1.2 Organic HAP's. Baseline organic HAP emissions
were estimated from emission factors developed by the EPA
from the THC and organic HAP data presented in chapter 3.0
and appendix A. A ratio of 0.28 kg organic HAP's per 1 kg
of THC emissions was developed from the THC and organic HAP
emission rates measured during the EPA testing program. The
ratio was used to estimate organic HAP emissions from
controlled THC emissions determined for each furnace type
from test data. A more detailed description of the
methodology used to estimate baseline organic HAP emissions
is presented in attachment C of appendix D.
Blast furnaces are the largest sources of organic HAP
emissions unless they are controlled by an afterburner or by
combining exhaust streams with a reverberatory furnace.
Relative to metal HAP's and HC1, organic HAP's are the
largest mass fraction of HAP's emitted. Organic HAP's are
not subject to any Federal emission limits and are not
generally subject to State emission limits.
4.2.1.3 Hydrochloric Acid and Chlorine. Baseline
estimates of HC1/C12 emissions were developed using HC1/C12
emission factors derived from the EPA test data presented in
chapter 3.0 and appendix A. No emission limits for HC1 or
Cl2 were identified.
Furnaces that add fluxing agents (soda ash or
limestone), typically blast and rotary furnacas. have vary
low HC1/C12 emissions [less than 1 Mg/yr (1 tpy) per
furnace]. Reverberatory furnaces, which do not tvpicall/
add fluxing agents, have higher HC1/C12 emissions [90 Mg/yr
(39 tpy) per furnace]. However, liCl/Cl? araj-ssi^ns -ir--* ~.i_^
4-10
-------
controlled by a scrubber, if one is present. Baseline
estimates reflect whether a furnace is using fluxing agents
or a scrubber. The methodology used to estimate baseline
HC1/C12 emissions is presented in more detail in
attachment D of appendix D.
4.2.2 Baseline Process Fugitive Emission Estimates
Baseline estimates for process fugitive emissions of
metal HAP's from dust-agglomerating furnaces, refining and
casting operations, and smelting furnace process fugitive
sources (charging and lead and slag tapping) were developed
from standard AP-42 emission factors for PM and lead
emissions from secondary lead smelters. Battery breaker
emission estimates were based on an emission factor
developed from a single test measurement. Baseline* process
fugitive emission estimates for metal HAP's are summarized
in table 4-3, above. The emission factors used to estimate
process fugitive emissions have quality ratings of "C" or
below. The methodology used to estimate baseline process
fugitive metal HAP emissions is presented in more detail in
attachment E of appendix D.
Organic process fugitive emissions may originate from
blast furnace charging systems, depending on the design,
operation, and maintenance of the furnace and the charging
ventilating system. These emissions can be potentially
significant. The estimated organic HAP emissions from one
furnace at which a problem was detected are about 50 Mg/yr.
(See the discussion of the Schuylkill Metals testing data in
appendix A). This furnace had a unique charging system, so
organic emissions from blast furnace charging is probably
not a common occurrence. However, no baseline estimate is
provided for these emissions because no estimate is
available on the total number of furnaces that may have
organic emissions originating from the charging mechanism.
4.2.3 Baseline Fugitive Dust Emission Estimates
Baseline estimates for fugitive dust emissions of metal
HAP's were developed using standard amission factor
equations contained in AP-42,, coupled with litarature va^uas
4-11
-------
and actual or estimated plant data for input parameters and
activity factors. Estimated default values had to be used
for the input parameters to the fugitive dust emission
factor equations for the majority of the smelters and the
emission factors have quality ratings of "C" or below.
Separate fugitive dust emission estimates were developed for
plant roadways, battery breaking areas, materials storage
and handling areas, furnace and refining areas, and finished
product storage areas. The baseline fugitive dust emission
estimates are presented in table 4-3, above.
Roadway emission factor equations contained in AP-42
were used to estimate emissions due to equipment traffic in
all areas of the plant. Materials handling emission
estimates are a function of the mass of materials handled
per year and were estimated from the material handling
emission factor equations. The estimates for materials
storage emissions resulting from wind erosion were based on
estimated storage pile area and were estimated from the wind
erosion emission factor equations. A more detailed
description of the methodology used to estimate baseline
fugitive dust emissions is presented in attachments F and G
of appendix D.
4.3 IDENTIFICATION OF MACT FLOOR CONTROLS
Separate candidate MACT floor control alternatives were
identified for process, process fugitive, and fugitive dust
emission sources. In developing the candidate MACT floor
alternative for process sources, smelters were grouped
according to smelting furnace configuration. Separate MACT
floor alternatives were developed for each furnace
configuration because of differences in emissions and
control options applicable to each configuration. However,
in developing MACT floor alternatives for process fugitive
and fugitive dust sources, the same alternative was
identified for all 23 smelters in the source category. A
single MACT floor control alternative was identified in the
latter two cases because process fugitive and fugitive dusr
4-12
-------
sources are nearly identical across all smelters, regardless
of furnace configuration.
4.3.1 Candidate MACT Floor Control Alternative for Process
Sources
The candidate MACT floor control alternatives for
process emissions were developed after grouping the model
plants into the following furnace configurations:
(1) collocated reverberatory and blast furnaces; (2) blast
furnaces not collocated with other smelting furnace types;
(3) rotary and reverberatory furnaces; and (4) electric
furnaces.
These groupings were adopted because smelting furnaces
differ substantially, based on configuration, in both
emissions potential (mix and amounts) and achievable control
levels for organic HAP's. For each configuration, candidate
MACT floor controls were identified for new and existing
sources based on the controls found within that
configuration for metal HAP's, organic HAP's, and HC1. For
existing sources, the candidate MACT floor control is the
control demonstrated by the median of the five best-
controlled sources in a configuration. For new sources, the
candidate MACT control is the control in use by the
best-controlled source in a configuration. Table 4-4 shows
the number of sources using each process control
combination.
4.3.1.1 Reverberatory/Blast Furnace Configuration.
Control measures currently in use to control furnace
emissions at collocated reverberatory/blast furnace
facilities are combinations of afterburners, gas stream
blending, baghouses, wet scrubbers, and flux addition. As
discussed in chapter 3.0, afterburners used to control blast
furnace emissions are capable of achieving about 84 percent
control of organic HAP's, THC, and CO when operated at a
temperature of 700 °C (1300 °F). Gas stream blending
consists of mixing blast furnace gases wirh hot-car and
larger-volume reverberatory furnace gases in a chamber fcr
incinerar^on. Gas stiraam blending provides .ncra ces~-
4-13
-------
COMBINATIONS
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effective control of organic HAP's than do afterburners by
utilizing the large volume of hot exhaust produced by the
reverberatory furnace. Greater than 99-percent control of
THC (the surrogate for organic HAP's) and 98-percent control
of CO has been demonstrated.
Baghouses are used to control PM and lead. As
discussed in chapter 3.0, properly operated and maintained
baghouses are capable of achieving greater than 99-percent
control of PM and about 98-percent control of lead and other
metal HAP compounds. Wet scrubbers, primarily in place to
control SO2, are capable of providing 99-percent control of
HC1/C12. The addition of soda ash or limestone fluxing
agents to the furnace feed to enhance the removal of
chlorides through slagging can achieve HC1/C12 control
equivalent to that of wet scrubbing.
Nine smelters operate a total of 10 reverberatory/blast
pairs in this configuration. The best-controlled source and
best-performing five sources all blend gas streams to
control organic HAP emissions. They also use baghouses to
control metal HAP emissions and either scrub or flux to
control HC1/C12 emissions. Consequently, the combination of
these controls constitutes the candidate floors for both new
source and existing source MACT.
