United States
                    Environmental Protection
                    Agency
 Industrial Environmental Research    s
 Laboratory
 Cincinnati OH 45268
                    Research and Development
 EPA-600/S2-84-026 Mar. 1984
SERA          Project Summary
                    Inspection  and  Operating  and
                    Maintenance  Guidelines for
                    Secondary  Lead Smelter Air
                    Pollution Control

                    Fred Hall, Ron Hawks, Gary Saunders, and John 0. Burckle
                     Secondary lead  smelters are an
                   important segment of the domestic
                   nonferrous metals industry-  Over the
                   last five years they accounted for 55 to
                   58 percent of the total domestically
                   supplied  lead. In  1982, about 95
                   percent of the secondary lead was
                   produced by 48 major operating plants
                   with the balance supplied by a large
                   number of very small plants.
                     The toxicity of lead together with its
                   relatively high vapor pressure at operating
                   furnace temperatures make it a serious
                   environmental/occupational health
                   problem that  is difficult to control
                   economically. The U.S. Environmental
                   Protection Agency (EPA) has promul-
                   gated a National Ambient Air Quality
                   Standard (NAAQS) for lead of 1.5/ug/m*.
                   The Occupational Safety and Health
                   Administration (OSHA) has promul-
                   gated a workplace standard of 50
                   /ug/m3 and a blood level standard of 40
                   /ug/100 ml of whole blood. Operation
                   and maintenance (O&M) techniques
                   will become important tools in main-
                   taining  continued compliance with
                   these standards.
                     This Project Summary was developed
                   by EPA's Industrial Environmental
                   Research Laboratory. Cincinnati, OH.
                   to announce key findings of the research
                   project that is  fully documented in a
                   separate report of the same title (see
                   Project Report ordering information at
                   back).

                   Introduction
                     The success of an air pollution compli-
                   ance program ultimately depends upon
the competence of the field inspectors
and the adequacy of their inspections.
The ability to  identify, describe, and
evaluate air pollution emissions and
those factors  responsible  for their
occurrence is a fundamental requirement
of the inspection  process.  Both the
availability of sound inspection procedures
and adherence to the procedures are of
vital importance to the inspection process.
An air pollution control agency having
adequate enforcement powers but inade-
quate inspection procedures  would be
unlikely to make significant progress
towards attainment of air quality goals.
Also, such an  agency may  even see
erosion of its enforcement powers as a
result of adverse court decisions arising
from improperly executed inspections.
  The most important aspect of mainte-
nance of air quality is the attainment of
"continuing compliance." A "continuing
compliance inspection" is an inspection
of sources, which have previously proved
initial compliance with the regulations in
that they have installed the necessary air
pollution  control equipment and/or
modified their process(es) to be able to
meet required emission limits, to deter-
mine that they remain in compliance on a
continuing,  long-term basis. Most agen-
cies perform a continuing compliance
inspection once or twice a year depend-
ing upon their resources or any complaints
received.

Report Summary
  The  manual  was developed as an
inspection manual incorporating opera-
tion and maintenance  information for