4.3.1.2 Blast Furnace Configuration. Control measures
currently in use to control furnace emissions at blast
furnace facilities are afterburners, baghouses, wet
scrubbers, and fluxing. Afterburners are primarily used to
control CO, but they also reduce emissions of organic HAP's.
The most important variable in afterburner performance is
temperature, although residence time and turbulence are also
important. Temperature, however, is the most important
variable in determining the cost of control.
The operating temperature of the best-performing
afterburner in this furnace configuration is 870 °C
(1,600 °F), which represents an estimated 98-percent organic
HAP control. The average temperature of the five
afterburners opera-ing at tne highest temperaturas is ~ :c. -c
4-15
-------
(1,300 op)f which represents an estimated 84-percent organic
HAP control. Baghouses provide 98-percent control for metal
HAP's, and wet scrubbers and fluxing provide 99-percent
control for HC1/C12.
The blast furnace-only configuration encompasses
13 blast furnaces at eight smelters. The best-controlled
blast furnace uses an afterburner at 870 °C (1,600 °F) to
control organic HAP's and a baghouse to control metal HAP's,
and fluxes with soda ash or limestone or operates an S02
scrubber to control HC1/C12 emissions. Consequently, the
combination of these controls constitutes the candidate
floor for new source MACT.
Seven blast furnaces use an afterburner to control
organic HAP's and a baghouse to control metal HAP's% and
perform fluxing or use a scrubber to control HC1/C12. The
average temperature of the five hottest afterburners is
700 °C (1,300 °F) . Consequently, the combination of these
controls constitutes the candidate floor for existing source
MACT.
4.3.1.3 Rotary and Reverberatorv Furnace
Configurations. Control measures currently in use to
control furnace emissions at rotary furnace and
reverberatory furnace facilities are baghouses, wet
scrubbers, and the addition of fluxing agents. Baghouses
and wet scrubbers provide 98-percent control for metal HAP's
and 99-percent control for HC1/C12, respectively. Soda ash
and limestone are added to all rotary furnaces and some
reverberatory furnaces as fluxing agents, providing HC1/C12
control equivalent to that of scrubbing.
As discussed in chapter 3.0, the high exhaust
temperatures of rotary and reverberatory furnaces ensure
nearly complete destruction of organic HAP's. Because these
furnaces do not have .any appreciable organic emissions. no
rotary or reverberatory furnaces utilize add-on emission
controls for organic HAP's. As a result, there is no
candidate floor level of control for oraanic HAP's.
4-16
-------
Six smelters operate either rotary or reverberatory
furnace configurations. The best-controlled furnace and
best-performing five furnaces use a baghouse to control
metal HAP's and a scrubber or fluxing to control HC1/C12-
Consequently, the combination of these controls constitutes
the candidate floors for both new source and existing source
MACT.
4.3.1.4 Electric Furnace Configuration. There is
currently only one electric furnace in use in the secondary
lead smelting source category. It is used to process slag
generated at three reverberatory furnace-only smelters. The
furnace is equipped with a baghouse to control PM and lead
emissions. Controls for organic HAP's and HC1/C12 are not
used on this furnace. As discussed in chapter 2.0,, neither
organic HAP's nor HC1/C12 are emitted from this furnace
because it processes only slag that is relatively free of
organic matter and available chlorides. Consequently, a
baghouse constitutes the candidate floor for both new source
and existing source MACT for controlling metal HAP's.
4.3.2 Candidate MACT Control for Process Fugitive Sources
The entire population of secondary lead smelters was
used to identify the candidate MACT controls for metal HAP
emissions from process fugitive sources. This was done
because these sources, their emissions, and applicable
controls are similar across all smelters, regardless of the
smelting furnace technology being used.
Candidate MACT floor controls were identified for four
types of process fugitive sources: (1) Smelting furnace
charging and tapping locations, (2) flue dust agglomerating
furnaces, (3) refining kettles, and (4) dryers. All of
these are sources of metal HAP's and are typically
controlled by hoods ventilated to baghouses.
The candidate MACT controls for process fugitive
sources also require the capture hooding and ventilation to
be consistent with the specifications in OSHA's "Coopsrac^vB
Assessment Program Manual for the Secondary Lead Smelter
Indus-cry".- The OSKA manual specifies cnat procass ;uc..-_- .-.
4-17
-------
sources should be controlled by an enclosure-type hood, that
is ventilated so that a minimum face velocity is achieved.
Face velocity is the velocity at which air is drawn into a
hood, and, along with hood type, is a primary factor in hood
capture efficiency. The minimum recommended face velocity
varies by source type, but is generally about 110 m/min
(350 fpm). These controls represent state-of-the-art
ventilation practices to protect workers by promoting
effective capture and ventilation of process fugitive
emissions.
Based on observations at operating secondary lead
smelters, the EPA believes that the capture and ventilation
systems installed and operated at secondary lead smelters
are designed and operated in accordance with the
specifications in OSHA's cooperative assessment program
manual. These controls consequently establish the candidate
MACT floor.
4.3.2.1 Smelting Furnace Charging and Tapping.
Smelting furnace charging and tapping are sources of metal
HAP's. With one exception, all furnace charging and lead
tapping and slag tapping locations are enclosed in a hood
and captured emissions are ventilated to a baghouse for the
control of metal HAP's. One blast furnace has no hooding or
ventilation on the charging chute. Consequently, the
candidate MACT floor control for new and existing sources is
hooding and ventilation to a baghouse for the control of
metal HAP's.
Blast furnace charging can also be a source of organic
HAP's. The candidate MACT to control organic HAP emissions
from blast furnace charging is a hood over the charging
chute with a ventilation flow rate that is balanced against
the primary exhaust flow rate from the furnace. The two
flow rates are balanced to minimize the escape of primary
exhausts and organic HAP's to the furnace charging hood.
4.3.2.2 Agglomerating Furnaces. Agglomerating
furnaces are sources of metal HAP's. They are used at. nir.e
smelters and all are hooded and ventilated -a a. oaghcusa.
4-13
-------
Therefore, the candidate MACT floor is a hood with
ventilation to a baghouse.
4.3.2.3 Refining Kettles. Refining kettles are
sources of metal HAP's. There are about 170 refining
kettles and they are hooded and ventilated to baghouses at
all but three smelters; three smelters use wet scrubbers
instead of baghouses. Baghouses typically offer greater
control of metal HAP's than wet scrubbers. Therefore, the
candidate MACT floor is a hood and ventilation to a
baghouse.
4.3.2.4 Dryers. Dryers are sources of metal HAP's.
They are currently in use at six smelters to remove moisture
from materials just prior to charging them to reverberatory
smelting furnaces. Each dryer has a transition piece
between the dryer cylinder and the furnace feed chute.
These transition pieces on all dryers are hooded and
ventilated to a baghouse. The MACT floor for dryers is,
therefore, hoods over the transition pieces with ventilation
to a baghouse.
4.3.3 Candidate MACT Control for Fugitive Dust Sources
The entire population of secondary lead smelters was
used to identify the candidate MACT controls for metal HAP
emissions from fugitive dust sources. This was done because
these sources, their emissions, and applicable controls are
similar across all smelters, regardless of the smelting
furnace technology being used.
The four areas of fugitive dust sources for which
candidate MACT controls were identified are:' (1) battery
breaking areas, (2) furnace and refining and casting areas,
(3) materials storage and handling areas, and (4) plant
roadways.
Controls for fugitive dust sources include (1) paving
all areas subject to vehicle traffic to facilitate the
removal of accumulated dust; (2) periodic cleaning of all
paved areas to remove deposited dust and prevenr. its re-
entrainment or transfer to other areas by vehicle traffic-
(3) vehicle washes ar. exits from materials storage and
4-19
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handling areas to prevent carry-out of metal HAP-bearing
residues and dust; (4) wetting or use of chemical
surfactants, binding agents, or sealers on storage piles
coupled with partial or total enclosures to limit wind
erosion and the generation of dust associated with materials
storage and handling; and (5) ventilating total enclosures,
where used, to a baghouse or equivalent device to capture
airborne dust.
Total enclosure of a fugitive dust source and
ventilation of the enclosure to a control device may at
first appear to be the most effective means of controlling
fugitive dust emissions. However, the EPA has determined
from observations of operating smelters and a technical
analysis of fugitive dust control measures applicable to
this source category that partial enclosures with
appropriate wetting and pavement cleaning are equally
effective in controlling fugitive dust emissions and at much
lower cost when coupled with monitoring and recordkeeping to
ensure these activities are performed.5
4.3.3.1 Battery Breaking Area. At least nine smelters
control fugitive dust emissions from the battery breaking
area. Controls include partial or total enclosures, vacuum
or powerwashing systems, and the wetting of storage piles.
Therefore, these controls are the candidate MACT floor for
new and existing sources. An equivalent alternative
technology is to totally enclose the area and ventilate the
entire building or enclosure volume to a baghouse.
4.3.3.2 Furnace and Lead Refining and Casting Areas.
At least 12 smelters either totally enclose the furnaca and
lead refining and casting areas and ventilate the enclosure
to a baghouse or partially enclose this area on at least
three sides and vacuum or powerwash the pavement. The
remaining smelters use some, but not all, of these
techniques. Therefore, partial enclosure coupled with
pavement cleaning (vacuuming or powerwashing) or total
enclosure ventilated to a baghouse is the candidata MACT
floor for new and existing sources.
4-20
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4.3.3.3 Materials Storage and Handling Areas. At
least 12 smelters have paved the materials storage and
handling areas, operate vehicle washes at exits from these
areas, and either totally enclose the area and ventilate the
enclosure to a baghouse or partially enclose the storage
piles and use wetting or other dust suppression techniques
on the storage piles. The remaining smelters use some, but
not all, of these techniques. Therefore, the combination of
vehicle washes, paving, and either partial enclosure coupled
with wet suppression or total enclosure and a baghouse is
the candidate MACT floor for new and existing sources.
4.3.3.4 Roadways. At least 16 smelters have paved
their roadways and periodically clean the pavement by
vacuuming or powerwashing. Therefore, these controls are
the candidate MACT floor for new and existing sources.
4.4 UPGRADES NEEDED TO MEET THE MACT FLOOR LEVEL OF CONTROL
This section describes the physical upgrades that
individual facilities would need to perform in order to meet
the MACT floor levels of control for process, process .
fugitive, and fugitive dust emission sources. The emission
reductions and cost impacts associated with performing the
upgrades required to meet the MACT floor level of control
are presented in chapters 5.0 and 6.0, respectively.
A more stringent level of control for organic HAP's,
described below in section 4.5, was also evaluated. The
organic HAP emission reductions and cost impacts of
performing the upgrades required to meet the MACT floor
level of control are presented in chapters 5.0 and 6.0,
respectively, as alternative I. The emission reductions and
cost impacts associated with the more stringent option are
presented in chapters 5.0 and 6.0 as alternative II.
4.4.1 Process Sources
Many of the smelters operating in the
reverberatory/blast, blast, rotary, and reverberatory
furnace configurations would need to upgrade their smei~ircj
furnace controls to meet the MACT floor level cf control.
4-21
-------
No upgrades would be needed for the one electric smelting
furnace.
4.4.1.1 Reverberatorv/Blast Furnace Configuration. In
order to meet the candidate MACT floor level of control, six
smelters that operate furnaces in this configuration would
have to upgrade their process emission controls.
Facilities 3, 13, 15, 26, and 28 would need to install
additional ductwork to accomplish gas stream blending
between the reverberatory and blast furnaces to control
organic HAP's. Facilities 13, 14, 15, and 26 would need to
add fluxing agents to the reverberatory furnace feed
material to control HC1/C12 emissions. All of the furnaces
have baghouses, so no upgrades would be needed to meet the
candidate MACT floor control for metal HAP's.
4.4.1.2. Blast Furnace Configuration. In order to
meet the candidate MACT floor level of control, five
smelters that operate blast furnaces would need to upgrade
their process emission controls. Facilities 5, 9, and 25
would need to purchase and install new afterburners and
increase their natural gas consumption to meet the candidate
MACT floor control for organic HAP's. Facilities 2 and 27
would not need to purchase new afterburners, but would need
to increase their natural gas consumption in order to
increase the operating temperature of their existing
afterburners to the MACT floor operating temperature of
700 °C (1,300 °F). All of the furnaces in this
configuration have baghouse and currently perform fluxing,
so no upgrades would be needed to meet the candidate MACT
floor level of control for metal HAP or HC1/C12 emissions.
4-22
-------
4.4.1.3 Rotary and Reverberatory Furnace
Configuration. All rotary and reverberatory furnaces have
baghouses, so no upgrades in metal HAP controls would be
needed. No add-on organic HAP controls are needed for
rotary or reverberatory furnaces, so no upgrades are needed
for this class of pollutants. Two smelters that operate
reverberatory furnaces would need to upgrade their process
emission controls to meet the candidate MACT floor level of
control. Facilities 10 and 17 both operate reverberatory
furnaces and would need to perform fluxing to control
HC1/C12 emissions. All rotary furnaces already perform
fluxing, so no upgrades to control HC1/C12 are needed.
4.4.1.4 Electric Furnace Configuration. The one
electric furnace in operation has a baghouse to control
metal HAP's, and no add-on controls are needed for organic
HAP or HC1/C12 emissions from this furnace. Therefore, no
upgrades would be needed to meet the candidate MACT floor
level of control for this configuration.
4.4.2 Process Fugitive Sources
Nearly all process fugitive emission sources at all
smelters are enclosed in hoods that are ventilated to either
a baghouse or a wet scrubber to control metal HAP's. At
facility 15, there is no hood over the blast furnace
charging chute and one would need to be installed to meet
the candidate MACT floor level of control.
At facilities 6, 20, and 25, the hoods over the
refining kettles are ventilated to wet scrubbers rather than
to baghouses to control metal HAP's. Although baghouses
generally achieve a higher level of control than scrubbers,
data from analogous sources at battery manufacturing plants
indicate that scrubbers in this situation could offer a
comparable level of control.6 No upgrades may be necessary
to achieve the same emission level as a source controlled by
a baghouse. No emission reductions or cost impacts are
estimated for replacing these scrubbers with baghouses.
4-23
-------
4.4.3 Fugitive Dust Sources
In order to meet the candidate MACT floor level of
control for fugitive dust sources, 14 smelters would need to
upgrade their fugitive dust controls. Smelters 2, 5, 6, and
15 would need to purchase mobile vacuum sweepers and
allocate additional labor hours to operate them.
Smelters 3, 4, 9, 13, 14, 22, 26, and 27 would need to
allocate additional labor hours to operate existing vacuum
sweepers in areas not currently covered. Smelters 16 and 19
would need to perform wet suppression in additional areas
not currently covered.
4.5 EVALUATION OF A CONTROL OPTION ABOVE THE MACT FLOOR
For most of the process emission sources and all of the
process fugitive and fugitive dust emission sources, the
candidate MACT floor level of control is the only available
control option; there is no control alternative more
stringent than the floor level of control. The only control
option more stringent than the floor is for blast furnaces
to be controlled by afterburners operated at 870 °C rather
than at the MACT floor temperature of 700 °C. Metal HAP and
HC1/C12 controls are the same as the floor level of control
in this option.