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secondary lead smelting. It presents an
overview of secondary lead operations,
describes typical emission problems
associated with the material preparation,
smelting, refining, and oxidation process-
es (Figure 1), and reviews the  potential
causes  of  the problems and  possible
corrective measures.  It also  describes
types of control equipment  used  in
secondary lead smelting operations and
typical O&M problems experienced with
control  equipment. Topics  include:  (1)
process description and flow diagrams for
a typical secondary lead smelter and lead
oxide process;  (2) operating conditions
typical of secondary  lead smelting
operations; (3) process  and fugitive
emissions operations and their control;
(4)  design considerations to  improve
O&M;  and (5) basic  operation and
maintenance  procedures necessary to
remain  in compliance, including typical
O&M problems  associated with the
secondary lead industry, such  as corro-
sion, proper instrumentation required for
reliable operation, proper recordkeeping
                                   procedures, waste handling guidelines,
                                   and safety considerations.
                                      The prevention of lead emissions from
                                   secondary smelters is shown to depend
                                   largely on O&M practices. Fabric filters
                                   are usually used to remove paniculate
                                   matter from lead smelter process  and
                                   ventilation gas streams. Because proper-
                                   ly operated fabric filters are very efficient,
                                   little lead particulate matter is emitted in
                                   stack gases when operated under condi-
                                   tions of continuing compliance. Fugitive
                                   emissions, however, are a major prob-
                                   lem.  Control systems are only partially
                                   effective in capturing fugitive emissions.
                                   Also,  handling  of the  lead particulate
                                   matter after it has been  collected  is a
                                   potential cause  of fugitive emissions.
                                   Lead dust escapes from the  material
                                   handling and smelting processes into the
                                   workplace and is continually reentrained
                                   and dispersed throughout the smelter.
                                   Emission factors for specific sources are
                                   given in Table 1. Sufficient reentrainment
                                   may occur to cause the NAAQS of 1.5
                                   //g/m3 to be exceeded. Continued compli-
ance can be achieved only by applying the
appropriate combination of engineering
and  administrative controls, and  by
adopting operating, maintenance, and
housekeeping  practices to make  those
controls work effectively.
  The manual  is heavily oriented toward
an inspection approach emphasizing tech-
niques to  achieve improvements  in the
status of continuing compliance through
operations and maintenance procedures.
It has been written for use  both  as  an
educational and a reference tool by state
and  local  enforcement field  inspectors
and entry-level engineers  whose  famil-
iarity with secondary lead operations may
be limited, and,  as such, can be  useful
both as a training manual and as a guide-
book during field inspections.
  Inspection of a secondary lead smelter
requires that data be recorded on site for
later use in evaluating  smelter emission
control  and compliance practices. The
following items are useful to ensure that
the inspection is complete and to maximize
the pertinent  information that can  be
Pretreatment


   n nn
                                                                             Refining
                                                                                                  Products
    Draining and
     Decasing
   Sloping Hearth
  Dross
  and — *|
Fine Dust   [
      ,--H  Dust   f	1
      I  Agglomeration   \
  _j    niwi
  e,   !
                                               \> Solid
                                                  Residues
           I— »JZinc,  ty% -
               I Leaching \ v

 Figure 1.    Sources of air emissions from secondary lead plants.

                                    2

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Table 1.    Sources and Emission Factors for Point and Fugitive Emissions from Secondary Lead Smelters"

                                                    Point source emissions. Ib/ton
                                                  Fugitive emissions, Ib/ton
Source
Raw material handling and transfer
(scrap lead, scrap iron, coke,
limestone, etc.)
Lead and iron scrap burning
Battery decasing
Crushing or shredding
Rotary or reverberatory furnace
Paniculate
NA
NA
NA
NA
32-70
Lead Basic*
NA
NA
NA
NA
7-16 £
Paniculate
NA
NA
NA
NA

Lead Basicc
NA
NA
NA
NA

  sweating
    Charging
    Tapping
    Scrap removal

Reverberatory furnace smelting
    Charging
    Slag tapping
    Lead tapping/casting

Blast furnace smelting
    Charging
    Slag tapping
    lead tapping/casting

Holding pot

Reverberatory furnace softening
    Charging
    Tapping (drossing, skimming,
    lead removal)

Kettle softening/refining
    Charging
    Tapping fdrossing, skimming,
    lead removal!

Kettle alloying/refining
    Charging
    Tapping, drossing, skimming

Kettle oxidation"
    Charging

Reverberatory furnace oxidation
    Charging
 147




 193




 NA

 NA
34




44




NA

NA
B
 0.8




<40


 NA
0.2
NA
NA
                                                1.6-3.5
              2.8-15.7
                 NA

                 NA
                0.04




                 NA


                 NA
NA - data not available.
"Source: U.S. Environmental Protection Agency. Compilation of Air Pollution Emission Factors. 1980.
b All emission factors are based on the quantity of material charged to the furnace (except paniculate kettle oxidation).
0 The basis of the emission factor refers to the method from which the emission factor was obtained.
 B - Emission factor based on source test data and is rated (EPA 1980) as above average.
 E - Engineering estimate supportable by visual observation and emission tests for similar sources.
    These emission factors are rated (EPA 1980) poor.
" Factors based on amount of lead oxide produced.
' Factors based on amount of lead cast.
                                                 0.4-1.8
0.6-3.6
  NA