Under this more stringent control option, facilities 2,
5, 6, 9, 16, 25, and 27 would have to purchase new
afterburners and increase their natural gas consumption. It
was assumed that the operating temperature of an existing
afterburner could not be increased by more than 100 °C
(180 °F). Facility 12 would be the only blast furnace
smelter that would not have to perform any upgrades to its
smelting furnace controls. The organic HAP emission
reductions and cost impacts achieved by performing the
upgrades required to meet the level of control above the
MACT floor are presented in chapters 5.0 and 6.0,
respectively, as alternative II.
4.6 CONTROLLED EMISSIONS
Controlled emissions were estimated for each sneltar
for process, process fugitive, and fugitive dusT; emissions.
4-24
-------
Controlled emissions were estimated assuming that each
smelter adopted the controls in alternatives I and II and
performed the upgrades describes above in sections 4.4 and
4.5. The controlled emission estimates are summarized in
table 4-5. Emission reductions (the difference between
controlled and baseline emissions) are presented in
chapter 5.0 along with the other environmental impacts of
the control alternatives.
4.6.1 Process Emissions
Controlled process emission estimates were developed
for metal HAP's, organic HAP's, and HC1/C12 using the same
methodology as used for estimating baseline emissions but
assuming that the smelters had installed the controls
described in each alternative. Controlled process emissions
of metal HAP's are the same as baseline emissions because
all process sources are already controlled by baghouses,
which are the candidate MACT floor control for metal HAP's
under both alternatives.
Controlled organic HAP emissions are lower than
baseline emissions under both alternatives I and II. Under
both alternatives, organic HAP emissions are lower at five
reverberatory blast furnace smelters (facilities 3, 13, 15,
26, and 28). Organic HAP emissions are lower at five blast
furnace smelters (facilities 2, 5, 9, 25, and 27) under
alternative I and at seven blast furnace smelters
(facilities 2, 5, 6, 9, 16, 25, and 27) under
alternative II. Controlled organic HAP emissions are the
same as baseline emissions under both alternatives at
reverberatory and rotary furnace smelters, and from the one
electric smelting furnace.
Controlled HC1/C12 emissions would be lower than
baseline at four reverberatory/blast furnace smelters
(facilities 13, 14, 15, and 26) and at two reverberator-/
smelters (facilities 10 and 17) under both alternatives I
and II. Controlled emissions would be the same as base^ne
from blast furnace and rotary furnace smelters and fro^. tii^
one •alec'cric smelcing furnaca.
4-25
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4.6.2 Process Fugitive Emissions
Controlled process fugitive emissions of metal HAP's
were estimated using the same methodology as for baseline
emissions. Controlled emissions are the same as baseline
emissions at all smelters except facility 15. Controlled
emissions are lower than baseline because a hood would be
added to the blast furnace charging chute at this facility.
All other smelters had process fugitive controls equivalent
to the candidate MACT floor controls.
4.6.3 Fugitive Dust Emissions
Controlled fugitive dust emissions of metal HAP's were
estimated using the same methodology as for baseline
emissions. Controlled fugitive dust emissions are lower
than baseline at 14 smelters (facilities 2, 3, 4, 5y 6, 9,
13, 14, 15, 16, 19, 22, 26, and 27).
4-27
-------
4.7 REFERENCES
1. Memorandum from Pelt, R., Radian Corporation, to George
Streit, U. S. Environmental Protection Agency,
Industrial Studies Branch. Development of Databases
for Existing and New Secondary Lead Smelters (Final).
June 15, 1992.
2. Memorandum from Pelt, R., Radian Corporation, to George
Streit, U. S. Environmental Protection Agency,
Industrial Studies Branch. Documentation of Input Data
Bases Defaults. May 17, 1993.
3. Background Information for Proposed New Source
Performance Standards: Asphalt Concrete Plants,
Petroleum Refineries, Storage Vessels, Secondary Lead
Smelters and Refineries, Brass or Bronze Ingot
Production Plants, Iron and Steel Plants, Sewage
treatment Plants. Volume 1, Main Text. Publication
No. APTD-1352a. U. S. Environmental Protection Agency.
Research Triangle Park, North Carolina. June 1973.
pp. 37-43.
4. Cooperative Assessment Program Manual for the Secondary
Lead Smelting Industry. Occupational Safety and Health
Administration. Washington, DC. 1983. 83 pp.
5. Memorandum from Palmer, B., Radian Corporation, to
George Streit, U. S. Environmental Protection Agency,
Industrial Studies Branch. Summary of Candidate MACT
Floor Controls for Process Fugitive and Area Fugitive
Emission Sources at Secondary Lead Smelters. June 7,
1993.
6. Lead-Acid Battery Manufacture—Background Information
for Proposed Standards. U. S. Environmental Protection
Agency. Research Triangle Park, North Carolina.
Publication No. EPA-450/3-79-028a. November 1979. pp.
4-1 thru 4-43.
4-28
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5.0 ENVIRONMENTAL IMPACTS OF CONTROL ALTERNATIVES
This chapter discusses the beneficial and adverse
environmental impacts of the candidate MACT control
alternatives described in chapter 4.0. Impacts are
discussed in terms of HAP's and other air pollutants, water
consumption, solid waste disposal, and energy consumption.
Environmental impacts of the control alternatives were
assessed assuming that the candidate MACT controls are fully
implemented at existing individual smelters. Pre-existing
emission controls equivalent to the candidate MACT control
are taken into account in this assessment.
5.1 HAZARDOUS AIR POLLUTANT IMPACTS
Impacts were evaluated for metal HAP's, organic HAP's,
and HCl and Cl2• The impacts are discussed below in terms
of emission reductions for process sources, process fugitive
sources, and fugitive dust sources, and are summarized in
table 5-1. These reductions are the difference in baseline
emissions and emissions under a candidate MACT control
alternative. Baseline and MACT emissions are presented in
chapter 4.0.
5.1.1 Process Sources
Emission reductions were estimated for metal HAP,
organic HAP, and HC1/C12 emissions for each of the four
basic smelting configurations.
5.1.1.1 Metal HAP's. The candidate MACT control for
process metal HAP emissions is a baghouse. Because ail
facilities currently have a baghouse, there would be no
metal HAP emissions reductions from process sources.
5.1.1.2 Organic HAP's. Under alternative I, the
candidate MACT conzroi for biasz furnacas is an aJcar-^n^r
operating at a temperature of 700 °C (1,300 °F). The
5-1
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candidate MACT alternative for collocated blast and
reverberatory furnaces is a combined exhaust stream with a
temperature of 930 °C (1,700 °F). The total annual
reduction of organic HAP's achieved by adopting the MACT
controls under alternative I is 1,463 Mg (1,613 tons). In
this scenario, 10 facilities would upgrade their air
pollution controls and achieve emission reductions.
Under alternative II, the candidate MACT control for
blast furnaces is the control eguivalent of an afterburner
operated at 870 °C (1,600 °F). The candidate MACT control
for collocated blast and reverberatory furnaces is still a
combined exhaust stream with a temperature of 930 °C
(1,700 °F). The total annual reduction of organic HAP's
achieved by adopting alternative II is 1,616 Mg
(1,778 tons). In this scenario, 12 facilities would upgrade
their controls and achieve emissions reductions.
5.1.1.3 HCl/Cl^. The candidate MACT control
alternative for HC1/C12 emissions is either the addition of
fluxing agents (soda ash and limestone) to furnace feed
materials or the use of acid gas scrubbers, including HC1
and SO2 scrubbers. Fluxing and scrubbers are considered
equivalent in controlling HC1/C12 emissions. Assuming that
fluxing or a scrubber will achieve 99 percent reduction of
HC1, the total annual reduction of HC1 from all furnaces is
715 Mg (788 tons). These emission reductions are from six
reverberatory furnaces and reverberatory/blast combinations
that currently do not have scrubbers and that would upgrade
their controls by fluxing or by installing scrubbers,
5.1.2 Process Fugitive Sources
Process fugitive sources include battery breaking,
furnace charging, slag tapping, lead tapping, refining,
casting, and dust agglomerating. Emission reductions frc^
these sources were estimated for metal HAP's and organic
HAP's. Process fugitive sources are nor sourcas of iiCI ~r
Cl2 emissions.
5.1.2.1 Meral HAP's. The canaidaca .-1ACT 7or.rrc_ ; ^r
metal HAP's from process fugitive sources is a liood over ~r.e
5-4
-------
source ventilated to a baghouse. Currently, the only
uncontrolled process fugitive source for metal HAP's is the
blast furnace charging chute at facility No. 15. Based on a
98-percent emissions reduction from installing a charging
hood on this one source and ventilating to a baghouse, the
estimated total annual reduction of metal HAP's is 29 Mg
(32 tons).
5.1.2.2 Organic HAP's. Blast furnace charging may be
a source of organic HAP emissions if process emissions
escape from the furnace top to the charging hood. This
occurs when an imbalance exists between the ventilation of
the charging hood and the off-take to the afterburner. It
is not known how many furnaces may be sources of organic
HAP's because of such a ventilation imbalance but this is
not believed to be a common occurrence. Organic HAP
emissions from one furnace with this imbalance were
estimated to be 48 Mg/yr (53 tpy).1 Emissions from two
other furnaces with properly balanced ventilation were
estimated to be each less than 0.5 Mg/yr (0.6 tpy).2'3
Based on these data, the potential emission reductions from
the one affected smelter are 47 Mg/yr (52 tpy).
5.1.3 Fugitive Dust Sources
Sources of fugitive dust emissions include plant
roadways, the battery receiving/breaking area, materials
storage and handling areas, the furnace and refining/casting
area, and the cast lead storage area. Fugitive dust
emissions include metal HAP's but not organic HAP's or HC1.
Metal HAP fugitive dust emissions sources are controlled by
wet suppression, vehicle washing, roadway paving, pavement
cleaning, and area enclosure as described in the candidate
MACT control alternative. Reduction estimates took into
account existing fugitive dust controls at each model plant.
These metal HAP reductions, as shown in table 5-1, total
25 Mg/yr (28 tpy) . These reductions would b'e from at lease
14 facilities and would be achieved through increased
pavement: cleaning and wet suppression.
5-5
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5.2 OTHER AIR POLLUTANT IMPACTS
Pollutants other than HAP's that are expected to be
affected by the candidate MACT control alternatives include
lead, PM, CO, THC, CO2, nitrogen oxides (NOX), and SO2.
5.2.1 Lead and PM
Control of process and process fugitive emissions by a
baghouse and control of fugitive dust emissions by wet
suppression and pavement cleaning would decrease emissions
of PM, which also contains lead and metal HAP's.
Consequently, emission reductions for lead and PM are based
on the metal HAP candidate MACT control alternatives and the
methodologies discussed above. Lead and PM reductions were
achieved from the same sources as the metal HAP reductions.
As shown in table 5-2, the total annual reductions from all
sources are 135 Mg (149 tpy) for PM and 38 Mg (42 tpy) for
lead. These estimates are based on a PM-to-metal HAP ratio
of 2.5 and a lead-to-metal HAP ratio of 0.7; both ratios
were determined from emissions testing data.
5.2.2 CO. THC. COo^ and NO^
The MACT alternatives for organic HAP's—increased
temperatures of afterburners and combined blast furnace and
reverberatory furnace exhausts—will decrease emissions of
CO and THC by increasing thermal oxidation of these
pollutants. Under alternative I, with afterburners
operating at 700 °C (1,300 °F), CO emissions would decrease
by 83,000 Mg/yr (91,000 tpy) and THC emissions would
decrease by 6,400 Mg/yr (7,100 tpy) nationwide. Under
alternative II, CO and THC emissions would be reduced by
95,000 Mg/yr (105,000 tpy) and 7,000 Mg/yr (8,000 tpy),
respectively. These emission reductions are presented in
table 5-2.
The increase in afterburner temperature, however, vcul.i
increase NOX emissions based on the increased natural gas
consumption by afterburners. Using"AP-42 NOX emission
factors for natural gas-fired commercial boilers, NOX
emissions would increase Jay aocuc 6.0 .-ig/yr (o.6 -p/, ^c.j
afterburners operating at 700 °C (1,300 °F) (alternative I)
5-6
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and by 16.8 Mg/yr (18.5 tpy) for afterburners operating at
870 °C (1,600 °F).4 The increase in natural gas consumption
would also increase CO2 emissions by 6,700 Mg/yr (7,400 tpy)
for afterburners operating at 700 °C (1,300 °F) and by
19,000 Mg/yr (21,000 tpy) for afterburners operating at
870 °C (1,600 °F).
5.2.3 Sulfur Dioxide
Sulfur dioxide emissions from process sources would be
reduced by scrubbers if they were installed on the six
reverberatory furnaces that do not have scrubbers. It is
assumed that SC>2 scrubbers would be installed on the two
furnaces that do not practice paste desulfurization and,
consequently, have relatively higher SO2 emissions. It is
also assumed that the remaining four reverberatory furnaces
without scrubbers that do practice paste desulfurization
would install HC1 scrubbers. Based on the permitted SC>2
limits for these furnaces, estimated total annual SC>2
emissions are 12,200 Mg. Assuming 90-percent control of SC>2
emissions by the SC>2 scrubbers and 30-percent control of SC>2
emissions by the HC1 scrubbers, SC>2 emissions would decrease
by 7,400 Mg annually. This estimate is likely high because
the plants operating these furnaces may choose to reduce HCl
emissions by fluxing or by flue dust dechlorination.
If a plant chooses to control HCl emissions by adding
fluxing agents to the furnace, SO2 emission reductions are
likely. However, these reductions would be small and have
not been estimated.
5.3 WATER CONSUMPTION IMPACTS
Increased water consumption may result from increased
wet suppression of fugitive dust emissions and from the
operation of additional wet acid-gas scrubbers.
5.3.1 Impacts from Fugitive Dust Control
Water usage for wet suppression of fugitive dust
emissions was estimated to increase by a total of
1.0 million liters per year [274,000 gallons per year
(gal/yrj] from six plants under cha candidate tfACT concro-
alternatives. These six plants would need to install
5-9
-------
sprinkler systems in the battery breaker and materials
storage areas. Water usage rates were based on an
application rate of 7,500 liters per hectare per day
(800 gallons per acre per day). It was also assumed that
treated storm water could be used to supply 75 percent of
the water requirements because all secondary lead smelters
are required to collect and treat storm water runoff. Some
of the water used for wet suppression may create runoff that
would need to be treated prior to disposal or that could be
recycled within the facility without treatment (e.g., make-
up water in the battery separation process).
5.3.2 Impacts from Wet Scrubbers
If SO2 or HC1 scrubbers are installed at the six plants
that must control HC1/C12 emissions, then water evaporation
from these scrubbers is estimated to increase water usage by
1.6 billion liters per year (430 million gal/yr). This
estimate assumes the following gas characteristics:
• Scrubber inlet temperature of 120 °C (250 °F);
• 10 percent by volume inlet moisture content;
• outlet temperature of 65 °C (150 °F); and
• 100 percent relative humidity outlet moisture
content.