  NA
 0.01




  NA


  NA
Casting (pigging f
Flue dust handling and transfer
Vehicular traffic
Traffic on paved roads
Traffic on unpaved roads
Hooding, ductwork, control
device, or furnace leaks
NA
NA
NA
NA
NA
NA
NA
NA
0.88
NA
NA
NA
0.2
NA
NA
NA
E




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obtained while the inspector is on site:
  • Smelter plot plan
  • Engineering drawings or sketches
     of equipment and specifications
  • Process flowsheet  and equipment
     checklist
  • Raw material/product checklist
  • Individual process worksheets
  • Emission control equipment (systems)
     acceptance or performance  test
     results
  • Maintenance records

Most  of these  items can be obtained
during the file review at the appropriate
EPA Regional and local offices, especially
results of performance tests conducted to
determine compliance.
  Prior to the inspection, the worksheets,
process flows, and  maintenance  records
should be reviewed  with the  plant's
representative  at the plant. Organizing
these items prior to the actual inspection
helps ensure that all necessary data are
obtained.
  The purpose of  inspecting  control
equipment is to evaluate system perform-
ance with respect to regulatory  require-
ments and operation and maintenance
procedures. Inspections can  vary  in
detail, depending upon the objective. For
example,  cursory  inspections  can be
performed by only quick, external exami-
nation of the control equipment  and
recording of several temperature  and
static pressure  readings. Thorough
inspection requires more detailed analy-
sis  of the control system and perhaps an
internal inspection of the equipment.
Inspection requirements should be
tailored to the characteristics  of each
facility,  and the time available for each
inspection.
  An inspector, upon arrival at the plant
to be inspected, should determine exist-
ing plant self monitoring procedures  by
questioning plant management.  Any
records that show control system operat-
ing parameters and production levels
should be quickly  reviewed to estimate
plant "baseline values". A baseline value
is the value of a given parameter  (e.g., fan
static pressure and temperature  or fabric
filter pressure drop) when all  the equip-
ment in a system is operated in a manner
that provides acceptable performance. If
actual operating values differ significant-
ly from  baseline values, operation of the
process or control equipment has  changed
enough to warrant further questioning of
plant personnel to determine  probable
reasons for these deviations.
  Some parameters can indicate the
performance of the control equipment.
These include opacity and fan parameters.
Opacity
  Observation of the opacity and compar-
ison of this value with the baseline value
provides the  initial  indicator  of  any
process  or control equipment perform-
ance variation.

Fan Parameters
  Fan parameters are generally the
parameters  that  plant and  regulatory
personnel use  the least in  evaluating
control equipment performance. Each fan
has  a  unique  static pressure/motor
current/gas volume curve at any given
speed. Because fan speed is usually fixed
(and must be manually and intentionally
changed by plant personnel), it need not
be measured each time plant personnel
check the system.  The  gas  volume
through  the fan  may be  read  directly
from the curve.

Fabric Filters
  The most frequently used indicator for
fabric filter  operation  is  the  pressure
drop across the filter medium.  The
cleaning system operation should be con-
firmed, and the timing sequence should be
recorded. The waste handling system
(including  hoppers, airlocks, and convey-
yors) should be checked  for proper
operation. Hoppers should not be used for
storage  of  captured dust. Although
hoppers may be  insulated,  the hopper
discharge should be warm to the touch. A
cold hopper discharge on a "hot source"
may indicate hopper plugging.
  The  previous  steps  provide some
information, but the only reliable method
of evaluating fabric filter performance is
internal inspection. Safety  is  a prime
concern in performing an internal inspec-
tion. Generally,  special equipment is
required to enter these baghouses.
  The actual internal inspection takes
little  time.  The  majority of the  time
required is used to prepare equipment and
to isolate and open compartments. The
location and nature of  all bag failures
should  be recorded for  maintenance
schedule  optimization. The use  of a
fluorescent dye and a portable UV light
may be helpful in identifying problems.
Pinholes and bag seal leaks are easily
spotted. Figure 2 indicates the  steps for
internal and external inspections of fabric
filters.

Wet Scrubbers
  Inspection  of a wet  scrubber relies
heavily on  baseline values  because
internal inspection of the equipment is
not usually possible.  An inspector  must
attempt to  quantify  any  change  in
efficiency based upon a change in the   |
water  flow rate,  pressure drop,  gas   1
volume (throat velocity), or gas tempera-
ture. The only other parameter that can
significantly affect scrubber performance
is a shift in the particle size distribution.
Such a shift is difficult to  measure, but
generally decreases collection efficiency,
when the shift is to smaller sizes, when
all other parameters are held constant.
  Because of the low gas stream temper-
ature, other problems with liquor solids
content and evaporation are not typically
encountered. Corrosion  is generally
limited because of construction practices
(e.g., the use of 316 stainless steel). Little
day-to-day variation in scrubber operation
is expected.
  For inspection purposes, the ventilation
system is def i ned as the ductwork leadi ng
from the emission points to the  control
devices. Two major problems with venti-
lation systems  are duct plugging  and
excessive  air  inleakage, both of which
cause changes in the static pressure and
temperature  profiles  of the ductwork
system. An inspector should  carefully
examine the ventilation system to identify
the problem.  Static pressure taps  are
recommended throughout  the length of
ductwork to provide data on air inleakage
and ductwork plugging.                  A
  The  ventilation system  inspection   ™
should include routine measurement of
the temperature and static pressure at
the furnace or kettle hood  outlet, at the
afterburner outlet (if applicable), at the
inlet and outlet of the cooling loops, and
at some point downstream  of dilution air
dampers.  These parameters vary with
production rate, and ambient temperature
and operating logs should be examined to
determine long-term baseline values,
which take into account normal process
variations.
  In addition to the measurement of
static pressure  and temperature at  the
emission  point, the  face  velocity and
positioning of all fugitive hooding should
be checked.  Improper  positioning of
hooding or hood damage may result in the
reduction  of  capture  efficiencies.  Low
duct static pressures indicate an undersized
or underperforming fan.

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           External Inspection
  Internal Inspection
       Check Pressure Drop Across
       Each Compartment,
                 I
         Check Condition of Lines
         and Pressure Gauges.
                 I
         Check Cleaning System
         Equipment:
           Pulse-Jet Mechanism
           Solenoids
           Reverse-Air Blowers
           Shakers
                 I
          Check Solids Removal
          Equipment-
           Screw Conveyor
           Pneumatic System
           Heaters
           Vibrators
                 1
          Investigate any Other
          Indications of Nonoptimal
          Performance.
Check Bags:
  Bag Tears
  Bag Deterioration
  Dropped Bags
  Oily Bags
  Wet Bags
  Improper Bag Tension
  Deposits on Floor
         ±
Check Clean Air Chamber
for Possible Leaks.
         ±
Check Hoppers for
Incomplete Solids Removal
and for Corrosion.
Figure 2.    Steps for external and internal inspection of fabric filters.
   Fred Hall. Ron Hawks, and Gary Sounders, authors of the Project Report are with
     PEDCO Environmental. Inc., Cincinnati. OH 45246; John BurcUe, author of the
     Project Summary and EPA Project Officer (see below}, is with the Industrial
     Environmental Research Laboratory, Cincinnati, OH 45268.
   The complete report,  entitled "Inspection and Operating and  Maintenance
     Guidelines for Secondary Lead Smelter Air Pollution Control," (Order No. PB
   84-149 368; Cost: $14.50, subject to change) will be available only from:
           National Technical Information Service
           5285 Port Royal Road
           Springfield, VA22161
           Telephone: 703-487-4650
   The EPA Project Officer can be contacted at:
           Industrial Environmental Research Laboratory
           U.S. Environmental Protection Agency
           Cincinnati, OH 45268
                                                                                     U. S. GOVERNMENT PRINTING OFFICE: 1984/759-102/0897

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United States
Environmental Protection
Agency
Center for Environmental Research
Information
Cincinnati OH 45268
                                                                                                          "34
Official Business
Penalty for Private Use $300
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