Because this water is lost through evaporation, no
additional water treatment is needed.
Scrubber blowdown from these scrubbers, however,
requires waste water treatment. Under this scenario,
assuming SC>2 scrubbers will be installed at two facilities
and HC1 scrubbers will be installed at four facilities, the
estimated annual increase in waste water requiring treatment
was 100 million liters per year (27 million gal/yr). This
estimate assumed the following:
• Scrubber blowdown when the solids content reaches
15 percent;
• All sodium sulfite in the SO2 scrubbers is
oxidized to sodium sulfate;
* 7,400 Xg/yr ^3,200 tpy) absorption of SC>2 ', ^nu
• 715 Mg/yr (790 tpy) absorption of HC1 and C12.
5-10
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5.4 SOLID WASTE DISPOSAL IMPACTS
Adoption of a standard based on the candidate MACT
alternatives may have impacts on several solid waste streams
generated by secondary lead smelters (including flue dust,
slag, scrubber sludge, and wastewater treatment sludge) and
on the disposal of used batteries.
5.4.1 Flue Dust
The amount of flue dust generated may increase under
the candidate control alternatives through the increased
control of process fugitive sources, but flue dust is
normally recycled to the smelting furnace, so there is no
impact on solid waste disposal.
5.4.2 Slag
The amount of slag generated under the control
alternative was estimated to increase by about 3,100 Mg/yr
(3,400 tpy) because of the increased use of fluxing agents
in reverberatory furnaces to control HC1 and C\2 a"t six
facilities, assuming all six facilities employ fluxing. The
average increase at each facility is 520 Mg/yr (570 tpy),
and the largest increase is 900 Mg/yr (990 tpy). These
estimates assume that the reaction between flux and HC1 is
30 percent efficient, so that each Mg reduction in HC1 and
Cl2 emissions requires 4.3 Mg of flux. It also assumes that
1 Mg of flux produces 1 Mg of slag.
Because the smelters are considered to be processing
hazardous waste, all of the residue (including slag) must
satisfy the treatment standards in 40 CFR 268 for D008
(lead-bearing) hazardous waste before the residue can be
land disposed. Chemical Waste Management v. EPA. 976 F. 2d
2 (D.C. Cir. 1992) .
The reverberatory furnace slag generated by fluxing at
the six affected siaeitars would be further processed in
either a blast or electric furnace to recover additional
lead bullion. The final slag genera-cad by chesa smeicars
may or may not be characterized as a hazardous waste,
depending on furnaca operation. In aadirion, seme 3 nie.L ".= :."
may determine that is it more cost-effective no dispose on
5-11
-------
some slag as hazardous waste than to reprocess all of the
slag through a smelting furnace until it is rendered
nonhazardous.
5.4.3 Scrubber Sludge
If S02 scrubbing rather than fluxing is employed, 3 Mg
of scrubber sludge will be produced for each Mg of HCl
reduced, and 3.74 Mg of scrubber sludge will be produced for
each Mg of SO2 reduced. Assuming that SC>2 scrubbers are
installed at two facilities, the total additional scrubber
sludge produced is 21,400 Mg/yr (23,600 tpy). This estimate
assumes that calcium scrubbers will be installed at both
facilities with reverberatory furnaces that do not practice
paste desulfurization. In addition, it was assumed that
0.2 moles of CaCO3 will remain unreacted per mole of SO2
absorbed, based on the average of values reported in the
literature.5 This scrubber sludge impact could be mitigated
by available scrubber technology that produces a marketable
by-product, rather than a solid waste.
5.4.4 Water Treatment Plant Sludge
Smelting facilities send wastewater treatment sludge to
the smelting furnaces for recovery of lead. Therefore, the
generation of additional wastewater treatment sludge will
have no impact on solid waste disposal. However, the acid-
gas scrubber sludge discussed above cannot be recycled to
the smelting furnace because of its high sulfur content.
5.4.5 Battery Recycling
The EPA estimates that under the candidate MACT control
alternatives, nationwide secondary lead production would
decrease by less than 1 percent.6 It is not expected that
the recycling of lead-acid batteries or the rate of disposal
in landfills or by roadside dumping will be affected. The
most recent estimate of the battery recycling rate was
98 percent in 1990.7 Moreover, consumers and households are
storing nany used batteries in garages and basements, rather
than turning them in for recycling or disposing of cnem aj
o
solid wasta. J Thus, raw battiarias ar3 entar^ng ens c=o
waste stream.
5-12
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5.5 ENERGY IMPACTS
Natural gas consumption by afterburners will increase
by an estimated 3.7 million cubic meters per year (m3/yr)
[130 million standard cubic feet per year (scf/yr)] at
700 °C (1,300 °F) and by 1.0 million m3/yr (370 million
scf/yr) at 870 °C (1,600 °F) under candidate MACT control
alternatives I and II, respectively. Other than the natural
gas used in afterburners, no significant increases in
electric power consumption or fossil fuel consumption are
anticipated under the MACT control alternatives.
5.6 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES
The increase in natural gas consumption by afterburners
is the only significant commitment of irretrievable
resources anticipated under the candidate MACT control
alternatives.
5-13
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5.7 REFERENCES
1. Roy F. Weston, Inc. Emission Test Report: HAP
Emission Testing on Selected Sources at a Secondary
Lead Smelter—Schuylkill Metals Corporation, Forest
City, Missouri. Draft. Six Volumes. Prepared for the
U. S. Environmental Protection Agency. Research
Triangle Park, North Carolina. Contract
No. 68-D1-0104. January 1993.
2. Pacific Environmental Services, Inc. Draft Final
Report—Total Hydrocarbon Testing at a Secondary Lead
Smelter: GNB, Columbus, GA. Prepared for the U. S.
Environmental Protection Agency. Research Triangle
Park, North Carolina. Contract No. 68-D2-0162.
November 1993. 22 pp. plus appendices.
3. Pacific Environmental Services, Inc. Draft Final
Report—Total Hydrocarbon Testing at a Secondary Lead
Smelter: Gulf Coast Recycling, Tampa, Florida.
Prepared for the U. S. Environmental Protection Agency.
Research Triangle Park, North Carolina. Contract
No. 68-D2-0162. November 1993. 22 pp. plus
appendices.
4. U. S. Environmental Protection Agency. Compilation of
Air Pollutant Emission Factors; Volume 1: Stationary
Point and Area Sources. Washington, DC. Publication
No. AP-42. September 1985. p. 1.4-2.
5. Radian Corporation. S(>2 Technology Update Report.
Prepared for the U. S. Environmental Protection Agency.
Research Triangle Park, North Carolina. Contract
No. 68-02-3816. July 1984. p. 2-52.
6. Economic Impact Analysis of the Secondary Lead Smelters
NESHAP (Draft Report). U. S. Environmental Protection
Agency. Research Triangle Park, North Carolina.
Publication No. EPA-453/D-94-010. February 1994.
70 pp.
7. Smith, Burklin and Associates, Inc. 1990. National
Recycling Rate Study. Prepared for the Battery Council
International. Chicago, Illinois. May 1992. 10 pp.
8. Memorandum from Peter D. Hart Research Associates.
Inc., to Fox, Weinberg & Bennett. April 11, 1990.
Survey for Battery Council International. 5 pp.
5-14
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6.0 COST IMPACTS OF CONTROL ALTERNATIVES
This chapter presents the cost impacts of the candidate
MACT control alternatives on the 23 model plants described
in chapter 4.0. Cost impacts were estimated for applying
the control alternatives to smelting furnace process
sources, process fugitive sources, and fugitive dust
sources. A more detailed explanation of the procedures used
in developing these cost impact estimates is contained in
appendix E.
Estimates of capital and annualized costs were
developed according to standard EPA cost estimating
procedures1 and are presented in December 1991 dollars. An
interest rate of 7 percent was used in estimating cost
impacts. The model plant specific and aggregate cost
impacts of applying the candidate MACT control alternatives
are summarized in table 6-1. Under candidate MACT control
alternative I, the estimated total capital investment cost
impact is $1,400,000 and the estimated total annual cost
impact is $2,000,000. Five smelters would have no capital
or annual cost impacts. The highest capital and annual cost
impacts on individual smelters would be $317,000 and
$175,000, respectively. Under control alternative II the
estimated total capital investment cost impact is $3,100,000
and the estimated total annual cost impact is $3,100,000.
Again, five smelters would have no capital or annual cost
impacts. The highest capital and annual cost impacts on
individual smeltars would be $317,000 and $355,000,
respectively.
Capital investment costs include equipment: costs for
afterburners, auxiliary equipment such as duct work and
fans, and installation costs. Annual costs include dirsc^
6-1
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annual costs (such as operating and supervisory labor, soda
ash, and natural gas) and indirect annual costs (such as
overhead, property tax and insurance, and capital recovery).
Capital and annual costs reported in this chapter do not
include costs for continuous monitoring. The costs
associated with the continuous monitoring alternatives are
provided in chapter 7.0.
6.1 SMELTING FURNACE PROCESS SOURCES
Separate cost impacts were estimated to meet the
candidate MACT control alternatives•for metal HAP's, organic
HAP's, and HC1/C12.
6.1.1 Metal HAP's
All smelters currently control smelting furnace
exhausts with baghouses; which is the candidate MACT
control. No equipment upgrades will be required and there
are no cost impacts associated with the installation and
operation of new air pollution control devices.
6.1.2 Organic HAP's
The cost impacts associated with the candidate MACT
control alternatives for organic HAP emissions are dependent
on the furnace configuration used at a plant. The control
alternative for plants with collocated reverberatory and
blast furnaces is based on combining the blast furnace
exhaust with the hot reverberatory furnace exhaust. Four of
the nine plants operating both reverberatory and blast
furnaces do not currently combine the blast furnace exhaust
with the reverberatory furnace exhaust. The capital cost
impact of retrofitting duct work to combine the exhausts is
estimated at $54,000 per blast furnace, with an associated
annual cost of $6,000. These costs were estimated using
standard cost procedures and assumed duct dimensions of 60 m
(200 ft) in length and 0.9 m (3 ft) in diameter.
The candidate MACT control aitarnative for smelters
operating only blast furnaces is an afterburner with an
operating temperature cf 700 °C (1,300 °F) under
•alternative I. Five cut of eight blast-only smelt^rr- •":••.."_ •
need to upgrade their controls to meet this control level.
6-3
-------
Three smelters would need to install afterburners where none
previously existed and two smelters with afterburners would
need to increase natural gas consumption to increase the
afterburner temperature to 700 °C (1,300 °F). The estimated
total capital cost impact for these five smelters is
$810,000 and the total annual cost impact is $590,000.
These cost estimates are based on standard EPA cost-
estimating procedures for afterburners and a natural gas
cost of $107 per thousand cubic meters ($3.03 per thousand
cubic feet).
Under alternative II, the candidate MACT control for
blast furnace smelters is an afterburner with a temperature
of 870 °C (1,600 °F). Seven blast furnace smelters would
need to upgrade their controls to meet this control level.
All seven would need to install new afterburners. The
operating temperatures of these existing afterburners is
more than 100 °C (180 °F) below the MACT control temperature
of 870 °C (1,600 °F) and it is assumed that the temperature
of an existing afterburner cannot be increased by more than
100 °C. Therefore, these afterburners would need to be
replaced. The estimated total capital cost impact for the
new afterburners is $2.6 million and the estimated annual
cost impact is $1.7 million, which includes the cost of
increased natural gas consumption.
There are no cost impacts associated with the candidate
MACT control alternatives for organic HAP's from rotary,
reverberatory, or electric furnaces.
6.1.3 Hydrochloric Acid and Chlorine
The candidate MACT control alternative for reducing
HC1/C12 emissions from smelting furnaces is either wet
scrubbing or the addition of limestone or soda ash fluxing
agents to the furnace charge. Wet scrubbers and fluxing
provide equivalent levels of control. Six smelters would
need to upgrade their controls to meet this level of
control. The laast-ccnt option is to perform fluxing r-;i~.r.
soda ash or limestone. The estimated total annual ~csr,
impact for this option would be about: $160,000. These JGS-J
6-4
-------
are based on the addition of soda ash to the reverberatory
furnaces at six smelters at an application rate of 4.3 Mg of
soda ash per Mg of HC1/C12 reduced and a cost of $50 per Mg
of soda ash. No additional equipment is required to perform
furnace fluxing, so there are no capital cost impacts.
A cost estimate was made for wet scrubbers in the event
that a smelter would prefer to install a wet scrubber rather
than perform furnace fluxing. The capital cost impact of a
single sodium hydroxide tray scrubber installed on a
reverberatory furnace with a 50,000 Mg/yr lead production
capacity was estimated at $1,700,000. The annual cost
impact of this scrubber was estimated at $850,000 per year.
6.2 PROCESS FUGITIVE SOURCES
The candidate MACT control alternative for process
fugitive sources is capture and control of emissions from
process fugitive sources with hoods ventilated to baghouses.
Nearly all smelters are meeting this control level for all
process fugitive sources. However, one smelter does not
have a hood over the blast furnace charging chute. The cost
of installing hooding and ducting on this emission source
was estimated. The hood exhaust can be controlled by the
smelter's existing baghouse because the smelter currently
has excess baghouse capacity. Therefore, the cost impact
does not include costs for installing additional baghouse
capacity. The capital cost impact was estimated at $47,000,
with a resulting annual cost impact of $4,400 per year.
At three smelters, the refining kettle emissions are
controlled by scrubbers rather than by baghouses. No
performance data are available for these scrubbers.
However, data from lead reclamation kettles and other
sources at battery manufacturing facilities controlled by
wet scrubbers indicate that scrubbers should be able to
achieve the same level of control as a baghouse.^
Therefore, costs were not estimated for replacing these
scrubbers with baghouses.
The cosr impacts of controlling organic 'lA? 2miz3_-. :r_-
associated with blast furnace charging would be minimal, if
6-5
-------
any. Only minor adjustments to existing equipment would be
necessary to achieve a correct air flow balance between the
charging hood and the off-take to the afterburner.
Therefore, there would be no capital or annual cost impacts.
6.3 FUGITIVE DUST SOURCES
Cost impacts were estimated for reducing metal HAP
emissions from fugitive dust sources. The candidate MACT
control alternative requires a combination of control
techniques, including enclosures, area vacuuming, and wet
suppression. Nine of the 23 existing smelters employ
controls equivalent to the candidate MACT control
alternative for all fugitive dust sources and would not be
affected.
Cost impacts were estimated for 14 smelters that would
need to update their controls to meet the candidate MACT
control level. Four smelters would need to purchase vacuum
sweepers to control fugitive dust emissions from paved
areas. The capital cost of these sweepers was estimated to
be $47,000 per unit. Twelve smelters (including the four
that purchased vacuum sweepers) would have to expend
additional labor hours to perform pavement cleaning in
additional areas of the smelter. The labor cost was
estimated based on one hour of labor per eight-hour shift
per affected area.
Wet suppression would need to be increased at six of
the affected smelters, including two smelters at which no
other fugitive dust control upgrades would be required.
Capital costs were assumed to be negligible for the
installation of an automated sprinkler system. The annual
wet suppression cost impact was based on water usage costs
and an application rate of 7,500 liters per hectare per day
(800 gallons per acre per day), and it includes waste water
treanaenr. costs. It was also assumed that treated szorr.
water could be used to supply 75 percent of the wet
suppression water requirements because all secondary lead
smelters ars requirad to collect and tirsat: 3~tcm vatar
runoff. The nationwide cost impact for wet suppression was
6-6
-------
estimated at $2,000 per year. Total annual costs for all
fugitive dust emission controls at all affected smelters are
estimated to be about $110,000.
6-7
-------
6.4 REFERENCES
1. Vatavuk, W. M. Estimating Costs of Air Pollution
Control. Lewis Publishers. 1990.
2. Lead-Acid Battery Manufacture—Background Information
for Proposed Standards. U. S. Environmental Protection
Agency. Research Triangle Park, North Carolina.
Publication No. EPA-450/3-79-028a. November 1979.
pp. 4-1 to 4-43.
6-8
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7.0 CONTINUOUS MONITORING
This chapter discusses the continuous monitoring
alternatives that may be considered for continuous
compliance certification with emission limits for metal
HAP's, organic HAP's, and HC1/C12 in the secondary lead
smelting industry. Continuous compliance certification is
required for all major stationary sources under
section 114(a)(3) of the Clean Air Act. Continuous
compliance certification enables a regulatory agency to
determine whether an affected source remained in compliance
with an applicable emissions limitation throughout a
reporting period. Continuous monitoring, which can be used
for continuous compliance certification, is the collection
of emissions or parameter data on a predetermined frequency
and is subject to specified data quality objectives for
accuracy and precision. Continuous monitoring also provides
a means of determining whether a control technology is
performing properly. A continuous emissions monitor (CEM)
measures and records air pollutant emissions on either a
continuous or semicontinuous basis. Similarly, a continuous
parameter monitor measures and records a process or control
device parameter on a continuous or semicontinuous basis.
7.1 METAL HAP'S
No CEM's are available to continuously monitor metal
HAP emissions controlled by baghouses, the typical control
device in use at secondary lead smelters. Similarly, no
monitoring methodologies for baghouses are satisfactory for
continuous compliance certification. However, opacity can
•
be used to monitor baghouse performance and continuous
opacity monitors can be used to determine comolianca vi~r. ^r:
opacity standard on a continuous basis. Jpacizv sranciaris
7-1
-------
are separately enforceable standards that are generally
established in order to assure good baghouse operation and
maintenance.
Continuous opacity monitors measure the attenuation of
visible light by the effluent stream in a stack. The amount
of light attenuation (opacity) is a function of the
concentration and particle size of the PM and is expressed
as a percent of the light that is attenuated. Techniques
are available for establishing a site-specific opacity
equivalent to a given PM concentration. The opacity of
controlled smelting furnace emissions in the secondary lead
industry is typically about 1 to 2 percent.
Several secondary lead smelters are using COM's for
complying with opacity standards, and these COM's are
capable of indicating baghouse failures. The performance of
COM's, however, may be adversely affected by moisture
condensation, corrosion from HC1, and residual PM
accumulations typically encountered in the furnace exhaust
from secondary lead smelters.
Estimated initial costs for a COM are $37,300,
including an equipment performance specification test and a
quality assurance and quality control (QA/QC) plan.
Estimated annual costs are $16,500, including operation,
maintenance, recordkeeping, reporting, annual review of
records, and annual update of records.^
7.2 ORGANIC HAP'S
No CEM's are available for organic HAP's. Continuous
emission monitors are available for volatile organic
compounds (VOC) and THC, but their applicability to
secondary lead smelters is limited and none are currently in
use at secondary lead smelters. The VOC CEM's cannot
measure the actual VOC emitted unless the constituents of
the composition of the VOC emissions are consistent over
time. Because the exhaust stream constituents, from
secondary lead smelters are inconsistent over time, VOC
CEM's are net feasible for this industr*'.
7-2
-------
The technology for THC OEM's has not been applied to
this industry. The estimated cost of purchasing and
installing a THC GEM, including a CO2/O2 analyzer, is
$143,600. Annual operation and maintenance costs are
estimated to be $64,600.!
Monitoring the afterburner outlet temperature or the
combined reverberatory and blast furnace exhaust temperature
is the most feasible means of compliance certification for
sources using these controls. Continuous temperature
monitoring can provide a reliable demonstration of
continuous compliance with an organic HAP or THC emissions
standard. Temperature data are readily available from the
thermocouples that are used for afterburner control.
Sources already using these instruments would not incur
additional instrumentation costs. However, inaccurate
temperature readings may be produced by thermocouple
scaling, requiring frequent thermocouple maintenance.
7.3 HYDROCHLORIC ACID AND CHLORINE
Continuous emission monitors are available for HC1.
However, they have not been used in the secondary lead
smelting industry and no information is available on the use
of HC1 CEM's in this application. The estimated cost to
purchase and install an HCl monitor for a secondary lead
smelter is $126,900. The estimated cost to operate and
maintain the HCl monitor on an annual basis, including QA/QC
procedures, is $60,300.1
Sulfur dioxide scrubbers, which are in use at many
secondary lead smelters, also control HC1/C12 emissions.
Therefore, monitoring SO2 may serve as an appropriate
surrogate where HC1/C12 control is achieved through an SC>2
scrubber. Unlike HCl CEM's, SO2 CEM's are already in use in
this industry by smelters that operate SO2 scrubbers. The
estimated costs for an SO2 CEM are the same as those for an
HCl CEM.
An alternative to an S02 CEM is to monitor the SC2
scrubber operating parameters. The scr-Jicer niccia ir.;;c~ir-
rate and the pH of the media at the scrubber inlet are
7-3
-------
reliable indicators of proper scrubber operation and
consistent scrubber performance.
7-4
-------
7.4 REFERENCES
1. Memorandum and attachments from Wood, G. H., EPA/EMB,
to Crowder, J. U., EPA/ISB. September 28, 1993.
Enhanced Monitoring for Secondary Lead Smelters.
7-5
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA-450/R-94-024a
2.
3. RECIPIENT'S ACCESSION NO
4. TITLE AND SUBTITLE
Secondary Lead Smelting - Background Information
Document for Proposed Standards - Volume 1
5 REPORT DATE
June 1994
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Emission Standards Division (MD-13)
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
1C PROGRAM ELEMENT NO
11 CONTRACT/GRANT NO
68-D1-0117
12. SPONSORING AGENCY NAME AND ADDRESS
Director
Office of Air Quality Planning and Standards
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
13. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Under the authority of the 1990 Clean Air Act Amendments, a national
emission standard for hazardous air pollutants (NESHAP) is proposed to control
emissions from secondary lead smelters. This document provides background
information on hazardous air pollutant emissions (EAP) from secondary lead
smelters, the demonstrated technologies available to control HAP emissions,
and the costs and environmental impacts of applying these technologies.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.fOENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Air Pollution
Secondary Lead Smelters
Hazardous Air Pollutants
NESHAP
Hazardous Air Pollutants
Secondary Lead Smelters
18. DISTRIBUTION STATEMENT
Release Unlimited
19. SECURITY CLASS I This Report!
Unclassified
21 NO. OF PAGES
155
20. SECURITY CLASS (This page;
Unclassified
22 PRICE
EPA Form 2220-1 (R«v. 4-771 PREVIOUS EDITION is OBSOLETE
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JS EPA Region 5 Library
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